Thanks for using TRI Recruit or visiting our website. This policy explains the what, how, and why of the information we collect when you visit one of our websites, or when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell lists or email addresses.
These definitions should help you understand this policy. When we say “we,” “us,” “our,” and “TRI Recruit,” we are referring to TRI Recruit Ltd. When we say “Member,” we are referring to the person or entity that is registered with us to use the Services. When we say “you,” we are referring either to a Member or to some other person who visits any of our Website. “Personal Information” means any information that identifies or can be used to identify you or a Subscriber, directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information. A “Distribution List” is a list of Subscribers and all associated information related to those Subscribers (for example, email addresses).
4. Questions & Concerns
If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use contact us by post or email at:
46 The Priory Queensway
5. Information We Collect
(c) List and email information: When you add a Distribution List or create an email with the Services, we have and may access the data on your list and the information in your email. If a Subscriber chooses to use the ‘forward to a friend’ (FTF) link in an email campaign you send, it will allow the Subscriber to share your email content with individuals not on your Distribution List. When a Subscriber forwards an email to a friend, we do not store your Subscriber’s email address or their friend’s email address, and no one is added to any Distribution List as a result of the FTF.
(d) Information from your use of the Service: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Services for both you and for all of our users.
(f) Web beacons: We use web beacons on our Websites and in our emails. When we send emails to Members, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments of Members. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create reports about how your email campaign performed and what actions your Subscribers took. Reports are also available to us when we send email to you, so we may collect and review that information.
(g) Information from other sources: From time to time we may obtain information about you or your Subscribers from third party sources, such as public databases, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services. For example, we use this information to develop Social Profiles, a tool that helps you learn about your Subscribers and allows you to send them more relevant content.
6. Use and Disclosure of Personal Information
We may use and disclose Personal Information only for the following purposes:
(b) To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
(e) To protect the rights and safety of our Members and third parties, as well as our own.
(f) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
(g) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
(h) To prosecute and defend a court, arbitration, or similar legal proceeding.
(i) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
(j) To provide, support, and improve the Services we offer. This includes our use of the data that our Members provide us in order to enable our Members to use the Services to communicate with their Subscribers. This also includes, for example, aggregating information from your use of the Services or visit to our Websites and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your Subscribers with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.
7. Data Collected for and by our Users
As you use our Services, you may import into our system Personal Information you have collected from your Subscribers or other individuals. We have no direct relationship with your Subscribers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. Consistent with the uses of Personal Information covered in Section 6, we may transfer Personal Information of you or your Subscribers to companies that help us promote, provide, or support our Services or the services of our Members (“Service Providers”). All Service Providers enter into a contract with us that protects Personal Information and restricts their use of any Personal Information consistent with this policy. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about Subscribers. We may share this information, including Subscriber email addresses, with third parties in line with the approved uses in Section 6.
We will retain Personal Information we process on behalf of our Members for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
8. Public Information and Third Party Website.
(a) Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
9. Third Parties
We may disclose Personal Information to the following types of third parties for the purposes described in this policy:
(a) Service Providers. Sometimes, we share your information with our third party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like enable a feature such as Social Profiles), then we may share your and/or your Subscribers’ Personal Information with a Service Provider for that purpose. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy. Examples of Service Providers include hosting services and content delivery services.
10. Contest and Sweepstakes
We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.
11. Content of Email Campaigns
When you send an email marketing campaign, it bounces from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email was not built for confidential information. Please do not use TRI Recruit to send confidential information.
12. Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you, then TRI Recruit will notify you as soon as possible and later report the action we took in response.
13. Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
Our servers are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this policy.
TRI Recruit is responsible for the processing of Personal Information it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
We will not use or disclose Personal Information for the purpose of our direct marketing to you unless: you have consented to receive direct marketing; you would reasonably expect us to use your personal details for the marketing; or we believe you may be interested in the material but it is impractical for us to obtain your consent. You may opt out of any marketing materials we send to you through an unsubscribe mechanism or by contacting us directly.
16. Accuracy and Retention of Data
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.
We will give an individual, either you or a Subscriber, access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete information we hold about them by contacting us. . Unless it is prohibited by law, we will remove any Personal Information about an individual, either you or a Subscriber, from our servers at your or their request. There is no charge for an individual to access or update their Personal Information.
18. Do Not Track Disclosure
“Do Not Track” is a standard that is currently under development. Because it is not yet finalized, TRI Recruit adheres to the standards in this policy and does not monitor or follow any Do Not Track browser requests. That said, some of our features may have the ability to monitor or follow Do Not Track browser requests.
Policy dated Dated 5th December 2017