This policy sets out how we handle your personal information if you’re a Trumpet Media Canada user or visitor to our Sites. It applies across all Trumpet Media Canada Sites (the “Sites”).
When we say ‘we’, ‘us’ or ‘Trumpet Media Canada’ it’s because that’s who we are and we own and run the Sites.
The type of personal information we collect
We collect certain personal information about visitors and users of our Sites.
The most common types of information we collect include things like: user-names, member names, email addresses, IP addresses, other contact details, survey responses, blogs, photos, payment information such as payment agent details, transactional details, tax information, support queries, forum comments, content you direct us to make available on our Sites (such as business descriptions) and web analytics data. We may will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).
How we collect personal information
We collect personal information directly when you provide it to us, automatically as you navigate through the Sites, or through other people when you use services associated with the Sites.
We collect your personal information when you provide it to us when you complete membership registration and buy or provide items or services on our Sites, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.
Personal information we collect about you from others
Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
third party service providers (like Google, Facebook) who are located in the US or UK, which may provide information about you when you link, connect, or login to your account with the third party provider and they send us information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider; and
other third party sources/ and or partners, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification service.
How we use personal information
We will use your personal information:
To fulfil a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the Sites, like where you purchase an item from our marketplace.
Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
Where you give us consent:
When we disclose your personal information
We will disclose personal information to the following recipients:
Where we transfer and/or store your personal information
We are based in Canada so your data will be processed in Canada and the US. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based outside Canada and the US. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How we keep your personal information secure
We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in Canada. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.
How you can access your personal information
You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us for any of our Sites at any time. To make an access or correction request, contact our privacy officer using the contact details at the end of this policy.
Marketing Choices regarding your personal information
Where we have your consent to do so (e.g., if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly in your case.
Cookies and web analytics
When you visit our Sites, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
Information about children
If you are under 18 we ask that you do not give us your personal information. You can browse the Sites but you’ll need the supervision of a parent or guardian to become a registered user. It’s the responsibility of parents or guardians to monitor their children’s use of our Sites.
Information you make public or give to others
How long we keep your personal information
When we need to update this policy
We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
How you can contact us
If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our privacy champion in writing at 1439 Legion Road, Burlington, ON, Canada L7S 1T6 or [email protected].
If you’re a user or visitor in the European Economic Area these rights also apply to you:
For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
How you can access your personal information
You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.