Privacy Policy

Your privacy is important to us.

Trapeze Software Group, Inc. and its affiliates (“TripSpark”), which provides this Privacy Statement to ensure you understand how your personal data is collected, protected, shared, and used when you engage with TripSpark. If you have any questions about our practices or how we treat your data, please contact us using the contact details below.

TripSpark commits to the following principles with respect to your personal information:

· TripSpark will endeavor to maintain the confidentiality of your personal information.

· We will never sell, rent, or loan your personal information to third parties for any purpose.

· Your privacy will be respected if we contact you about our products and services; we will always honor your choices about whether and how we contact you.

· You will always have control over whether we may use or share your personal information – including having access to your information.

When does this Privacy Statement Apply?

This Privacy Statement applies to TripSpark and its controlled subsidiaries and affiliates. References to “us” or our “Services” in this Privacy Statement include our public-facing website(s), whenever you interact with TripSpark, or whenever you purchase products and services from TripSpark. This Privacy Statement applies to personal information collected by TripSpark through our Services and not to any data collected by any third-party for which we provide links or data for which a separate privacy statement or privacy policy applies.

This Privacy Statement only applies to personal information. TripSpark may aggregate or process information it collects through its Services in such a way that the information can no longer identify (or be used to identify) any individual. This aggregated data is not personal information, and TripSpark may use such information for its business purposes at its discretion.

Trapeze will collect, use and may disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances; and endeavors to collect as little information as possible as may be necessary under the circumstances.

Please note that aggregated statistics and information, where the identity of a specific individual cannot be identified, is not Personal Information. Trapeze reserves the right to use aggregated information in any manner it determines, in its discretion, to be appropriate. Use of such aggregated information may include, but not be limited to, the preparation of aggregated user statistics and information summaries to improve efficiencies, more effectively describe our product and service offerings, and assist in the marketing of our products and services. Aggregated statistics and information will not contain Personal Information.

What Personal Information Does TripSpark Collect?

TripSpark relies on different lawful bases to collect and process your personal information. These bases include collection with your consent (where appropriate), to enable the TripSpark Services, to operate our business, to meet our legal and contractual obligations, to protect our systems or customers, or to fulfill other legitimate interests. This information is collected in a number of different ways including from you directly, automatically, and on occasion from third party sources. In all cases TripSpark will only collect and use the minimal amount of personal information required for its purposes.

Information collected directly from you may include:

· Information you provide so that we may take and fulfill orders from you (addresses, email addresses, contact information, names, shipping information, etc.) or when you register for services or create accounts with us.

· Information you choose to input into our systems or services so that we may track our interactions or complete our transactions with you (billing information, transaction history, feedback you provide).

· Other information you provide to us by directly by filling our webforms, requesting information, engaging with our employees, etc.

When you use our Services or visit our website(s), some information about you may be collected automatically, including:

· Information from your device (IP addresses, geography, browser types and configurations, dates and times of access, website navigation, language, etc.)

· We and our third-party providers may also use cookies, web beacons and other technologies including “clickstreaming” to collect information about you and your interaction with our Services. These technologies may place small text or other files on your device that allows for the collection of information about your use of the Services or website(s). This would include your browsing behavior, product and services preferences, certain demographic information, the navigation of our site(s) etc. You may often control your browser settings to remove or reject such cookies and other technologies. For more information about cookies and how we use them, please see our cookie policy.

We may also obtain information from third parties including customer, membership, or recipient information that we lawfully acquire or license.

Certain forms of information, such as government issued or private sector issued licenses, permits, certificates, cards, in the nature of driver’s licenses, social insurance/security number, passports, insurance cards, voucher numbers, and the like, although convenient for identification, is voluntary. It is up to you whether you want to provide this, or other suitable identification, subject to any legal requirements.

How Does TripSpark Use Personal Information?

TripSpark uses the personal information it collects as described in this Privacy Statement or as otherwise disclosed to you. TripSpark only uses your personal information in a way it believes a reasonable person would consider appropriate. For example, TripSpark may use personal information to:

· Provide and deliver the services to you including as necessary to take and fulfill your orders, to verify your identity, process transactions, deliver products, perform security verifications, and to provide customer support and services, etc. This may include your name, address, email address and other information you provide.

· To enhance your experience and enjoyment while using our products and services. We use data to provide you with information, to better understand your preferences and interests, to recommend products we believe may meet your needs or which you may be interested in, etc. This information may include your history on our site, your order history, how you interact with us, etc.

· To communicate with you about orders, issues, services, questions, etc. we may use your contact information you provide; and

· To maintain the security of our site, to protect against fraud or misconduct, or to protect our platform or other customers. We may also use your personal information to co-operate with law enforcement and legal authorities, where required, to comply with applicable laws and with court orders.

How Does TripSpark Share Personal Information?

TripSpark may share personal information it collects as follows:

· TripSpark may share personal information with its affiliates, subsidiaries, employees, contractors and agents in the course of providing you with our business services, support, or the fulfillment or delivery of our products or services.

· TripSpark may disclose personal information if we are required to do so a court of competent jurisdiction, other legal or regulatory authority, or, if there is a good faith belief, and reliance on said belief that disclosure is necessary to: comply with any legal process served on TripSpark; maintain, uphold or protect TripSpark's rights or property; protect and ensure the personal safety of the public or other TripSpark clients; or protect against criminal or quasi-criminal activities, or to detect, prevent, investigate allegations of, or address, misrepresentation or fraud.

· TripSpark may share personal information in the event of a bankruptcy filing, mergers with third parties, acquisition by third parties, sale of assets (all or partial), or any other transfer of all or substantially all of TripSpark relevant assets to a third party.

Advertising Purposes

We may allow third parties to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These third parties may use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information (see above for information collected automatically). In some cases, the information in these cookies and other technologies may be linked to other data we collect about you, such as your email address, which we may share in hashed or encrypted form. We may use this information (and these third parties) to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and mobile applications, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used in this way, please visit https://youradchoices.ca (Canada) or www.aboutads.info/choices (United States).

We may also work with third parties to serve ads to you as part of a customized campaign on third-party platforms or other websites (such as Facebook or Google). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and to serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads and may have different privacy statements that apply to the manner in which they collect, protect, use and share your data.

How Does TripSpark Protect Personal Information?

TripSpark endeavors to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to help minimize the risk of any loss, misuse, unauthorized access, disclosure, or modification of personal information. This also applies to our disposal or destruction of personal information. Of course, no system or process of data transmission is completely secure and we cannot guaranty that your personal information will at all times be safe from disclosure. We encourage you at all times to take appropriate precautions to secure your personal information.

We also take all reasonable and appropriate steps to maintain the confidentiality of your personal Information including through the way in which our systems (including our data centers) have been designed to include appropriate security features. Only authorized personnel will ever have access to your personal information and we provide them with training to help ensure your information’s security.

Where is Personal Information Maintained?

Personal information may be stored or processed in any jurisdiction in which we or our affiliates, suppliers, subsidiaries or agents maintain facilities or provide Services. By supplying us with personal information, you consent to any transfer of this information to other jurisdictions (including countries which have not been assessed for adequacy of privacy laws).

How Long Does TripSpark Retain Personal Information?

We keep information only for so long as it is needed for the efficient and effective delivery or fulfillment of the products or services you are using or contemplating using and for a reasonable time thereafter, or to meet any legal requirements. We will either destroy or remove information when it is no longer needed.

Your Choices About Personal Information and How to Contact Us

TripSpark is committed to treating you and your information with the greatest respect and consideration. If you would like to review, update or delete personal information (if these rights are available to you under applicable law), please contact us at privacy@trapezegroup.com or write to the attention of Privacy Policy Manager, Trapeze Group, 5060 Spectrum Way, Mississauga, ON, L4W 5N5, Canada and we will endeavor to respond within thirty days.

You may also choose whether to receive promotional communications from us by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message. These choices do not apply to mandatory service communications that are part of certain of our products, or to surveys or other informational communications that may have their own unsubscribe methods.

California Privacy Rights

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (the “CCPA”), you have certain rights with respect to that information. You also have the right to not be discriminated against for exercising rights set out in the CCPA.

Right to Know: You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Please note that we have provided much of this information in this privacy statement.

Right to Request Deletion: The CCPA also provides California residents the right to request that we delete personal information under certain circumstances, subject to a number of exceptions. These exceptions to deletion include when information is: (1) needed to complete the transaction for which it was collected or to provide goods or services requested by the consumer; (2) used in the context of the business relationship with the consumer; (3) required to perform a contract; (4) used to detect security incidents and protect against malicious, fraudulent or illegal activity; (5) needed to engage in scientific, historical, or statistical research in the public interest; (6) used solely for internal uses that are reasonably aligned with the expectations of the consumer; or (7) required to comply with a legal obligation or applicable laws.

Right to Opt-Out: TripSpark does not sell your data for advertising or any other purposes and has not done so in the past 12 months. This being so, we do not offer an opt-out to the sale of personal data.

Note that although TripSpark does not and has not sold personal information, we have disclosed personal information for business purpose as described in the “How Does TripSpark Share Information?” section of this statement. The CCPA defines “business purpose” broadly; and because we use service providers for a number of business purposes that require access to our systems that hold personal information (such as supplying cloud data storage, maintaining the security of our systems, and providing customer support), in the past 12 months we have disclosed for a business purpose data from each of the categories of personal information that we maintain.

California residents may make requests related to the right to know, a request to delete, or a request for further information about our compliance with the CCPA by e-mailing privacy@trapezegroup.com. To provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by requiring you to provide information necessary to verify your account. Further, you may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Personal Information of Children

TripSpark is committed to protecting the safety of children. TripSpark will not knowingly request or use personal information from children under the age of thirteen without parental consent. If TripSpark receives actual knowledge of such collection TripSpark will take steps to have such information deleted. The Services TripSpark provides are not intended for any person under the age of eighteen and any such persons should immediately discontinue use of this website.

Updates

TripSpark may from time to time update this Privacy Statement and will post the updated policy (with its effective date) on the TripSpark website(s). The use of personal information provided to TripSpark prior to the update will continue to be governed by the policy in effect at the time the information was provided. We recommend that you revisit this Privacy Statement from time to time and on a regular basis.

Contacts

Should you have any questions about this Privacy Statement of how TripSpark treats your personal information, please email privacy@trapezegroup.com or direct communication to:

Trapeze Group
Attn: Privacy Policy
Unit 200
5060 Spectrum Way
Mississauga, ON, L4W 5N5, Canada