1. Introduction
Trap Plan (also referred to as: we, us, our) is committed to protecting the privacy and security of individuals (also referred to as: you, users, visitors) according to all applicable Data Protection Laws.
We ensure the protection of your personal data by applying high standards of conduct for privacy issues. We also ensure that our employees are provided with the appropriate training to handle personal data in accordance with the applicable laws.
This privacy policy (“Privacy Policy”) explains how we control and/or process personal data in connection with our services (the “Services”). This policy sets out the basis on which any personal data we collect, or that you provide to us, will be processed by us. It also describes the rights you have and control you can exercise in relation to it.
Please read this Privacy Policy in conjunction with our Terms of Use.
2. Personal Data
For the purpose of this Privacy Policy, we are the data controller. The term ‘personal data’ used in this Privacy Policy applies to any information about you which can be used to personally identify you, such as your name, address, telephone number, email address, or any other personal information you might supply.
Keeping users’ information safe and secure is among our highest priorities. Data protection laws vary by country and those applicable in the USA and elsewhere are not equivalent to those applicable in, for example, the UK and/or the EU or certain other jurisdictions. We will take steps to protect your information in line with locally applicable data protection requirements. For EU citizens, for example, we have implemented privacy protection mechanisms that reflect the General Data Protection Regulation (EU) 2016/679.
Please read the following carefully to understand our views and practices regarding your personal data and how we treat it, prior to accessing or utilizing our Services.
3. What Kind of Personal InformationDo We Process?
Information You Give Us:
Contact Information
You may give us information about you by filling in forms on our Service or by corresponding with us by email or otherwise. This includes information you provide when you register to use our Service, subscribe to our Service, participate in discussion boards or other social media functions on our Service, and when you report a problem with our Service. The information you give us may include, but not be limited to, your name, postal address, email address, phone number (including mobile phone number where provided), personal description, and photograph.
Children’s Privacy
We do not knowingly collect personally identifiable information from anyone under 16 years old. If you are under 16 years old, you may not submit any personal data to us. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information.
Information We Collect About You:
With regard to each of your use of our Service, we may automatically collect the following information:
Your Logon ID and Password:
For access to our direct services or platforms.
Information from Public Sources:
e.g. LinkedIn and similar professional networks, directories, or internet publications.
Subscriptions/Preferences:
When you subscribe to receive updates or newsletters as well as consent preferences to help us identify which materials you are interested in receiving.
Events Data:
Attendance at and provision of feedback forms in relation to our events.
Social Media:
Posts, likes, tweets, and other interactions with our social media presence.
Technical Information:
When you access our Services, we may collect information such as IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system you are using, device type, hardware model, MAC address, unique identifiers, and mobile network information.
Online Data:
When you access our Services, we may collect information about your visit including URL clickstream to, through, and from our website (including date and time), information about your network such as information about devices, nodes, configurations, connection speeds, and network application performance; pages viewed or searched for, page response times, download errors, length of visits, interaction information (such as scrolling, clicks, mouse-overs), and whether you click on particular links or open our emails.
Cookies:
Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. The personal data we collect through these technologies will also be used to manage your session.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website.
For more information about cookies and how we use them, please see our Cookies Policy.
4. Our Reasons for UsingYour Personal Data
We will process your personal data for a number of reasons, including:
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
To maintain back-ups of our databases and communicate with you.
To improve our Service to ensure that content is presented in the most effective manner for you and your computer.
To allow you to participate in interactive features of our Service, when you choose to do so.
As part of our efforts to keep our Service safe and secure.
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
To make suggestions and recommendations to you and other users of our Service about services that may interest you or them.
To understand topics of interest, market demand and trends, website usage and engagement, visitor profiles, e.g. geographical.
To improve our website design and content.
To improve our products and services.
To market our products/services better, including marketing communications and search engine optimization.
To respond to any feedback.
To send emails, newsletters, and other messages to keep you informed of developments, insights, and our services.
5. With Whom Do We Share Your Data?
We will process your personal data for a number of reasons, including:
Suppliers:
Who support our business including IT and communication suppliers and outsourced business support. Our suppliers have to meet minimum standards as to information security and they will only be provided data in line with their function.
Our Employees:
Who are acquainted with the applicable laws.
Shared Service Centres:
Operated by us or third parties including IT services, marketing, risk management, and office support services.
Law Enforcement Bodies and Regulators:
Or other competent authorities in accordance with legal requirements or good practice.
Appropriate Parties in Emergencies:
To protect the safety of our clients, staff, and organizations.
Advertising Networks and Analytics Service Providers:
To support and display ads on our website, apps, and other social media tools.
Third Parties:
In the context of the acquisition or transfer of any part of our business or in connection with business reorganizations, such as:
Acquisitions and transfers of our business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If our company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use; or to protect the rights, property, or safety of us, our customers, or others as provided below.
To any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries from time to time.
Other Third Parties:
Including business partners, suppliers, and subcontractors for the performance of any contract we enter into with them; advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and analytics and search engine providers that assist us in the improvement and optimization of our website.
Other Delegates:
Where your name will appear on the attendee list for events where you have told us you plan to attend.
6. What are the Legal Grounds for Our Processing of Your Personal Information?
We may share information (including personal information) if:
You have given us consent, for example where you share details for particular purposes.
This is necessary to comply with legal or regulatory obligations, for example anti-money laundering and mandatory client screening checks.
We have a legal obligation to do so, and/or when we have a good faith belief that such action is necessary to comply with either a court order or legal process served on us.
Processing is necessary for our legitimate business interests or those of a third party, provided this does not override any interests or rights that you have as an individual. Our legitimate interests are listed in the next section.
7. Legitimate Interests
We have legitimate business interests in:
Managing our business and relationship with you or your company or organization.
Understanding and responding to inquiries and client feedback.
Understanding how our clients use our services and websites.
Identifying what our clients want and developing our relationship with you, your company, or organization.
Improving our services and offerings.
Enforcing our terms of engagement and website and other terms and conditions.
Ensuring our systems and premises are secure.
Ensuring debts are paid.
Operating suppressors to exclude you from direct marketing if you unsubscribe.
Sharing your data in connection with acquisitions and transfers of our business.
Any other purpose(s) which has been agreed by or notified to you.
8. Security of Your Personal Data
The data that we collect from you may be transferred to, and stored at, a destination outside the UK and the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
We have implemented administrative, technical, and physical measures designed to protect your personal information from accidental loss and from unauthorized access, disclosure, use, alteration, or destruction. These measures include computer safeguards and secured files and buildings, Internet firewalls, intrusion detection, anti-virus protection, network monitoring, and encrypted browsers. Unfortunately, the transmission of information via the internet is not completely secure.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Service; any transmission is at your own risk. Once we have received your information, we will use reasonable measures and security features to try to prevent unauthorized access.
If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential. Please also be careful to avoid “phishing” scams, where someone may send you an email that looks like it is from us asking for your personal information. We will never request your personal information through email.
9. How Long Your Data is Kept
We keep the data for the time necessary to fulfill the purpose of processing your services or requests.
10. Right to Access and Control Your Personal Data
If you are within the jurisdiction of the UK or of one of the EU Member States or in certain other jurisdictions where similar rules apply, you have certain rights in relation to your information. The availability of these rights and the ways in which you can use them are set out below in more detail.Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact the relevant Data Privacy contact as listed in this Policy above.
Access:
You are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it.
Correction:
You are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
Erasure:
You are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
Restriction:
You are entitled to ask us to suspend the processing of certain of your personal data about you, for example, if you want us to establish its accuracy or the reason for processing it.
Transfer:
You may request the transfer of certain of your personal data to another party.
Objection:
Where we are processing your personal data based on legitimate interests (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes.
Automated Decisions:
You may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
Consent:
Where we are processing personal data with consent, you can withdraw your consent.
If you want to exercise any of these rights, please contact one of the Data Privacy contacts set out in this Policy above, in writing at the relevant email address.
You also have a right to lodge a complaint with a data protection supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where we are based, or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner’s Office.
11. Right to Object
If you are resident within the UK and/or EU or in certain other jurisdictions where similar rules apply, you may have a right to object to us processing your information in certain circumstances. This applies where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.
12. Direct Marketing
As described above, you can opt out of receiving direct marketing from us at any time. We may use the information you give us on our or other means for direct marketing purposes to provide emails, newsletters, and other messages to keep you informed of developments, market insights, and our services including events that we think may interest you.
You can opt out of receiving direct marketing from us at any time. You can do this by changing your marketing preferences on your online account settings page or by clicking on the “unsubscribe” link included at the end of any marketing email we send to you.
13. External Links
Our Service may, from time to time, contain links to and from the websites of partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
14. Changes to this Privacy Policy
We may update this Privacy Policy periodically and will note the date of its most recent revision above. If we make material changes to this Privacy Policy, we will notify you by prominently posting a notice of such changes prior to implementing the changes.
We encourage you to review this Privacy Policy frequently to be informed of how we are using, protecting, collecting, retaining, disclosing, and transferring your information.
15. Contacting Us
Questions, comments, and requests regarding this Privacy Policy should be addressed to support@trapplan.com
Please let me know if you need any further adjustments or additional information included.
