Privacy Policy

Last revised: December 29, 2020

Principles of Data Protection

This Privacy Policy pertains to the use of https://trustref.net (the “Website”) and related services (collectively, the “Services”) provided by the Trusted Referral Network (“TRN”), a DBA for Software Development Resources Inc, a New York corporation. The policy covers information we collect through these Services.  By using the Services or otherwise agreeing to this Privacy Policy, you are consenting to the collection, use, disclosure and other handling of your information as described below.

If you have any concern about providing information to us or having such information displayed on the Services or otherwise used in any manner permitted in this Privacy Policy, you should not use the Services.

1. The Information We Collect

Information Submitted by You

Information about you. We collect information about you when you participate in our research process and use the Services in a variety of ways:

When you create an account, you provide us with information such as your name and email address. We may also ask for your credit card or other banking details if you purchase certain Services. You can provide additional information to enhance your profile such as your location, industry, bio, picture, and phone number. If you believe that someone has created an unauthorized account depicting you or your likeness, you can request its removal by contacting us.

If you wish to submit a recommendation, you must become a registered user of the Services. As part of the registration process, we will collect your user ID, name, photo, phone number, and email address for our records. Of this information, only your user ID and photo will be made available to the public when your recommendation is published. Do not select a user ID or upload a photo that will reveal your identity if you wish to remain anonymous.

Information about Others

You may provide information about others (e.g. clients), including their names, emails, phone numbers and companies to support our reference check and recommendation process. You should obtain the consent of other individuals prior to providing TRN with their information. The information you provide about others is only used in the reference check and recommendation process.

Information from Third Parties

We may collect, process and store your user ID associated with any social media account (such as your LinkedIn account) that you use in connection with the use of the Services. When you use your social media accounts as part of the Services, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you choose to make available to us through the social media interface. This could include, without limitation, any information that you have made public in connection with your social media account, information that the social media service shares with us, or information that is disclosed as being shared during the sign-in process. Please see your social media provider’s privacy policy and help center for more information about how they share information when you choose to connect your account.

We may also obtain information about you if it is contained in user-generated content that other users post to or on our Services. For example, a user could include information about you in a recommendation that they post.

Automatically Collected Information

We and third parties may use automated means to collect information about you, your computer or other device, and your use of the Services. These automated means include technologies such as cookies, Web server logs, Web tags, and JavaScript.

Cookies are files that websites and online services create and access on your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device to help us recognize you, improve your experience, increase security, and measure use of our Services. Our Services may use cookies and other types of local storage (such as browser-based or plugin-based local storage). Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict, disable or delete certain cookies. Please note that without cookies or local storage you may not be able to use all of the features of our Services.

In conjunction with the gathering of information through cookies and other automated means, Web servers may log information such as your device type, operating system type, mobile device identifier provided by your mobile device operating system), browser type, domain, and other system settings, the name of your ISP or mobile carrier, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record information such as the address of the Web page that referred you to our Services and the IP address of the device you use to connect to the Internet. They also may log information about your interaction with our Services, such as which pages you visit. To control which Web servers collect information by automated means, we may place tags on our Web pages to link these pages to particular Web servers and their cookies. We also may include such tags in e-mail messages. We or third parties also may send instructions to your device using JavaScript or other computer languages to store or gather other details about your interactions with the Services.

We may also collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if you provide a zip code that indicates that you live in New York, the Services may be customized with New York-specific information and advertisements. In order to do this, your location information may be passed along to our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with GPS location-tracking information, you may disable the GPS or other location-tracking functions on your device. See your device manufacturer’s instructions for further details about disabling GPS location tracking and similar services.

2. How We Use Information

What legal basis do we rely on to process your personal data?

Consent – When you receive our promotional material, you consent that your Personal data will be processed by us and we rely on this consent. You have the right to withdraw consent at any time. We will stop processing your data after consent is withdrawn, where consent is the only legal basis for processing.

When you fulfill a contract – We will process your Personal data when you take steps to enter into a contract with us such as signing up for a free trial, using or purchasing our service or products and for the performance of contracts that you have entered into with us.

Legitimate Interest – We process your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights.

Legal obligation – We may process your Personal data to comply with our legal and regulatory obligations such as preventing, investigating and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies. Your data may be processed in order to satisfy the applicable law or enforceable governmental request. We use the information we collect about you to:

Please note that we may anonymize and/or de-identify information collected through the Services or via other means so that the information no longer relates to you. Where we have appropriately anonymized and/or de-identified information so that it no longer identifies you personally, our use and disclosure of such information is not subject to this Privacy Policy and may be used and disclosed to others without restriction.

3. How We Share Information

Information about you may be shared for the following purposes:

Any information included in your user profile and any content you post on the Website (e.g., your recommendations) may be seen by others. When you post a recommendation, your content, including your user ID and photo as the contributor, may also be displayed in search engine results.

If you provide any recommendations or testimonials either about TRN or service providers on the Website or otherwise covered in our research, we may post those recommendations or testimonials or portions thereof. Recommendations or testimonials and advertisements may include your name, title, company, and other information that you have provided.

When we have your consent or where it is necessary to carry out your instructions;

As reasonably necessary to provide TRN features and functionality to you, we may share your information with third-party vendors or business partners who provide services on our behalf, which may include analytics, customer service, survey providers, payment processing, marketing, and fraud prevention. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of our Services. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.

In connection with significant corporate events (for example, we may share or disclose information we have about you in the event we sell or transfer all or a portion of our business or assets — such as in connection with a merger, acquisition, reorganization, bankruptcy, dissolution or liquidation — or take steps in anticipation of any such event);

When we believe in good faith that sharing is reasonably necessary to investigate, prevent, or take action regarding possible unlawful activities or to comply with legal process or other legal requirements; when we deem disclosure appropriate in situations involving potential threats to the physical safety of any person, potential violations of our terms, or claims of violation of the rights of third parties; or when we deem disclosure appropriate to protect our rights, property and safety and that of our employees, users, or other persons or entities (the disclosures described here may involve the sharing of your information with, for example, law enforcement, government agencies, courts, or other parties).

4. Online Analytics, Advertising and Do-Not-Track

Online Analytics Providers

To help us better understand your use of the Services, we may use third-party analytics. These third parties may use the sorts of technologies described in the “Automatically Collected Information” section above. The information collected by this technology will be disclosed to or collected directly by these service providers.

Advertising Technology Providers

Data about your activities on our Services may be collected by us or by advertising technology providers for use in delivering online advertising tailored to your individual characteristics, activities, interests and other factors. These ad services may track your online activities over time by collecting information through automated means, including through the use of the various technologies described above, and they may use this information, and other information they receive from us or other sources, to deliver advertisements to you on our Website, our emails, and other websites. We and third-party vendors may use first-party cookies and third-party cookies together, and other automated technologies, and in some cases additional information, (i) to inform, optimize, and serve ads based on past visits to our Services or other factors and (ii) to report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Services or other factors.

You may visit the Network Advertising Initiative’s Consumer Opt-Out page or the Digital Advertising Alliance’s Consumer Opt-Out page to opt out of receiving tailored advertising based on your Internet browsing activities from companies that participate in those programs. Some of our advertising-related activities may involve the services of companies that do not participate in those programs. For example, we may use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our Website. You can set preferences for how Google advertises to you using the Google Ad Preferences page. The opt-outs apply only to the browser in which you set them. For example, if you set the opt-out while using Safari, but then use Chrome, the opt-out will not be active in Chrome. To opt out in Chrome, you will need to repeat the opt-out process.

The opt-outs described in this Privacy Policy do not block or delete cookies or prevent the use of cookies or other technologies for purposes other than selecting ads based on your interests as inferred by your online behavior. If you opt out, data may still be collected about your web browsing activities and you will still see advertising. Ads may be delivered based on other factors, such as the content of the web page in which they are shown, or demographic information obtained through other means.

Do Not Track Disclosure

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT.

5. Information Access, Correction, and Deletion Options.

You have a right to (1) access, modify, correct, or delete certain aspects of your information regarding your user profile, and (2) close your user account. You can also contact us regarding any account information which is not on your profile or readily accessible to you. If you close your account, your information may be removed or unpublished from the Services within a reasonable amount of time.

Once you submit a recommendation and the recommendation has been approved for posting, it cannot be removed, and may only be edited by us per the Recommendation Guidelines.

Note that information that others might copy from TRN Services may be published elsewhere on the internet, social media, or other media outlets over which we have no control. Such republications may remain visible and inaccessible, even after the original information is removed from TRN Services. Furthermore, information removed from TRN Services may be displayed in search engine results until the search engine refreshes its cache.

Data Retention

We retain your information as long as your account is active or as needed to provide you services or because we have an ongoing legitimate business need to do so. We also retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We store your information as long as is necessary for the purpose for which we have collected it. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or securely store and isolate it from any further processing until the deletion/erasure is possible.

6. Security

We have implemented various technical, administrative, and physical safeguards to protect your information. These safeguards vary depending on the sensitivity of the information at issue.

7. Third Party Links and Services

The Services may contain links to third-party websites, applications and services, including social media services, as well as embedded images or other third-party content and features. Your use of these features may result in the collection, processing or sharing of information about you, depending on the feature. We are not responsible for the content, features, security or practices of any third parties. We do not vet, endorse, or make any representations about third parties or their websites, applications or services. The information you choose to provide to or that is collected by these third parties is not covered by our Privacy Policy.

8. Changes to this Policy

This Privacy Policy may be modified from time to time as our business practices and legal requirements evolve. If this Privacy Policy is modified, we will provide appropriate notice of the change, and we will include the effective date of the update. Please review the changes carefully. If you disagree with the Privacy Policy, you must stop using the Service. If you continue to use TRN Services after we publish or communicate a notice about any changes to this Privacy Policy, you are consenting to such changes.

9. Children’s Privacy

The Services are not intended for use by minors under the age of 18. We do not knowingly collect (or knowingly allow any third party to collect) personal information from persons under the age of 18. If we become aware that personal information has been collected from a person under the age of 18, we will delete this information and terminate the person’s account as quickly as possible.

10. International Users

The Services are hosted in the United States and are governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are hosted. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Privacy Policy.

11. Your California Privacy Rights

We do not disclose your personal information to third parties for their own direct marketing purposes without your consent. If you have any questions regarding this policy, or would like to change your preferences, you may contact us using the information in Section 13 below.

12. Your Rights within the EU

Whenever you use our services from within the EU the following rights apply to your user account:

The right to be informed, The right of access, The right to rectification, The right to erasure, The right to restrict processing, The right to data portability, The right to object and rights in relation to automated decision making and profiling.

If you wish to exercise any of the above rights, please contact us using the contact details set out below. For the protection of your privacy and security, our data protection team shall take every reasonable step to ensure that your identity is verified before granting access, or rectification, or deletion.

13. No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

14. How to Contact Us

If you live in the EU, the Controller of your data is Trusted Referral Network, a DBA of Software Development Resources Inc with its principal place of business at 1825 Madison Avenue, Suite 9E, New York, NY 10035.

If you have any requests, questions, comments, or concerns regarding our Privacy Policy or practices, please contact us here.