Privacy Policy

TRACOM Policy on Data and Privacy

Effective Date: 1 May 2024

Introduction

TRACOM Group (collectively, “TRACOM”, “We”, “Us”, or “Our”) is committed to safeguarding the privacy and rights of all individuals who use our products and services. We strictly adhere to a policy of not selling, leasing, or renting any personal data to third parties for any reason. Our approach to data collection and use is fully transparent, ensuring our customers are well informed about how their information is handled. This privacy policy details our methods for collecting, utilizing, and securing customer information. By choosing to use our products and services, you consent to the practices described in this policy.

Personal Data

TRACOM collects personal information from our customers when they register for and use our products, services, and websites.  While delivering these services, the personal data gathered includes, but is not limited to the following:

Contact Information
Examples: First name, last name, email address, street address, phone number
Purpose: To identify you, communicate with you, respond to your requests, and perform Our services.

Demographic Information (Optional)
Examples: Country, Company, Job, Job Level, Industry, Age Range, Gender, and Ethnicity (US respondents only)
Purpose: For statistical analysis, and to improve Our products and services.

Identifying Information
Examples: Username, Password, Security Questions and Responses.
Purpose: To authenticate and grant you authorized access to Our products and services.

Behavioral Information
Examples: Training assessment responses.
Purpose: To perform the training services provided by TRACOM.

Non-Personal Information
Examples: IP address, browser type, browser version, pages visited, date/time visited, referring URL, and others.
Purpose: This information is used to improve quality, reliability, and remediate any technical issues.

This information may also be used to comply with any legal obligations and to send you marketing materials, special offers, and other information we think you might find interesting.  You can unsubscribe from these communications at any time by selecting the unsubscribe link at the bottom of our marketing or sales emails.

Children

Our products and services are not designed for individuals under 18. We don’t intentionally gather personal data from minors. Should a child under 18 provide us with such information, guardians should immediately inform us.  In addition, if we find that personal data from a child under 18 was collected without parental consent, it will promptly be deleted from our systems.

Cookies

TRACOM websites use cookies and other tracking technologies to provide a better user experience and to analyze how our customers use our services. You can control cookies by adjusting your browser settings to refuse cookies or notify you when cookies are being sent.  However, some features of our websites may not function properly if you disable cookies.

Data Retention

We retain our clients’ personal information for as long as necessary to provide our products and services, and for the purposes described in this privacy policy. We may also retain personal information to comply with legal obligations, resolve disputes, and enforce our agreements and policies.

Data Security

Ensuring the protection of personal data is paramount at TRACOM. We strictly follow industry standards for privacy and security, utilizing encryption technologies to safeguard information both stored and in transit. Despite these measures, absolute security cannot be guaranteed. Should you have any concerns about the privacy or security of your personal information, we encourage you to contact us.

Data Transfer

TRACOM manages your personal data on systems within the United States, potentially under different data protection laws than those in your region. By agreeing to this Privacy Policy or sharing your information, you approve this transfer. We commit to handling your data securely, aligning with this policy, and will not transfer it internationally unless stringent data protection and security measures are confirmed to protect your personal information.

In the event of an asset sale, merger, consolidation, restructuring, reorganization, liquidation, or similar transaction involving TRACOM, we may transfer some or all personal data to the successor company. TRACOM will notify you via email and/or prominent notice on Our websites of any change in ownership, choices, or uses regarding your personal data.

Google Analytics

Google Analytics is a web analytics service offered by Google LLC that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.  For more information on Google’s privacy practices, please visit the Google Privacy and Terms page.

Legal Disclosure

TRACOM may disclose your personal data to third parties in certain circumstances, including the following:

  • TRACOM Group is involved in a merger, acquisition, or asset sale (with prior notice).
  • To comply with legal obligations, court orders, or other legal processes.
  • To protect our rights, property, or safety, or that of others.
  • To prevent fraud or other illegal activities.
  • To enforce our policies and terms of service.

Payments

For purchases of our products and services, we may request payment information and use a PayPal payment gateway for secure processing. We don’t store or collect card details; this information is directly managed by payment processors adhering to their privacy policies and the Payment Card Industry Data Security Standards (PCI-DSS), ensuring secure transaction handling. For more information on PayPal’s privacy practices, please visit the PayPal Privacy Statement page.

Service Providers

TRACOM may share personal information with third-party service providers who assist us in providing our services, such as payment processors, email service providers, and analytics providers. These service providers are required to protect the confidentiality of our customers’ personal information and are prohibited from using it for any other purpose.

Tracking

TRACOM does not support the Do Not Track (“DNT”) browser option. Do Not Track is a preference you can set in some web browsers to inform websites that you do not want to be tracked.

TRACOM gathers certain information automatically, storing it in log files. Information may include Internet Service Provider (ISP), Internet Protocol (IP) addresses, operating system, browser type, referring or exit pages, date/time stamp, and clickstream data to improve our analytics and services.

GDPR Compliance

TRACOM complies with the European Union’s General Data Protection Regulation regarding your data privacy and processing requirements.  As a data subject under the GDPR, you have the following rights:

  • Right of access: You have the right to access your personal information that we hold.
  • Right to rectification: You have the right to have any inaccuracies in your personal information corrected.
  • Right to erasure: You have the right to have your personal information deleted.
  • Right to restrict processing: You have the right to restrict the processing of your personal information.
  • Right to data portability: You have the right to receive your personal information in a structured, commonly used, machine-readable format.
  • Right to object: You have the right to object to the processing of your personal information.

To learn more please visit the European Commission or national Data Protection Authority in your country.

Should you wish to exercise your rights with respect to your personal data you have two options:

1) You can unsubscribe (opt-out) from some or all TRACOM communications at any time by selecting the unsubscribe link at the bottom of our marketing or sales emails.  Upon selecting that link, a screen will display where you can choose your desired communication preferences.

2) Contact DataRep with any concerns or questions.  DataRep has locations in each of the 27 EU countries, Norway, Iceland in the European Economic Area (EEA), and UK.  Contact them via any of the following methods:

  • Send an email to DataRep at tracom@datarep.com
  • Fill out the online webform at DataRep-TRACOM
  • Submit in writing to DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom
  • Submit in writing to DataRep, 3rd and 4th Floor, Altmarkt 10 B/D, Dresden, 01067, Germany
  • (NOTE: For the written methods above, be sure to use DataRep, and not TRACOM, as the recipient)

DPF Compliance

TRACOM is certified and complies with the principles regarding the processing of personal data received from the European Union in reliance on the EU-U.S. Data Privacy Framework (EU-U.S. DPF), United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF, and Switzerland in reliance on the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), as set forth by the U.S. Department of Commerce.

TRACOM is responsible for the processing of personal data it receives, and any subsequent transfers to a third-party acting agent on its behalf, under the DPF.  TRACOM complies with DPF principles for all onward transfers of personal data from the EU, United Kingdom, and Switzerland, including the onward transfer liability provisions.

TRACOM is subject to the regulatory enforcement powers of the US Federal Trade Commission with respect to personal data received or transferred.  TRACOM may also be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

To learn more or view our DPF certification please visit the Data Privacy Framework Program.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, TRACOM commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States, Canada, and the United Kingdom.

If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit the TRUSTe Feedback & Resolution page for more information or to file a complaint. The services of TRUSTe are provided at no cost to you.

Under certain conditions outlined in Annex I of the DPF Principles, individuals have the right to invoke binding arbitration to resolve claims. To initiate this process, the individual must provide formal notice to our organization and comply with the procedures and conditions specified in Annex I. Our organization is committed to engaging in the arbitration process and adhering to its terms as required.

As a data subject under the DPF, you have the following rights:

  • Right of access: You have the right to access your personal information that we hold.
  • Right to limit usage: You have the right to restrict the usage of your personal information.
  • Right of limit disclosure: You have the right to restrict the disclosure of your personal information.

Should you wish to exercise your rights with respect to your personal data you have two options:

1) You can unsubscribe (opt-out) from some or all TRACOM communications at any time by selecting the unsubscribe link at the bottom of our marketing or sales emails.  Upon selecting that link, a screen will display where you can choose your desired communication preferences.

2) Contact TRACOM directly with any concerns or questions using any of the methods listed in the How to Contact Us section of this privacy policy below.

TRACOM does not share your personal information with any third-party agents. All personal data processing activities are carried out in-house by our team, ensuring direct control over the handling and security of your personal information.

TRACOM collects explicit consent before using or sharing your sensitive personal information such as health, ethnic/racial, political, or religious data.  Consent is obtained through your employer’s contractual agreement with TRACOM.  You may withdraw your consent at any time by notifying your client administrator, who will in turn notify us.  TRACOM ensures the highest level of protection for sensitive information, regardless of its source.

SCC Compliance

TRACOM also relies upon the Standard Contractual Clauses (decision 2010/87/EU), which are in effect with many client organizations, as a mechanism for transferring of personal data outside of the EU. TRACOM processes the personal data it receives in The United States (U.S.).

Privacy Policy Changes

TRACOM may update its Privacy Policy for evolving information practices and service improvement. You’ll need to accept these updates on your next login. We advise regularly checking this page for the latest data and privacy information.

How to Contact Us

If you have any questions or concern regarding this Privacy Policy, please contact us via any of the following methods:

The TRACOM Corporation
6675 South Kenton Street, Suite 118
Centennial, Colorado, USA 80111