1. General Information
1.1 Scope
Tromml, a North Carolina LLC (“Company”, “We”, “Us” and “Our”), respect your privacy and are committed to protecting it through Our compliance with this Privacy Policy (this “Policy”). This policy applies when you visit www.tromml.com, access website features, register for events including webinars, contact customer support, do business with the Company, or otherwise interact with Us.
If you decline to provide personal data or request deletion, you may not be able to access the services.
1.2 Update of This Policy
The Company may change or substitute this Policy at any time. You should check regularly for updates whenever accessing services.
2. Data Categories
The Company collects and processes categories of data depending on your interactions:
2.1 Contact and Business Data
Includes last name, first name, email address, physical address, phone number, country of origin, usernames, passwords, position, and company name.
2.2 Communication and Transaction Data
Refers to interaction data including emails, chat messages, webinars visited, files downloaded, product interest information, registration details, travel information, scheduling data, food preferences, and accessibility requests.
2.3 Device and Browser Data
Includes device type, location, browser type and version, operating system, ISP or mobile carrier, IP address, geographic areas, access times, duration, referring URLs, and device identifiers.
3. Origin of the Data
In most cases, you provide Personal Data directly to Us by accessing the Website or by registering and/or using the Services. The Company may also obtain data from employers, third-party suppliers, social networks, or partners. Collection uses cookies, web beacons, or similar technologies.
4. Purposes for Processing
4.1 Providing the Requested Service
The Company collects and processes data to:
- Provide and deliver products and services including updates.
- Operate and improve operations, systems, products, and services.
- Understand preferences to enhance user experience.
- Provide service and support including confirmations, invoices, notices, updates, security alerts, and administrative messages.
4.2 Comments and Questions
The Company processes data to understand and respond to requests and provide customer service.
4.3 Sales & Marketing Activities
The Company uses email addresses for direct advertising, event communications, product updates, and surveys. Marketing emails include an “unsubscribe” link. Users may opt-out by contacting lauren@tromml.com.
4.4 Statistics
The Company analyzes aggregated, anonymized, or statistical information to improve services, assess user experience, identify development opportunities, and assess capacity requirements.
4.5 Security & Compliance
The Company analyzes data to maintain security, enforce terms and conditions, protect against fraud or illegal activity, and detect misuse.
5. Lawfulness of Processing
The Company processes data where:
5.1 Processing is necessary to perform contractual responsibilities and provide tools and services (GDPR Article 6(1)(b)).
5.2 The Company has legitimate interest to process information (GDPR Article 6(1)(f)).
5.3 Users have given consent to process data (GDPR Article 6(1)(a)).
5.4 Processing is necessary to comply with legal obligations (GDPR Article 6(1)(c)).
7. Recipients
7.1 Data may transfer to affiliates, partners, and service providers performing operations like database monitoring, hosting, ticketing, or software provisioning. Service providers process data only per Company instructions and implement reasonable safeguards.
7.2 For webinars or training events, the Company may forward data to third parties who may use it for event access or marketing communications.
7.3 For transfers outside the European Economic Area without adequacy decisions, the Company ensures adequate protection through EU Standard Contractual Clauses and additional safeguards, or requests prior consent.
7.4 The Company may disclose data to comply with legal requirements like court orders or subpoenas. We will use all reasonable and lawfully available measures to object to overbroad, unclear or otherwise inappropriate requests. The Company may share data with auditors, attorneys, or advisors under professional confidentiality obligations.
7.5 SMS/Text Messaging Data
We do not share SMS opt-in consent or text messaging originator opt-in data with any third parties, affiliates, or non-affiliates for their own marketing purposes. This information is excluded from sharing with third parties except aggregators and text service providers.
8. Duration of Data Storage
8.1 Data is deleted upon request or when no longer required for the service purpose. Legal regulations (fiscal, commercial, contractual) may require longer storage. The Company retains data to assert or defend legal claims until expiration of storage periods or claim settlement.
8.2 User accounts and related data where the Company acts as a controller are deleted upon request.
9. GDPR Rights
9.1 Upon request, the Company informs whether and what data it has stored about users. Where legal requirements are met, users have rights to correct, block, or delete data. Users may receive provided data in a structured, commonly used, machine-readable format and transmit it to another controller.
9.2 Where processing relies on balancing interests, users may object if legal requirements are met.
9.3 Where consent is the processing basis, you may withdraw your consent at any time for the future. This does not affect lawfulness of prior processing.
9.4 Users may exercise rights by contacting the Company in writing with identity proof at user-privacy@tromml.com.
9.5 EU residents have the right to direct questions or complaints to the lead supervisory authority.
10. California Privacy Rights
10.1 This section provides details about data the Company collects from California residents under the California Consumer Privacy Act (CCPA). Personal data categories collected over 12 months are described in Section 2. Business purposes are in Section 4. Third-party sharing is in Section 7. We do not sell, as such term is defined in the CCPA, Personal Data We collect and will not sell or use Personal Data without providing a right to opt out.
10.2 The CCPA provides California residents the right to request details about collected data categories or specific pieces, deletion rights, sales opt-out, and non-discrimination for exercising these rights.
10.3 Users may submit CCPA requests at www.tromml.com. The Company verifies requests using associated account information including email address. Government identification may be required. Users may designate authorized agents to exercise rights.