In this Privacy Notice (“Notice”) we describe how Trust20 (“Trust20”, “we”, “our” or “us”) collects, uses and discloses information that we obtain about those that interact with Trust20 via online advertisements or marketing emails, visitors to our website www.trust20.co (the “Site”) and clients that engage us to provide products and/or services, enroll in our courses, and/or engage with any other websites, pages, features, or content we own or operate (collectively with the Site, the “Services”).
By using the Services, you agree that you have read and accept this Notice and acknowledge and agree that your personal information will be collected and handled as described in this Notice. Your use of the Services, and any dispute over privacy, is subject to this Notice, the Cookie Policy and if you elect to enroll in a course, the Training Services Agreement (“Training Services Agreement”).
We take privacy very seriously, and we will not share personal information in ways unrelated to those described in this Notice. The Services are intended for companies located in the United States only, and you hereby expressly acknowledge and agree that if you are accessing and/or using the Services that you reside in the United States and will only access and/or use the Services in the United States.
Last Updated: October 1, 2021
How We Collect Your Information
How We Use Your Information
How We Share Your Information
How We Keep Your Personal Information Secure
What Choices Do I Have Regarding Use of My Personal Information?
How We Retain Your Personal Information
Other Important Information
Other Jurisdictions
Contact Information
Types of Information We Collect About You
We collect information about you directly from you and automatically through your use of our Services. The information we collect from you depends on how you use our Services. This information includes the following:
| Context | Types of Data | Primary Purpose for Collection and Use of Data |
| Customer Information | We collect the name, contact information and email address of our customers. | We have a legitimate interest in contacting our customers and communicating with them in relation to the Services. |
| Customer User Account information |
We collect information you provide to create an account, specifically your name, email address, phone number and payment information. | We have a legitimate interest in providing certain account-related functionalities to our users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, we use this information to fulfill our obligation to provide you with Services. |
| Cookies and first party tracking | 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 have a legitimate interest in making the Services operate efficiently. |
| Cookies and Third Party Tracking | 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 Services. | We have a legitimate interest in capturing website analytics and engaging third parties to assist with providing Services to you. |
| Email Interconnectivity | 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. | We have a legitimate interest in understanding how you interact with our communications to you. |
| Employment | If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your social security number. Providing this information is required for employment. | We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations, and provide Services to our customers. |
| Feedback/Support | We collect personal data from you contained in any inquiry you submit to us regarding the Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue. | We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries. |
| Mailing List | When you sign up for one of our mailing lists, we collect your email address or postal address. | We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products and services. |
| Mobile Devices | We collect information from your mobile device such as unique identifying information broadcast from your device when using the Services. | We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices. |
| Enrolling in a Course | We collect your name, billing address, e-mail address, phone number, and credit card number when you enroll in a course. | We have a legitimate interest in using this information to provide Services |
| Surveys | We may collect your name and email address when you choose to participate in a survey. | We have a legitimate interest in gaining your feedback to improve the Services. |
| Website &Application Interactions | We use technology to monitor how you interact with the Services. This may include: IP addresses, preferences, web pages you visited prior to using the Services, 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), information about how you interact with the Services (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors). | We have a legitimate interest in understanding how you interact with the Services to better improve the Services, and to understand your preferences and interests and to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
| Web logs | We collect information, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. | We have a legitimate interest in monitoring web logs to provide the Services and enhance the Services. |
How We Collect Your Information
Information We Collect Directly From You. If you would like more information about the Services, you can provide your name and email address to us via the Site. We also collect any additional information you choose to submit via any open text box we provide.
Information We Collect Automatically. We automatically collect information about your use of the Services through cookies and other technologies, such as the pages you view and your IP address. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- to provide the Services;
- to communicate with you about your use of the Services, to respond to your inquiries, and for other customer service purposes;
- to tailor the content and information that we may send or display to you, to offer certain location-specific information, and personalized help and instructions, and to otherwise personalize your experiences while using the Services;
- to better understand how users’ access and use the Services, both on an aggregated and individualized basis, such as evaluating which features of the Services are most used;
- to administer surveys for market research or customer satisfaction purposes;
- to comply with legal obligations, as part of our general business operations, and for other business administration purposes; and
- where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Notice or the Training Services Agreement.
How We Share Your Information
We may share your information, including personal information, in the following instances:
- Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf, such as email marketing providers and other third-party providers used to provide the Services (“Third Party Providers”). The third party service providers we are engaged with to provide the Services include without limitation ‘Stripe’ (https://stripe.com/), ‘Talent LMS’ (https://www.talentlms.com/), ‘Mailchimp’ (https://mailchimp.com/), ‘Hubspot’ (https://www.hubspot.com/), ‘Databox’ (https://databox.com/) and ‘Optimizely’ (https://www.optimizely.com/) and theterms and policies related to such products and services are set forth on such third party’s website.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Notice.
- Process payments. We transmit your personal information via an encrypted connection to our payment processor. To learn more about the payment processor we use and their policies related to privacy, learn more at https://stripe.com/.
- Third Party Plugins and Social Media Platforms. We may share personal information with website plugins, social media platforms or similar third-party services to improve your experience, at your direction, or when you intentionally interact with the plug-in. For example, when you use elect to log in to your account via your social media account, we may share your personal information with such third-party social media company.
- Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, attorneys and consultants.
- In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena
- To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Notice or the Training Services Agreement, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
How We Keep Your Personal Information Secure
While take your privacy seriously and have a security team dedicated to keeping personal information safe. alteration, disclosure and/or destruction of information we hold. We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Because the internet is not a completely secure environment, we cannot warrant the security of any information a user transmits to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. We are not responsible for the functionality, privacy and/or security measures of any other organization and are not responsible for the practices employed by any websites and/or services linked to and/or from the Services, including without limitation the information and/or content contained therein.
What Choices Do I Have Regarding Use of My Personal Information?
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 any Services.
Your Rights and Choices
- Right to Know. You have the right to request disclosure about our personal information collection practices during the prior 12 months, including the categories of personal information we collected, the sources of the 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.
- 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 Opt-Out. You have the right to opt-out of any ‘sales’ of your personal information, if a business is selling your information.
- Non-Discrimination. You have the right to not be discriminated against for exercising these rights.
You can make the following choices regarding your personal information:
- Access To Your Personal Information. You may request access to your personal information by contacting us at the address below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. We will provide this information in a portable format, if required. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
- Changes To Your Personal Information. We rely on you to update and correct your personal information. Please contact us at the address below immediately if there are any changes to your personal information. Note that we may keep historical information in our backup files as permitted by law.
- Deletion Of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required or permitted by law, or as otherwise described in this Notice. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
- Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address below.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include ‘Do Not Track’ instructions.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you Service-related communications.
- Revocation Of Consent. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you Services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address below.
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.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice. We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide us with requested information, you may not be able to use the Services. You can request further details of retention periods for different aspects of your personal data by contacting us.Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.
Other Important Information
Third Party Providers. The Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Notice, 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 and we have no liability related thereto.
Children Under 13. Our Services are not designed for children under 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 delete such information.
Changes to this Notice. We may change this Notice from time to time. When we make updates, we will post any changes to this Notice on the Site and we will update the ‘Last Updated’ date above. We encourage you to check back periodically to review this Notice for any changes since your last visit. If we make any changes to this Notice that materially affect our practices with regard to the personal information, we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and/or by sending you an email to the email address, if any, we have on file for you.
Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
Other Jurisdictions
Company is located in the United States. The Services 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.
California
This Section is only applicable to you if you are a resident of the state of California (“California Residents”) and only applies to personal information for which Company is a “Business” (as defined in the California Consumer Privacy Act (“CCPA”), but does not apply to personal information we collect from you in the course of our provision of services to you where you are an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. It applies to personal information we collect from California Residents on or through our Services and through other means (such as information collected offline or in person).
Rights and Choices. Under the CCPA and subject to certain limitations and exceptions, if you are a California resident, you may have certain rights with respect to information we have collected about you that constitutes personal information under the CCPA as set forth herein. This Notice describes the personal information we collect about you. We collect this information for the purposes described herein and we share this information as described herein. Company uses cookies as described in our Cookie Policy.
Exercising Your Rights. If you’re a California resident and desire to exercise your data protection rights, please contact us at help@trust20.co. 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. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. 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 that we not sell your 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. For requests for a copy of the personal information we have collected during the 12endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us. For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if (1) the information is necessary for us to (a) complete a transaction for you or otherwise perform a contract; or (b) detect, protect against, or prosecute security incidents, fraud or illegal activity; (2) we use the information only internally in ways reasonably aligned with your expectations as our customer, and (3) we are required to retain the information to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged and provided your information to delete your information as well.
Selling Information. We do not sell your information for monetary consideration, and we do not disclose your information for other valuable consideration. If, in the future, we enter into arrangements that fall within the definition of a ‘sale’ under the CCPA, we will update this Notice.
Using an Authorized Agent. You may submit a request through someone holding a formal ‘Power of Attorney’. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us, and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
Categories of Information Collected. During the past 12 months we may have collected the following categories of information about California residents from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. This includes information about Site visitors, customers that have enrolled in courses, employees, vendors, suppliers, and any other person interacting with us either online or offline. Not all information is collected about individuals. For instance, we may collect different information from applicants for employment than from customers. Please see more information below:
| Categories of Personal Information That We Collect | To Whom We Disclose Personal Information for Business Purpose |
| Identifiers – this may include name, postal address, phone number, unique personal identifier, online identifier, IP address, device ID, email address or other similar identifiers. |
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| Financial information – this may include bank account number, credit or debit card number, or other financial information. |
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| Commercial information –this may include information about Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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| Network activity data– this may include internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. |
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| Professional/employment information – this may include occupation and professional references. |
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| Education information –such as information contained in education records. |
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Affiliates or subsidiariesContact Us
If you have questions about this Notice, please contact us at:
Relish Works Inc., d/b/a Trust20
Attn: Privacy Team
222 W Merchandise Mart Plaza
Suite #575
Chicago, IL 60654
Email: help@trust20.co
773.831.5692