Effective Date: March 11, 2020

Last Updated: March 11, 2020

 

The Entrust Group (“Entrust,” “we,” “us,” or “our”), oversees the website, https://www.theentrustgroup.com/ (the “Site”), including the services underlying the site and the content appearing herein (collectively, the “Services”). This Privacy Policy (“Privacy Policy”) is applicable to all users of the Services (“user(s),” “you,” or “your”) and was developed to inform you about how we collect data through our Services, how we use the collected data, and users’ rights with respect to the collected data.  You should also read our Terms of Use and Cookie Policy, which are incorporated herein, to understand the general rules about your use of this website, and any additional terms that may apply when you access particular services or materials on certain areas of this website. 

Read this Privacy Policy carefully before you begin using this Site.  This Privacy Policy is binding on all those who access, visit, and/or use our Services, whether acting as an individual or on behalf of an entity, including you and all persons, entities, or digital engines of any kind that harvest, crawl, index, scrape, spider, or mine digital content by an automated or manual process or otherwise. BY ENTERING, ACCESSING, BROWSING, SUBMITTING INFORMATION TO, OR OTHERWISE USING THE SITE OR SERVICES YOU ACKNOWLEDGE AND AGREE TO THIS PRIVACY POLICY. If you do not agree to be bound by this Privacy Policy, then do not access or use the Services.

If you have any questions about this Privacy Policy, please contact us at the contact information below or at  teg@theentrustgroup.com.

 

1. Information We Collect

When you use the Site, we collect and process the following types of information:

a. Personal Information

Personal Information” means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  When you register to use our Services, set up a profile, obtain a financial product or service from us, conduct a transaction with us or affiliated third parties, respond to communications from us (e.g., surveys, requests for feedback), contact us via phone, e-mail, or postal mail, and so on, we will collect certain types of Personal Information that you provide to us. We may collect information from other sources, and to the extent that we collect Personal Information from a source other than those listed here, such Personal Information will also be treated in accordance with this Privacy Policy.

When you create a user profile on our Site, you may be asked to provide, and we will collect, certain types of Personal Information, which may include your first and last names, e-mail address, zip code, birth month and year, credit card number, and a photo identification. You will also be asked to generate a password as part of your login credentials. Other Services offered on the Site may require additional types of Personal Information. You are not required to use these Services, but your use of these Services may depend on your provision of additional Personal Information.

If you provide Personal Information through our Services, we may aggregate that Information with other active Information, unless we specify otherwise at the point of collection.

 

b. Non-Personal Information

We collect information about your use of our Services, including, but not limited to, your Internet connections, computer equipment, web browsers, sites visited before using or accessing our Site, sites visited after leaving our Site, and other similar information about traffic and usage, as you navigate to, through, and away from our Site.  This is called “Non-Personal Information,” because it does not identify you, but provides insights to us regarding your use of the Services.  Because Non-Personal Information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share Non-Personal information.

We collect Log Data through our Site. Log Data refers to certain information about how a user (including both profile holders and non-profile holders) uses our Services, and may include information such as a user’s Internet Protocol address, browser type, operating system, the pages or features of our Services to which a user browsed and the time spent on those pages or features, search terms, the links on our Services that a user clicked on, and other statistics.

We also use automated data collection tools, such as Cookies and Web Beacons, to collect certain types of Non-Personal Information.  For more information on Cookies and Web Beacons and how the Services use them, please see our Cookie Policy. You can set your browser to reject Cookies, but that may limit your use of some convenience features on the Services. 

Collectively in this Privacy Policy, Personal Information and Non-Personal Information is referenced as “Information.”

 

c. Third-Party Information

If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Site, we may receive your Personal Information and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services. For example, some social networking services allow you to push content from our Site to your contacts or to pull information about your contacts so you can connect with them on or through our Site. Some social networking services also will facilitate registration or enhance or personalize your experience on our Site. Your decision to use a social networking service in connection with our Site is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking sites/services.

 

2. Use of Information

We use Non-Personal Information collected by Cookies and Web Beacons to store your preferences, improve website navigation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve our content and the products, services, materials, and other content that we describe or make available through our Site, and otherwise help administer and improve the Services.

We may identify you from your Personal Information and merge or co-mingle Personal Information and Non-Personal Information, for any lawful business purpose.  Where you provide registration information, cookies can also be used to identify you when you log onto the Services or portions of the Services.  Except as otherwise stated, we may use information we collect from you for the legitimate business purpose of providing our Services to you, including but not limited to:

  • to establish profiles to use the Services, to check on your profile status and maintain record of activities in connection with your use of the Site, and to validate your username, e-mail, password, and/or other login credentials;
  • to respond to your requests, questions, or comments and to provide user support;
  • to provide you with services or products that you have requested, or to process any commercial transaction;
  • to send you e-mail and postal mail supplying you with the most recent service information or to send you information about your order (e.g., order confirmations, shipment notifications, etc.);
  • to send you a welcome e-mail after you create a profile, when you sign up for our e-mail list, or when you download content or webinars, to communicate information and promotional materials to you (where you have not expressed a preference otherwise);
  • to customize the Services to your preferences;
  • to evaluate and improve the content of our Services and to conduct aggregate analysis and develop business intelligence that helps us to enhance, operate, protect, make informed decisions and report on the performances of our Services;
  • to work with our service providers who perform certain business functions or services on our behalf and who are bound by contractual obligations consistent with this Privacy Policy;
  • to notify you of any changes to relevant agreements or policies, and to enforce our agreements, terms, conditions, and policies;
  • to prevent or investigate fraud (or for risk management purposes), or to comply with a legal obligation, court order, or in order to exercise our legal claims or to defend against legal claims;
  • to describe our Services to current and prospective business partners and to other third parties for other lawful purposes;
  • to share your information with our corporate parents, subsidiaries, other affiliated entities, and associated entities for the purposes described in this Privacy Policy; and
  • for other purposes identified to you and as requested by you (please note that you have the right to withdraw your consent to such use at any time by contacting us via the contact information at the bottom of this page).

In addition, we may use third‐party e‐mail providers to deliver communications to you. If you no longer want to receive these e-mail communications, you may opt out of receiving e-mail communications through the “unsubscribe” link available at the bottom of all emails.

We may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and our Services. The information collected by these surveys is used to research market trends, company growth, etc. Your input will help us to improve customer experience and shape development of our products and Services.

 

3. How We Share Information

We do not sell or rent Personal Information to marketers or unaffiliated third parties.  We do have relationships with trusted third parties, but we will not share any Personal Information that we have collected from or regarding you except as described below:

  • Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform) and have access to your Personal Information only for the purpose of performing services on our behalf (“Service Providers”). We may also share your Personal Information with other third parties to help facilitate the Services. While we may seek to limit these third parties’ use of your Information solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Information and not make unauthorized use or disclosure of the Information, we may not have contracts mandating such measures in place with all of our third parties. A complete list of third parties that may have access to users’ Personal Information is available upon verified request;
  • Authorized third parties, who are parties directly authorized by you to receive the applicable Information, such as when you authorize a third-party application provider to access your profile or choose to complete a transaction on or through features on the Services, in which case we may forward your information to third parties for services such as credit card or other payment processing, order fulfillment, credit pre-authorization, and address verification;
  • Third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), in which case we will require the recipient to use such information in accordance with this Privacy Policy;
  • Third parties advertising on our Services, so that such third-party advertisers can serve advertisements to you that meet your needs or match your interests;
  • We may share aggregated, de-identified Information with our sponsors and business partners to inform them of how many users viewed and interacted with their materials; this information does not identify any individual or corporate entity;
  • As we believe necessary: (i) under applicable statute, regulation, or other law; (ii) to enforce applicable terms and conditions; (iii) to protect and enforce our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; and (vi) to respond to requests or other valid legal process from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence; and
  • Pursuant to your explicit approval prior to the disclosure.

 

4. Information Security

We take reasonable steps online and offline to safeguard the Personal Information that you provide to us, including Secure Sockets Layer (SSL) encrypted connections (HTTPS) to the website(s) on our Services, secure multi-tiered firewalls, and portions of your data may also be encrypted on our storage server for additional security, secure cloud-based environments and uses server authentication and industry-standard firewalls in an effort to prevent interference or access from outside intruders. We also require unique profile identifiers, usernames, and passwords that must be entered each time users access the Site, or use of secure password credentials to an authorized third party portal.

For transactions on our Site, we only work with credit card processors who maintain ongoing PCI compliance and adhere to stringent industry standards for storing, processing and transmitting credit card information online.

Nonetheless, it is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee the security of your Personal Information, or any other information, transmitted to or through any of our Services.  As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us or that are otherwise provided to us and we cannot be responsible for the theft, destruction, or inadvertent disclosure of information.   It is your responsibility to safeguard any passwords, ID numbers, or other special access features associated with your use of the Services.  Any transmission of Personal Information, or other information, is at your own risk.  By using our Services, you acknowledge and accept these risks.

If you have any questions about security on our Services, if you become aware of any unauthorized use of a profile, loss of your profile credentials, or if you suspect a security breach, notify us immediately via e-mail at  teg@theentrustgroup.com.  If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.

 

5. Information Transfer and Hosting

Our Site is hosted and operated in the United States. If you use our Site from outside the United States, please be aware that the information you provide to us is transmitted to, processed, and stored in the United States.           

 

6. Information Retention

Unless otherwise described or requested by you, we will retain your Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. At any time, users may request deletion of their profiles by e-mailing teg@theentrustgroup.com. When you delete your profile, it cannot be recovered.

Please note that we do retain Non-Personal Information, including aggregated, de-identified data for the purposes described in the section above titled “How We Use Information.”

 

7. Third-Party Services; Links to Third-Party Sites; Third-Party Tracking

Some areas of the Services may be managed or participated in by third parties. In such cases, Information you provide may be used by us and by such third parties, each pursuant to its own policies. Additionally, our Services may contain links to other sites that are not operated by us.  If you click on a third-party link, you will be directed to that third party’s site.  Such links do not constitute an endorsement by us of those other websites, their content or services, or the persons or entities associated with those websites. This Privacy Policy does not apply to third-party websites.  We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.  We encourage you to review the privacy policies and terms of all third-party websites or services that you may visit.

Furthermore, when you use the Internet, unaffiliated parties such as ad networks, web analytics companies, and social networking platforms may collect information about your online activities over time and across our and other websites.  This information may be used to provide advertisements for products and services that may interest you, and those companies may use Cookies, clear GIFs, and other tracking technologies.  Although we do not track your activity across different websites or online services, we do not honor “do not track” signals transmitted by web browsers. For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer website here or here. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Internet Explorer, Firefox, or Safari) that you use on each device.

For clarity, use of your Information by a third party is subject to the third party’s privacy policy.

 

8. Children’s Privacy

We do not sell products or services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Information from anyone under the age of thirteen (13) without verifiable parental consent.  In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical.  We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).  Moreover, our products are not designed for or directed to children under the age of eighteen (18).  It is our policy that children under the age of eighteen (18) should not utilize our Services, Site, or products. 

 

9. Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.  Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to teg@theentrustgroup.com.

 

10. Changes in the Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time by posting an amended version of the statement on our Site.  Please refer to this Privacy Policy regularly.  If at any time we decide to use Personal Information in a manner different from that stated at the time it was collected, we may notify you either on the panel home page of our Site or via e-mail. For clarity, regardless of whether we provide notice, all updates are effective immediately when posted.  It is your responsibility to check the Terms of Use and Privacy Policy periodically for updates, and your continued use of this Site after we have made updates to this Privacy Policy is considered acceptance of those updates. 

 

11. How to Contact Us

Because protecting your privacy is important to us, you may always submit concerns regarding our Privacy Policy on the contact us page.  We will attempt to respond to all reasonable concerns and inquiries expeditiously.

If you have any questions or comments about our Privacy Policy, please contact us at one of the following:

Phone:                          800.392.9653

Email:                            teg@theentrustgroup.com

Regular Mail:              The Entrust Group

                                      555 12th Street, Suite 900

                                      Oakland, CA 94607

Please be assured that any Personal Information that you provide in communications to us will not be used to send you promotional materials unless you so request.