TRM defines “personal data” as any data or information in any media that on its own or when combined with other data could identify a particular individual, or any other data or information that constitutes personal data under applicable law. Examples of personal data include an individual’s combined first and last name, home address, telephone number, fax number, email address, social security number or other government-issued identifier (including government identification numbers, tax identification number, driver’s license number, or passport number), geolocation information of an individual or device, biometric data, medical or health information, and credit card or other financial information (including bank account information). Personal data also includes cookie identifiers associated with registration information, or any other browser or device specific number or identifier not controllable by the end user, and web or mobile browsing or usage information that is linked to the foregoing.
Personal data does not include information that is de-identified, aggregated, or anonymized as defined by applicable law. Risk-related data entered or developed by you during a software ‘Test Drive’ is not considered personal data and is permanently deleted at the end of the Test Drive.
This policy defines how TRM protects and uses your personnel data obtained through use of our services and/or websites. If there is a Master Services Agreement in effect between you and TRM for use of the risk management app (the “app”), any areas where this agreement conflicts with the Master Services Agreement are governed by the terms of your Master Services Agreement.
Personal Data We Collect
We may collect personal data in several ways, including from you directly, automatically when engaging our services and/or websites, or through third parties.
We may collect information directly from you when you use the services and websites including when you set up accounts, sign up for or engage in any of our services, contact support via telephone or email, provide comments after a test drive, or otherwise contact us. The information we may collect includes:
- your name, phone number, and other contact details, including the company you work for
- your username, password, and email when you register for a test drive
- information you provide for technical support or customer service requests including via chat, email or offline communications
- site tools such as cookies
- any other information you may provide to us voluntarily through your use of our services and/or websites, feedback, and through your communication with us.
TRM does not obtain your financial information or process credit card or other payments as this service has been contracted to the Microsoft App Store.
TRM automatically collect information regarding the actions you take when using the services and/or websites. This type of usage data helps us understand user needs so we can better consider new features or otherwise tailor the services. We may share this usage data with third parties for legitimate business purposes, including to help us better understand our customers’ needs, improve the services and websites, and the app. Some examples of the usage data we may collect include:
- the type of Web browser you use
- device type
- log or site access data
- your operating system
- your web request, Internet Service Provider, and cookies
- location data, such as your IP address
- referring/exit pages and URLs
- the pages you view and how you interact with links
- the time and duration of your visits to the services and websites
- other information relating to your devices and your activity on the services and websites.
When you use the services or website from a mobile device, we may collect certain additional information automatically, including the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, available storage space, connection type (e.g., WiFi vs. cellular), and information about the way you use the application. We may also use GPS technology (or other similar technology) to determine your location at the time of use.
We may use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded. We may link certain information we store within the analytics software to authorized users for customer usage and metrics, and to aid in customer success.
You can remove persistent cookies and change your privacy preferences by following directions provided in your Internet browser’s “help” directory, or by clicking the Cookie Settings button above. However, removing cookies may reduce the functionality of the services and websites.
TRM services and websites do not recognize automated browser signals regarding tracking, including “do-not-track” signals.
We may receive information about you from other sources, including your company or third parties who are TRM customers or users or both, and combine this any data with information we may already have about you. If others give us your information, we will only use that information in compliance with relevant statutes and for the specific reason for which it was provided to us (for example, as part of a referral of marketing campaign). The types of personal data we may collect include:
- name, phone number, and other contact details including the company for which you work.
How We Use Your Personal Data
We may use your personal data for the following purposes:
- creating an account
- enabling a test drive of the app
- questions and requests – If you contact us by email or otherwise, we will use the personal data you provide to answer your question or resolve your problem
- marketing, research, and data analysis – In an ongoing effort to better understand and serve the users of the services and websites, TRM may conduct research on its Customers’ and users’ demographics, interests, and behavior based on usage data and other information provided to us
- Service improvement – We may use your personal data, aggregated personal data, and other information collected through the services and websites to help us improve content and functionality
- order fulfillment – We may use your personal data that you provide to fulfill any orders or request for Services you may place as offered by TRM
- testimonials –;
- blog – Our website may offer publicly accessible blogs or community forums. We may display personal blog comments of satisfied customers on our services and/or websites in addition to other endorsements. By posting a blog comment, you forgo any expectation of privacy with respect to the information provided and give your consent for TRM to use your statement, along with your name, and company name in all media. You should be aware that any information you provide in blogs or other public forums may also be read, collected, and used by others who access them and the information is not deemed private;
- providing customer service;
- detecting, investigating, and preventing fraudulent transactions and other illegal activities; and
- carrying out any other purpose described to you at the time the information was collected.
Sharing Your Personal Data
Your personal data, such as your name or username, may be available to others, for example when you create a profile or submit public queries in the blog. This information may be accessed by users who use the services and/or websites and may be accessed by commercial search engines such as Google, Yahoo, and Bing to the extent that such engines are permitted to access the services and/or websites.
We may disclose your personal data to the following categories of recipients:
- Partner organizations who support us in our efforts to deliver services, websites, and the app in a technically sound and secure manner. We only provide our partner organizations with the information necessary for them to perform these services on our behalf. Each partner organization must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, to protect your personal data from unauthorized access, use, or disclosure.
- law enforcement, public authorities, or legal counsel in response to lawful requests or court orders. TRM will cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose personal data and any other content and information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to or comply with legal requests (including court orders and subpoenas), to protect the safety, property, or rights of TRM or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law;
- a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice; and
- any other person or organization provided you have given consent to the disclosure.
TRM has implemented appropriate physical, operational, and technical safeguards designed to protect your personal data from accidental or unlawful alteration, unauthorized disclosure, or access. We also require that our partner organizations protect such information from accidental or unlawful alteration, unauthorized disclosure, or access.
You should be aware that no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Sites, we cannot and do not guarantee the security of any information you transmit on or through the services or websites.
We will retain your information for as long as we have an ongoing business relationship with you or the business need to do so (for example: to comply with applicable law, tax requirements, or enforce our agreements).
When we have no ongoing legitimate business need to process your personal data, we may either delete or de-identify it, or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
International Data Transfers
Your personal data may be transferred to and processed in countries other than the country in which you are a resident. These countries may have data protection laws that are different from the laws of your country. Our Sites are hosted in the United States and our organizational partners operate around the world.
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to use some of our features. If we have collected and processed your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.
Please note that we may still use any aggregated and de-identified personal data that does not identify any individual, and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
Privacy Notice Changes
From time to time, we may change this Privacy Notice and will note that it has been changed on the services and websites.
Any changes will go into effect on the last updated date shown in the revised Privacy Notice. You can see when this Privacy Notice was last updated by checking the “Last Updated” date at the top of this Privacy Notice. By using the Sites or providing information to us following such changes, you will have accepted the amended Privacy Notice.
Please print a copy of this Privacy Notice for your records.
How To Contact Us
If you have questions or concerns about our use of your personal data, please contact us at:
TRM Advantage Ltd.
PO Box XXXX
246 Stewart Green SW
Canada T3H 3C8