Data Privacy Notice

1.1 Purpose

This Data Privacy Policy explains how Trapp Technology, Inc., hereby referred to as “Trapp Technology”, collects, uses, and disclose s information you provide to us or which we otherwise collect (“Information”), including “Personal Data” by which we mean Information that allows us to determine your identity.

This Data Privacy Policy applies to TrappTechnology.com and to other websites Trapp Technology operates that link to this Data Privacy Policy.

The use of Trapp Technology products and services, including those available through other Trapp Technology websites that link to this Data Privacy Policy (collectively, “Offerings”), are subject to the terms of the applicable customer agreement.

1.2 Data Collection

There are two primary ways in which Trapp Technology collects Information about you; through Interactions and through Offerings as set forth below.

1.3 Interactions

When you interact online or offline with Trapp Technology, we may receive your Information, including your Personal Data. For example, Trapp Technology receive your Information when you:

  • Visit Trapp Technology websites or offices
  • Download materials through Trapp Technology websites
  • Provide or update account information through Trapp Technology websites
  • Register for or attend Trapp Technology-hosted or sponsored events (such as promotional events, webcasts, or contests)
  • Communicate with Trapp Technology, including by emails, phone, texts, and online
    chats
  • Provide testimonials
  • SMS Opt-in messages

Trapp Technology collects Information about you from other sources such as public databases, commercial data sources, joint marketing partners, resellers, managed services providers and other partners, social media platforms, and conference/event hosts.

Trapp Technology refers collectively to these contacts as “Interactions” and this Data Privacy Policy explains how we use the Information we collect through them.

1.4 What Trapp Technology Collects via Your Interactions

Trapp Technology (or others acting on our behalf) may collect your Information, including your Personal Data, through Interactions. The Personal Data that Trapp Technology collect includes such things as:

  • Name or alias
  • Email address
  • Physical address, including country
  • Employer
  • Title / position
  • Payment details
  • Phone number
  • Username / user ID
  • IP address
  • MAC address (or other device identifiers automatically assigned to your device when you access the Internet)
  • Images and related metadata (for example, when visiting Trapp Technology offices or attending an event)
  • Content of your communications and files you input, upload, or create
  • Videos (for example, when you provide a product testimonial)
  • SMS Opt-in information and information collected for SMS purposes

Trapp Technology collects Personal Data in various ways, such as when you manually key in your Personal Data to our website forms or provide it to us or others from whom we receive marketing leads.

IP addresses are also collected on an automated basis through your use of the website services using cookies, web beacons, and like technologies. Trapp Technology may infer your location from your IP address. For more on the use of cookies and like technologies, see the “How Trapp Technology Uses Information Collected from Interactions” section below.

Trapp Technology does not collect sensitive Personal Data, such as information relating to health, race, ethnicity, sexual orientation, or trade union membership, except that we collect health information as needed to administer employee benefits, and we may collect other sensitive information from employees or applicants if required to show compliance with fair hiring and employment laws. Trapp Technology does not collect or store credit card data. You may enter such data into the system of an independent credit card processor, but it is not accessible to or stored by Trapp Technology. Trapp Technology services are not directed at people under the age of eighteen, and we request that they not provide us any Personal Data. Trapp Technology will erase any such data that is inadvertently provided or stored.

1.5 How Trapp Technology Uses Information Collected from Interactions

Trapp Technology uses the Information collected from your Interactions to deliver services to you in accordance with our terms, to fulfill our contractual and legal obligations, or to “pursue legitimate business interests”, as described below. Trapp Technology takes seriously the need to balance our legitimate interests with your privacy rights. Your Information is used, including Personal Data, to:

  • Fulfill your orders or respond to your requests for information and other inquiries
    For example, to satisfy your requests for website materials such as marketing collateral or white papers, Trapp Technology collects and uses your name and email address.
  • Operate, enhance, and personalize your experience on Trapp Technology’s website
    Trapp Technology collects Information via cookies and other information gathering technologies to fulfill our legitimate interest in operating our website, making it easy to navigate, enriching the available content and offering information tailored to your interests. In doing so, Trapp Technology may receive your location information, which you can stop at any time by configuring the location setting permissions in your device. You may choose to control and/or delete all cookies from your hard drive. If you delete a cookie, however, please be advised that some features of Trapp Technology’s Site may not be accessible to you. Another option available to you is to change the preferences or settings in your web browser to control cookies. In some cases, you can choose to accept cookies from a primary Site, block them from third parties, or clear out all cookies.
  • Issue you Trapp Technology accounts for access to online communities and forums and to enable your participation there
    When you join Trapp Technology’s online communities and forums, including blogs and Trapp Technology-branded business communication and streaming platform channels(collectively, “online forums”), Personal Data is collected to enable your access and provide an interactive experience when you participate. The guidelines associated with those online forums recommend not sharing private or proprietary information on them, as many of their aspects are public. If you choose to submit content to online forums, such content will be considered “public” and will not be subject to the privacy protections set forth in this Privacy Policy except as required by applicable law. Online forums that display the Trapp Technology name but present you with their own privacy notice are subject to such privacy notice and not this Privacy Policy.
  • Send you administrative notices
    Trapp Technology may need to notify you (or we may choose to inform you) when we make updates to our terms or policies or make changes to our website services. Trapp Technology will use your name and email address to send such administrative notices to you, which due to their nature are treated differently from marketing communications from which you can opt out.
  • Manage your Trapp Technology accounts
    To perform the services under the contract between you and Trapp Technology, we need to collect certain Information from you such as your contact and payment details. Without this Information, Trapp Technology may not be able to deliver the services or comply with our contractual or legal obligations.
  • Advertise and market to you
    With your consent or to pursue legitimate business interests, Trapp Technology may contact you with product announcements, educational materials, announcements about special offers, or information about upcoming or ongoing online/offline events. If required by applicable law, Trapp Technology will ask you for your consent before sending and/or give you the choice to opt out of receiving these communications.
  • Administer prize promotions and events
    Trapp Technology uses your Information to administer prize promotions and events based on the terms of the promotion or event. For example, if you enter into a prize promotion, Trapp Technology may use your data to select a winner and provide the prize to you if you win. Or, if you register for a workshop or other event, Trapp Technology may add your name to the list of expected attendees.
  • Invite you to participate on customer advisory boards or in surveys, studies, and assessments of Offerings
    Trapp Technology may use your Personal Data to register you to participate on advisory boards (such as our Customer Advisory Board or Product Advisory Council) or to request feedback from you about Trapp Technology Offerings. Trapp Technology use your feedback to fulfill our legitimate interest in improving our Offerings and growing our business. Your participation is voluntary and subject to the terms of your agreements with Trapp Technology and this Data Privacy Policy.
  • Diagnose and fix technical issues, monitor for security, and otherwise protect Trapp Technology property
    Trapp Technology does this to satisfy our legitimate interest in assessing actual or potential threats to our facilities, attendees at Trapp Technology-sponsored events, our IT systems and networks, and website services. Trapp Technology may process your
    Information, in particular your IP address, for this purpose.
  • To recruit you for a position at Trapp Technology
    Trapp Technology may use your username or handle and contribution information from Trapp Technology-managed repositories on third-party open-source platforms to fulfill legitimate interest in identifying candidates for open positions at Trapp Technology.
  • Comply with law
    Trapp Technology may use your Information to comply with any applicable law, regulation, legal process, or governmental request, or to protect our legal rights or those of others.
  • Send SMS messages about products, services, and promotions
    With your consent or to pursue legitimate business interests, Trapp Technology may use your information to send SMS messages about products, services, and promotions.
  • For any other purpose disclosed to you in connection with Trapp Technology website services from time to time

If Trapp Technology process your Personal Data for other purposes, we will provide you with information about such processing, and if required, obtain your consent.

1.6 SMS Terms and Conditions

The following Terms and Conditions apply to Trapp Technology use of SMS messaging to send messages about products, services, and promotions, or to communicate other relevant information as needed.

  • Messaging frequency may vary.
  • Message and data rates may apply.
  • By opting into our SMS service, you agree that Trapp Technology will collect your mobile phone number and use it to send you messages related to our products, services, and promotions, or communicate other relevant information as needed.
  • To opt out at any time, reply “STOP” to an applicable SMS message.
  • or assistance, text ìHELPî or visit our website at https://trapptechnology.com/
  • Visit https://trapptechnology.com/legal/data-privacy-notice/ for complete details on our Privacy Policy and Terms of Service.

1.7 Opting Out of Marketing Communications

If you no longer want to receive marketing emails from Trapp Technology on a go-forward basis, please submit your request by emailing us at legal@TrappTechnology.com. Alternatively, you may use the “unsubscribe” feature in Trapp Technology email messages and/or by replying “STOP” to an applicable SMS message.

1.8 Offerings

Trapp Technology also collects Information, including Personal Data, when providing our Offerings. Trapp Technology may ask you for this Information directly, or in some cases, we may collect it when certain features are enabled. For example, Trapp Technology collects Information from or about you when you (or someone you work with):

  • Order or sign up for a trial of Trapp Technology Offerings
  • Interact with Trapp Technology online or offline, including when you request support services
  • Use Trapp Technology Offerings to process information

1.9 What Trapp Technology Collects via Our Offerings and How We Use It

Trapp Technology collects and processes different types of product data (described below) when you deploy our Offerings in order to fulfill our contractual and legal obligations and operate our business or fulfill other legitimate interests. Trapp Technology works hard to help ensure a balance between our legitimate interests and your privacy rights.

  • License Usage Data is Information that allows Trapp Technology to identify your on premises account entitlements, such as license consumption, capacity, or type in our systems through an assigned license ID. Trapp Technology uses this information to validate accounts and automate license verification.
  • Usage Data is Information about your operating environment and configuration, user/product interactions, and sessions. This may include information about your network and systems architecture and configurations, OS and product versions, product configuration, applications installed, page loads and views, searches by number and type, errors, number of active and licensed users, source types and format (e.g., json, xml, and csv), web browser, http referrer page, and app workflows. Trapp Technology uses Usage Data to fulfill our contractual obligations in providing the Offerings to you and to fulfill our legitimate interest in supporting and enhancing them. For example, Trapp Technology may use this data to:
    • Troubleshoot issues, provide support, and update Trapp Technology Offerings
    • Provide guidance to help you optimize your configuration, security, and usage of Trapp Technology Offerings
    • Better understand how our users configure Trapp Technology Offerings
    • Determine which configurations or practices optimize performance (e.g., best practices)
    • Benchmark key performance indicators (“KPIs”)
    • Recommend enhancements
    • Perform data analysis and audits
    • Identify, understand, and anticipate performance issues and the factors that affect them
    • Identify product security issues that may affect you and inform you of them
    • Improve and develop new features and functionality
    • Monitor the health, performance, and security of Trapp Technology Offerings
  • Support Usage Data includes License Usage and/or Usage Data as part of a customized support program that offers you accelerated troubleshooting, notices of patches/upgrades, tips to optimize usage, security, configurations and/or performance, and suggestions about other Offerings that may be of interest to you. The data is customer-identifiable so that Trapp Technology can help personalize your experience. From time to time, Trapp Technology may also use the Information to analyze usage trends, such as by data type, environment size, scale and architecture, and industry or sector, to develop and prioritize product enhancements (e.g., bug fixes or new features). This Information is essential for the operation of Trapp Technology cloud Offerings.
  • Call Recordings. With your consent, Trapp Technology may record customer service calls for training purposes only. Trapp Technology may also record certain calls when responding to reported issues, but only with consent for the purpose of validating Support Center quality-related research. You may choose not to participate in a recorded call at any time during the call.
  • Mobile Device Data is Information Trapp Technology collects in certain Trapp Technology Offerings (“Apps” as discussed below) that associates your mobile device with an identifier for your App to help us improve the user experience and personalize your services and content. Trapp Technology may also receive information that your mobile device sends when you use our Apps, such as a device identifier or OS. Depending on a customer’s configuration of Trapp Technology Offerings, location information about a customer’s end users may be shared with Trapp Technology. You can disable location sharing using the location setting features on your mobile device.
  • Security Offerings Data. Certain security-focused Offerings collect and, in some cases, allow sharing of Customer-submitted “artifacts” (such as logs, alerts, emails, cases, and incidents) and intelligence sources to support security investigation, threat detection and monitoring. In some cases, this Information may contain names, IP addresses, email addresses, phone numbers and other types of Personal Data contained in such artifacts and intelligence sources. You determine the extent and nature of the data you submit and whether to participate in such Offerings and in some cases to share the data with Trapp Technology. Participation in these services is voluntary and is further described in the relevant terms of service

Certain Trapp Technology Offerings rely on automated methods of processing, such as artificial intelligence, which is a set of technologies and processes that allow computers to learn, reason, and assist in decision making. These technologies may consume Usage Data or other data you submit to the Offering that may be associated with you. The use of data in connection with such Offerings is set forth in the relevant terms.

1.10 Other Collection Practices

Trapp Technology also collects Information from you to fulfill our contractual commitments to you. For example, Trapp Technology collects contact information such as name, address (email and physical) and phone number to enter you into our databases and manage your account. Trapp Technology also collects billing and payment information and information about Offerings, such as browser type, version number and OS, to administer your account, respond to customer service/support inquiries, and provide you with information about software updates via alerts or other “push” notifications. Trapp Technology may share this Information as described in How Trapp Technology Share Your Information. Trapp Technology does not sell this Information.

1.11 Data Collection Practices Associated with Apps

The Trapp Technology Offerings are extendible using software applications commonly called “apps,” “add-ons,” “widgets,” or “technical add-ons” that we offer through Trapp Technology or other websites that link to this Privacy Policy. Trapp Technology refers to these collectively as “Apps.” These Apps are versatile and have access to a broad set of web technologies that can be used to collect and use your Information. This Privacy Policy only applies to Apps built by or on behalf of Trapp Technology. It does not apply to Apps developed by others (“App Developers”) and available through third-party marketplaces or repositories (e.g., AWS Marketplace, Google Play Store, and GitHub), or interoperable with Trapp Technology Offerings.

Trapp Technology collects Information generated from the use and performance of Trapp Technology , such as crash information, version, session duration, and user engagement (e.g., number of downloads, active/licensed users, and logins). Trapp Technology may share this data with our App Developers so they can improve and enhance the performance of Trapp Technology.

1.12 How Trapp Technology Shares Your Information

Trapp Technology may disclose your Information to others in the following ways:

  • Subsidiaries. Trapp Technology may disclose Information to our subsidiaries subject to this Privacy Policy so that they can help market, sell, and service our Offerings. Trapp Technology is the party responsible for the management of jointly used Personal Data. Trapp Technology maintains intragroup agreements covering the use of Personal Data within the Trapp Technology family of companies.
  • Partners and Sponsors. Trapp Technology may disclose contact and account Information to our partners and event hosts/sponsors (identified at time of registration or event participation) pursuant to written agreements with confidentiality, privacy, and security obligations. They may use the Information to assess your interest in Trapp Technology Offerings, conduct user research and surveys, or send you marketing communications, subject to the terms of their privacy policies. Trapp Technology may also share Support Usage Data with partners when they manage your Offering for you.
  • Online Forums. When you take certain actions on blogs and Trapp Technology-branded business communication and streaming platform channels (“online forums”) that are public or intended to be public in nature, such as when you broadcast content, participate in a chat room, post profile information, or follow a channel, that information may be collected, used, or disclosed by other participants in the online forums. In addition, some features of online forums are designed to provide others with information about user activity, such as the subscription status of users for a given channel.
  • Compliance and Safety. Trapp Technology may disclose Information as necessary or appropriate under applicable laws (including laws outside your country of residence) to: comply with
    legal process or requirements; respond to requests from public or government authorities (including those outside your country of residence); enforce our terms and conditions; and protect our operations, rights and safety, and that of you and others, as needed.
  • Merger, Sale, etc. Trapp Technology may disclose Information in the event of a proposed or actual corporate or financing transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or disposition of all or any portion of Trapp Technology business, assets, or stock (including Information regarding any bankruptcy or similar proceedings).

Your Personal Data, including SMS Opt-in information, phone numbers collected for SMS purposes, and other data as defined in the “What Trapp Technology Collects via Your Interactions” section above, is not shared with, or stored on platforms provided by, third parties (persons or companies who are not part of Trapp Technology). Your Personal Data will not be sold to or otherwise provided to third parties for purposes of marketing their goods or services. Your Personal Data will not be subject to any automated decision-making or profiling that would affect your rights.

1.13 How Trapp Technology Secures Your Information

Trapp Technology takes reasonable technical and organizational measures to safeguard Personal Data against loss, theft, and unauthorized access, disclosure, alteration, misuse, or destruction.

Trapp Technology complies with all laws and regulations applicable, including data protection laws, and has appropriate technical and organizational measures in place to ensure that your Personal Data is:

  • Processed lawfully, fairly and in a transparent manner
  • Collected for the purposes specified above and not further processed in a manner incompatible with those purposes
  • Adequate, relevant and limited to what is necessary for those purposes;
  • Accurate and where necessary, kept up to date with inaccurate data promptly corrected or deleted
  • Retained for no longer than necessary for the purposes stated above
  • Kept secure as per relevant Information Security policies

Unfortunately, no data transmission, software, or storage system can be guaranteed to be 100% secure. If you have reason to believe that your Personal Data may no longer be secure (for example, if you feel that the security of an account has been compromised), please notify us immediately in accordance with the “Contact Trapp Technology” section below. If Trapp Technology learns of a breach of its systems, Trapp Technology may notify you or others consistent with applicable law and/or as agreed in our contract with you. Trapp Technology may communicate with you electronically regarding privacy and security issues affecting Information collected through your Interactions or use of our Offerings.

1.14 Other Observed Practices

Retention Period

Trapp Technology retains your Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or not prohibited by applicable law. Trapp Technology retains your contract information for the duration of your agreement with us and thereafter as required or permitted by law. Trapp Technology keeps a record of your data requests, including your requests to opt out of marketing communications, to honor them in the future.

Use of Trapp Technology Offerings by Minors

Trapp Technology Offerings are not directed to individuals 18 and under or those not of the age of majority in your jurisdiction, and we request that these individuals, or others on their behalf, not provide us with their Information.

1.15 Your Rights

You have important data rights, including the following:

  • Right to Access: You have the right to access and review Personal Data.
  • Right to Rectification: You have the right to have inaccurate or incomplete personal data corrected or updated.
  • Right to Erasure (Right to be Forgotten): You can request the deletion of your personal data.
  • Right to Restriction of Processing: You can request limitations on how your data is processed in specific situations.
  • Right to Data Portability: You can receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller.
  • Right to Object: You have the right to object to the processing of your personal data based on legitimate interests or direct marketing.
  • Right to Withdraw Consent: If you have consented to the use of your Personal Data, you have the right to withdraw consent at any time and to unsubscribe from all marketing emails.
  • Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights.
  • Right to Lodge a Complaint: You have a right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.

If you would like to exercise these rights, please submit your request, with a description of the nature of your request to legal@TrappTechnology.com and we will respond as soon as reasonably practicable consistent with applicable law. Trapp Technology will verify your identity before we comply with your request and ask for your cooperation with our identity verification process.

1.16 Lawful Basis for Transferring Your Data: Cross-border
Transfers

Your Personal Data may be stored and processed in any country where Trapp Technology, its subsidiaries, partners, sub-processors, and third-party service providers conduct business or host events. These locations may be outside of your country of residence, including in the United States, where different data protection laws may apply. When Trapp Technology transfers Personal Data, we implement safeguards for protection of the transferred Personal Data, such as standard contractual clauses. Trapp Technology put in place appropriate terms to protect your Personal Data in our agreements with our service providers

1.17 Supplemental Terms and Conditions for Certain Regions

European Union (EU)

Trapp Technology rely on a variety of legal bases to process Personal Data, including your consent, a balancing of legitimate interests, necessity to enter into and perform contracts, and compliance with a legal obligation. If Trapp Technology processes your Personal Data based on your consent, you may withdraw your consent at any time. Trapp Technology will let you know if we are seeking to rely on your consent at the time of collection.

Trapp Technology has offices in countries whose data protection laws have not been deemed to be adequate by the EU, including the United States, and may transfer your Personal Data among those offices. Trapp Technology will not transfer your Personal Data to third parties who assist in providing or marketing our goods or services, who may be located in countries that do not have data protection laws as strong as those in your own country. To address these risks, Trapp Technology enters into Data Transfer Agreements containing Standard Clauses approved by the EU Commission, which contractually require the level of data protection mandated by the EU.

If you have any questions or concerns about Trapp Technology’s privacy practices, you can contact us at any time via the contact options listed under the “Contact Trapp Technology” section below. If your request or concern is not satisfactorily resolved by us, you can approach your local data protection authority.

California

If you are a California resident, California law provides you with specific rights regarding your personal information, subject to certain exceptions, including the right to know about the personal information a business collects about you, the right to request that Trapp Technology delete the personal information we collect from you, and the right to non-discrimination for exercising your rights. For purposes of California law, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household.

If you or a designated third-party agent would like to exercise these rights, please submit the request through our data request form, and we will respond as soon as reasonably practicable consistent with applicable law. Trapp Technology will verify your identity, and the identity of any third-party agent acting on your behalf, before we comply with the request, and ask for your cooperation with our identity verification process. Please note that Trapp Technology is only required to respond to two such requests per individual each year.

1.18 Updates to this Data Privacy Policy

Trapp Technology regularly review our Information Security Policies and provides updated versions to our Auditors and Customers. Trapp Technology posts our updates here; https://trapptechnology.com/legal/data-privacy-notice/. Trapp Technology will also communicate any material changes of the Data Privacy Policy to you.

1.19 Contact Trapp Technology

Exercising your Rights

If you want to exercise any of your rights or need to contact Trapp Technology’s Data Protection Office, please email legal@trapptechnology.com or call (toll-free in the US and Canada) at 1+ 844-682-7667 Ext. 5, should you have any questions or concerns.

Exercising your Rights – GDPR

You have the right to lodge a complaint about the treatment of your personal data by contacting the data protection authorities in your home country, state or by contacting the U.K.’s Information Commissioners office at 0303 123 1113 or https://ico.org.uk/concerns or initiate a Live Chat at https://ico.org.uk/global/contactus/live-chat.

Trapp Technology, Inc.
Legal Department
2600 N. Central Ave
Ste 1100
Phoenix, AZ 85004

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