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Privacy Policy

 

Updated: July 2019

TruSens is committed to protecting your privacy. This privacy notice provides information on how we may collect and use your personal data. It also describes how you can manage your data.  If you have any questions regarding this privacy notice or your personal data, you can reach us anytime at DataPrivacy@acco.com.

We are also a participant in the EU-US Privacy Shield Framework, as operated by the U.S. Department of Commerce ("Privacy Shield"). Details of our compliance with the Privacy Shield can be found here.

Table of Contents

  1. Summary of use of your data
  2. What does this data privacy notice cover?
  3. What data do we collect?
  4. How do we use your data and what is the legal basis for this?
  5. Which data do you have to disclose?
  6. How can you withdraw your permission or how can you object to receiving direct marketing materials?
  7. With whom, where and when do we share this data?
  8. Tracking via Google Analytics
  9. What rights do I have?
  10. How do I contact you?
  11. Which department at TruSens is responsible for my data?
  12. How long will you keep my data?

1. Summary of use of your data 

  • We at TruSens will use your personal data exclusively for the purpose of conducting business, particularly to provide our online services and send you marketing communications.
  • Our company uses processors, such as cloud service providers and platforms for running our marketing campaigns, to process personal data on our behalf. We also use payment service providers to process credit card data, and to better protect that data, we do not process or store it ourselves. When your personal data is transferred, it will be encrypted using 256-bit SSL encryption.
  • We will not share your data with third parties for their own marketing purposes. A transfer of data to companies outside of TruSens will only take place if necessary to for our legitimate interests, where you have granted us your permission, where necessary to fulfill legal requirements, or where necessary to perform a contract between you and our company.

2. What does this data privacy notice cover? 

This privacy notice describes how TruSens collects, uses and transfers data associated with your use of our website or online services, when you purchase our products or when you interact with our customer services employees, or our company in another manner.

Furthermore, it describes your privacy rights, including your right to object to various types of this processing by Trusens. Further information regarding your rights and how to use them are included in the section “What rights do I have?” 

3. What data do we collect? 

We collect and process personal data about you if you interact with our company or our websites or if you communicate with our customer services employees. This includes:

  • Your name, username, and password;
  • Your gender;
  • Your date of birth;
  • Your payment and delivery information, including billing and delivery address;
  • Your order history;
  • Your private or business address, e-mail address, and phone number;
  • Your marketing preferences, including all permissions you have granted us; and

Information regarding the browser or device with which you access our website.

4. How do we use your data and what is the legal basis for this?

We process your personal data for the following purposes:

  • To fulfill a contract or to take steps in connection with a contract: This is relevant if you make a purchase from us or if you participate in one of our promotions This includes:
    • Verifying your identity;
    • Accepting payments;
    • Communicating with you;
    • Providing customer service; and
    • Arranging the delivery or provision of products, prices or services.
  • To conduct our business and to pursue our legitimate interests.
    • We use your data to provide you with products and services you requested and to respond to comments or complaints you may submit to us.
    • We use your data to monitor our products, content, services and websites, online as well as offline, to protect and improve them.
    • We use the data you provide to us to personalize our website, products marketing or services for you.
      If you provide a credit or debit card as a means of payment, we will also use third parties to verify the validity of the routing number, account number and card number you provided and to prevent fraud (see below for data transfer details).
    • We use the data you provide to us to review complaints made by you or others regarding our website or our products or services.
    • We will use data in connection with legal claims, for compliance and regulatory and investigative purposes (including the disclosure of such data in connection with court proceedings or legal disputes).
    • We will use your data to market to you products similar to those that you have previously purchased from us.
    • We will use the data of some people to invite them to join our marketing research.
  • If you grant your permission for this, we will use your personal data for the following activities:
    • We will send you direct marketing regarding products and services provided by us or our affiliates.
    • We use cookies and similar technologies, in accordance with our cookie settings selected by you and the information when these technologies are used.
    • If we use data for other purposes that require your permission, we will ask you for your permission at that time.
  • For legally prescribed purposes:
    • To meet our privacy and data protection obligations, such as ensuring that consent we obtain is valid.
    • In response to requests by authorities or criminal prosecution authorities who are conducting an investigation.

5. Which data do you have to disclose? 

The disclosure of your name, address as well as your e-mail address is mandatory, if you are placing an order with us or if you would like to participate in a promotion or sweepstake. If you do not provide this data, we will not able to fill your orders and we will not be able to permit you to participate in sweepstakes and promotions.

The disclosure of any further data is optional. If you do not list a phone number, there may be delays in case of complaints or service requests (e.g. if we are not able to reach you by phone). 

6. How can you withdraw your permission or how can you object to receiving direct marketing materials? 

You have the right to withdraw your permission in all cases in which you granted us the permission to process your data. In that case, we will terminate the data processing relating to the respective permission.

In some cases, we may send you direct marketing without your permission based on our legitimate interests. In that case, you have the right to opt out of direct marketing at any time. You can do this by following the instructions we provide to you in the message, if this was an electronic message. Alternatively, you can follow the directions in the “What rights do I have?” section below.

7. With whom, where and when do we share this data? 

We may transfer your personal data to other companies in the ACCO Brands Group and to service providers to process orders, organize sweepstakes or conduct other marketing activities.

If we receive a request from administrative or criminal prosecution authorities, we will transfer your personal data, if this is required by law or if this is required to protect our legitimate interests.

We transfer your personal data to order processing sites who process this data as directed by TruSens for the above purposes. These order processing sites include providers of website hosting, maintenance, call centers marketing agencies, shipping and logistics providers and analysis services.

If a business section of our company sold or integrated into a different company, we may disclose your data to our consultants and to the consultants of the potential buyer and will pass the data to the new owners of the company.

We will only transfer data outside the European Economic Area if this is necessary to fulfill a contract or if sufficient privacy is ensured. This is the case if there is an adequacy decision by the Commission of the European Union or, if the data is adequately protected by standard contractual clauses promulgated by the EU Commission, a relevant Privacy Shield certification or binding corporate rules. A copy of the relevant mechanism is available  for your review upon request to sending an e-mail to DataPrivacy@acco.com. 

8. Tracking via Google Analytics 

We use Google Analytics to analyze your use of our website. In this context, we transfer data about the use of our web pages to our order processor Google Inc. Google Analytics is configured to transfer your IP address anonymously to Google (anonymizeIP). Google compiles statistical reports for us about the use of our website.

If you do not want to be tracked via Google Analytics, you can install a browser add-on, which will prohibit tracking by Google Analytics. 

9. What rights do I have? 

You have the following rights:

  • To request that we provide you with information regarding the processing of your data;
  • To request a copy of your personal data;
  • To correct, delete, or limit the processing of your personal data; and
  • If we process your data on the basis of your permission or to fulfill a contract, you can ask us to provide you with a structured, machine-readable format of the data that you have submitted to us.

Furthermore, you can object to the processing of your personal data under certain conditions (especially we do not need to process your data in order to fulfill a contractual or other legal obligation or if we use the data for direct marketing).

These rights may be limited, for example, if fulling your request would result in disclosing data about another person or if you ask us to delete data that is still necessary for the purpose for which it was collected.

In order to execute these rights or if you wish to opt out of direct marketing, you can click on “Manage My Data” in the footer or visit https://mydata.accobrands.com/.  If you have unresolved concerns, you have the right to file a complaint with an EU data protection authority at your place of residence, your place of work, or where you think a violation has occurred.

10. How do I contact you?  

If you have concerns regarding the processing of your data you can contact us at DataPrivacy@acco.com or at the following address: 

ACCO Brands USA LLC (d.b.a. TruSens) 
Four Corporate Drive
Lake Zurich, IL 60047

Toll Free:1-833-TRU-SENS (1-833-878-7367)

11. Which department at TruSens is responsible for my data?

Your data will generally be processed by our Marketing Department, Sales Department, or IT Department.

In individual cases, other departments may access your personal data, such as our Legal Department in case of a legal dispute.

12. How long will you keep my data? 

If we process registration data, we will keep your data as long as you are an active user of our websites.

If we process personal data for marketing purposes or with your permission, we will keep this data until you ask us to stop the processing, as well as for a short time thereafter (until we can implement your request). We will keep your request to not send you direct marketing materials or process your data indefinitely, so that we will be able to fulfill your request in future as well.

If we process personal data for the purpose of website security, we will keep your data as long as you are an active user of our websites.

If we process personal data in connection with the execution of a contract or for a sweepstake, we will store your data for 6 years following your last interaction with us.