Skycrafters Privacy Notice

 

Effective Date:  April 1, 2021

 

Skycrafters takes your privacy & security seriously and we want you to know how the information you supply will be used.  This Privacy Notice will help you understand the types of personal information that you provide to Skycrafters, what we do with that information and how we protect that information. We are committed to protecting your privacy and ensuring you have a positive experience on Skycrafters.  “Skycrafters” shall also refer to Trend Micro Incorporated (including its subsidiaries and affiliates), who is the sponsor of the Skycrafters community.

 

Skycrafters may update this Privacy Notice from time to time. When we make changes to the Privacy Notice, we will revise the date at the top of the Privacy Notice. If there are material changes to this Privacy Notice or in how we will use your Personal Information or where we intend to further process your Personal Information for a purpose other than that for which the Personal Information were collected, we will notify either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.

 

What information does Skycrafters collect?

 

"Personal Information" is any information about one of our Members which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as a username and password, an email address, a real name, an Internet protocol (IP) address, and a photograph are examples of “Member Personal Information.”

 

Personal Information does not include aggregated, non-personally identifying information that does not identify a Member or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, non-personally identifying information for research purposes and to operate, analyze, improve, and optimize the Skycrafters website.

 

 

Information You Provide to Skycrafters:

 

Registration Information

In order to leave comments on articles or participate in conversations in the forums, you will need to register for a free account. When you create your account, we will ask you for your email address, full name, username and password.

 

Profile Information

Once your account is created, you may add more information to your profile, such as a profile image which may include a photograph, your biography, your location, and your date of birth. Please note that your profile information may be visible to other Members of Skycrafters if you choose to share it with other Members.

 

Information Skycrafters automatically collects from your use of Skycrafters

 

Skycrafters’ email messages may use technologies such as web beacons to collect certain information automatically from individuals' devices. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

The information we collect automatically may include information like individuals' IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.

To the extent that IP addresses or similar identifiers are considered personal information by applicable data protection law, we treat these identifiers as personal information. Similarly, to the extent that nonpersonal information is combined with personal information, we treat the combined information as personal information for the purposes of our Privacy Notice.

 

How does Skycrafters use your information?

 

We may use the information described above for the following business purposes:

·      We use your registration information to create your account, and to provide you access to Skycrafters.

 

·      We use your Personal Information to identify you on Skycrafters.

 

·      We use your Profile Information to fill out your Member Account profile and to share that profile with other users if you ask us to.

 

·      We use your email address to communicate with you, only if you give us permission, and only for the reasons you have given us permission.

 

·      We use your Personal Information to respond to support requests.

 

·      We use your Personal Information and other data to make recommendations for you, such as to suggest articles or conversations you may want to follow or contribute to.

 

·      We may use your Personal Information to invite you to take part in surveys, beta programs, or other research projects, subject, where necessary, to your consent. 

 

·      We may use your Personal Information if it is necessary for security purposes or to investigate possible fraud or attempts to harm Skycrafters or our Members.

 

·      We may use your Personal Information to comply with our legal obligations, protect our intellectual property, and enforce our Terms of Service.

 

·      We limit our use of your Personal Information to the purposes listed in this Privacy Statement. If we need to use your Personal Information for other purposes, we will ask your permission first. You can always see what information we have, how we're using it, and what permissions you have given us in your user profile.

 

Our legal bases for processing Personal Information (EEA Only)

 

If you are a visitor located in the European Economic Area ("EEA"), Trend Micro EMEA Limited is the data controller of your Personal Information.

Skycrafters processes Personal Information on the following legal bases:

Contract Performance:

When you create a Skycrafters Member Account, you provide your Registration Information. We require this information for you to enter into the Terms of Service agreement with us, and we process that information on the basis of performing that contract. We also process your username and email address on other legal bases, as described below.

Consent:

We rely on your consent to use your Personal Information under the following circumstances: when you fill out the information in your user profile; when you create a support request. All of this Personal Information is entirely optional, and you have the ability to access, modify, and delete it at any time. While you are not able to delete your email address entirely, you can make it private. You may withdraw your consent at any time.

Legitimate Interests:

Generally, the remainder of the processing of Personal Information we perform is necessary for the purposes of our legitimate interest, for example, for legal compliance purposes, security purposes, or to maintain ongoing confidentiality, integrity, availability, and resilience of Skycrafters’ website.

If you would like to request deletion of data we process on the basis of consent or if you object to our processing of personal information, please see our Individual Rights page.

 

How we Share Information we Collect

Trend Micro is a global organization and may share personal information with its affiliated companies.

Service Providers

We work with service providers that work on our behalf which may need access to certain personal information in order to provide their services to us. These companies include those we've hired to operate the technical infrastructure that we need to provide the Skycrafters community platform.  These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such service providers, we explicitly require these service providers to acknowledge and adhere to our privacy and data protection policies and standards.

Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

 

How We Transfer Data We Collect Internationally (EEA Only)

Trend Micro is a global organization, with affiliated legal entities, business processes, management structures, and technical systems that cross borders. We may process Members’ Personal Information outside the country in which Members are located, including at data centers in the United States as well as other locations operated by Trend Micro, affiliates of Trend Micro or data processors engaged by Trend Micro for the Skycrafters community. When we share Members’ personal information among Trend Micro affiliates globally, we will do this on the basis of Binding Corporate Rules or standard data protection clauses.

We may also transfer Members’ Personal Information to our contractors based in various countries in the world where we do business, who carry out data processing on behalf of Trend Micro. Some of these countries may provide less legal protection than others for Members’ 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-outsideeu/model-contracts-transfer-personal-data-third-countries_en.

 

Data Retention

We will keep Members’ Personal Information for as long as we have an ongoing legitimate business need to do so (for example, to provide a service a Member has requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process Members’ Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because Members’ Personal Information has been stored in backup archives), then we will securely store that Personal Information until deletion is possible.

 

Protection and Security of Personal Information

We understand the importance of securing Personal Information. Skycrafters has taken appropriate security measures – including administrative, technical and physical measures - to maintain and protect Members’ personal information against loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. Access to Members’ Personal Information is restricted to authorized personnel only.

 

Managing Your Personal Information

If you participate in a Skycrafters discussion forum, you should be aware that the information you provide will be made broadly available to others, and can be read (or watched), collected or used by other users of these forums, inside or outside of Skycrafters. Members are responsible for the personal information Members choose to submit in these instances. For example, if a Member lists their name and email address in a forum posting, that information is public. Members should be careful and responsible when participating in any forum or discussion group on Skycrafters. Each Member’s opinion on a forum is his or her own and should not be considered as reflecting the opinion of Skycrafters. Skycrafters is not responsible for the personal information or any other information Members choose to submit in these forums. Members are responsible for keeping his or her Member Account password secure and confidential.

 

How to Unsubscribe From Email Communications

Depending on your email settings, Skycrafters may send you notification emails about popular topics or when another member replies to your posts, mentions your username, or invites you to a topic. You can manage your email communications from the preferences tab on your Skycrafters account page.

 

EEA data protection rights (EEA only)

Members located in the EEA have certain data protection rights under the General Data Protection Regulation of the European Union of 27 April 2016 (“GDPR”). These are briefly explained below.  If Members wish to contact us in relation to those rights, please see the contact information at section 1.L below. We will endeavor to assist Members where reasonably possible but please note that these rights may not apply in all circumstances and exceptions exist under the GDPR or applicable national law.

·       Right to restrict processing– Members have the right to restrict Skycrafters from processing their Personal Information, where: (1) they believe that the Personal Information held by us about them is not accurate; (2) they believe that the processing of their Personal Information is unlawful; (3) they believe that we no longer have any reason to process their Personal Information; or (4) they object to the processing as described below. In these circumstances we will restrict use of these Members’ Personal Information during the review period.

·      Right to object to processing– Members have the right to ask Skycrafters to stop processing their Personal Information for direct marketing purposes or other purposes on grounds relating to their particular situation.

·       Right to make a complaint to a Data Protection Authority - If Members have a complaint or concerns about how we are processing their Personal Information or if they consider that the processing of their Personal Information by Skycrafters infringes the GDPR, then we will endeavor to address such concerns. However, if they would like to direct their complaint/concerns to a Data Protection Authority, they have such right under the GDPR.

 

Contact and Data Protection Officer

If you are based outside the EEA, and have any questions, requests, comments or

concerns regarding this Privacy Notice, you can contact us using the details below:

 

Trend Micro Privacy Program

Trend Micro Incorporated

c/o Legal Department

225 East John Carpenter Freeway

Suite 1500

Irving, Texas 75062

USA

E-Mail: [email protected]

 

If you are based inside the EEA, the contact details of the data protection officers

designated by Trend Micro are:

 

GDPR DPO:

Trend Micro (EMEA) Limited

Lianne Harcup

Median House

IDA Business & Technology Park

Model Farm Road

Cork, Ireland

Telephone: +44 203 54 93 304

E-Mail: [email protected]

 

California Privacy Rights

 

California Consumer Privacy Act Disclosures: These California Consumer Privacy Act Disclosures (“CCPA Disclosures”) supplements our Privacy Notice only for consumers of California (“you” or “your”) and summarizes our practices to align with the California Consumer Privacy Act of 2018 (“CCPA”). Skycrafters does not sell your personal information. If you are not a California consumer, these CCPA Disclosures do not apply to you.

See Trend Micro’s CCPA Disclosures. For any questions regarding the CCPA Disclosures, please email [email protected].