LAST UPDATE: June 4, 2018
This Privacy Statement describes information that Trail Tech and its affiliates (“Trail Tech”, “we”, “our”, and “us”) collect, use, share and store, including personal information. Trail Tech cares about the integrity and security of consumer personal information. However, Trail Tech cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use personal information for improper purposes. You acknowledge that you provide your personal information at your own risk.
This Privacy Statement focuses on the types of personal information we collect through your operation of various Trail Tech products and services (collectively, “Trail Tech”).
Consent to Data Collection and Processing
You hereby agree with and consent to the collection and processing of your personal information as described in this Privacy Statement.
Consent to International Data Transfers
Your personal information may be collected, processed and stored by Trail Tech or its services providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. You hereby agree with and consent to the transfer of your personal data to the United States and other countries where Trail Tech operates.
Withdrawal of Consent
You have the right, at any time, to withdraw your consent to Trail Tech’s collection and processing of your information, or to the transfer of your personal data to the United States and other countries where Trail Tech operates. You may withdraw your consent by emailing Trail Tech at email@example.com.
2. GENERAL PRINCIPLES FOR THE PROCESSING OF PERSONAL INFORMATION
Personal information will be collected, stored, processed and transmitted in accordance with Trail Tech’s established policies and applicable federal, state, local and foreign laws, rules and regulations.
The principles of Trail Tech with respect to the processing of personal information are as follows: (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by Trail Tech will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and processed, (4) personal information collected by Trail Tech will be accurate and, where necessary, kept up to date to the best of our ability, (5) personal information collected by Trail Tech will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected, and (6) personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
If Trail Tech engages in the processing of personal information for purposes other than those specified in this Policy, Trail Tech will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.
3. INFORMATION COLLECTED
As you interact with Trail Tech, there may be opportunities for you to provide us with your information. Additionally, we may collect certain information about your or your Trail Tech products as further described below.
You may provide us with information about you or your Trail Tech products through a number of sources: Trail Tech websites, applications, product and related events, surveys, social media platforms, sweepstakes entries, and through our customer contact centers. We also receive information about you through Trail Tech product sales records provided by your dealer and we may obtain, with your consent, data obtained from your Trail Tech product.
The types of information that Trail Tech collects about you may include, but are not limited to:
Contact information (such as name, address, city, state and ZIP code, age or date of birth, occupation, social security number, email address and telephone number)
Payment information (such as your bank account information, credit card number, debit card number, bank or investor account, CVV code, expiration date, and payment history)
Information related to your creditworthiness, assets, income, or liabilities
Information about your Trail Tech product
Information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our products, services, apps, and websites (such as IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information)
Demographic information (such as gender, date of birth, marital status, and household composition)
Marketing profile information (such as when you plan to purchase a Trail Tech product)
Photographs and videos such as those that you may submit for contests, sweepstakes and social sharing
Relationships you have with Trail Tech in addition to the purchase and servicing of your Trail Tech product (such as through a rewards card, etc.)
Incentive eligibility verification information (such as college name, branch of service, or credit union name for Trail Tech product purchase programs)
Social Security Number (in limited circumstances Trail Tech may collect SSN, for example if you win a sweepstakes or receive compensation that must be reported for government tax purposes)
Investor Information (name, address, phone number, and email address)
The kind of Trail Tech product you purchased
The kind of service provided to you
In order to register an account with Trail Tech, or join a Trail Tech rider community, you will need to provide your name, address, telephone number, and email address.
If you decide to purchase any Trail Tech Products or services offered by Trail Tech directly from Trail Tech, Trail Tech will ask for your name, mailing address, telephone number, email address and certain financial information such as a credit card number to be used for order processing and payment. Trail Tech may use a third party for payment processing on its behalf. You may also choose to finance your purchase of Trail Tech Products from Trail Tech pursuant to one of several financing options made available by third party financial institutions. If you choose to finance your purchase of Trail Tech Products, you will be directed to one of the third party financial institutions with which Trail Tech has a business relationship to make an application directly through that financial institution in connection with which the financial institution will ask you for the personal and financial information applicable to their own application process, the privacy and security of which will be governed by their privacy policies.
If you decide to purchase any Trail Tech Products or services through an independent dealer, the dealer will ask for your name, mailing address, telephone number, email address, and certain financial information such as a credit card number to be used for order processing. The dealer may use a third party for payment processing on its behalf, and will transmit to Trail Tech all or a portion of the information that you provide to the dealer in connection with your purchases.
If you decide to voluntarily participate in a sweepstakes, game, contest, survey, or other similar activity offered by Trail Tech or in conjunction with a third party provider, you may be asked to provide your name, mailing address, email address and age as well as other information on an optional basis such as your gender or other types of Trail Tech products purchased in order to participate in the sweepstakes, contest, or survey. Occasionally, Trail Tech will refer to this information to better understand your needs and interest in our products and services. If you consent, Trail Tech will also use this information to send you information about Trail Tech products.
4. HOW WE MAY USE INFORMATION WE COLLECT
The information Trail Tech collects about you and your Trail Tech products may be used:
To provide products and services and maintain customer relationships
To improve the quality, safety, and security of our products and services
To administer your account(s) and process your payments for products and services
To operate our websites and applications, including online registration processes
To facilitate and support Trail Tech dealer and supplier diversity programs and Trail Tech grant programs
To autofill data fields on our websites to improve your online experience
To develop new products and services, including connected, autonomous, and car-sharing products and services
To provide customer and Trail Tech product support and service (such as recall information)
For warranty administration and validation
To provide information and product updates
To evaluate Trail Tech product performance and safety
For research, evaluation of use, and troubleshooting purposes
To verify eligibility for Trail Tech product purchases or incentive programs
For marking and analytics purposes
To support the electronic signature and delivery process between you and your dealer
To customize and improve communication content
To comply with legal, regulator, or contractual requirements
Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social medial, or other electronic messages, or via our websites and applications.
We may also receive information from Trail Tech dealers, from our partners, and from other sources and combine that with the information in your Trail Tech account. Personally identifiable information about you that Trail Tech receives from third parties will be processed and stored by Trail Tech and will be treated in accordance with this Privacy Statement. This information may be processed in the same or different ways as any other data that is part of your Trail Tech account.
The following are examples of situations where we may share your personally identifiable information:
With your consent.
For external processing, storage, and management. We may also utilize third party vendors to assist with monitoring our servers for technical problems and data security and privacy compliance. These third party vendors (as well as Trail Tech employees) may access certain information about you or your account in line with this work, but are not permitted to use this data for purposes unrelated to Trail Tech Products and services.
Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the Privacy Statement in place at the time of its collection.
We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, we may disclose information in response to legal process and we may disclose information in response to lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security.
Uses of information and data may include:
“Contact Information” means information that allows someone to identify or contact you (e.g., your name, phone number, home address, and email address). Unless otherwise stated in this Privacy Statement, we do not share your Contact Information with anyone without your permission. However, we may use your Contact Information to market Trail Tech Products and third-party products and services to you via various methods. You can stop the delivery of future promotional emails from us by following the specific instructions in the advertising emails you may receive. These choices do not apply to the receipt of mandatory service communications that are considered important to the Trail Tech Products or services you receive.
“Service Information” means information necessary or useful to us in providing the Trail Tech Products to you (e.g., Trail Tech Products you use and how/when you use them). This information is used by us for operation of the Trail Tech Products, to provide services or information to you, to maintain the quality of our products and services, and to provide general statistics regarding use of the Trail Tech Products. We may also use Service Information for customer support, Trail Tech Product restoration, research and development activities for new products and services, and other similar purposes. Finally, we may provide certain Service Information to selected third parties, such as our dealers and other business partners, to improve the Trail Tech Products or the services we provide, for marketing purposes, or otherwise where we have obtained your consent.
Sometimes we may “anonymize” your information by removing any identifier that can be associated with you. Anonymized information helps us develop reports and analyses about how our customers use the Trail Tech Products and for other research such as behavioral inferences. We may publically share or sell anonymized information and reports and analyses based on anonymized information. We may disclose aggregated, anonymized information, and analyses and reports derived from such information to third parties including utilities, our service providers, suppliers, advertisers, merchants, consumer and market research companies and other organizations. We may share non-personally identifiable information (for example, aggregated or anonymized customer data) publicly and with our partners. We take steps designed to keep this non-personally identifiable information from being associated with you, and we require our partners to do the same.
5. YOUR RIGHTS OVER YOUR INFORMATION
You can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. You can also ask for it to be erased and you can ask for us to give you a copy of the information. You can also ask us to stop using your information and limit how we use your information.
Your California Privacy Rights
Under California’s “Shine the Light Law”, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.
To obtain this information on behalf of Trail Tech, please send an email message to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in the response. Please be aware that not all information is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. For an explanation of our privacy practices, please review our Privacy Statement by clicking the “Privacy Statement” link on our home page.
6. RETENTION AND DELETION OF INFORMATION
We generally store your information or data on our servers or on the servers of our third party vendors until the later of (i) the date you request that we delete or edit it, (ii) the date on which you are no longer a Trail Tech Products customer, or (iii) as long as is required by applicable law.
If you cease to be a Trail Tech Products customer, Trail Tech will deactivate your account and will, upon receipt of a written notice from you, request that our third party vendors delete your account information from their servers. Because of the way we maintain certain services, however, after your information is deleted, backup copies may linger for some time before they are deleted, and we may retain certain data for a longer period of time if we are required to do so for legal reasons.
Trail Tech will take reasonable steps to protect the personal data in its possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction, and will take all useful precautions with regard to the nature of the data and the risks of the processing, to preserve the security of the data and, in particular, prevent its alteration and damage or access by non-authorized third parties. Trail Tech has put in place technical, physical, and organizational procedures and security measures designed to safeguard and secure the personal data from destruction, loss, alteration, unauthorized access or disclosure, or other forms of unauthorized or unlawful processing commensurate with the risks posed by the particular type of processing, the nature of the personal data and in accordance with applicable law, and taking into consideration the cost of implementing such measures. Trail Tech cannot guarantee the security of personal data on or transmitted via the Internet.
Trail Tech will comply with applicable local laws, rules and regulations with respect to data breach disclosure and notification.
8. CHANGES TO THIS PRIVACY STATEMENT
Please note that this Privacy Statement may change from time to time. We will provide notice of any changes on the website or by contacting you.
9. YOUR RIGHT TO COMPLAIN
If you have a complaint as to our use of your information, you may file a complaint with us, the GDPR supervisory authority (for residents of the EU, EEA, or Switzerland), any other governmental agency, and/or a judicial body.
A complaint may be submitted directly to Trail Tech:
For residents of the EU, EEA, or Switzerland, in writing by filling out the Complaint Form;
In writing to the contact information below.
10. CONTACT US
If you have any questions about this Policy, please contact Trail Tech directly.
For a resident of the EU, EEA, or Switzerland, our contact information is:
By mail : Trail Tech Sales Europe Place de l’Industrie 2 1180 Rolle – Switzerland
By email : email@example.com
For all others, our contact information is as follows:
By mail: Trail Tech
1600 SE 18th Ave
Battle Ground, WA, 98604
By email: firstname.lastname@example.org
By phone: 1-844-378-8143 (Monday to Friday, 8am – 5pm PST)