TRACE REGISTER, LLC PRIVACY STATEMENT
Last Updated: September 28, 2014
This Privacy Statement describes our privacy practices for our internet-delivered supply chain traceability and information management software service (our “Software Service”). It governs all of your use of the Software Service, whether you access it from our application portal on our Web site at http://www.TraceRegister.com or from any other mobile applications, mobile sites, widgets, portals or other internet points of presence that we make available to you (collectively, our “Site”).
Trace Register is committed to respecting the confidentiality of our users’ personal and business information. That said, a core function of the Software Service is to facilitate sharing and analysis of product, logistical, certification, and other information among suppliers, buyers, processors, distributors and other companies who have business relationships with each other. Since the fundamental nature of the Software Service involves sharing of data, we encourage you to familiarize yourself with this Privacy Statement and the information-sharing settings available to you within the Software Service. If you have any questions about our privacy practices or how the Software Service works, please email us at inquiry@TraceRegister.com.
1. SCOPE OF PRIVACY STATEMENT; ELIGIBILITY
Scope. This Privacy Statement describes our privacy practices with respect to our Software Service and Site. It applies to personal information we collect about you and the information we collect about your company via the Software Service. When we use the terms “you” and “your” below, we mean your company, but we also describe our treatment of information (including payment information and other personally identifiable information) submitted by individuals. By using or accessing our Site or Software Service, you agree to this Privacy Statement and our User Agreement.
This Privacy Statement covers our Trace Register Standard platform. We may release new products or services on the Site from time to time, which may be governed by separate privacy policies or by modifications to this Privacy Statement. Any modifications we make to this Privacy Statement will take effect with respect to such new products and services as soon as we post them. Also, this Privacy Statement covers only our Site; it does not cover third party Web sites or applications to which you may find links on our Site.
Eligibility. Before you can use our Software Service, you must first receive a user name and password from us. If you are interested in using the Software Service, please contact us at inquiry@TraceRegister.com.
2. INFORMATION WE COLLECT AND RECEIVE ABOUT YOU.
Information You Provide When You Use the Software Service. When you use the Software Service, we obtain the following categories of information about you:
Account Information. In order to use the Software Service, you are required to provide or verify certain identifying information about your company, including (1) the first name, last name, email address and title of a company contact, (2) a corporate name, country, postal code, street address, telephone number and fax number for the company, (3) information about the role the company typically plays in its supply chain (buyer, processor, retailer, etc.), (4) user names, passwords, and other login credentials, and (5) other similar information we may request from time to time (“Account Information”).
Billing Information. In order to purchase a subscription to the Software Service, you will be required to provide us with financial qualification and billing information, such as billing name, address and payment information (“Billing Information”).
Correspondence. We may receive emails from you and other users from your company (for example, in connection with customer support inquiries or for training purposes). We use and retain these emails as described below.
Product Traceability Information. The Software Service allows you to provide information about products and/or specific shipments of products (“Product Traceability Information”) in what the Software Service calls “Trace Documents.” As more fully described in the “Information You Share With Your Trading Partners and Supply Chains” section below, the Software Service offers settings that allow you to control whether to share Product Traceability Information with other users in Trace Documents. Product Traceability Information can include a variety of information about the source and attributes of product shipments, including the identity of and contact information for your suppliers, the product’s common and scientific name, a certificate or certification document, a lab report, shipping lot number, production date, production method, per unit weight, total net weight or other quantity measurement, scientific name, country of origin, feed, treatments, and added ingredients. The Software Service also allows you and other users to attach files and content to Trace Documents. We do not generally review or control the information included in these attachments (or in any user-submitted data), so you should take care to avoid including sensitive data or information in them that you do not want to share with your trading partners.
Information Other Users Provide About You. Other companies may also submit to the Software Service information and data about you, including personal contact information and Trace Documents about transactions in which you participate. As more fully described below, some or all of this information may be available to other users of the Software Service depending on the settings you and other users select when you use the Software Service.
Information We Collect Automatically When You Use Our Site. We receive and store certain types of information whenever you interact with our Site. We keep track of your “clicks” and pages you view on our Web site. We use “cookies” and obtain certain types of information when your Web browser accesses the Site, such as the Internet Protocol (IP) address of your computer, information about your browser software and operating system, and the date and time you access our site. “Cookies” are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser and to provide certain features on the Site. The “Help” feature in most Web browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable some cookies altogether. Keep in mind, however, that disabling cookies may prevent you from logging into the Software Service or result in some features of the Software Service not working properly.
3. HOW WE USE YOUR INFORMATION
To Provide, Manage and Improve the Site and Our Services. We use Account Information and information in Trace Documents to make the Software Service and its features available to you and other users consistently with our User Agreement and this Privacy Statement. For example, we use information in emails you send us to provide customer support and training, and we use Product Traceability Information in order to operate the Software Service in accordance with the sharing features described in Section 4 below. We use Billing Information to process and collect payments. And we use information about your activity on the Site to improve the features of our Software Service.
To Contact You. We will use Identification Information to contact you with service-related announcements and notifications.
4. INFORMATION YOU SHARE WITH YOUR TRADING PARTNERS AND SUPPLY CHAINS
The Software Service is designed to enable companies who operate in the same global supply chains to share information with each other. As more fully described below, the Software Service gives you choices about what information you share, and with whom you share it.
In this Section, we use “Supply Chain” to mean groups of companies, such as suppliers, buyers, processors, wholesalers and retailers, that are involved at some point with a specific shipment of product (a “Shipment”) during its path to eventual retail sale. We use the term “Supplier” to refer to a company who identifies you in the Software Service as the recipient of their Shipment. We use the term “Buyer” to refer to a company that you identify in the Software Service as the recipient of a Shipment from you.
Sending (or Not Sending) Product Traceability Information to Your Trading Partners.
When your Supplier identifies you in the Software Service as the recipient of a Shipment, your Supplier may or may not send you Product Traceability Information about the Shipment. This Product Traceability Information may include information about the Supplier, information about products in the Shipment, and/or information about the other companies in your Supply Chain that were involved with the Shipment before it reached your Supplier.
If you use the Software Service to identify a Buyer for a Shipment, you may send your own Product Traceability Information to that Buyer. The Software Service also gives you the option to “link” your Supplier’s Product Traceability Information to the information you send your Buyer. Alternatively, you may choose not to send any Product Traceability Information at all to your Buyer.
If you do opt to link your Supplier’s Product Traceability Information to a transaction, you can manage the amount of information your trading partner will be able to see and share by using the “Approved” and “Non-Approved” settings described in the next paragraph. You should carefully review Product Traceability Information from your Supplier before you “link” it to information you send to your Buyers, to ensure that it does not include information you don’t wish to share.
“Approved” and “Non-Approved” Trading Partners.
The Software Service allows you to designate each of your Suppliers and Buyers as either “Approved” or “Non-Approved.”
If you designate a Buyer as “Approved,” that Buyer will see all of the Product Traceability Information in the Trace Documents you send your Buyer via the Software Service, including information from your Supplier that you “linked” to your Trace Document. Your Buyer will also be able to send your Product Traceability Information to other members of your Supply Chain.
If you designate a Supplier as “Approved,” that Supplier will automatically see any Product Traceability Information you send to your Buyer about the Shipment you received from Approved Supplier. Accordingly, your Supplier could, if they chose, share that Product Traceability Information with any of their suppliers in the same Supply Chain.
When you designate Buyers or Suppliers as “Non-Approved,” those Buyers and Suppliers will see all of the Product Traceability Information that you enter into Trace Documents you send those Buyer or Suppliers. However, with respect to Product Traceability Information from another user that you “link” to your Trace Document, the Non-Approved Buyer or Supplier will see only the following data fields: product common name, scientific name, country of origin, and the country where you have indicated your supplying facility is located. In addition, you Non-Approved trading partners will see data entered into other product attribute fields that you generally approve for public display within your Supply Chain. Your Non-Approved trading partner will only be able to share this limited Product Traceability Information that you provide with others in your Supply Chain. You should carefully review any “linked” Product Traceability Information to ensure that your Suppliers or Buyers have not entered information in inappropriate fields that you do not wish to disclose to “Non-Approved” trading partners.
Sharing Information Outside the Software Service
Keep in mind that the settings and options described in this Section are not a guarantee of secrecy. Once your trading partners receive information from you from any source – including the Software Service – we do not control what they do with that information. You should take care not to share sensitive information with trading partners with whom you do not have a relationship of trust. Also, users that you block from obtaining Product Traceability Information or your Account Information may be able to obtain such information elsewhere. For example, they could obtain it from other users with whom you shared information, or by using available information combined with their own knowledge.
Finally, you should also keep in mind that, if you use our Software Service to comply with tracing or tracking obligations required or requested by your buyers or suppliers, using the “Non-Approved” setting may cause you to fall short of your obligations to those trading partners.
5. HOW WE SHARE YOUR INFORMATION
We do not share any of your Account Information, Billing Information, Product Traceability Information or correspondence with other users or any third parties except under the circumstances described in Section 4 and this Section 5.
Third Party Service Providers. We may rely on third party service providers to assist us in operating the Site. For example, we may use third parties to host our Site and payment processors to process credit card payments. We seek to obtain appropriate contractual and technical protections to limit these third parties’ use and disclosure of your information.
Business Transfers. If Trace Register is (or its assets are) acquired by another company, user information would almost certainly be among the assets transferred to the acquirer. In the event of such an acquisition, the Privacy Statement in force at the time would continue to apply to your information.
To Protect Trace Register and Others from Liability or Harm. We release posted content and user information, including contact information, when we believe we must do so to comply with the law, to enforce our User Agreement, or to protect the safety and rights of Trace Register itself or our users.
With Your Consent. In addition to the circumstances described above, we may also share your personal information or content with third parties when you give us your consent to do so.
6. HOW TO VIEW AND EDIT YOUR INFORMATION
Contact and Profile Information. You or your company administrator can view your company’s contact and profile information at any time from your Account page. You are responsible to keep a current email address and other contact information on file with us.
Product Traceability Information. Though you can view your own Trace Documents and those that have been shared with you by other users at any time, it may not be possible to delete or modify certain information within them once posted. If you have concerns about the accuracy of data you have submitted, you may contact us at inquiry@TraceRegister.com and we will work with you to resolve them.
7. ACCOUNT DEACTIVATION AND DELETION OF DATA.
If you wish to de-activate your account, please email us at inquiry@TraceRegister.com requesting account deletion. When an account is deleted, all Account Information and Product Traceability Information that were shared with other users before you deleted your account in will remain available to other users, all in accordance with the Approved/Non-Approved settings and other sharing options you selected when using the Software Service. We also maintain certain Account Information, such as company contact name, address, and email addresses, in a master contact list available to all users of the Software Service, even after your account is deleted. We retain Billing Information in order to comply with accounting requirements and in accordance with our standard archival and backup procedures. Finally, we may retain email correspondence you send us in connection with support and training inquiries indefinitely (but we do not share this information with any other users except under the circumstances described in Section 5 above). Otherwise, except as described in this Section 7, all Account Information, Product Traceability Information, and other information you enter into the Software Service will be deleted within sixty (60) days after you deactivate your account in accordance with our standard procedures. We may retain archival, backup copies of information for a longer period of time, but if we do so, we will not share or disclose such backup copies with any third parties except our service providers who need to access them to provide services to us and who are contractually bound to keep them confidential. We will retain your data for at least 30 days after account de-activation; thereafter, we have no obligation to retain or make it available to you.
8. SECURITY.
We take the privacy and security of your information seriously. We take industry standard technical precautions to maintain the security and integrity of your information stored on our systems, including storage of your Account Information and other information on a secure server behind a firewall. We also maintain industry standard administrative safeguards, limiting access to your information to those of our personnel who need access in order to perform their job functions, and who are bound by confidentiality obligations to refrain from disclosing your personal information other than as described in this Privacy Statement.
9. MODIFICATIONS TO THIS PRIVACY STATEMENT
We may modify this Privacy Statement at any time. If you maintain a Trace Register account, we will notify you, at the email address you provide to us when you register for an account, of any material modifications to this Privacy Statement. All such changes will take effect thirty (30) days after we post the updated Privacy Statement; except that no such modifications will be binding on you if they expand our rights to share your Product Traceability Information or personally identifiable information without providing you with a means (including email or settings available on the Service) to prevent or opt out of such additional sharing. We may from time to time make changes to the sharing settings and features available via the Service that control sharing of Product Traceability Information among users. Accordingly, we may change the description of those settings and features in this Privacy Statement from time to time, and any such changes will be effective thirty (30) days after being posted, as long as we offer you the ability to use those settings and features to prevent or limit any further sharing of your Product Traceability Information.