For the purposes of this policy, “Trinity SCS” is defined as the Trinity SCS Limited, “personal data” as data that identifies living individuals, “prospect” as a business in contact with but does not have an established relationship with Trinity SCS (or representative of a business) and the term “client” as a business with which Trinity SCS does have an established relationship (or representative of a business).
Trinity SCS collects and combines personal data, such as name, addresses, emails, telephone numbers, transactional data, lifestyle and demographic data both online and offline through questionnaires, promotions, our partners, public sources, commercially available databases and our websites. Personal data may be kept in its identifiable form, or in an aggregated form (so that individuals cannot be identified), for the purposes listed below.
Information Uses and Disclosures
Trinity SCS, the Trinity SCS group of companies, and our business partners, prospects and clients (where permitted by Trinity SCS) may use this personal data:
• to send you relevant marketing communications
• to improve the relevance of marketing communications through the use of lifestyle and demographic insight data
• to clean, validate and enhance marketing databases
• to undertake research and analysis,
• for product development and testing,
• for identity validation and fraud reduction,
• support client relationship,
• to connect and link your data to other marketing and advertising databases and platforms and
• for work planning, management and strategic decision making.
All personal data that Trinity SCS collects are used in accordance with the Data Protection Act 1998. When personal data is collected from people who voluntarily complete our questionnaires, the personal data are also used in accordance with the use and disclosure statements on the questionnaires.
Personal data used in Trinity SCS’s data products and services may be passed to and used by members of the Trinity SCS group of companies worldwide, after obtaining appropriate permissions where applicable. We will only pass personal data outside this group to our contracted suppliers that process personal data on our behalf and to our business partners, prospects and clients and their subcontractors. When we do so, we ensure that appropriate contractual safeguards are put in place. These parties may be located in UK or abroad.
Trinity SCS Corp is registered with the US Department of Commerce on www.privacyshield.gov in accordance with the Privacy Shield agreement between the EU and the USA. Trinity SCS may also disclose personal data as required by law and to comply with legal process.
Data Subjects’ Rights
Individuals may access or correct their personal data, or withdraw their consent at any time by contacting us or by refusing technologies such as cookies.
Individuals wishing to inquire about our policies, to access or correct their personal data, or withdraw consent should contact Trinity SCS by writing to us at Consumer Services department, Trinity SCS Limited,
Other Important Information
Trinity SCS Limited has notified its processing activities with the Information Commissioner. We have implemented measures designed to ensure compliance with the Data Protection Act 1998, the Telecommunications Act 2003 and other applicable legislation as amended from time to time. Furthermore, Trinity SCS Compliance is checked annually by the Direct Marketing Association of which Trinity SCS is an active member.
At all sites owned by or partnered with Trinity SCS, where technologies such as “cookies” are used, web-browsers can be set to notify individuals when a cookie is received. This will give individuals the chance to choose whether to accept it or not. Detail explanation of the way cookies work is available at www.cookiecentral.com
Trinity SCS UK Digital Advertising Products Opt-Out
To opt out of Trinity SCS’s digital advertising products, click the opt out link. Trinity SCS also participates in the Online Behavioural Advertising Icon program which enables the consumer to learn about how a tailored ad was developed and offer a choice about receiving future tailored ads. To learn about the Advertising Option Icon displayed in online advertising solutions that leverage behavioural advertising click here.
Opting out of Trinity SCS digital advertising products does not mean you will no longer receive digital advertising. It does mean that Trinity SCS will no longer collect or share digital advertising data about you with our clients.
The Trinity SCS opt-out tool is cookie-based. In order for the tool to work on your computer, your browser must be set to accept third party cookies. If you buy a new computer, change Web browsers or delete this cookie, you may need to perform the opt-out task again.
Transfer of Assets
As Trinity SCS develops its business, there may be a change of control of Trinity SCS or divisions, subsidiaries, affiliates or portions of Trinity SCS. In this situation, personal data is typically considered a transferable asset. Also, in the event that Trinity SCS or a part of its divisions, affiliates or subsidiaries are purchased, personal data will be one of the transferred assets.
Trinity SCS takes security seriously. We make considerable investments to keep our sites and systems secure and to prevent personal data from being made available to any unauthorised persons or businesses.
General Data Protection Regulation
A new privacy law called the General Data Protection Regulation, or the GDPR, will apply in the EU from May 2018 onwards. If the GDPR becomes law in the UK the following additional matters shall apply:
1. legal basis: you shall be entitled to know the ground upon which your personal data is processed which will either be consent or legitimate interests; where your personal data is processed on the basis of legitimate interests, an explanation of why our legitimate interests take precedence shall be made available.
2. data protection officer: if we are required to appoint a Data Protection Officer under the GDPR then we shall make available their identity.
3. data retention: we keep your data for as long as we have a legal ground to process it for a particular purpose; more detailed data retention information shall be made available if we are required to do so.
4. supervisory authority: we shall be required to notify you that in the event of a complaint you may contact the relevant supervisory which in the UK is the Information Commissioner’s Office.
5. right to object and to erasure: where our legal basis is legitimate interests, you may object to that processing unless we can demonstrate compelling legitimate grounds for the processing; under certain circumstances you will also have the right to erasure of your personal data.
6. international transfer: where we transfer your personal data outside the EU we shall ensure we have a valid transfer mechanism in place to protect your information.
7. source of data: where your personal data is not obtained directly from you, you may ask for the identity of the source of the data.
Effective date: December 2022