Privacy Policy

Updated: March 2019

For TruSens, its parent, subsidiaries and affiliated entities (collectively, “TruSens” or “we” or “us”), protecting your privacy is extremely important. This Policy describes how we may collect, manage and use your personal data. It also describes the rights you have over the use of that data. If you have any questions regarding this Policy 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 this Policy
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 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. Social Media
   
10. What rights do I have?
11. Contact Us
12. Which department at TruSens is responsible for my data?
13. How long will you keep my data?

1. Summary of this Policy 

• We at TruSens will use your personal data exclusively for the purpose of conducting business, especially to provide our online services and for payment processing in connection with the TruSens web shop.
• Our company uses processors to process personal data on our behalf, such as cloud service providers and platforms for running our marketing campaigns. 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. Any time your personal data is transferred, it will be encrypted using 128 bit SSL encryption.
• Once you have provided us with your personal data, we generally will not pass the data on to third parties. A transfer of data to companies outside of TruSens will only take place where necessary to provide our services, to process your requests or questions, or to process your order. Furthermore, we will transfer personal data to the relevant authorities where needed to fulfill any legal requirements.  In other cases, we will obtain your permission before transferring the data to third parties.
• You also have rights over how your data is used. For example, if we rely on your permission for marketing purposes, you have the right to withdraw that permission at any time. We will process your request as promptly as possible to prevent further marketing.

2. What does this data privacy notice cover? 

 This Policy describes how TruSens collect, use and transfer data when you use our website or online services, when you purchase our products, and when you interact with our customer service employees, or our company in another manner.

Furthermore, this Policy describes your data privacy rights, including your right to object to various types of processing. 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 your personal data when you interact with our websites, when you use our website or online services, when you purchase our products, and when you interact with our customer service employees, or our company in another manner. This includes:

• Your name, username, and password
• Your personal or business address, email address, and phone number
• Your gender and date of birth
• Your payment and delivery information, including billing and delivery address
• Your order history
• Your marketing preferences, including all permissions you have granted us
• 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:

• In order 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 or sweepstakes. This includes:
  • Verifying your identity;
  • Accepting payments;
  • Communicating with you;
  • Providing customer service; and
  • Arranging the delivery or provision of products, prices or services.

• In order 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 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, we will use your personal data for the following activities:
  • We will send you direct marketing materials regarding our products and services or other products and services, provided by our subsidiaries and carefully selected business partners.
  • We use cookies and similar technologies, in accordance with our cookie notice.
  • 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:
  • Following requests by authorities or criminal prosecution authorities who are conducting an investigation.

5. Which data do you have to disclose? 

The disclosure of your first name, last name, address, and a current email address is mandatory, if you are placing an order with us or if you would like to participate in a promotion or sweepstakes. If you do not provide this data, we will not able to fill your orders and we will not be able to include you 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 permission or how can you object to receiving direct marketing materials? 

You have the right to withdraw your permission at any time, in all cases where you have given us the permission to process your data. In that case, we will terminate the relevant data processing.

In some cases, we may send you direct advertising without your permission. In this case, you have the right to opt out of this direct marketing at any time. You can do this by following the instructions included in the message, if this was an electronic message. Alternatively, you can contact us using the information 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 in order to process orders, sweepstakes or for other marketing activities. In some cases, we also may transfer your personal data to certain agencies in order to process orders, for sweepstakes, or for marketing activities.

If we receive a request from governmental or regulatory authorities, we may transfer personal data to the extent that it is required by law or in the event that this is necessary to protect our legitimate interests under the law.

We will also transfer your personal data to processors, who will process this data on behalf of TruSens for the above-described purposes. These processors include providers of website hosting, maintenance, call center operators, advertising agencies, as well as shipping and logistics providers.

If our business or a part of our business is 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 such data on to the new owners of the company.

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 website to our processor Google Inc. 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. Social Media

At various places on our websites we have implemented social network/ social media features. These include:

• Links to TruSens websites on social networks
• “Like” or “Share” buttons
• Embedded content, such as videos

Such embedded content may be used by the providers of the above features to identify you, the source of a visit, and how you use our websites.

When you use the recommendation functions, this communicates the URL of the respective website to the social network you have picked. A number of networks then immediately supplement the link with an excerpt of the content provided by our website. With most social networks, you are asked for confirmation before this is saved or forwarded.

We have integrated social media tools from the following providers into our websites:

• Google
• Facebook
• Twitter
• YouTube
• LinkedIn
• Instagram
• WordPress

Please note that we neither have knowledge of nor influence on how social networks deal with the information you share with them and whether this information is made available to other websites. We recommend that you read their privacy policies carefully in each case. 

10. 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.
• 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 your data that you have submitted to us.

Furthermore, you can object to the processing of your personal data under certain conditions, such as when 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 advertising.

These rights may be limited, for example, if during the fulfillment of your request, data about another person would be disclosed or if you ask us to delete data that we are legally required to store.

In order to execute these rights, you can contact us using the contact details listed below.

11. How do I contact you?  

We hope that we were able to answer your questions regarding the processing of your data. If you have concerns regarding the processing of your data or if you wish to opt out of direct marketing, 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)

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

Your data will generally be processed by the departments responsible for the respective processing. This can be the Sales Department, Marketing Department, or IT Department.

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

13. How long will you keep my data? 

We maintain and protect data for as long as necessary in connection with the purposes for which it was collected or otherwise lawfully processed, including as required by applicable laws and limitation periods.