TRC Global Mobility Privacy Policy, Effective September 9, 2024

TRC Global Mobility (“TRC,” “we,” “us,” or “our” in this document) recognizes the importance of protecting the privacy of our users and visitors to our site(s). We exercise due care in gathering and sharing information via our public website, www.trcglobalmobility.com, and any private portals used by our clients, their relocating employees or other authorized users. We gather information to provide contracted employee relocation and assignment management services to our clients and their relocating employees.

We also comply with the EU Data Privacy Directive on the use of employee and company data for direct marketing, as opposed to transactional purposes, without permission. It is TRC policy only to require information that is absolutely necessary to meet our contracted obligations for our clients and their employees. Confidential information is available only to those TRC employees who require it to provide services or to comply with legal requirements. All TRC employees sign confidentiality agreements before joining the company and are trained in the appropriate management of sensitive data.

The following information outlines our compliance mechanisms and practices and outlines actions available to you as a user.

EU-U.S. DPF, the UK Extension to the EU-US DPT, and the Swiss-U.S. DPF

TRC Global Mobility, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

TRC Global Mobility, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.

TRC Global Mobility, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.

To learn more about the Data Privacy Framework (DPF) program and to view TRC’s certification, please visit https://www.dataprivacyframework.gov/.

TRC is responsible for data in processes under the EU-U.S. DPF, the UK Extension to the EU-US DPT, and the Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on our behalf. We comply with the EU-U.S. DPF, the UK Extension to the EU-US DPT, and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, the United Kingdom, and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the EU-U.S. DPF, the UK Extension to the EU-US DPT, and the Swiss-U.S. DPF, TRC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, TRC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If You Have Data Privacy Concerns

If you have concerns regarding data privacy, you may file a written complaint with TRC, and we must respond to you within 45 days. You are entitled to have any concerns or complaints that TRC has not resolved to your satisfaction be reviewed by an independent professional third-party administrator, the American Arbitration Association/International Centre for Dispute Resolution. There is no cost to you.

Under certain conditions, more fully described on the EU-U.S. DPF, the UK Extension to the EU-US DPT, and the Swiss-U.S. DPF website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Information TRC Collects on our Public Site

Users can visit our public website without providing any personal information. Data captured is limited to the following:

Data provided by users who have logged on to our website and completed forms and information requests. Usage data is collected on known users for client-specific targeted content.
IP addresses and non-personal information related to that IP address, such as the referring website, date and time of visit, and the browser type and version used for those individuals browsing the public site. This information is in no way linked to any personal information. It is kept completely anonymous and used for site administration only. This includes, but is not limited to, evaluation of our own advertising methods, writing browser-specific code, etc.

Tracking Technologies

TRC and our partners use cookies to monitor website usage and administer the site. Users are notified and must affirmatively approve cookies. You are entitled to disable cookies as a user, but it might limit your use of certain features or functions on TRC’s website.

Third-Parties

TRC does not share information collected with any third party beyond the scope of employee relocation services. TRC does not sell, trade, or provide collected information to third parties for marketing purposes.

Service Partners

In delivering relocation services, we work with affiliated partners, such as household goods companies, temporary housing providers, real estate agencies, destination service providers, and other related service providers. We may share your information with third parties who provide services on our behalf. These companies are authorized to use your personal information only as necessary to provide the authorized services.

Private Website Only

Use of TRC’s private website is optional. To enable us to deliver relocation services, we receive personal information from your employer or from you on a voluntary basis. Personal information includes names, addresses, telephone numbers, email addresses and benefit eligibility instructions. Additional information may come from suppliers who assist us in providing services to you and your dependents. This information is used only for the limited purposes for which it is provided.

We may retain your information for as long as your account is active or as needed to deliver service, comply with applicable laws and regulations, resolve disputes and meet our contractual agreements to clients.

Security

We enter into agreements with suppliers to provide services to us or to make products and services available directly to you. These agreements allow them to receive information about you, but only as long as these suppliers are able to maintain applicable compliance. Additionally, these agreements state that they must safeguard this information and use it only to the extent needed to provide those services specifically authorized by your employer and for no other purposes.

TRC has implemented administrative and technical safeguards to protect your data and personal identity. This is accomplished through:

The assignment of usernames and passwords to those individuals seeking information pertinent to their relocation process.
Encryption technology used to create a secure session between your web browser and our website, so that no information can be intercepted by a third party.
TRC’s practice of not storing Social Security numbers on our Web site.
Limiting access to information to only those employees who need it to service the client or relocating employee.
Requiring supplier partners to safeguard relocating employee information and use it only to the extent needed to provide services authorized by our client.

Links to Third-Party Sites

TRC is not responsible for and cannot certify the privacy practices of any linked websites. Users should verify the applicable Privacy Policy of such websites before providing personally identifiable information via such websites.

Disclosure to Public Authorities

If required, TRC will disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements or to comply with a subpoena or other legal process.

Consent

TRC acknowledges that under GDPR, we must have a lawful basis to store and process your data and to communicate with you. Our information systems have established numerous checkpoints to ensure we have this consent.

User Options and Opt-Out (The Right to be Forgotten)

Upon request, TRC will advise you of whether we hold any of your personal information. You can ask us to amend, correct or delete any of this information, or if you are using a TRC private website, you can make these changes yourself. Be advised that if you are currently engaged in transactions with TRC, this personal information is needed to continue to provide services. You may also opt out of regular TRC newsletters or communications by contacting your Relocation Counselor, Client Services Manager, or Carrie Morales, Director of Information Technology/Data Protection Officer, at [email protected]. You may unsubscribe to our blog or other opt-in informational communications at any time.

By using this website, it is understood that you have agreed to the terms of the TRC Global Mobility Privacy Policy. You should not use this site if you do not agree with these terms.

Limitation of Liability

Under no circumstances shall TRC be held liable for any special, incidental or consequential damages which may result from the use of information or materials made available on TRC’s websites.

Changes to Privacy Policy

We reserve the right to amend the TRC Global Mobility Privacy Policy at any time. Any changes made to this Privacy Policy will be effective the date they are posted online. Your ongoing use of this site serves as your implied agreement with the revised terms. TRC’s Privacy Policy is always available for viewing at https://trcglobalmobility.com/privacy-policy.

Questions or Concerns

If you have a question or concern regarding the TRC Global Mobility Privacy Policy, please contact:

Carrie Morales

Director of Information Technology/Data Protection Officer

TRC Global Mobility World Headquarters

7270 S. 13th Street, Suite 201, Oak Creek, Wisconsin USA 53154

Phone: +1-414-226-1611