2019

Privacy

Trend Micro Competition Privacy Notice

Last updated: 01 September 2019

Hello! At Trend Micro, we are committed to protecting the privacy of your personal information. This Privacy Notice tells you how we collect, use and share information that you provide to us when you take part in the “What’s Your Story” (the “Competition”).  If you are under 16, you should always check with a responsible parent or guardian (we’ll call them “Adults“) before taking part in the Competition and discuss this Privacy Notice with them.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice. We may update this Privacy Notice from time to time, and when we do we will post the latest version on our website. If we wish to use your information in a way that is different from what we say in this Privacy Notice, we will contact you (or an Adult) to get your consent.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

Table of Contents

After the Summary, the Detailed Privacy Notice for Adults has the following sections:

  1. What personal information do we collect and why?
  2. Who do we share your personal information with?
  3. Legal Basis for processing personal information.
  4. How do we keep your personal information secure?
  5. International data transfers.
  6. Third party sites.
  7. What are my data protection rights?
  8. How long will you keep my personal information for?
  9. How to contact us.

Summary

We encourage you to read this entire Privacy Notice with an Adult. However, you may find this quick summary helpful to understand some of the most important questions you may have about how we use your personal information.

Who is your data controller? Trend Micro is the controller of your personal information. This means that we decide what to do with your data once we have collected it (and we are responsible for keeping it safe!)

What personal information do we collect and why? The personal information we collect about you falls in to the following categories:

  • Information that you provide voluntarily (such as the information you provide when you register on our Website, when you enter the Competition and when you opt-in to receive emails from us).
  • We use this personal information to create an account for you on our Website, to see if you are eligible to enter the Competition, to assess your entry and to get in touch with you if you are selected as a finalist.
  • You have a choice regarding what emails you receive. By opting-in to emails you will have access to important updates about the Competition. You also have an option to unsubscribe from such emails by following a link to opt-out on your email.
  • Information that we collect automatically. This includes information about your computer or other device. We may also receive information about you from other websites that you or an Adult has visited.
  • Collecting this information enables us to better understand who comes to our Website, where they come from, how they use our Website and what content on our Website is of interest to them. We use this information for our internal analytics purposes, to improve the quality and relevance of our Website to our visitors, and improve our products, services and advertising.
  • Information that we obtain from other sources (for example, if you participate in the Competition as part of a school or group entry, we may receive information about you from your school or group.
  • We use this information to run the Competition.
  • We rely on certain legal justifications, known as “legal basis”, to collect and use your personal information. When you enter this Competition (or when an Adult enters on your behalf), we normally collect your personal information (and that of any relevant Adult) only where we have your consent (or an Adult’s consent) to do so.
  • Please see the “Legal Basis for Processing Personal Information” section below for further details.

Who else can see your information? We sometimes share your information with other people (“third parties“). These third parties including the following:

  • Companies and people we hire to help us operate the Competition and our Website (for example our Competition Web Developer and a platform called Mailchimp that we use to create and send emails if you sign up to receive communications from us);
  • business partners (for example the judges of the Competition);
  • law enforcement officers or others as needed to protect or defend our rights (and your rights too);
  • actual or potential buyers should there be a sale, merger or acquisition of any part of our business; and
  • any other person with your consent to the disclosure
  • We only share your information to the extent necessary. For example, if you signed up to receive communications from us, we only provide Mailchimp with your name and email address
  • Some of your information may be shared internationally. When this occurs we put protections in place. For more information, please see “International Data Transfers” below.

How do we keep your personal information secure? As a global security leader, we understand the importance of securing personal information. We have taken appropriate security measures to maintain and protect your personal information. For example, we limit the number of people that can see your information. We also review our security procedures frequently to ensure your data is always kept safe.

How long will you keep my personal information for? We keep your information for as long as we have an ongoing valid business need to do so (which may include keeping in touch with you if you are a Winner, a Runner Up, or if you get an Honourable Mention), or for as long as we need it to run the Competition; so as to communicate with you and/or to comply with legal, tax or accounting requirements.

What are my data protection rights? In certain circumstances, you have the following rights in relation to your personal information:

  1. to access, correct, or update or request deletion of it;
  2. to object to processing of your personal information (i.e. object to us using your personal information);
  3. to ask us to restrict processing of it (i.e. ask us to only process it for specific reasons);
  4. to request portability of it (i.e. to be able to give your personal information to someone else);
  5. to opt-out of marketing communications;
  6. to withdraw your consent; and
  7. to complain to a data protection authority about our collection and use of your personal information

For more information, see “Your Data Protection Rights” below. You can ask to exercise these rights by contacting us  or directly using the below details.

How to contact us? We have data protection officers that you can contact as follows:

Email: gdpr@trendmicro.com Phone: +44 203 54 93 304

Post: GDPR DPO, Trend Micro (EMEA) Limited, Lianne Harcup, Median House, IDA Business & Technology Park

Model Farm Road, Cork, Ireland.

Detailed Privacy Notice for Adults

1. What personal information do we collect and why?

The personal information that we collect about you falls into the following categories:

a) Information that you provide voluntarily

  • Registration: When you register online, we collect the following information to help log you in and identify you so that you can use this Website:
    • First name
    • Last name
    • Email address
    • Username
    • Password
    • Birth date: you need to be 8 years of age or older to register on our Website. If you are younger than 16 we will need your parent or legal guardian to decide whether to give us permission to have your personal information.
    • Parent’s/Guardian’s details: If you’re under 16, we also need your parent’s/Guardian’s full name and email address

For further details of information collected from Website visitors, please see our Website Privacy Notice.

  • Competition entries: when you enter the Competition we ask you for extra information about you:
    • If you enter as an individual we ask for your home address
    • For a school or group entry we need that address
    • Your phone number
    • When you upload your Competition entry we receive any personal information in your entry (for example video footage of you in a video entry).

We use the personal information in your Competition entry to see if you are eligible to enter, win a prize, and to get in touch with you if you are selected as a finalist

  • Emails:
    • You have a choice regarding what emails you receive.
    • By opting-in to emails from “What’s Your Story” you will have access to important updates about the Competition.
    • You also have an option to unsubscribe from such emails by following a link to opt-out on your email.

b) Information that we collect automatically

When you visit our Website, we will collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

We use cookies and similar tracking technology (collectively, “Cookies”), to collect and use personal information about you. This may also include Cookies placed by third parties in addition to Trend Micro. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice and the website section of our main Privacy Notice.

The information we collect may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Trend Micro also collects log files of traffic that visit our Website. These log files may include information such as your Internet Protocol (IP) address, browser information and language, domain name, date and time of request. We use this information to track aggregate traffic patterns throughout our websites. Trend Micro may collect and retain for a certain period IP address information of customers in order to provide technical support, obtain geo-location information, for subscription and registration purposes and to secure our networks and systems.

Collecting this information enables us to better understand who come to our Website, where they come from, how they use our Website and what content on our Website is of interest to them. We use this information for our internal analytics purposes, to improve the quality and relevance of our Website, and improve our products, services and advertising.

For more information on the technologies used and to learn how to manage cookie preferences, please see Trend Micro’s Website “Cookie Notice”.

c) Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources but only where these third parties either confirm they have your consent or that they are otherwise legally permitted or required to disclose your personal information to us.

For example, if you participate in the Competition as part of a school or group entry, we may receive information about you from your school or group.

2. Who do we share your personal information with?

Trend Micro is a global organisation. We may disclose your personal information to the following categories of recipients:

  • to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website and the Competition), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. For the purposes of administering the Competition, personal information is shared with third parties including our partners who act as judges, our Competition Web Developer and a platform called Mailchimp that we use to create and send emails (if you sign up to receive communications from us).
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
  • to a third party if we determine that such disclosure is necessary to enforce our terms and conditions or protect our products or Website visitors; and
  • to any other person with your consent to the disclosure.

3. Legal Basis for Processing Personal Information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

When you enter this Competition (on behalf of yourself or on behalf of a minor), the use of your personal information (or the relevant minor’s personal information) is on the basis of your consent. It is the responsibility of the entrant to make sure that each participant (or their parent/legal guardian) is made aware and accepts the Competition rules/terms and conditions and made aware of this Privacy Notice.

Please see our general Website Privacy Notice for further details of how we use the personal information of visitors to our Website.

If you upload a Competition entry that contains footage of anyone else or information about anyone else, please make sure that each participant (or their parent/legal guardian) is made aware of the Competition Rules and this Privacy Notice and are happy for you to agree to the Competition Rules and have their personal information used as set out in this Privacy Notice.

4. How Do We Keep Your Personal Information Secure?

As a global security leader, Trend Micro understands the importance of securing your personal information. Trend Micro has taken appropriate security measures – including administrative, technical and physical measures – to maintain and protect your personal information against loss, theft, misuse, unauthorised access, disclosure, alteration and destruction. Access to your personal information is restricted to authorised personnel only.

5. International data transfers

Trend Micro is a global organisation, with affiliated legal entities, business processes, management structures, and technical systems that cross borders. We may process your personal information outside the country in which you are located and outside of the European Economic Area. This can include data centres in the United States as well as other locations operated by Trend Micro, partners of Trend Micro or data processors engaged by Trend Micro. When we share your personal information among Trend Micro partners globally, we will do this on the basis of “Binding Corporate Rules” or standard data protection clauses. These contracts oblige the parties involved to protect your personal information in set ways.

We may also transfer your personal information to our contractors based in various countries in the world where we do business, who process personal information on behalf of Trend Micro. Some of these countries may provide less legal protection than others for personal information. However, in such cases the data transfer will be subject to appropriate safeguards, namely EU Standard Contractual Clauses available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

6. Third party sites

Trend Micro’s Website contains a number of links to websites of Trend Micro business partners or to co-branded websites that are maintained by Trend Micro and one or more of our business partners who are collecting your personal information pursuant to their own policies and purposes. You should carefully read the privacy policies on such websites or co-branded websites as they may differ from Trend Micro’s Privacy Notice, especially as personal information collected on such websites are governed by the relevant privacy policies. Trend Micro is not responsible for the content, their Products or privacy practices or misuse of any information you provide on those websites.

7. What are my data protection rights?

In certain circumstances, you have the following rights in relation to your personal information:

  • Right to rectification of personal information – you have the right to request that any inaccurate personal information held by or on behalf of Trend Micro is corrected.
  • Right to access personal information– you have the right to access their personal information held by Trend Micro. Please note that before we are able to respond to a request, we may ask you to verify your identity and to provide further details about your request. We will endeavour to respond without undue delay and, in any event, within the timescales required by law.
  • Right to data portability– you have the right to receive personal information they have provided to us or to ask us to transfer it to another company.
  • Right to erasure (or “right to be forgotten”)– you have the right to request that Trend Micro delete all of the personal information that we hold about you.
  • Right to restrict processing– you have the right to restrict Trend Micro from processing your personal information, where: (1) you believe that the personal information held by us about you is not accurate; (2) you believe that the processing of your personal information is unlawful; (3) you believe that we no longer have any reason to process your personal information; or (4) you object to the processing as described below. In these circumstances we will restrict use of your personal information during the review period.
  • Right to object to processing– you have the right to ask Trend Micro to stop processing your personal information for direct marketing purposes or other purposes on grounds relating to your particular situation.
  • Right to withdraw consent – If we are relying on your consent to use and process your personal information, you are free to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • Right to make a complaint to a Data Protection Authority – if you have a complaint or concerns about how we are processing your personal information or if you consider that the processing of your personal information by Trend Micro infringes the GDPR, then we will endeavor to address such concerns. However, if you would like to direct your complaint/concerns to a Data Protection Authority, you have such right under the GDPR.

Please note that these rights may not apply in all circumstances and exceptions exist under the GDPR or applicable national law.

If you have any questions, comments or concerns regarding this Privacy Notice or if you would like to change your communication preferences, update or review personal information we have about you or if you wish to exercise a right, please Contact Us or email us directly at gdpr@trendmicro.com.

8. How long will you keep my personal information for?

Trend Micro will keep your personal information for as long as we have an ongoing legitimate business need to do so. For example, for as long as we need it to run the Competition, to communicate with you and/or to comply with any legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store that personal information until deletion is possible.

9. How to contact us

The data controller of your personal information is Trend Micro EMEA Limited.

If you have any questions or concerns about our use of your personal information, please contact us or directly to our Data Protection Officer using the following details:

  • Email: gdpr@trendmicro.com
  • Phone: +44 203 54 93 304
  • Post: GDPR DPO, Trend Micro (EMEA) Limited, Lianne Harcup, Median House, IDA Business & Technology Park, Model Farm Road, Cork, Ireland.