Privacy Policy

Effective Date: May 25, 2018
Last Update: May 25, 2018

Table of Contents

  1. What Personal Data Do We Process and Their Sources
  2. Purposes and Legal Bases of Processing Your Personal Data
  3. With Whom Do We Share Your Personal Data
  4. International Transfer of Personal Data
  5. How Long We Keep Your Personal Data
  6. Security
  7. Your Rights With Respect to Your Personal Data
  8. Contact
  9. Glossary
  10. Amendments

This Web site is operated by Trojan Battery Company, registered at 12380 Clark Street, Santa Fe Springs, CA 90670, USA (“Trojan,” “we,” “our” or “us”), in its capacity of a controller. This Privacy Policy only applies with respect to information Trojan Battery Company collects from Web sites on which a direct hyperlink to this Privacy Policy is posted.

This Privacy Policy describes the way we handle your personal data learned about you from your visit to our Web sites. Some of our subsidiaries also operate public Web sites, and in this Privacy Policy, any references to “website” or “websites” generally means the Trojan Battery Company homepage and the websites of our subsidiaries linked through the Trojan Battery Company website. Other third-party Web sites (including those we link to from time to time) not owned or operated by or for us have different data processing practices for which we do not vouch or assume responsibility. Please refer to the privacy policies of those Web sites for information about providing your personal data on those Web sites.

In particular circumstances indicated below, Trojan is not solely but jointly responsible with other Trojan companies, in particular its subsidiaries (“Trojan Group”), for the lawfulness of the processing of your personal data.

1 WHAT PERSONAL DATA DO WE PROCESS AND THEIR SOURCES

The categories of personal data that the Trojan processes about you for the purposes described in Section 2 below are:

1.1 Personal Data Collected Directly from You

We collect personal data about you that you voluntarily submit to us, such as filling out a form on our Web site or survey or emailing us. We also collect personal data from you at other points on our Web sites that state that such personal data is being collected.

This information includes:

Personal Details, such as name, contact details including address, telephone number, e-mail address;

Professional information, such as company (i.e., employer/in case of one-man company your company information) information including name, address, and telephone number;

Web site visitor Background and Preferences, such as general product and product purchase information, product usage information and your interest in our products;

General enquiries and our responses.

1.2 Personal Data the Trojan Group collects

Trojan collects personal data from other Trojan Group companies. For example, Trojan collects information regarding general enquiries made vis-à-vis other Trojan Group companies but which are appropriate to be handled by Trojan. In this circumstance, the two Trojan Group companies involved act as joint controllers. Additionally, as discussed in Section 3 and 4 below, Trojan and other Trojan Group entities share personal data among themselves, for the purposes defined in Section 2 below.

1.3 Information Collected Automatically

We collect statistical information about you, such as the pages visited on the Trojan Battery Web sites, unique URLs visited within our Web sites and IP address. Generally, we do not link such information to any of your contact information (such as name, email address or user name). Most of this information is collected via cookies or other analysis technologies. For information about cookies and other tracking technologies used on this Web site, please see our Cookie Policy.

1.4 From Third Parties

Finally, Trojan receives some of the categories of personal data listed above from third parties who provide services to Trojan, in particular providers of marketing services, cookie and other tracking technologies related services and providers of hosting services. In this respect Trojan receives the following categories of personal data set out in Section 1.1.

1.5 Children Personal Data

We do not knowingly collect personal data from children under 16 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use this website, and do not provide any personal data to us.

2 PURPOSES AND LEGAL BASES OF PROCESSING YOUR PERSONAL DATA

We process personal data for the purposes set out below. For each purpose, the legal basis of the processing is specified, in accordance with Articles 6 and 9 of the General Data Protection Regulation, as the case may be. Where applicable, we will point out, at the time of the data collection, if the provision of the personal data is a statutory or contractual requirement and whether you are obliged to provide the personal data and the possible consequences of failure to provide such data.

Trojan processes personal data for the following purposes:

2.1 Marketing and Advertising

This includes processing personal data to: advertise our products and services to you, including by sending you newsletters or other direct marketing communications by e-mail and by phone.
Legal Bases: This processing is justified based on:

  • Your consent.

2.2 Sales
This includes processing personal data to: communicate with you regarding your purchases of our products and related services we offer.
Legal Bases: This processing is justified based on:

  • The necessity to perform a contract to which you are a party;
  • Our legitimate interests as specified above.

2.3 General Inquiries and Communication with You

This includes processing personal data to: process and respond to consumer inquiries, in particular through Web site-based forms.
Legal Bases: This processing is justified based on:

  • The necessity to perform a contract to which you are a party;
  • Our legitimate interests as specified above.
  • Your consent

2.4 Network and Information Security, Technical Support and Web site Administration

This includes processing personal data to: ensure network and information security, continuity of the Web site administration and to provide technical support within the Trojan Group.
Legal Bases: This processing is justified based on:

  • The necessity to comply with legal obligations in the EU or an EU Member State;
  • Our legitimate interests as specified above.

2.5 Statistical Data

This includes processing personal data to: gather website usage statistics about behavior on our site.
Legal Bases: This processing is justified based on:

  • Your Consent

3 WITH WHOM DO WE SHARE YOUR PERSONAL DATA

Unless we tell you otherwise, or unless otherwise stated in this Privacy Policy or required by law, we do not sell or rent your personal data to any third parties. However, we share your personal data and aggregated (non-personally identifiable) information as outlined below.

3.1 Intra-Group

We share your personal data with other Trojan Group companies, for all the purposes specified in Section 2 above. A list of Trojan Group companies is available at https://www.trojanbattery.com/contact-us/.

3.2 Third Parties

We share your personal data with our customers as well as our service providers who perform services on our behalf for the purposes described in Section 2 of this Privacy Policy. In particular, we share personal data with providers of marketing services, cookie and other tracking technologies related services, hosting services, and IT support. The service providers are bound by law and/or contract to protect the confidentiality and security of personal data, and to only use personal data to provide requested services to the Trojan in accordance with applicable law.

We share your personal data with other companies, vendors and business partners which perform certain functions for us, whereby these companies are themselves responsible to determine the purposes and/or means of the processing and for the lawfulness of the processing, in particular: marketing and prospecting companies.

We disclose personal data to buyers, lawyers or professional advisors, courts, tribunals, opposing or other related parties to the proceedings and their professional advisors, where needed to affect the sale or transfer of business assets, to defend or enforce our rights, protect our property, assets or safety of others. We will also disclose personal data when required to do so by law, such as in response to a subpoena, in order to investigate, prevent, or take action regarding illegal activities and suspected fraud to law enforcement agencies, tribunals and courts in countries where Trojan operates.

4 INTERNATIONAL TRANSFER OF PERSONAL DATA

Given that Trojan Group companies are located and provide services all over the world, we need to transfer your personal data internationally. In particular, personal data collected by us are transferred to and processed in countries outside the EEA. Those countries may not have the same level of protection for personal data as in the EEA. Please write to EUPrivacy@trojanbattery.com if you want to receive further information or, where available, a copy of the relevant data transfer mechanism.

4.1 Intra-Group

We share your data within the Trojan Group, including the entities that are located in the United States of America and other third countries outside the EEA, where they have offices. The transfer of your personal data outside the EEA takes place on the basis of our Global Intra-Group Data Transfer and Processing Agreement, which is based on the European Commission’s standard contractual clauses for data transfers, and in accordance with applicable data protection laws.

4.2 Third Parties

Some of the third parties with whom we share personal data are also located outside the EEA. Certain third countries have been officially recognized by the European Commission as providing an adequate level of protection (see here). Transfers to third parties located in other third countries outside the EEA take place using an acceptable data transfer mechanism, such as the EU-US Privacy Shield framework for transfers to self-certified US organizations (see here), the European Commission’s standard contractual clauses for data transfers (see here), Binding Corporate Rules (see here), approved Codes of Conduct and certifications, or in exceptional circumstances on the basis of permissible statutory exceptions.

5 HOW LONG WE KEEP YOUR PERSONAL DATA

We keep your personal data that we obtain about you through this website for no longer than is reasonably necessary for the purpose(s) for which they were collected. In certain cases, personal data may be kept for an extended period of time in order to comply with legal obligations, or for the establishment, exercise or defence of a legal claim, in accordance with the applicable data protection laws.

If you have further questions regarding our retention of your personal data, you can contact us (see Section 8 below).

6 SECURITY

There is no such as “perfect security” on the Internet. E-mails you send us are not necessarily secure when they are transmitted to us. If your communication is sensitive or includes highly confidential information, you may want to provide it by post or via the telephone instead. We restrict the number of employees internally who can access such data and instruct such employees that the data is to be used only in adherence with the principles set forth in this Privacy Policy and our internal policies.

7 YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

The below rights apply to you only if you are visiting our website from the EU or EEA, or where applicable EU or EEA data protection laws so provide.

In instances where Trojan entities act as joint controllers, you can exercise these rights in respect of and against each of them. Trojan entities which act as joint controllers have entered into an arrangement, reflecting their respective roles and relationships. Please see Section 8 if you would like to contact us to know more about this contractual arrangement.

Under the conditions set by applicable data protection laws, you may exercise the following rights:

Access
You have the right to obtain from us confirmation if your personal data are being processed, relevant information about such processing as provided by applicable EU or EEA data protection laws, and a copy of the personal data undergoing processing.

Rectification

You have the right to obtain from us the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.

Objection

You have the right to object to the processing of your personal data on grounds relating to your particular situation.

You can also object at any time to the processing of your personal data for marketing purposes. (Please note that even if you object to your use of personal data for direct marketing purposes, we can still send you transactional messages in relation to services that you have purchased from us. These include responses to your questions and information about a service you have purchased from us.)

Portability

You have the right to receive the personal data concerning you which you have provided to the controller in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller.

Restriction

You may request to restrict processing of your personal data.

Erasure

You may request to erase (delete) your personal data.

Right to lodge a complaint

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State or EEA country of your residence, place of employment, or the location where the issue that is the subject of the complaint occurred.

Right to refuse or withdraw consent

You are free to refuse to give consent and you can withdraw (with effect for the future) your previously provided consent to the processing at any time without any adverse negative consequences. The lawfulness of any processing of your personal data that occurred prior to the withdrawal of your consent will not be affected.

If you wish to exercise any of your rights under this section, please contact us at EUPrivacy@trojanbattery.com.

8 CONTACT

If you have any questions, comments, or requests regarding privacy, please direct your request at:

Address: Trojan Battery Company
12380 Clark Street
Santa Fe Springs
CA 90670
USA

or

Trojan Battery Ireland Ltd.
Temple Chambers
3 Burlington Road
Dublin 4
Ireland

E-mail address: EUPrivacy@trojanbattery.com

9 GLOSSARY

The following terms are used within this Privacy Policy and are defined here for clarification:

“Controller” means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by EU Member State’s national or EU laws or regulations, the controller or the specific criteria for his nomination may be designated by EU Member State’s national or EU law;

“Data subject” means an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;

“EEA” means the European Economic Area and comprises besides the EU Member States, Norway, Iceland and Liechtenstein;

“Personal data” means any information relating to a data subject;

“Processing” means any operation or set of operations performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;

“Processor” means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.

“Supervisory authority” means the independent public authorities which are responsible for monitoring the application of the applicable data protection laws in the EEA.

10 AMENDMENTS

Trojan Battery Company may amend this Privacy Policy from time to time but we will not reduce your rights.