Trust20 Privacy Notice

Welcome to the Trust 20 Privacy Policy. We take your privacy seriously, and we have developed this Policy to describe Trust20 (“Trust20”, “we”, “our” or “us”) collects, uses and shares Personal Information, including Personal Information collected when you visit our website www.trust20.co (the “Site”) or use our food safety training service (“Service”).

Updates to this Policy: We may change this Policy from time to time. When we make updates, we will post any changes to this Policy on the Site, and we will update the ‘Last Updated’ date above or we will notify you in another manner. We encourage you to check back periodically to review this Policy for any changes since your last visit.

What is Personal Information?
For the purposes of this Policy, Personal Information means any information, which alone or in combination with other data, can be used to identify or locate a natural person. Personal Information expressly excludes information that is lawfully publicly available or data that is de-identified or aggregated and can no longer be used to identify a natural person.

Types of Information We Collect About You

We may collect the following categories of Personal Information from you, including when you visit our Site or use our Service:

Sources of Personal Information We Collect

We collect the categories of Personal Information described above from the following sources:

Information We Collect Directly From You. We will collect Personal Information you provide to us. For example, we will collect your name and email address when you create an account, or when you correspond with us.

Information We Collect Automatically. We automatically collect information about your use of the Site and the Service using cookies and other technologies, as described below.

• Cookies – We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our Cookie Policy for more information. We participate in behavior-based advertising, this means that a third party uses technology (i.e.: a cookie) to collect information about your use of the Site and the Service.
• Usage Details – We use technology to monitor how you interact with the Site and use the Service. This may include: IP addresses, preferences, web pages you visited prior to using the Service, information about how you interact with the Site and the Service (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors). If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.
• Device Information – information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs  and language and other regional settings). We collect information from your mobile device such as unique identifying information broadcast from your device when using the Site or the Service.

Information We Receive from Third Parties. We receive information from our service providers and other third party sources, such as from analytics providers and targeted advertising service providers.

Purpose for Collection and Use of Personal Information

We collect and use Personal Information for the following purposes:

How We Share Your Information

We may share your information, including Personal Information, in the following instances:

How We Protect Your Personal Information

We have implemented reasonable physical, technical, and organizational precautions to protect the information we collect from unauthorized access or acquisition.

Use of Cookies and Your Consumer Data Choices

We use cookies, session replay software and other tracking technologies (collectively “Cookies”) when you use our Site and our Service. A cookie is a small text file that our Site saves onto your computer or device when you use the Site. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site or the Service. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.

We describe below some of the tools we use on our Site and our Service to collect information, including Personal Information, for Targeted Advertising and Analytics and how you can opt-out, customize ad preferences or limit collection or use of Personal Information for those purposes.

Analytics

We use third-party analytics tools on our Site, including those listed below.

• Google Analytics’ Advertising Features. We have enabled and implemented the following Google Analytics Advertising Features: create Remarketing Audiences based on specific behavior, demographic, and interest data, and share those lists with Google Ads. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use of this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site or the Service.
  
  For more information on how Google uses this data, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners’ sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics opt-out browser add-on will not prevent us from using other analytics tools and will not prevent Personal Information from being sent to the Service itself or to Google.

Targeted Advertising

• Google AdWords. We also use Google AdWords, an online advertising service provided by Google, to serve ads on our behalf across the Internet and sometimes on the Site or the Service. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site or the Service.
  
  
• Facebook Custom Audience. We use the remarketing services of Meta, 1601 S. California Ave, Palo Alto, CA 94304, USA on our website. We use Facebook Custom Audience to deliver targeted advertisements to Site visitors on Meta based on email addresses that we have collected. A lookalike audience was created in December 2022, and use was discontinued in February 2023. You may learn more about Facebook Custom Audience by visiting here. To learn more about Meta’s Privacy Policy including their services and your rights, please click here: Meta Privacy Policy - How Meta collects and uses user data | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy.
  
  
• LinkedIn Matched Audiences. We use the remarketing services of LinkedIn, Sunnyvale, CA, USA on our website. We use LinkedIn Matched Audiences to deliver targeted advertisements to Site visitors on LinkedIn based on email addresses that we have collected. A lookalike audience was created in August 2023, and use was discontinued in October 2023. You may learn about LinkedIn Matched Audiences by visiting here. To learn more about LinkedIn's Privacy including their services and your rights, please click here: LinkedIn Privacy Policy.
  
  
• Pinterest Actalike Customers. We use the remarketing services of Pinterest, San Francisco, CA, USA on our website. We use Pinterest Actalike Customers to deliver targeted advertisements to Site visitors on Pinterest based on email addresses that we have collected. An actalike customer was created in March 2023, and use was discontinued in April 2023. You may learn about Pinterest Actalike Customers by visiting here. To learn more about Pinterest's Privacy including their services and your rights, please click here: Pinterest Privacy Policy.

Behavior analytics and website analysis

• Fullstory, Inc. We used the Session Replay and Heat Map services of Fullstory, Inc., 1745 Peachtree Rd NW Suite N, Atlanta, GA, USA, on our website from June 2021 until July 2023. We use these services to observe the behaviors of Site visitors in order to make improvements to our Site and Services. You may learn about session replay on Fullstory by visiting here and heat maps here. To learn more about Fullstory's Privacy including their services and your rights, please click here: Fullstory Privacy Policy.
  
  
• Hotjar Ltd. We began using the Heat Map and Recording services of Hotjar, Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ, Malta, in August 2023. We use these services to observe the behaviors of Site visitors in order to make improvements to our Site and Services. To learn more about Hotjar's Privacy, including their services and your rights, please click here: Hotjar Privacy Policy.

What Choices Do I Have Regarding Use of My Personal Information?

Targeted Marketing. We may send periodic promotional emails to you. You may unsubscribe to promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process unsubscribe requests. If you unsubscribe from receiving promotional emails, we may still send you emails about your account or the Service.

Updating your Account Information. You can access and update your account information, including your name and e-mail address, by logging into your Trust20 account.

Digital Advertising opt-outs. To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads.

Terms Applicable to California Residents

Under the California Consumer Privacy Act of 2018, as amended, including by the California Privacy Rights Act (the “CCPA”), California residents have certain additional privacy rights, with certain exceptions. If you live in California, you may exercise those rights using the manner described, below. Capitalized terms in this section that are not defined elsewhere in this Policy have the definitions attributed to them in the CCPA.

Categories Of Personal Information Disclosed For A Business Purpose. During the past 12 months, we have disclosed the following categories of Personal Information for a Business Purpose: Identifiers, Protected Classifications, Customer Records, Commercial Information, Internet Activity Information, Geolocation Data, Employment Information and Educational Information.

Right to Know. You have the right to request information about our Personal Information collection practices during the prior 12 months, including the categories of Personal Information we collected, the categories of the sources of that information, our business purposes for collecting or sharing the information, and the categories of third parties with whom we shared such information. You may request a copy of the specific pieces of Personal Information we may have collected about you in the last 12 months. When we disclose this information to you, you have the right to receive it in a machinereadable, portable format.

Right to Delete. You may request that we delete (and direct our service providers to delete) your Personal Information, subject to certain exceptions.

Right to Correct. You may request for us to correct inaccurate Personal Information we maintain.

Right to Opt-Out. You have the right to opt-out of the sale or sharing of your Personal Information.

Right of Non-Discrimination. You have the right to not be discriminated against for exercising these rights.

How to exercise your California privacy rights

1. Contact us using the following methods:

Relish Works Inc., d/b/a Trust20
Attn: Privacy Team
222 W Merchandise Mart Plaza
Suite #575
Chicago, IL 60654

Email: help@trust20.co

Phone: 773.831.5692

OPT-OUT PREFERENCE SIGNAL (GLOBAL PRIVACY CONTROL) You may use the Global Privacy Control (“GPC”) or another opt-out preference signal to opt-out of the sale or sharing of your Personal Information under California law.

2. Contents of your request; verification.

When submitting a request to exercise your California Consumer Privacy rights, you must provide sufficient information to allow us to verify that you are the person about whom we collected the Personal Information and for us to respond to your request. You may be required to provide additional information necessary to confirm your identity before we can respond to your request, and we will use that information only for that purpose. If we cannot reasonably verify you, we will not be able to process your request.

3. Authorized agents.

You may permit an authorized agent to submit a request on your behalf. In order for us to process a request from an authorized agent, we must:

a. Be able to verify both your own identity and the identity of your agent; and
b. Receive signed, written consent from you allowing the agent to submit the request on your behalf
If we cannot verify the agent is authorized to act on your behalf, we may deny your request.

4. What to expect after sending a verifiable request.

We will acknowledge receipt of your request within 10 days from receipt of such request and will endeavor to respond within 45 days after receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. For requests to limit the use and disclosure of your sensitive Personal Information we will comply with your request within 15 days after receipt of such request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm that the Personal Information relates to you. You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.

How We Retain Your Personal Information

We will retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise periods for which we keep your Personal Information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We may retain information (including without limitation your Personal Information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. You can request further details of retention periods for different aspects of your personal data by contacting us at help@trust20.co. 

Other Jurisdictions

Company is located in the United States. The Site and the Service are hosted in, provided from the United States, and intended for those that reside in the United States. Personal information that you submit through the Services may be transferred outside of the jurisdiction in which you live. We also store Personal Information locally on the devices you use to access the Services. Your Personal Information may be transferred to other jurisdictions that do not have the same data protection laws as the jurisdiction in which you initially provided the information. The following provisions may apply to you depending on where you are located.

Nevada

This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing customers, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at help@trust20.co or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: AGCinfo@ag.nv.gov.

Vermont

In accordance with Vermont law, we will not share information we collect about you with companies outside of ours except as described herein, otherwise required or permitted by law.

Virginia

This Section is only applicable to you if you are a resident of the state of Virginia (“Virginia Residents”). If you have a complaint, first contact us at help@trust20.co. We will respond within 45 days after receipt of your request, and such time may be extended for an additional 45 days if it is reasonably necessary. We will notify you of any extension within the initial 45-day period. If you are not satisfied with our responses, you have the right to appeal. We will respond within 60 days after our receipt of your appeal. If you still have an unresolved complaint, please direct your complaint to the Virginia Attorney General at service@oag.state.va.us or call (804)786-2071.

Other Important Information

Links to Other Websites or Content. The Site and the Service may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites. We have no control over the privacy practices of websites or applications that we do not own.

Social Media. We are active on social media platform, such as Facebook, YouTube, Instagram, Twitter, and LinkedIn. Any content that you post on our social media sites is public information, and we may post your content from those sites to the Site or social media pages.

Children Under 13. Our Site and our Service are not designed for children under 13, we do not target our Service or Site to anyone under the age of 13, and we do not knowingly collect Personal Information directly from users under the age of 13 or from other websites or services directed at children. If we discover that a child under 13 has provided us with Personal Information, we will take reasonable efforts to delete such information. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted Personal Information to us without your permission or consent, we will make reasonable efforts to remove the information from our records, at your written request. To request the removal of your child's information, please send us an email at help@trust20.co and be sure to include the same information that your child submitted. For clarity, we do not knowingly sell or share the Personal Information of anyone under the age of 13 years old.

Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.

Contact Us

If you have questions about this Notice, please contact us at:

Relish Works Inc., d/b/a Trust20
Attn: Privacy Team
1 N. Dearborn St., 1750
Chicago, IL 60602
Email: help@trust20.co
773.831.5692