Last Updated: February 2023
TraceLink is committed to protecting your privacy where we process your Personal Information. This Privacy Policy sets out the basis on which any of your Personal Information will be collected, stored and used by us where you use our website https://www.tracelink.com/, any of our web based services or products (including our supply chain management platforms) or otherwise interact with us. “Personal Information” here means any information that we process about you that relates to you or that can be used to identify you directly or indirectly, for example your name, email address, company, job title or any account profile related content.
References to “TraceLink”, “we”, “us” or “our” in this Privacy Policy are to, TraceLink Inc. 200 Ballardvale St. Building 1, Suite 100, Wilmington, MA 01887, U.S.A.. We are the controller of your Personal Information described in this Privacy Policy (this simply means we are responsible for your Personal Information).
Please note that when you are provided with access to our platform by any of our customers for their business purposes, TraceLink will be the processor of the Personal Information you provide on the platform for that customer’s purposes. This means that we will only process such Personal Information on the instructions of that customer for their business purposes, and that customer will be responsible for your Personal Information. You should refer to that customer’s privacy policy to contact them or exercise your rights. Where you register for an individual TraceLink account on our website, we will also be the processor of any Personal Information you process on our platform through your account (other than the TraceLink Account Registration and Profile information discussed in the sections below), on behalf of your company (as represented by you) who are responsible for that Personal Information as controller. This Privacy Policy will not apply to such processing.
This Privacy Policy does not apply to any third party applications or software that integrate with any of our products or any other third party products, services or businesses. Certain pages of our website may, from time to time, contain external links to third party websites or content. Please note that we are not responsible for the content and privacy practices of any external websites; you should verify and validate the privacy policies and practices of any such websites prior to providing your Personal Information.
Quick Guide To Contents
- How We Use Your Personal Information
- How We Share Your Personal Information
- International Transfers
- Personal Information Retention
- Rights of UK and EEA Residents
- Changes to this Privacy Policy
- How to Contact Us
1. HOW WE USE YOUR PERSONAL INFORMATION
We collect Personal Information about you, either directly from you, from a third-party source or by automated means (when you use our website for example)
The table below sets out in more detail how we collect and use your Personal Information. Please note that under the laws of certain countries, including the United Kingdom (“UK”) and countries in the European Economic Area (“EEA”), we can only use your Personal Information where we have a lawful reason or justification (also called a “lawful basis”) and this can be either “to carry out a contract with you or to take steps on your instruction prior to entering a contract with you”; “where we have a legal obligation”; where you have given us your consent”; or “where it is necessary for our legitimate interests” (this means that we have commercial interests in using your Personal Information that is not unfair to you).So, if you are based in the UK or EEA, please see the table below, where we have included each lawful basis as a subheading. Please disregard these subheadings if you are not located in the EEA or UK - they will not affect how we use your Personal Information.
Please not that if you choose not to provide Personal Information requested by us, or refuse our use of your Personal Information, we may not be able to provide you with the services you have requested where this Personal Information is necessary or these services may be delayed
Information you give us
| Personal Information we collect | How we use your Personal Information and our lawful basis |
TraceLink Account Registration and Profile You give us Personal Information about you when you create a TraceLink account on our website. This information may include your name, email address, country, company details (name, URL and industry), business segments, job function and applicable referral codes. When you complete your profile on your account you may give us additional information on your screen name, phone number (work, mobile and fax), photograph, and details of your skills and experience (professional summary, interests, education, areas of expertise, professional experience and projects and accomplishments). | Legitimate Interests
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TraceLink Community Membership You give us Personal Information about you when you sign up to become a member of a TraceLink Community Group. This information may include your name, company name, email address and country. | Legitimate Interests We use your Personal Information to register you as a member of a TraceLink Community group and to contact you with information relating to the Community group(s) you are a member of. |
TraceLink University Learning Platform You give us Personal Information about you when you sign up for an account on our TraceLink University learning platform and when you interact with the courses provided on this platform. This information may include your name, email address, affiliation with TraceLink, date of enrolment, course progression, courses attended, course completion, course certification, course expiry details and notification preferences. | Legitimate Interests
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Request Information/Schedule a Demo You give us Personal Information about you when you request to speak with any of our sales team about our products or for a live demo (on our website or otherwise). This information may include your name, job title, company, email address, telephone number, country and any pre-appointment notes you provide to us. | Legitimate Interests We use your Personal Information to respond to your inquiries and fulfil your requests, when you request information about our products or when you request a live demo. |
Event or Webinar Registration You give us Personal Information about you when you register yourself and any other person in your group for any of our events or webinars. This information may include your name, email address, telephone number, company, job title, details of the relevant event or webinar, your marketing preferences and attendance record. Where payment is required for an event or webinar, you may also provide us with payment details (bank card details and billing address). | Legitimate Interests We use your Personal Information to complete and fulfil your registration for any of our events or webinars, including sending you a confirmation message so you know your registration is confirmed, sending you updates on the event or webinar you have registered for and providing you with access to your registered event or webinar. |
Marketing Communications and Updates You give us Personal Information about you when you subscribe to receive marketing communications and updates from us or we are otherwise legally allowed to send you such marketing communications. This information may include your name, email address and your marketing preferences (i.e. the marketing and updates you want to receive and how you want to receive them). | Consent We use your Personal Information to send you marketing communications (and to manage our marketing processes) where you have provided your consent to receive these communications. We will only do this in line with your marketing preferences. You can opt-out of receiving these communications at any time by selecting the unsubscribe link in any email we send you, or by contacting us. Legitimate Interests We use your Personal Information to send you marketing communications (and to manage our marketing processes) where we are legally allowed to do so without having received your consent. For example, in some countries we are allowed to send marketing communications to email addresses without receiving prior consent. You can opt-out of receiving these communications at any time by selecting the unsubscribe link in any email we send you, or by contacting us. |
Surveys, Reviews and Testimonials You give us Personal Information about you when you participate in and complete any of our surveys or when you write a review/testimonial about us or any of our products. This information may include your name, contact information, job role, your survey responses and the content of your review/testimonial. | Legitimate Interests
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Customers/Suppliers/Partners and Representatives You give us Personal Information about you when you enter into a customer/supplier/partnership agreement or relationship with us or are a representative of a customer/supplier/partner. This information may include your name, company, job title, email address, phone number and the content of our communications with you. | Legitimate Interests We use your Personal Information to contact you and to manage our relationship with you and/or your company where you are a customer/supplier/partner or the representative of a supplier/partner with whom we have a business relationship. |
Contacting Us You give us Personal Information about you when you contact us or otherwise interact with us, including via the contact us web forms on our website, phone, email, post or social media. This information may include your name, company, job title, contact preference (email address/phone number), areas of interest and what you have contacted us about. | Legitimate Interests To respond to your inquiries and fulfil your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our supply chain products or other offerings. We may also take this information into account when improving our websites, products and services generally. |
Office Visitors You give us Personal Information about you when you visit any of our offices and provide attendance information. This information may include your name, your company, who you are visiting, and the date and time of your visit. | Legitimate Interests We use your Personal Information to facilitate your access to our office premises, to ensure security of our office premises and for our record keeping purposes. |
Recruitment You give us Personal Information about you when you express interest or apply for a job role with us on our website or otherwise. This information may include your candidate profile, name, email, phone number, current company, current job title, job role applied for, CV/resume, education history, job expectations, assessment results and interview notes. | Legitimate Interests
Legal Obligation
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Information provided by third parties
| Personal Information we collect | How we use your Personal Information and our lawful basis |
Personal Information provided by your affiliated company Where you are an employee or representative of any of the company’s we have a relationship with (e.g. a customer, supplier or partner of TraceLink), we may be provided with your Personal Information by your affiliated company during the course of this relationship. This information may include your name, contact details, job title and company. | Legitimate Interests
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Recruitment. Referrals, Job Boards and Public Professional Networks. We may collect your Personal Information where you have been referred to us by a third party for potential employment (e.g. a recruiter or a friend of yours who is an employee) or from your public profile on job boards or professional networks (e.g. LinkedIn) where it is lawful to do so and if we think you may be a good fit for a job role at TraceLink. This information may include your name, email, phone number, company name, job role and CV/resume related information. | Legitimate Interests
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Information we collect automatically
| Personal Information we collect | How we use your Personal Information and our lawful basis |
Visiting our Website We collect Personal Information about you automatically when you visit and interact with our website. Our servers keep an activity log unique to you that collects certain administrative and traffic information including your device details, device location, source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. | Legitimate Interests We use your Personal Information to make sure you are able to use our website, to monitor how our website is being used, to help us discover and fix any problems with our website and to determine what country you are in when you use our website. |
Cookies (and Similar Technologies) We collect Personal Information about you by automated means when you visit and use any of our websites through cookies and similar technologies (e.g. web beacons, pixel tags, etc.) placed on your device. Cookies and similar technologies are simple pieces of computer code which are designed to collect information from the device you use to access our website. The information collected may include a user ID assigned to you, your IP address, the content you have interacted with, duration of each visit and error messages you encounter. Please see our Cookie Policy here for more information on what cookies (and other similar technologies) are and how we use them. | Consent
Legitimate Interests
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Internal business purposes
| Personal Information we collect | How we use your Personal Information and our lawful basis |
Fraud and Security Monitoring Our fraud and security monitoring processes may apply to any of the above Personal Information we collect about you. | Legitimate Interests We use your Personal Information to carry out fraud and security monitoring within our business (e.g. to detect and prevent cyberattacks or attempts to commit identity theft.) |
Business Administration Our processes for ensuring the proper day to day running of our business may apply to any of the above Personal Information we collect about you. | Legitimate Interests We use your Personal Information as necessary to operate our business efficiently. |
Legal Claims and Compliance with Legal Obligations Our processes for complying with our legal obligations and protecting our rights under the law may apply to any of the Personal Information we collect about you listed in this Privacy Policy. | Legitimate Interests We use your Personal Information to effectively defend or bring claims to protect our legal rights and interests, to respond to investigations from regulators or law enforcement, and to audit our internal processes for compliance with legal and contractual requirements. Legal Obligation We use your Personal Information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities, and audit our internal processes for compliance with legal requirements. |
Record of External Communications We may record the communications we have with you (e.g. Zoom meetings and/or phone calls) where we interact with you. For example, where you contact our customer support lines. If required under applicable law, you can object to a call being recorded. | Legitimate Interests We use these recorded communications for internal training, quality assurance and administration purposes, to ensure we maintain the high quality in our services |
2. HOW WE SHARE YOUR PERSONAL INFORMATION
We share your Personal Information for the following purposes and in line with this Privacy Policy:
- We share your Personal Information with trusted third parties who perform functions on our behalf and help us provide you with the services we offer and also in operating and maintaining our website. Third parties such as service providers (including website and cloud providers, database management providers, payment providers, business communication providers, email distribution providers, direct marketing and data collection providers, data storage and analysis providers, and customer service support providers), business consultants, and professional advisors (including lawyers, auditors and accountants). These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
- We may share your Personal Information with affiliates within the TraceLink group. Our affiliates will use the Personal Information we share in a manner consistent with this Privacy Policy.
- We share your Personal Information if we are under a duty to do so, in order to comply with (or where we reasonably believe we are under a duty to comply with) any legal obligation; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of TraceLink, third parties, users of our services or the public.
- We may share your Personal Information with a prospective or new owner of our business or company and their advisors, should we, or any of the TraceLink group companies be the subject of a merger, takeover, divestment or acquisition.
- We share your Personal Information where you give us express permission to do so in the course of your relationship with us from time to time.
3. INTERNATIONAL TRANSFERS
The TraceLink head office is based in the United States (US) and we use service providers in the US, which means Personal Information you provide to us will be processed and stored in the US. Please note that the US may have data protection laws less stringent than or otherwise different from the laws in effect in your country.
If you are located in the United Kingdom (UK) or European Economic Area (EEA), and we share your Personal Information to parties in the US or any other countries not recognized as adequate for the transfer of your Personal Information, to the extent a safeguard is required under law for such transfers of your Personal Information, we have put in place the UK government approved international data transfer agreement/addendum (for UK transfers) and Standard Contractual Clauses approved by the EU Commission (for EEA transfers). If you require further information from us, please use the details in the “HOW TO CONTACT US” section below.
4. PERSONAL INFORMATION RETENTION
We generally retain your Personal Information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy. This will generally be for the duration of time you interact with us, however, there may be situations where we retain your Personal Information for a longer or shorter period. When determining the relevant retention periods for your Personal Information, we take into account the following factors: (a) any permissions you give us with regards to your Personal Information; (b) our contractual obligations and rights in relation to the Personal Information involved; (c) our legal obligation(s) under relevant laws to retain data for a certain period of time; (d) our legitimate business and commercial interests; (e) whether retention is advisable in light of our legal position (such as with regard to applicable statute of limitations, investigations, litigation, and other potential and actual disputes); and (f) any guidelines issued by relevant data protection authorities.
5. RIGHTS OF UK AND EEA RESIDENTS
If you are a UK or EEA resident, under data protection laws (and in certain circumstances), you have the following specific rights concerning your Personal Information and can exercise these rights by contacting us.
Your rights may include the following:
- Request access to your Personal Information (commonly known as a “data subject access request”) and receive a copy of it, along with supplemental transparency information similar to what is provided in this Privacy Policy.
- Request correction of the Personal Information that we hold about you if it is incomplete or inaccurate.
- Request erasure of your Personal Information where there is no good reason for us continuing to process it or where you have successfully exercised your right to object to our processing of your Personal Information.
- Object to us processing your Personal Information where we rely on “legitimate interest” (see the “How We Use Your Personal Information” section above) as a lawful basis for processing your Personal Information or where we are processing your Personal Information for any direct marketing purposes (e.g. to send you direct marketing communications).
- Request portability of your Personal Information. If required to do so, we will provide you or another party with any Personal Information we have obtained from you, in a structured, machine readable and reusable format.
- Withdraw consent to the processing of your Personal Information at any time where we rely on your consent as a lawful basis for processing your Personal Information. This won’t affect anything we have used your Personal Information for before you withdraw your consent.
- Not be subject to decisions based solely on automated processing (including profiling) which have a legal effect on you or a similarly significant effect on you. This is relevant where we decide to use automated systems to process your Personal Information with no real human involvement.
- Lodge a complaint about the way we handle or process your Personal Information with a data protection regulator. You can find the relevant EEA data protection regulator names and contact details under https://edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK, this is the Information Commissioners Office (ICO) Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Phone number: 0303 123 1113. Website: https://ico.org.uk/make-a-complaint/.
6. CHANGES TO THIS PRIVACY POLICY
We may periodically make changes to this Privacy Policy. We will notify you of any significant changes where we have a relationship with you and otherwise post updated versions here. We recommend that you revisit this Privacy Policy regularly.
7. HOW TO CONTACT US
If you wish to exercise any data subject rights or have any questions about this Privacy Policy or our information practices, please feel free to contact us at:
Email: notices [at] tracelink.com (notices[at]tracelink[dot]com)
Address: 200 Ballardvale St. Building 1, Suite 100, Wilmington, MA 01887.
UK Office:
Email: notices [at] tracelink.com (notices[at]tracelink[dot]com)
Address: The Charter Building, Charter Place, Uxbridge, UB8 1JG, United Kingdom
EEA Office:
Email: notices [at] tracelink.com (notices[at]tracelink[dot]com)
Address: Monday, Pau Claris 79, 08010 Barcelona, Spain