PRIVACY NOTICE FOR TRUMPET

Effective Date: January 1, 2015

Service Management Group, Inc. (“SMG” or “we” or “us”) values our relationship with you and respecting and protecting your privacy. This Privacy Notice applies to www.TrumpetRatings.com and other websites, services and mobile applications on/in which this Privacy Notice is posted or referenced (collectively, the “Trumpet Services”).

This Privacy Notice describes:

  • The information we collect on or through the Trumpet Services and how we collect it.
  • How we use and process the information we collect.
  • Your choices regarding the collection and processing of your information.

When you submit information to or through the Trumpet Services, you hereby consent to the collection and processing of information as set forth in this Privacy Notice.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY BEFORE USING THE TRUMPET SERVICES.

1. Information We Collect and How We Collect It

When you use the Trumpet Services, we may collect the following types of information from or about you (collectively, “Information”):

(a) Personal Information: “Personal Information” is Information associated with or used to identify a specific person. Our definition of Personal Information does not include information that, whether alone or in combination with other information, does not identify a specific person. For example, Personal Information does not include information that allows us to calculate how many users access a particular feature of the Trumpet Services.

Personal Information that SMG collects from you depends on how you use the Trumpet Services. For example, SMG may collect:

  • contact and demographic data when you register and create an account, such as your [e-mail address, telephone number, password, gender, date of birth and zip code];
  • Information that helps us understand you, such as your age, income, gender, brand preferences and other demographic data;
  • Information that you voluntarily provide to us when you use our interactive tools and services, such the words that you type into free-form text boxes;
  • Information that you provide to us when you use the [“Contact Us” function], send us an email or otherwise contact us through the Trumpet Services or by email;

Providing your Personal Information to SMG is your choice but is required for you to use certain features of the Trumpet Services.

(b) Tracking Data: When you use the Trumpet Services, we automatically track and collect data associated with your use of the Trumpet Services, such as (1) IP address; (2) domain server; (3) type of device(s) used to access the Trumpet Services; (4) web browser(s) used to access the Trumpet Services; (5) referring webpage or other source through which you accessed the Trumpet Services; and (6) other statistics and information associated with the interaction among your browser or device and the Trumpet Services (collectively “Tracking Data”). Some Tracking Data may be Personal Information.

We may collect Information through cookies, web beacons, website analytics services and other tracking technology (collectively, “Tracking Tools”), as described below

2. Tracking Tools and ‘Do Not Track’

(a) Tracking Tools: The Tracking Tools that we may use and how we may use them include:

  • Cookies: “Cookies” are small computer files transferred to your computer's or tablet’s hard drive that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Services. We use Cookies to help us improve the Trumpet Services by tracking your navigation habits, storing your password so you do not have to re-enter it each time you use the Trumpet Services, customizing your experience with the Trumpet Services and for analytics and fraud prevention.]
  • Web Beacons: “Web Beacons” (a.k.a. clear GIFs, web bugs or pixel tags) are tiny graphic image files imbedded in a web page or email that provide a presence on the web page or email and send back to their home server information from the user’s browser. We may use Web Beacons to collect information about your use of our Trumpet Services, the websites of selected advertisers and the emails, special promotions or newsletters that we send you. The information collected by Web Beacons allows us to statistically monitor how many people are using the Trumpet Services.]
  • Website Analytics: We may use third-party website analytics services in connection with the Trumpet Services, including, for example, to record mouse clicks, mouse movements, scrolling activity and text that you type in to free-form text boxes. These website analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across websites which do not use their services. We use the information collected from these third-party services to help improve and make the Trumpet Services easier to use.]
  • Mobile Device Identifiers: Mobile device identifiers are files stored on your mobile device that can be used to track your mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers function like Cookies because they enable collection of Personal Information (such as media access control and location) and Tracking Data. As with other Tracking Tools, mobile device identifiers help SMG learn more about our users’ demographics and internet behaviors.]

(b) How SMG Responds to Browser “Do Not Track” Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including SMG, do not respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.

(c) Options for Opting Out of Cookies [and Mobile Device Identifiers]: Some web browsers (including some mobile web browsers) provide settings that allow you to reject Cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept SMG’s Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Trumpet Services.

You may opt out of receiving certain Cookies and certain trackers by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) consumer opt-out page. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer or tablet indicating that you do not want to receive interest-based advertising from NAI or DAA member companies.  If you delete Cookies on your computer or tablet, you may need to opt out again.  For information about how to opt out of interest-based advertising on mobile device identifiers, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device.

3. Use of Information

We use your Information to provide the Trumpet Services to you and to help improve them, including to:

  • conduct analyses to support, improve and enhance the Trumpet Services;
  • manage our relationship with you, including providing customer service;
  • send you with marketing communications and offers for products and services from our customers and other business partners, including for offers targeted based on your interests and Tracking Data;
  • recognize you when you return to use the Trumpet Services and customize and tailor your experience of the Trumpet Services
  • use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts
  • administer the Trumpet Services and enforce our agreements with you; and
  • prevent, detect and investigate security breaches and potentially illegal or prohibited activities.

We and our business partners and service providers may combine information collected from or about you through various sources, including Personal Information, and use the combined information for the purposes described in this Privacy Policy.

4. Disclosure of Information

We may disclose certain information that we collect from you:

  • We may share Information that we collect from or about you with our affiliated companies
  • We may share Information with our business partners who perform services (such as hosting, data storage and security) related to our operation of the Trumpet Services and/or by making certain features available to our users.
  • We may share Information as needed to operate other related SMG services, such as survey applications and other websites that we operate.
  • We may transfer information about you, including your Personal Information, to another company in connection with a merger, sale, acquisition or other change of ownership or control by or of SMG (whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
  • We also may need to disclose your Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (1) comply with a court order or other legal process; (2) protect the rights, property or safety of SMG or another party; (3) enforce our Terms of Use or other agreements with you; or (4) respond to claims that any posting or other content violates third-party rights.

5. Public Information

Any Information that you may reveal in a review posting or online discussion or forum is intentionally open to the public and is not in any way private. We recommend that you carefully consider whether to disclose any Personal Information in any public posting or forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.

6. Children’s Privacy

The Trumpet Services are not intended for use by children. If you are under the age of majority in your place of residence, you may use the Trumpet Services only with the consent of or under the supervision of your parent or legal guardian.

Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without his/her parent’s verified consent, we will use that information only to respond directly to that child (or his/her parent or legal guardian) to inform the child that he/she cannot use the Trumpet Services and subsequently we will delete that information.

7. Links to Other Websites & Services

The Trumpet Services may contain links to third-party websites and services with which SMG has no affiliation. A link to a non-SMG website or service does not mean that we endorse that website or the quality or accuracy of information presented on the non-SMG website or service. If you decide to visit a third-party website or service, you are subject to its Privacy Notice. We encourage you to ask questions before you disclose Information to others.

8. California Consumer Rights Information

A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed Personal Information within the previous calendar year, along with the type of Personal Information disclosed, for the third parties' direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to Service Management Group, Inc., 1737 McGee Street, Kansas City, MO 64108, or by email to privacyofficer@smg.com. Please note that, under California law, businesses are only required to respond to a customer request once during any calendar year.

Under California Civil Code Section 1789.3, we are required to provide California residents with the following specific consumer rights information:

  • Trumpet Services are owned and/or operated by Service Management Group, Inc., 1737 McGee Street, Kansas City, MO 64108.
  • Unless otherwise expressly stated, Trumpet Services are provided without charge.
  • To file a complaint regarding the Trumpet Services or to receive further information regarding use of the Trumpet Services, please send a letter to 1737 McGee Street, Kansas City, MO 64108 or contact us via email at privacyofficer@smg.com (with “California Resident Request” as the Subject Line). You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at 916.445.1254 or 800.952.5210.

9. Information Transmission

The Trumpet Services are hosted in the United States and other jurisdictions. If you are using the Trumpet Services from outside the United States, your information may be transferred to, stored and processed in the United States. The data protection and other laws of the United States may not be as comprehensive as those in your country. By using the Trumpet Services, you consent to transfer of your information to our facilities as described in this Privacy Policy.

10. Security of Information

The security of your Personal Information is important to us. Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. If we become aware that your Personal Information has been disclosed in a manner not in accordance with this Privacy Notice, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted or required by law.

11. Changes To This Privacy Notice

The Effective Date of this Privacy Notice is set forth at the top of this webpage. From time to time, we may update this Privacy Notice to reflect new or different privacy practices. We will place a notice online when we make material changes to this the Privacy Notice. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Additionally, if the changes will materially affect the way we use or disclose previously-collected Personal Information, we will notify you about the change by sending a notice to the email address associated with your account. Your continued use of the Trumpet Services after the Effective Date constitutes your acceptance of the amended Privacy Notice. The amended Privacy Notice supersedes all previous versions.

12. Controlling Your Personal Information

You can modify some of the Information that you have included in your account. If you wish to close your account, please email us at privacyofficer@smg.com. SMG will delete your account and the information in your account as soon as reasonably possible. Please note, however, that SMG may retain information from closed accounts, including to comply with law, prevent fraud, resolve disputes, enforce our Terms of Use and take other actions permitted by law.

Please promptly notify us if any of your account data is lost, stolen or used without permission.

13. How To Contact Us

If you have any questions about privacy, or need assistance with accessing or updating any of your Personal Information, please contact us at privacyofficer@smg.com.

You can also write to us at:

Service Management Group, Inc.

Attn: Privacy Officer
1737 McGee Street
Kansas City, MO 64108

 

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