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TRGRP (en) - Política de Privacidad y Puerto Seguro 18-jul-2017 | 2,58%
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0 PRIVACY POLICY PRIVACY POLICY
1 Privacy statement TRGRP, Inc., D/B/A The Roberts Group Privacy statement TRGRP, Inc.
2 1 GENERAL 1 GENERAL
3 TRG is dedicated to protecting the privacy of your personal information and that of our clients and their users. Our policies regarding the use of your personal information is set forth in the Privacy Policy. This policy applies to websites (public and private) owned and controlled by TRGRP, Inc., d/b/a The Roberts Group (“TRG”) that link to this Privacy Policy (“TRG Websites”). TRG Websites may contain links to or information pulled from third-party websites or services. TRG is not responsible for the information practices or the content of such other websites, and you should review the privacy policies of other websites to understand their information practices. TRG is dedicated to protecting the privacy of your personal information and that of our clients and their users. Our policies regarding the use of your personal information is set forth in the Privacy Policy. This policy applies to websites (public and private) owned and controlled by TRGRP, Inc. (“TRG”) that link to this Privacy Policy (“TRG Websites”). TRG Websites may contain links to or information pulled from third-party websites or services. TRG is not responsible for the information practices or the content of such other websites, and you should review the privacy policies of other websites to understand their information practices.
4 2 PRIVACY FRAMEWORKS 2 PRIVACY FRAMEWORKS
5 As set forth by the U.S Department of Commerce, the European Commission and the Swiss Commission, the EU-US and Swiss-US Privacy Shield frameworks have been set forth to ensure citizens of the European Union and Switzerland are provided data protection policies that comply with those in their respective countries when data is transferred to the U.S. TRG is committed to the protection of personal information for all our clients and visitors and implemented policies that adhere to these principles. As set forth by the U.S Department of Commerce, the European Commission and the Swiss Commission, the EU-US and Swiss-US Privacy Shield frameworks have been set forth to ensure citizens of the European Union and Switzerland are provided data protection policies that comply with those in their respective countries when data is transferred to the U.S. TRG is committed to the protection of personal information for all our clients and visitors and implemented policies that adhere to these principles.
6 2.1 EU-US Privacy Shield 2.1 EU-US Privacy Shield
7 TRG has certified that it adheres to the EU-U.S. Privacy Shield Framework; Privacy Shield Principle of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability. TRG has certified that it adheres to the EU-U.S. Privacy Shield Framework; Privacy Shield Principle of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.
8 Participation in the Privacy Shield applies to all personal data that is received from the European Union member countries, European Economic Area. TRG will comply with the Privacy Shield Principles in respect to such personal data. If there is any conflict between the policies of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Participation in the Privacy Shield applies to all personal data that is received from the European Union member countries, European Economic Area. TRG will comply with the Privacy Shield Principles in respect to such personal data. If there is any conflict between the policies of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
9 To learn more about the Privacy Shield program, and to view TRG’s certification, please visit www.privacyshield.gov . To learn more about the Privacy Shield program, and to view TRG’s certification, please visit www.privacyshield.gov .
10 2.2 Swiss-US Privacy Shield 2.2 Swiss-US Privacy Shield
11 TRG is committed to adherence to the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from Switzerland to the United States. TRG has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. TRG is committed to adherence to the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from Switzerland to the United States. TRG has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
12 To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov .
13 3 INFORMATION COLLECTED 3 INFORMATION COLLECTED
14 Through your use of this various TRG applications and public websites, TRG may possess certain information regarding visitors to publicly accessible websites and the employees and contractors of the businesses that have licensed the use of TRG applications (“Licensee”). Such information is referred to as the “Information”. Through your use of this various TRG applications and public websites, TRG may possess certain information regarding visitors to publicly accessible websites and the employees and contractors of the businesses that have licensed the use of TRG applications (“Licensee”). Such information is referred to as the “Information”.
15 3.1 Personal Information 3.1 Personal Information
16 We collect and store information you enter when asking for information about TRG Services, registering for and using TRG Services, or provide to us in any other way. We collect and store information you enter when asking for information about TRG Services, registering for and using TRG Services, or provide to us in any other way.
17 In addition, Licensee’s may provide (at its discretion) certain personal information including, without limitation, their employee names, work titles, work addresses, business telephone numbers and other personal information (i.e. IP address, etc.). In addition, Licensee’s may provide (at its discretion) certain personal information including, without limitation, their employee names, work titles, work addresses, business telephone numbers and other personal information (i.e. IP address, etc.).
18 3.2 Usage Information 3.2 Usage Information
19 TRG may record your usage details such as time, frequency, duration and patterns of use, features used, Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system, and other visitor details collected in our log files to analyze the trends, track user behavior and administer and improve TRG services. TRG may record your usage details such as time, frequency, duration and patterns of use, features used, Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system, and other visitor details collected in our log files to analyze the trends, track user behavior and administer and improve TRG services.
20 3.3 Additional Information 3.3 Additional Information
21 TRG may learn certain information regarding vendors and third parties with whom Licensee conducts business and certain other confidential and proprietary information regarding Licensee. TRG may learn certain information regarding vendors and third parties with whom Licensee conducts business and certain other confidential and proprietary information regarding Licensee.
22 3.4 User-Generated Content 3.4 User-Generated Content
23 We may provide the ability for users to post information to public and semi-public spaces on TRG websites (for example public and private blogs or customer support sites). Some of this information may be publicly available to users outside of TRG. When using any public or semi-public TRG website, we encourage users to be cautious in disclosure of Personal Information, as TRG is not responsible for the Personal Information users elect to disclose. We may provide the ability for users to post information to public and semi-public spaces on TRG websites (for example public and private blogs or customer support sites). Some of this information may be publicly available to users outside of TRG. When using any public or semi-public TRG website, we encourage users to be cautious in disclosure of Personal Information, as TRG is not responsible for the Personal Information users elect to disclose.
24 4 HOW INFORMATION IS USED 4 HOW INFORMATION IS USED
25 Information provided through TRG owned public websites is used by TRG for purposes in which it was intended when provided. This includes marketing as well as support and system administration services. Information provided through TRG owned public websites is used by TRG for purposes in which it was intended when provided. This includes marketing as well as support and system administration services.
26 For Information provided to TRG through licensed services, TRG shall use the Information provided to it only in connection with the provision of services by TRG on behalf of Licensee and as otherwise permitted pursuant to such agreements between TRG and Licensee. For Information provided to TRG through licensed services, TRG shall use the Information provided to it only in connection with the provision of services by TRG on behalf of Licensee and as otherwise permitted pursuant to such agreements between TRG and Licensee.
27 We will never share your information with a third-party except in cases where the third-party has been contracted by TRG to assist in the provisioning of the services provided. We will never share your information with a third-party except in cases where the third-party has been contracted by TRG to assist in the provisioning of the services provided.
28 TRG is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequent transfers to a third party acting on its behalf. TRG complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. TRG is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequent transfers to a third party acting on its behalf. TRG complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
29 With respect to personal data transferred or received pursuant to the Privacy Shield Framework, TRG is subject to the regulatory enforcement power of the U.S. Federal Trade Commission. In certain situations, TRG may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Unless prevented by court order, TRG will attempt to provide advance notice of such a lawful request for disclosure prior to complying with the order. With respect to personal data transferred or received pursuant to the Privacy Shield Framework, TRG is subject to the regulatory enforcement power of the U.S. Federal Trade Commission. In certain situations, TRG may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Unless prevented by court order, TRG will attempt to provide advance notice of such a lawful request for disclosure prior to complying with the order.
30 In the event that TRG posts user/client testimonials on the TRG Websites, such testimonials may include names or other personal information. We acquire permission from our users and clients before posting these on the TRG Websites. TRG is not responsible for Personal Information users elect to include in their testimonials. In the event that TRG posts user/client testimonials on the TRG Websites, such testimonials may include names or other personal information. We acquire permission from our users and clients before posting these on the TRG Websites. TRG is not responsible for Personal Information users elect to include in their testimonials.
31 5 SAFEGUARDS 5 SAFEGUARDS
32 TRG is dedicated to protecting the privacy of all users of TRG Services and providing our Licensees with the highest level of service and security. In furtherance thereof, TRG has implemented practices and procedures designed to safeguard the privacy and security of the Information. To demonstrate our commitment to Information Security, TRG submitted our Information Security Management System to an independent third-party review and has been certified compliant to the ISO/IEC27001:2013 standard through an accredited certification body. TRG is dedicated to protecting the privacy of all users of TRG Services and providing our Licensees with the highest level of service and security. In furtherance thereof, TRG has implemented practices and procedures designed to safeguard the privacy and security of the Information. To demonstrate our commitment to Information Security, TRG submitted our Information Security Management System to an independent third-party review and has been certified compliant to the ISO/IEC27001:2013 standard through an accredited certification body.
33 6 HOW YOU CAN HELP 6 HOW YOU CAN HELP
34 You can take steps to protect the privacy of the Information. Do not share your account information, passwords, user ID’s, PINs, code words or other confidential information with others. When conducting business over the Internet, always use a secure browser, exit online applications as soon as you finish using them, and make sure you have virus protection and a firewall and update them regularly. Protect and properly dispose of your account records. You can take steps to protect the privacy of the Information. Do not share your account information, passwords, user ID’s, PINs, code words or other confidential information with others. When conducting business over the Internet, always use a secure browser, exit online applications as soon as you finish using them, and make sure you have virus protection and a firewall and update them regularly. Protect and properly dispose of your account records.
35 7 ACCESSING, UPDATING and REMOVING PERSONAL INFORMATION 7 ACCESSING, UPDATING and REMOVING PERSONAL INFORMATION
36 Users that have submitted their information through one of TRG’s public sites can request access to see the information being held by TRG as well as request to have the data updated or removed by sending an email to dataprivacy@trgrp.com . Please note that a response and / or changes can take anywhere from 48hrs to 30 days to complete. Users that have submitted their information through one of TRG’s public sites can request access to see the information being held by TRG as well as request to have the data updated or removed by sending an email to dataprivacy@trgrp.com . Please note that a response and / or changes can take anywhere from 48hrs to 30 days to complete.
37 Requests regarding personal information stored by TRG as part of a licensed product should be directed toward the Licensee as the party that has submitted the information. TRG will provide assistance in contacting and working with the User and Licensee upon request. Requests regarding personal information stored by TRG as part of a licensed product should be directed toward the Licensee as the party that has submitted the information. TRG will provide assistance in contacting and working with the User and Licensee upon request.
38 8 DISPUTE RESOLUTION 8 DISPUTE RESOLUTION
39 In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, TRG commits to resolve complaints about your privacy and our collection or use of your personal information. European and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact TRG at dataprivacy@trgrp.com . In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, TRG commits to resolve complaints about your privacy and our collection or use of your personal information. European and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact TRG at dataprivacy@trgrp.com .
40 TRG has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism through the European Data Protection Authorities (DPAs). TRG commits to comply with the decision / recommendation of the DPAs. TRG has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism through the European Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. TRG commits to comply with the decision / recommendation of the DPAs.
41 9 OTHER AGREEMENTS 9 OTHER AGREEMENTS
42 TRG and Licensee may have entered into other agreements regarding the privacy of the Information. In this regard, all agreements between TRG and Licensee must be reviewed in connection with TRG’s privacy actions. TRG and Licensee may have entered into other agreements regarding the privacy of the Information. In this regard, all agreements between TRG and Licensee must be reviewed in connection with TRG’s privacy actions.
43 10 QUESTIONS 10 QUESTIONS
44 TRG welcomes the opportunity to answer any questions you may have about this statement or the safeguarding and confidentiality of information. For more information, please contact us at dataprivacy@trgrp.com . TRG welcomes the opportunity to answer any questions you may have about this statement or the safeguarding and confidentiality of information. For more information, please contact us at dataprivacy@trgrp.com .
45 11 RIGHT TO CHANGE PRIVACY STATEMENT 11 RIGHT TO CHANGE PRIVACY STATEMENT
46 TRG reserves the right to change this privacy statement at any time. Changes will be effective immediately upon posting. TRG reserves the right to change this privacy statement at any time. Changes will be effective immediately upon posting.
47 Last updated: June 26, 2017 Last updated: July 14, 2017