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LAST UPDATED: March 2, 2021
ABOUT THIS PRIVACY STATEMENT
This is the Privacy Statement (the “Statement”) of Trahan Macro Research LLC (“TMR”, “we”, “us” and “our”). At TMR, we understand that your personal data is important to you. If you or your organization has a relationship or shares personal data with us, then this Statement described in a simple and transparent way what personal data we collect, record, store, use, disclose and process and how.
TMR primarily has customers that are corporations or other legal entities (“Organizations”). TMR has no control over, and this Statement does not apply to, Personal Data collected and processed by Organizations that are TMR customers. We may collect and process information about individuals who represent Organizations or who work for, or are affiliated with, Organizations, and we do collect and process information about individuals who license the products and services we supply (any of the foregoing, collectively, “Individuals”). This Statement applies to Organizations and Individuals regardless of their location or residence as applicable, unless specifically stated otherwise.
WHAT IS PERSONAL DATA?
- Generally, Personal Data is any information that identifies or can be linked to an Individual. We collect and process the following Personal Data about you:
- Contact details: your name, postal address, phone number, mobile number, email address, online contact details and access credentials;
- Employment/position data: your Organization or employer, your title or position, your length of employment and documents that verify employment and signatory authority;
- Financial and transaction data: for Organizations and Individuals who subscribe to our products and services, your invoices and your payment information, which may include, but is not limited to, you bank account number or credit card information;
- Account login credentials: the username and password you use to log into our portal, password hints and similar security information, location data and other website of product access information;
- Information about devices, operating system, online behavior and preferences data, such as the IP address of your mobile device or computer, the type, version and brand of device used to access our website or apps, the operating system and browser version you use, your cookie settings, and the pages you visit on our website and apps, as well as content you upload and share or store in your account;
- Data about your interests and needs that you share with us, for example when you contact us or fill in an online survey; and
- Your interactions with us on social media, such as Facebook, Twitter, Instagram, Google+ and YouTube. We follow public messages, posts, likes and responses to and about TMR on the internet.
HOW DO YOU OBTAIN MY PERSONAL DATA?
We obtain your personal data in the following ways:
- You share your Personal Data with us when you become our customer, register for our online products and services, complete an online form, sign a contract with TMR, use our products and services, contact us through one of our channels or visit our website.
- From your Organization when it becomes a prospective customer or if it is an existing customer, and your personal data is provided to enable us to manage your access to our products and services or to help us contact your Organization.
- We may collect, to the extent permitted by applicable law, Personal Data directly from Individuals, customers, private lists, and publicly available sources.
WHAT DO YOU DO WITH MY PERSONAL DATA?
We collect, record, store, adjust, organize, use, disclose, transfer or delete Personal Data in accordance with applicable laws. We do not sell your data. We only use your Personal Data for business purposes such as:
- Providing the products and services requested by you. We collect and use Personal Information to:
- provide, activate and manage your access to, and use of, the products and services you requested;
- perform our obligations under any agreements we may have with you;
- process and fulfill requests, orders, download, subscriptions and other transactions;
- manage Organization relationships and inquiries, including when we need to contact Organizations or Individuals with important information or for other administrative purposes
- notify you about changes, updates and other announcements related to the products and services we provide to you; and
- carry out related business functions.
- Managing our relationship with you and marketing. We may ask you for feedback about our products and services or record your conversations with us online or by telephone. We may share this with certain members of our staff to improve our offering or to customize products and services for you. We may send you newsletters informing you about these products and services. Of course, if you don’t want to receive these offers you have the right to object or to withdraw your consent.
- Confirming a person’s authority as an Organization’s representative.We collect and use work contact details, position description, customer access or use data, and authentication data to confirm a person’s authority as a representative or agent of an Organization.
- Record keeping.We collect and use work contact details, position description, authentication data, customer access or use data, financial data, and background or credit check data to facilitate managing our records in a systematic manner so they can be retrieved when required for legal, regulatory or operational reasons.
WITH WHOM DO YOU SHARE MY PERSONAL DATA?
- Affiliates. We may transfer your Personal Data to an affiliate of TMR that may use it for purposes consistent with the purposes outlined above.
- Your Organization. If you access our products and services through a license administered by your Organization, your Personal Data, including usage data we collect through our portal (such as items you downloaded and fee-based content you accessed) may be accessed by or shared with your Organization’s administrator.
- Service providers Your Personal Data may be disclosed to information technology or other service providers (including outside the USA) engaged by us or operating under our instructions regarding the processing of such data (“Data Processors”). Any such Data Processors will be obligated contractually to implement appropriate technical and organizational security measures to safeguard the Personal Data, and to process Personal Data only as instructed.
- Legal reasonsYour Personal Data may be disclosed by us if required or permitted by applicable law or regulation, or if we believe in good faith that disclosure is necessary to:
- Comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever TMR or any of its affiliates may do business;
enforce, protect and defend the rights or property, including intellectual property, of TMR or any of its affiliates;
act in urgent circumstances to protect the personal safety of Individuals and contractors/employees of Organizations and TMR and any of its affiliates; or
- protect against any legal liability.
WHAT RIGHTS DO I HAVE WITH RESPECT TO MY PERSONAL DATA?
Under European law (EU General Data Protection Regulation 2016/679) and the privacy and data protection laws of certain other country, you have certain rights with respect to your Personal Data. Below is a brief overview of those rights.
- Right of accessYou may ask us for an overview of your Personal Data and an explanation of why we are holding your Personal Data. Upon request, we will provide this information in paper or electronic format
- Right of rectificationIf your Personal Data is incorrect or incomplete, you may ask us to rectify it. If you have an account with us, you can also change your data on our website [refer to appropriate website section] or by sending a written request to TMR’s Privacy Officer (information below).
- Right of objection to processingYou may object to our using your Personal Data for our own legitimate business interests. You also have the right to object to our direct marketing efforts or to our sending you personal offers. Your right to object to our processing your Personal Data does not apply if we are legally required to do so or if it is necessary to fulfil a contract we have with you. To exercise this right, you must send an email with your name and your account information to [insert email address] and a short explanation of the reasons why you are exercising this right.
- Right to restrict processingYou have the right to ask us to temporarily restrict the processing of your Personal Data if:
you have contested the accuracy of your Personal Data;
- the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of its use instead;
- we no longer need the Personal Data, but you need your Personal Data for the establishment, exercise or defense of legal claims; or
- you have objected to our processing, in which case processing is suspended pending the verification whether our legitimate grounds override your objections.
- Right to data portability
You have the right to receive Personal Data you have provided to us in a structured, commonly used, machine-readable format. You may also ask us to transfer your Personal Data directly to another company if that is technically feasible, but only with respect to Personal Data which we process based on your consent or pursuant to a contract you have with us and only if we process your Personal Data by automated means. For purposes of this Statement, this right only applies to residents of the European Union.
- Right to erasure
You may ask us to destroy your Personal Data. You have this “right to be forgotten” if
we no longer need your Personal Data for the purposes for which it was collected or processed;
you withdraw your consent;
you object to the processing and there are no overriding legitimate grounds for the processing;
you object to the processing for direct marketing purposes;
your Personal Data have been unlawfully processed;
- a law requires us to erase your Personal Data.
- Right to complain
You can exercise any of the rights described above and you can submit a complaint to us if you are dissatisfied with the way we have responded to your concerns by contacting us in writing at the address listed below. Please make sure you enclose of copy of passport, driver’s license or other form of government-issued identification with your letter.
Katherine Krantz, TMR Privacy Officer
For residents of the European Union only: If you are unhappy with the way we deal with your request or complaint, you may contact the data protection authority in your country of residence. See https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
SUPPLEMENTAL NOTICE TO RESIDENTS OF THE STATE OF CALIFORNIA, USA The following only applies to residents of the State of California, USA. Under the California Consumer Privacy Act of 2018 (“CCPA”), you have the further right to request that we disclose to you
- the categories of personal information we collected about you and the categories of sources from which we collected such information;
the specific pieces of personal information we collected about you;
the business or commercial purpose for collecting personal information about you; and
- the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months.
You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA. TMR does not sell personal information to third parties.
YOUR COMMUNICATION PREFERENCES
When you register for our products and services, you can customize and set your communication preferences. You can change or update those preferences at any time by using “opt-in/opt-out” or “subscriber/unsubscribe” features and tools on our website or in communications you received from us or by submitting a written request to:
Katherine Krantz, TMR Privacy Officer
HOW DO YOU KEEP MY PERSONAL DATA SECURE?
We have appropriate technical and organizational policies and procedures in place to safeguard your Personal Data against loss, theft and misuse, as well as unauthorized access, disclosure, alteration or destruction.
FOR HOW LONG DO YOU KEEP MY PERSONAL DATA?
Applicable laws require us to keep your Personal Data for specified periods of time. Retention periods vary from a few months to several years, depending on the law that applies.
CHANGES TO OUR PRIVACY STATEMENT
We reserve the right to update this Privacy Statement from time to time. Any changes will be posted on this page with an updated revision date. We will only notify you to changes to our Privacy Statement if those changes are material.