Tremr Privacy Policy
Background
This Privacy Policy forms part of the Tremr Terms of Service agreement. This agreement applies as between you, the user, and Tremr Ltd ("the Company") , the owner and operator of the Tremr service. Your agreement to comply with and be bound by these Terms of Service is deemed to occur upon your acceptance of the same. If you do not agree to be bound by these Terms of Service, you should stop using the Tremr service immediately.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means collectively the personal information, Payment Information and credentials used by Users to access Material and / or any communications System on the Web Site;
“Content” means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;
“Cookie” means a small text file placed on your computer by the Website when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Web Site. Where e-commerce facilities are provided, Cookies may be used to store your login details.
“Data” means collectively all information that you submit to the Web Site. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;
“Service” means collectively any online facilities, tools, services or information that the Company makes available through the Web Site either now or in the future;
“System” means any online communications infrastructure that the Company makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
“User” / “Users” means any third party that accesses the Web Site and is not employed by the Company and acting in the course of their employment; and
“Web Site” means the website that you are currently using (www.tremr.com) and any sub-domains of this site (e.g. blog.tremr.com) unless expressly excluded by their own terms and conditions.
Data Collected
Without limitation, any of the following Data may be collected: name, date of birth, gender, job title, profession, contact information such as email addresses and telephone numbers, demographic information such as post code, preferences and interests, financial information such as credit / debit card numbers, IP address (automatically collected), web browser type and version (automatically collected), operating system (automatically collected), a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected), cookie information (see 'Cookies' section below).
When you visit the System, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the System , we collect information about the individual web pages or products that you view, what websites or search terms referred you to the System, and information about how you interact with the System. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org .
- “Log files” track actions occurring on the Sites, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Sites.
When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Account Information.
Our Use of Your Data
We use the Personal Information that we collect to provide the Tremr service to you. Additionally, we use this Personal Information to:
- Communicate with you;
- Screen users and user behaviour for risks to the integrity of the System
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Sites (for example, by generating analytics about how our customers browse and interact with the Sites, and to assess the success of our marketing and advertising campaigns).
We may use Device information for serving relevant advertising to you on websites other those controlled by Tremr.
Any personal Data you submit will be retained by the Company for as long as you use the Services and Systems provided on the Web Site. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to 5 years. Unless we are obliged or permitted by law to do so, and subject to this privacy policy and our terms of service, your Data will not be disclosed to third parties. All personal Data is stored securely in accordance with the principles of the EU General Data Protection Regulation (2018).
For more details on security, see the 'Security' clause below. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons: internal record keeping; improvement of our products / services; transmission by email of promotional materials that may be of interest to you; contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Web Site.
Third Party Web Sites and Services
The Company may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing.
We will not share your personal information with others for marketing purposes unless you have given us your permission. If we have your permission, we will share your information only with other organisations we have chosen carefully.
We can access and release personal information to keep to relevant laws and government requests, to operate our systems properly and to protect both us and our users.
Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply.
We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA.
Some of our webpages use plug-ins from other organisations (such as the 'Facebook Recommend' function). These other organisations may use information about your visit to our websites on their pages. If you browse these pages while still also logged in to your account with us, information they collect may be connected to your account on their site. For more information on how these organisations use information, please read their privacy policies.
Do Not Track
Please note that we do not alter our Sites' data collection and use practices when we see a Do Not Track signal from your browser.
Your Rights
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Sites), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
Logging in using social networking credentials
If you log-in to our sites using a Facebook log-in, you are granting permission to Facebook to share your user details with us. This will include your name, email address, date of birth and location which will then be used to form a Tremr identity. You can also use your picture from Facebook as part of your profile. This will also allow us and Facebook to share your networks, user ID and any other information you choose to share according to your Facebook account settings.
If you log-in to our sites using a Google log-in, you grant permission to Google to share your user details with us. This will include your name, email address, date of birth, sex and location which we will then use to form a Tremr identity. You may use your picture from Google as part of your profile. This also allows us to share your networks, user ID and any other information you choose to share according to your Google account settings. If you remove Tremr from your Google settings, we will no longer have access to this information.
If you log-in to our sites using a twitter log-in, we receive your avatar (the small picture that appears next to your tweets) and twitter username.
Changes of Business Ownership and Control
The Company may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you. In the event that any Data submitted by Users will be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will not be given the choice to have your Data deleted or withheld from the new owner or controller.
Controlling Access to your Data
Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following: use of Data for direct marketing purposes; and sharing Data with third parties.
Your Right to Withhold Information
You may access certain areas of the Web Site without providing any Data at all. However, to use all Services and Systems available on the Web Site you may be required to submit Account information or other Data. You may restrict your internet browser’s use of Cookies. For more information see the 'Cookies' clause below.
Accessing your own Data
You may access your Account at any time to view or amend the Data. You may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and you may change this at any time. You have the right to ask for a copy of your personal Data.
Security
Data security is of great importance to Tremr and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online.
Cookies
When you use the Service, we use persistent and session cookies and other tracking technologies to: (a) store your username and password; (b) analyze the usage of the Service; (c) customize the Service to your preferences; and (d) control the advertising displayed by the Service. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled. We may also use other Internet technologies, log files, clear GIFs, Flash technologies, and other similar technologies, to deliver or communicate with cookies and track your use of the Service. We also may include clear GIFs in HTML-based emails sent to our users to determine whether the message has been opened. As we adopt additional technology, we may also gather additional information through other methods.
Changes to this Policy
The Company reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.
Contact Us
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:
Tremr Ltd
[Re: Privacy Compliance Officer]
Eros House
Grand Rue, St Martins
Guernsey, GY4 6LQ