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PRIVACY POLICY
(Last Updated 3.22.2024)

1. ABOUT THIS POLICY

This policy describes the types of personal information that TRACE International, Inc. (“TRACE” or “we” or “our”) may collect in our role as a data controller, or data processor, as the case may be in connection with our publicly available blog, BriberyMatters.com (the “Blog”); the purposes for which we may use the information, the circumstances in which we may share the information and the steps we take to safeguard this information. Please note, we may also process other data in our role as a data processor on behalf of other data controllers in strict accordance with their instructions, which may differ from what is described in this Policy.

The Blog is hosted on Wix.com. Please refer to their privacy policy here: About Privacy | WIX

 

2. THE INFORMATION WE COLLECT

TRACE collects the following information of users of the BriberyMatters.com blog:

  • Email Address (required to subscribe to the Blog)

  • Login credentials, IP addresses, website cookies, internal unique identifiers and other session details;

  • Optional Information you choose to share via comments, web inquiries, etc. (e.g. your name)

 

This is a broad description of the types of personal information that our company processes as a controller. To understand how your own personal information is processed in each particular instance you may need to refer to any personal communications you may have received from us, check any privacy notices we may have provided to you or made available on our site or contact us to ask about your personal circumstances. You can unsubscribe from the Blog at any time. Our Blog is not intended for children under the age of 13 and we do not knowingly collect personal information from children under the age of 13.

 

3. WHAT WE DO WITH COLLECTED INFORMATION

TRACE uses the information that we collect to:

  • Provide Blog users with access to the Blog content and related information (e.g. creating user accounts and logins or sending materials requested via forms);

  • Create profiles to help us manage our relationship with site visitors and ensure that users receive and maintain updated information;

  • Analyze data to Improve our products and services, troubleshoot issues, and personalize the content we offer;

  • Periodically send promotional emails about products, special offers or other information we think you may find interesting using the email address you have provided;

  • Post your user generated content and comments to the sites as you request;

  • To respond to any emails or requests that you directly make to us;

  • For our statistical, research, recordkeeping, and reporting purposes;

  • To comply with the law, and

  • For any other purpose identified at time of collection.

 

TRACE does not sell personal information and will not use the information provided to us in ways unrelated to the one described above.

 

4. DATA SECURITY

We are committed to safeguarding your information. We do this by:

  • Establishing policies and procedures for securely managing information;

  • Using access controls to limit personnel access to sensitive information;

  • Protecting against unauthorized access to user data by using physical security, firewalls, data encryption, authentication and virus detection technology, as required;

  • Providing data protection training to our employees; and

  • Continually assessing and improving our data protection, information management and data security practices as well as technical and organizational measures and safeguards.

 

We cannot, however, fully eliminate security risks associated with the storage and transmission of Personal Data.

 

5. USE OF COOKIES AND WEB BEACONS

We use “cookies” (small text files that may be placed on your web browser when you visit our website). The information derived from cookies is used for administrative purposes and to improve your experience with our website. For example, this information may help authenticate you (verify that you are who you say you are), an essential component of our website security. It also helps you more easily navigate our website by remembering your identity so that you do not have to input your password several times as you move between pages. You can prevent cookies from being set. However, if you decline to use cookies, you may experience reduced functionality and, when we require authentication, declining cookies may prevent you from using the website altogether.

We may also use web beacons (a small graphic image placed on a webpage or in an email message to monitor user activity, such as whether the webpage or email is accessed or clicked). We use this data for administrative purposes; to assess the usage and performance of our services; to improve user experience; and as otherwise permitted by applicable law or regulation.

In addition, cookies and web beacons may be used to track information and identify categories of visitors by items such as IP address, domain, browser type and pages visited to improve our service. We may use the Google Analytics™ web analytics tool to assist us in analyzing how visitors engage with our website and arrive at the public portion of the website. Further information about Google Analytics can be found at the Google Analytics Privacy Policy.

 

6.RETENTION PERIODS

We will retain your personal data for as long as you maintain an account or as otherwise necessary to provide you the Blog services. We will also retain your personal data in a secure backup system for a reasonable period of time in order to assure reliable service and as necessary to comply with our legal obligations, resolve disputes, protect our network security, and enforce our agreements.

Where we no longer need to process your personal data for the purposes set out in this Privacy Policy, we will delete your personal data from our systems.

Where permissible, we will also delete your personal data upon your request.

If you have questions about our retention of your data, please contact TRACE’s Data Protection Officer as explained below.

 

7. DISCLOSURE OF INFORMATION TO THIRD PARTIES

We will not share your personal information with third parties, except as described herein, in separate data notices that you may receive from us, or as authorized by you. For example, we may share information collected about you:

  • With third party blog contributors or online advertising partners when you elect to download additional information from their third-party site via link shared on the Blog. You will always have the option to not have your data shared by not registering for that specific product and by not accessing links. Please be aware that we do not control third-party linked websites and that this Privacy Policy does not apply to those websites.

 

  • To third party service providers helping us provide, improve, and market our Blog and services. Examples include but are not limited to:

  1. Online analytic tools such as Google Analytics which provides analytics about website usage;

  2. Social networking sites such as Twitter, LinkedIn, Instagram and Facebook, and

  3. Service providers / consultants that provide professional, legal, IT, data hosting, software development and technical services, translation, or customer support services.

  • Our email service provider;

  • With government entities as needed to provide our services and where required by law;

  • As part of an acquisition or merger with another company, or other corporate change;

  • To investigate, respond to or resolve problems or inquiries (including law enforcement or legal requests) or protect, enforce, or defend our rights, assets and/or interests, and

  • To prevent or respond to a violation of any law, regulation, or our Terms of Service, or as necessary to protect and defend our network security.

 

These third parties are required to maintain the confidentiality of your personal information, and to use your personal information only in the course of providing such services to TRACE, and only for the purposes that TRACE dictates. Any other disclosure of your personal information will be pursuant to your express consent.

If you have questions or concerns over your personal information’s disclosure to a third party as described above or wish to opt out from such disclosure, please contact the TRACE Data Protection Officer as explained below.

 

8. HOW YOU MAY ACCESS AND CORRECT INFORMATION

You may request deletion or correction of your personal information at any time by contacting us directly, and we will respond to your request without undue delay, typically within 30 days or less. In some circumstances, you may have other rights with regards to your information such as the right to data portability and the right to object to our processing of your data.

 

9. THIRD-COUNTRY TRANSFER OF EU/EEA AND 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 TRACE with relevant entities located in the EU, EEA or UK, as the case may be.

 

10. CHANGES TO OUR PRIVACY POLICY

This policy provides a general statement of the ways in which TRACE protects your personal information. We may supplement this statement by sending you a specific data notice or we may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way we treat your personally identifiable information, we will update this policy and may send you a personal communication summarizing the revisions.

 

11. CONTACT

If you have questions or concerns about our processing of personal information, please contact the TRACE Data Protection Officer at the following address:

 

TRACE International, Inc.

Attention: Data Protection Officer

151 West Street, Suite 300

Annapolis, MD 21401

United States of America

DPO@TRACEinternational.org

 

If you are not satisfied with our response or believe we are processing your personal information not in accordance with applicable law, you may contact our third party dispute resolution provider at https://feedback-form.truste.com/watchdog/request. It may be possible, under certain conditions, for individuals to invoke binding arbitration.

FOR EU RESIDENTS:

In addition to contacting TRACE’s Data Protection Officer, individuals residing in the European Union may contact TRACE’s EU Representative at EURepresentative@TRACEInternational.org.

If contacted, we 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 without undue delay. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you may either:

  • file a complaint with the Data Protection Commissioner at info@dataprotection.ie or the supervisory authority located in your jurisdiction; or

  • contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. It may be possible, under certain conditions, for individuals to invoke binding arbitration.

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