Personal Data Notice

Your Personal Data Notice
in connection with your use of the Tcompliance TPMS

Types of personal information and why we process it

TRACE Inc. d/b/a Tcompliance (“Tcompliance”) processes your personal information in connection with the provision of the Service (as defined below) and operation of the web site located at (the “Site”). Such information may include: your name, title, company name, business email, phone number, any other personal information you may choose to post, store or transmit using the Site or Service.

The “Service” includes (a) the Site, (b) third party risk and due diligence management system, the TRAC registry and intermediary directory, and/or other tools and services provided or made available to you through the Site, and (c) all software, data, text, images, sounds, video, and content made available through the Site or services (collectively referred to as the “Content”).

In addition, when you access the Site or use tools and services made available to you through the Site, Tcompliance or its authorized service providers may process your login credentials, IP address, website cookies, internal unique identifier, and other session details to authenticate your account, determine your account permissions, perform market research, implement Site functionality, handle system errors, maintain the security of the Site, preserve your user settings, address your requests for technical support, and for other similar purposes.

Where we process it

Personal data may be processed by Tcompliance for the purposes specified above in the following locations:

  • Ireland (the location of our servers, and the primary location of EU data processing);
  • United Kingdom (the location of our back-up servers);
  • United States (the location of Tcompliance’s headquarters);

Additionally, depending on your location and the types of Service you purchase or access, your personal data may be processed by the following Tcompliance Subprocessors, only as necessary for the performance of the relevant Service:

Subprocessor Location Nature of services to Tcompliance
TRACE International, Inc. United States TRACE International, Inc. provides Tcompliance with operational support services such as legal / contracts, marketing, IT, compliance training, and customer service, pursuant to a shared services agreement. The companies share an office space.
Microsoft Corporation (Microsoft Azure) Ireland, with a backup in the United Kingdom Cloud data hosting
DC Web Troupe, LLC, d/b/a Modern Signal United States Software development and IT support of the TPMS
Docebo NA, Inc. Global; primarily United States Compliance training / Learning Management System (LMS) solutions
Bureau van Dijk (formerly known as Regulatory DataCorp, Inc.) Global; primarily United States Access to politically exposed persons database (for searches of companies / individuals undergoing certain due diligence reviews)
LexisNexis, a division of RELX Inc. Global; primarily United States Access to media and other databases (for searches of companies / individuals undergoing certain due diligence reviews)
Google, LLC Global; primarily United States Certain components of G Suite and media searches (for searches of companies / individuals undergoing certain due diligence reviews)
Tcompliance Consultant(s) Currently located in Philippines, Spain, and the United Kingdom Tcompliance contracts with various independent contractors for the provision of marketing, customer service, due diligence review, and accounting support services, to enable us to better serve customers in their local language and time zones. Consultants based in the Philippines are firewalled from accessing any EU/EEA/UK personal data.

Any transfers of your personal data between countries will be done strictly in compliance with applicable law. Any transfer of personal data from the European Union and the European Economic Area (EU/EEA) or the United Kingdom (UK) to the United States is based either on specific consent of data subjects or the standard contractual clauses executed by Tcompliance with relevant entities located in the EU, EEA, or UK, as the case may be.

How long we keep it

We keep your personal data for up to sixty days from the moment your account with the Site is cancelled. We may keep your basic personal information (such as your name, position, contact information, signature) for a longer period of time if you are a signatory of a contract or an agreement with Tcompliance. More information on our retention schedule can be found on Tcompliance’s Privacy Policy

What are your rights?

At any time, you may:

  • request to see your personal data that we have;
  • request to correct or delete your personal data if you believe it is incorrect;
  • object to Tcompliance’s processing of your personal data or the transfer of your data to Tcompliance; or
  • bring a complaint on how we have handled your personal data.

In any such instance, you may contact Tcompliance’s Data Protection Officer by email at [email protected] In addition, if you reside in the European Union, you can contact Tcompliance’s EU Representative at [email protected] If contacted, Tcompliance may seek additional information from you to make sure that the personal data we may possess belongs to you. Once verified, we will evaluate your request and provide you with a response.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you may file a complaint with the Data Protection Commissioner at [email protected] or the supervisory authority located in your jurisdiction.

Last Updated: 1 December 2021

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