Privacy Policy for Trumpet

Effective Date: June, 2018

This Privacy Policy applies to SMG’s processing of Personal Data collected through this website and other websites, services, and applications, including mobile applications, on which this Privacy Policy is posted, linked or referenced (collectively, the “SMG Services”). “Personal Data” is information relating to an identified or identifiable natural person. The SMG Services are owned and/or operated by Service Management Group, LLC, Service Management Group Limited, Service Management Group GK, and their respective affiliates (collectively, “SMG,” “we” or “us”). This Privacy Policy addresses how we collect and process your Personal Data.

REVIEW THIS PRIVACY NOTICE CAREFULLY. Your Personal Data will be collected and processed as described in this Privacy Policy.

If you have not done so, review SMG Terms of Service, which sets forth the terms governing your use of our websites, applications, services and mobile applications (“SMG Services”).

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR TERMS OF SERVICE, DO NOT USE ANY OF THE SMG SERVICES.

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1. CHANGES TO THIS PRIVACY POLICY
2. INFORMATION WE COLLECT
3. HOW WE COLLECT INFORMATION AND PURPOSES OF PROCESSING
4. LEGAL GROUNDS FOR PROCESSING
5. HOW WE USE, SHARE AND DISCLOSE INFORMATION
6. YOUR CHOICES ABOUT INFORMATION COLLECTION
7. COOKIES POLICY
8. ONLINE ADVERTISING AND DATA COLLECTION
9. MANAGING YOUR ACCOUNT INFORMATION
10. CHILDREN’S PRIVACY
11. LINKS TO THIRD PARTY SERVICES
12. INFORMATION PROTECTION
13. INFORMATION FOR CALIFORNIA RESIDENTS
14. GEOGRAPHIC CONSIDERATIONS
15. HOW TO CONTACT US
16. DATA CONTROLLER AND DATA PROTECTION OFFICER

1. CHANGES TO THIS PRIVACY POLICY

We will update this Privacy Policy from time to time when we make changes impacting the Privacy Policy, such as adding new services and applications, improving our services, and addressing changes in technologies and laws. The Effective Date of this Privacy Policy, which is set forth at the top of this webpage, reflects the date the Privacy Policy was last updated. SMG will provide notice to you if these changes are material, and where required by applicable law, we will obtain your consent. This notice will be provided by posting notice of the changes on our website or through our applications.

2. INFORMATION WE COLLECT

Personal Data” means information associated with or used to identify a specific person. Personal Information includes: (1) contact data (such as e -mail address, telephone number and employer); (2) demographic data (such as gender, date of birth and zip code); and (3) your responses on Surveys to the extent the information identifies you or is linked to you as an individually identifiable person.

Usage Data” is information about activity while using or accessing TrumpetRatings such as (i) IP address; (ii) domain server; (iii) type of device(s) used to access TrumpetRatings (v) statistics and information associated with the interaction between your browser or device and Trumpet,; (vi) real-time GPS or other geolocation data from your mobile device when you allow us to receive that information through the location (or similar) settings on your mobile device; and (vii) referring webpage or other source through which you accessed TrumpetRatings (collectively “ Usage Data”).

3. HOW WE COLLECT INFORMATION AND PURPOSE FOR PROCESSING

We collect information from surveys (“Surveys”) that you take on the SMG SurveyMini App and on client-branded sites and we post that information to TrumpetRatings. The privacy policy of the SurveyMini App governs the collection of information through that App, and the privacy policies of the client-branded sites govern the collection of information through those sites. Please refer to those policies if you have questions about SMG’s practices with respect to the information collected from these sources.

In addition to collecting information through Surveys, we collect information that you provide to us from your use of TrumpetRatings. The information that we collect and how we process it depends on how you use and access TrumpetRatings.

Some information is collected automatically through use of data collection tools such as cookies. To learn more about how and why we use data collection tools, please click here.

From You : We collect information from you when you:

  • Use TrumpetRatings: We automatically collect Personal Data and Usage Data when you interact with the SMG Services through the use of cookies and other data collection tools. We use this to facilitate communications between your device and our systems, conduct market research, provide customer service, administer and improve our website and applications, and analyze usage of and improve and enhance SMG Services. To learn more about how and why we use cookies and similar data collection tools, see the “Cookie Policy” section of this Privacy Policy.
  • Access SMG Services through Social Media Credentials: SMG may offer you the opportunity to use social networking services (collectively, “Social Media”) to access certain SMG Services. When you choose to access SMG Services through Social Media login credentials, SMG may, depending on your privacy settings, have access to information that you have provided to the Social Media platform, such as your name, email address, profile photo, posts, comments and other information associated with your Social Media account. We may use this information for any purposes described in this Privacy Policy and for any additional purposes of which you were advised at the time the information was collected. If you do not want your Social Media information to be shared with SMG by a Social Media provider, you should not use your Social Media accounts to access SMG Services.

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4. LEGAL GROUNDS FOR PROCESSING

We process your Personal Data and Usage Date when you use Trumpetratings.com. We process such Personal Data and Usage data based on SMG’s legitimate interest in improving SMG’s products and services and based on SMG’s legitimate interest in providing authenticated reviews for brands consumer wishes to visit.

5. HOW WE USE, SHARE AND DISCLOSE INFORMATION

How we use and share the information that we collect or that you provide to us depends on the type of information and context for its use or disclosure.

  • Location Information. When you visit using a desk top computer, we collect your IP address and when you visit using a mobile device, we collect geo-location information to the extent you have not disabled this function on your phone. (“ Location Information”) This information is used to provide with relevant reviews based on your locations.
  • Relationship Management. We use your Personal Information, as needed, to manage our relationship with you, by mail, telephone, e -mail, including providing customer service (as described in our Terms of Services). We may share Personal Information with service providers that assist in managing our relationship with you. We will use your IP address to facilitate internet routed communication between our backend systems and the particular device you are using.
  • Marketing Communications. We may use your Personal Information to provide you with marketing communications, by mail, telephone, e-mail, mobile alerts and SMS text messaging and offers for products and services from SMG. We may share Personal Information with service providers that assist us with our marketing communications.
  • Services You Request. We may use and share your Personal Information in order to perform services you request or functions you initiate. We also may offer you the opportunity to share information with your friends and other consumers through TrumpetRatings.
  • Usage Analytics and Performance Improvement. We use information collected from data collection tools for usage analytics, fraud detection and performance improvement for TrumpetRatings.
  • Affiliates. We may share information that we collect from or about you with our affiliated companies. Please note that this includes information about your visits and use of TrumpetRatings, comments, opinions and other information that you type into text fields on TrumpetRatings. For these purposes “affiliates” are those companies that are under common control of our parent company Service Management Group, Inc.
  • To Perform Services on Our Behalf. We share your information, including your Personal Information, with our service providers to perform the functions for which we engage them (such as hosting, data storage and security). .
  • Legal Compliance. We may also share the information that we collect from you, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions. We will always disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection authority, legal process, governmental request or other legal or regulatory process, in each case this may be an entity outside your country of residence. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.
  • Corporate Changes. We may transfer information about you, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by or of SMG or any affiliated company (in each case 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.
  • Other Business Purposes. We also use your Personal Information for other legitimate business purposes, such as, product development and administration of TrumpetRatings.

6. YOUR CHOICES ABOUT INFORMATION COLLECTION

You can opt out of our further selection of your personal information by ceasing to use TrumpetRatings.com, declining to complete our surveys on our Client sites and discontinue your use of SurveyMini. If you do this, we will retain your Personal Information in our records for as long as is necessary for the purposes for which it is collected. When this standard is met, we securely delete all account information except for what is needed to comply with our legal obligations.

If you would like us to delete a specific review for which you authored, please email privacyofficer@smg.com and include details about the review content, including brand name and the approximate date when you completed the survey.

If you wish to have us delete your Personal Information, please contact us at privacyofficer@smg.com and we will assist you with that request.

7. COOKIES POLICY

7.1 What Are Cookies

SMG and our service providers use small text files called cookies. Cookies” are small computer files sent to or accessed from your web browser or your computer's, mobile device’s or tablet’s hard drive that contain information about your computer, such as a user ID, user settings, browsing history, and activities conducted while using the Services. A Cookie typically contains the domain name (internet location) from which the Cookie originated, the “lifetime” of the Cookie (i.e., when it expires), and a randomly generated unique number or identifier. Cookies may be linked to Personal Data.

7.2 How We Use Cookies and Data Collection Tools

Cookies help us improve SMG Services by tracking your navigation habits, and customizing your experience with SMG Services. This enables us to analyze technical and navigational information about SMG Services and helps us to detect and prevent fraud.

We also use Cookies and other Data Collection Tools (such as web beacons and server logs), which we collectively refer to as “ Data Collection Tools,” to help improve your experience with SMG Services – for example, by remembering you when you come back to visit us, and making the content you see more relevant to you.

SMG Services also may use Data Collection Tools to collect information from the device you use to access SMG Services, such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located.

7.3 Your Control of Cookies

Web browsers allow some control of most Cookies through browser settings. Some web browsers (including 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 SMG Services. In addition, if you reside in a jurisdiction that requires us to obtain your consent to use cookies on our websites and/or applications, you will have an opportunity to manage your cookie preferences on those websites and/or applications; except that certain cookies are required to enable the core functionality of such websites and applications and you cannot choose to disable those cookies.

8. ONLINE ADVERTISING AND DATA COLLECTION

8.1 Online Advertising.

Our advertising management partners use Data Collection Tools on our site to enable them to recognize a unique Cookie that has been placed on your browser, which in turn enables us and these ad management partners to learn which advertisements bring users to the TrumpetRatings. In addition, we and our ad management partners may use these Data Collection Tools to track the actions of users of the TrumpetRatings, to measure statistics of our marketing efforts, and to deliver advertisements on the TrumpetRatings that may be more relevant to you.

We and our ad management partners also may use Data Collection Tools to record the actions of users of the TrumpetRatings, to measure statistics of our marketing efforts, to deliver advertisements on the TrumpetRatings that may be more relevant to individual consumers and to improve the consumer experience on the TrumpetRatings.

We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance ("Principles"). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest based advertising purposes. More information about these Principles can be found here.

8.2 Opting Out of Interest-Based Advertisements .

If you want to "opt out" of receiving online interest-based advertisements, please follow the instructions at www.aboutads.info/choices or www.networkadvertising.org/choices/ . An "opt-out" Cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. If you delete Cookies on your device generally, you will need to opt-out again.

Please note that opting out of interest-based advertising does not mean you will no longer see advertisements from us or on TrumpetRatings; rather, opting out means that the online ads that you do see will not be based on your particular interests.

In addition, when you opt-out of receiving interest-based advertisements through the links above, Data Collection Tools on TrumpetRatings may still collect information about your use of TrumpetRatings for any purpose permitted under the Principles, including for analytics, fraud prevention and any other permitted purpose.

8.3 Data Collection by Third Parties .

Please note that certain third parties that we do not control may use Data Collection Tools on TrumpetRatings. This Privacy Policy does not apply to those third parties or their Data Collection Tools.

9. MANAGING YOUR ACCOUNT INFORMATION

You can visit the account section of the applicable SMG Service to manage and correct factual inaccuracies in the information we have about you. If you have questions about how to access or correct your Personal Data, contact our Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.

10. CHILDREN’S PRIVACY

SMG Services are intended for general audiences and are not directed to children who are under the age at which they may provide consent for the processing of their Personal Data in any jurisdiction where we operate. We do not knowingly collect Personal Data from such persons. If you become aware that a child under the age at which [s]he may legally provide consent to the processing of his/her Personal Data has provided us with Personal Data without parental consent, contact our Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108. If we become aware that a child under the age at which [s]he may provide consent to Personal Data processing in his or her jurisdiction has provided us with Personal Data without parental consent, we take steps to remove such information and terminate the child's account as soon as possible.

11. LINKS TO THIRD PARTY SERVICES

SMG Services may contain links to third party websites and services (“ Third Party Services”) with which SMG has no affiliation. A link to any Third Party Service does not mean we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third Party Service, you are subject to its privacy practices and not the privacy practices set forth in this Privacy Policy.

12. INFORMATION SECURITY

SMG has an information security program that implements technical, physical, and organizational measures designed to assist in maintaining the security and confidentiality of Personal Data; safeguarding against anticipated threats to the confidentiality, integrity and availability of Personal Data; and protecting your Personal Data against loss, misuse, unauthorized alteration or destruction, and unauthorized access or disclosure.

However, whenever Personal Data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical, physical, and organizational measures that SMG has in place to protect your Personal Data, you should use appropriate security measures to protect your Personal Data. If you believe that your SMG account or any information you provided to us is no longer secure, notify our Data Protection Officer immediately by email at privacyofficer@smg.com or by calling 1-800-764-0439 and asking to speak with SMG’s Data Protection Officer.

13. INFORMATION FOR CALIFORNIA RESIDENTS

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 party’s 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:

i. TrumpetRatings is owned and/or operated by Service Management Group, Inc., 1737 McGee Street, Kansas City, MO 64108.

ii. Unless otherwise expressly stated, TrumpetRatings is provided without charge.

iii. To file a complaint regarding TrumpetRatings or to receive further information regarding use of TrumpetRatings, 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.

14. GEOGRAPHIC CONSIDERATIONS AND CROSS-BORDER TRANSFERS OF PERSONAL DATA

SMG controls and operates SMG Services from the United States of America. SMG may transfer, store and process your Personal Data in the United States, the United Kingdom, Japan, or another location in Asia or in the European Union. Note that data protection and privacy laws of the country to which your Personal Data is transferred may not be as comprehensive as the laws in your country. For example, Personal Data transferred to the United States may be subject to lawful access requests by federal and state authorities in the United States.

Any transfers of Personal Data from the European Economic Area (“EEA”) to the United States are done pursuant to the EU-US Privacy Shield. SMG participates in and complies with the EU-U.S. Privacy Shield principles regarding the collection, use, sharing, and retention of Personal Data from the EEA, as described in our EU-US Privacy Shield certification. View the Privacy Shield list here. Learn more about the Privacy Shield here. SMG is subject to the oversight of the US Federal Trade Commission, and will remain responsible for processing of Personal Data in a manner inconsistent with the Privacy Shield Principles by third parties to which SMG has transferred personal data unless SMG proves it is not in any way responsible for the event giving rise to the damage. Any and all such transfers of Personal Data outside the EEA shall be in accordance with this Privacy Policy and all applicable laws. If you have a complaint about our Privacy Shield compliance, contact our Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108. You can also refer a complaint, free of charge, to our chosen independent dispute resolution body, American Arbitration Association, and in certain circumstances, invoke the Privacy Shield arbitration process.

You can also refer a complaint, free of charge, to our chosen independent dispute resolution body, American Arbitration Association ( http://go.adr.org/privacyshield.html ), and in certain circumstances, invoke the Privacy Shield arbitration process.

This English-language Privacy Policy is SMG’s official statement of its privacy practices relating to SMG Services. In case of any inconsistency between this English-language Privacy Policy and any translation into another language, this English-language document prevails.

15. HOW TO CONTACT US

If you have questions about privacy, need assistance with accessing or updating your Personal Data or have complaints relating to the processing of your Personal Data, contact our Data Protection Officer by email at privacyofficer@smg.com.

You can also write to us at:

Service Management Group, LLC
Attn: Data Protection Officer
1737 McGee Street
Kansas City, MO 64108

Service Management Group, Ltd.
Attn: Data Protection Officer
38-40 The Maltings
St Albans
Hertfordshire AL1 3HL
UNITED KINGDOM

Service Management Group G.K.
Attn: Data Protection Officer
2-7-16 No. 3 Komoriya Building 9F
Hamamatsu-cho, Minato-ku
Tokyo 1050013, Japan

16. DATA CONTROLLER AND DATA PROTECTION OFFICER

Personal Data collected by SMG is controlled by Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108. You may contact our Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.

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