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    TRC Global Privacy & Data Protection Policy

    We at TRC are committed to maintaining the privacy and security of the Personal Information of all the visitors to this website as well as all respondents participating in our hosted surveys. As a part of that commitment, TRC is in the process of implementing our updated Global Privacy and Data Protection Policy. These policies will address the current needs of our visitors and survey respondents to know what information about them we collect, why we collect it, and where it goes. We encourage you to read this Global Privacy and Data Protection Policy. In addition, as a member of the Insights Association, the professional trade association of survey research companies, TRC adheres to the mandated Insights Association Code of Standards and Ethics for Survey Research. You may visit them at www.insightsassociation.org. TRC is committed to maintaining the privacy and security of the Personal Information of all the visitors to this website as well as all respondents participating in our hosted surveys.

    Website Policy

    At this web site, TRC does not actively initiate any collection of any individual information. We passively collect information that is automatically sent to us by your web browser. This information typically includes your domain name (the site after the @ in your e-mail address). It may also contain your user name (the name before the @ in your e-mail address). The amount of information sent depends on the settings you have on your web browser; please refer to your browser if you want to learn what information it sends. At this page we do not actively seek to identify any individual visitor, with the exception of investigating security breaches or cooperating with authorities pursuant to a legal matter.
    We use the information we automatically receive from your web browser to see which pages you visit within our site, which site you visited before coming to ours, and where you go after you leave. We at TRC can then develop statistics that are helpful to understanding how this site is used by our visitors. This statistical data is interpreted by TRC in its continuing effort to present the web site content that visitors are seeking in a format they find most helpful.
    TRC will not use or share, either within TRC or with a third party, any information collected at this page for direct marketing purposes. Because of the nature of the Internet, we may transmit the information to another country, but within TRC, for purposes other than direct marketing, such as for storage, or because of where our servers are located. We may also use it to investigate security breaches or cooperate with authorities pursuant to a legal matter. We may also remove all the personally identifiable information and use the rest for historical, statistical or scientific purposes.

    If you e-mail us, you are voluntarily releasing information to us. Your e-mail address will be used by TRC to respond to you. We will not use the information that can identify you, such as your e-mail address, for direct marketing purposes.

    In addition, we may have collected similar information from you in the past. By entering this website you are consenting to the terms of our information privacy policy and to our continued use of previously collected information.

    In the event of a sale, merger, liquidation, dissolution, reorganization or acquisition of TRC, or a TRC business or business unit, information TRC has collected about you may be sold or otherwise transferred. However, this will only happen if the party acquiring the information agrees to be bound by the terms of TRC’s privacy policy and the notice provided to you when the information was collected.

    For your convenience, this page may contain certain hyperlinks to other TRC pages as well as to web sites outside TRC. While TRC has posted an appropriate Information Privacy Statement throughout our web site, we can make no promises or guarantees regarding data collection on the hyperlinked pages and sites that are not owned by TRC. We therefore recommend that you read the privacy policy/ statement for each site you visit.

    If you are concerned about our use of your Personal Information, please contact us at privacy@trchome.com, with the subject line, “privacy”.

    Data Protection Policy

    Introduction

    TRC depends on the collection and analysis of information about individuals (“Survey Respondents”) to carry out its market research and consulting business. This information may be collected from any kind of individual or organization.

    Phone Research

    Please note that your participation in research is voluntary. A survey may be web or telephone based. By providing your telephone number to us or one of our clients or partners, or by otherwise participating in phone research, you consent to be called or receive text messages, including artificial or prerecorded voice calls and calls or messages by means of an autodialer.

    Data Collection

    Survey Respondent data is the most common data that is collected by TRC. As a market research and consulting firm we may collect personal data from survey respondents during the survey process. The types of personal data we may collect could include but not be limited to the following, Name, Address, Email Address, Phone number or IP address. The data we collect will be used for Market Research purposes only. Your responses to Survey Questions are kept confidential and reporting is aggregated across all survey respondents.

    The data we collect will be stored on servers located in the United States managed in accordance to high industry security standards. The data may be accessed, subject to strict confidentiality obligations, by recipients who are employees of TRC Insights, LLC and it’s affiliated entities. The data will be retained as long as needed to fulfill our obligations to firms that we provide services to. At that time data will be removed and erased from our systems.

    Client provided data is also commonly processed by TRC. Clients usually provide us with sample or to enhance the existing sample for a project. In respect of any personal data that is received, TRC will process these personal data in accordance with the instructions received from the client and in accordance with TRC principles for processing personal data.

    Cookies on the survey environment
    Cookies may be used during the survey you are participating in to assist in the functioning of the survey and well as to protect from fraudulent behavior.

    Principles for Processing Personal Data

    TRC adheres to the following principles for processing personal data.

    • Accurate.
    • Secure
    • Processed in line with Data Subjects’ rights.
    • Processed fairly and lawfully.
    • Processed for limited purposes and in an appropriate way.
    • Adequate, relevant and not excessive for the purpose.
    • Not kept longer than necessary for the purpose.
    • Not transferred to people or organizations situated in other countries without adequate protection

    Security Measures

    TRC operates under a strong security and privacy regime. TRC has successfully undergone third party Service Organization Control auditing (SOC reports) and in the process of obtaining HiTrust certification. The SOC report provides assurance that we have designed and implemented effective security controls as defined in the SOC standards. During the examination, the independent auditors evaluated and tested controls over the following domains:

    • Organization and management
    • Communications
    • Risk management, design, and implementation of controls
    • Monitoring of controls
    • Logical and physical access controls
    • Systems operation
    • Change management

    Your Specific Rights and Choices

    The California Consumer Privacy Act of 2018 (CCPA) provides you with specific rights regarding our personal information. This section describes your rights and explains how you can exercise those rights.

    Right of Access

    You have the right to request access to your personal information. You can make this request for free, twice per year.

    Right to Opt Out

    You have the right to know if your personal data is being sold or shared, and to whom.

    You have the right to object to the sale of personal data.

    If TRC has actual knowledge that an individual is less than 16 years of age, TRC will prohibit the sale of their personal information. If TRC has actual knowledge that an individual consumer is between 13 and 16 years of age, TRC will collect an affirmative opt-in consent “right to opt-in” from parent or guardian before the sale of personal information.

    Right to Deletion

    You have the right to request that TRC delete any personal information about you which TRC has collected from you.

    Once TRC receives a verifiable request to delete personal information:

    • Your personal information will be deleted from TRC’s records and we will direct any service provider to delete your personal information from their records.

    However, this right does not apply where TRC has a need to retain the following personal information:

    • Provide goods or services to you
    • Detect or resolve security issues or functionality-related issues
    • Comply with applicable laws
    • Conduct research in the public interest
    • Safeguard the right to free speech
    • Carry out actions for internal purposes that you might reasonably expect

     

    Right to Non-Discrimination

    TRC will never discriminate against you for exercising any of the CCPA rights. Unless permitted by CCPA, we will not:

    • Deny you goods or services
    • Charge different prices for goods or services, whether through denying benefits or imposing penalties
    • Suggest you receive a different level or quality of goods or services

     

    Access Requests to TRC

    On receiving a verifiable access request, TRC will provide the necessary information in a portable and easily accessible format within 45 days of the request.

    Your request should include:

    • Sufficient information that will allow us to reasonably verify you are the person about whom we collected personal information.
    • Detail that allows us to properly understand, evaluate and respond

     

    Once TRC receives and verifies confirmation of your request, we will disclose the following to you:

    • The category of personal information that we have collected about you
    • The categories of sources from which the personal information was collected about you
    • Our business or commercial purposes for collecting or selling the personal information
    • The categories of third parties with whom we shared your personal information
    • The specific pieces of personal information we collected about you

     

    If TRC sold or disclosed your personal information for a business purpose, we will provide:

    • Sales, identifying the personal information categories that each category of recipient purchased; and
    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

    Privacy Questions, Access Rights, Incident Reporting

    If you have any questions about how we use your personal data or about this privacy notice, you can send an email to privacy@trchome.com. You can also contact us by mail at TRC , 1300 Virginia drive, Suite 200, Fort Washington, Pennsylvania 19034

    If you would like to reach TRC’s Data Protection Officer (as defined under the GDPR) you can contact DataProtectionOfficer@trchome.com or by phone at (215)641-2230. Upon request, TRC will provide you with information about whether we control any of your personal data on our own behalf. If you wish to obtain a copy of particular information you provided to TRC, if you become aware that the information is incorrect and you would like us to correct it, update it, or delete it, if you would like to exercise any of your legal rights such as those in relation to updating your preferences regarding how we use your personal data, or to withdraw consent, contact us at privacy@trchome.com. We will respond to your access request within a reasonable timeframe within the timelines prescribed by applicable law.

    Before TRC is able to assist you, provide you with any information, or correct any inaccuracies, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavor to respond within an appropriate timeframe.

    Should you want to report an incident relating to TRC’s security, confidentiality, or privacy, you are welcome to file a report by contacting privacy@trchome.com.

    Definitions

    In this privacy notice, the term “personal data” includes:
    • Under the laws of the United States, personal data shall include any “non-public personal information” as that term is defined in the Gramm-Leach-Bliley Act found at 15 USC Subchapter 1 §6809(4), and “protected health information” as defined in the Health Insurance Portability and Accountability Act found at 45 CFR §160.103.
    • Under the laws of the countries in the European Economic Area (“EEA”), personal data shall have the meaning given to it in Directive 95/46/EC (the “EU Directive”) and in the General Data Protection Regulation (“GDPR”).
    • Under the laws of Australia, personal data shall include information or an opinion about an identified individual or an individual who is reasonably identifiable: (a) whether the information is true or not; and (b) whether the information or opinion is recorded in a material form or not.