Privacy Policy

Data Controller and Jurisdiction

TRPscout Inc., a company incorporated under the laws of Hong Kong, acts as the Data Controller for the purposes of this Privacy Policy. This Policy is governed by the laws of Hong Kong Special Administrative Region (SAR).

What Is the Purpose of this Policy?

This Privacy Policy explains how TRPscout collects, uses, safeguards, and discloses personal data about you, as a result of our Services. By using our Services (explained below), you agree to the collection and use of your personal data in accordance with this policy.

What Is Personal Data?

Personal data means information about you, a natural person (also called a “data subject”), who can be identified from that data. Examples of personal data may include your name, your email address, cookies, details about your device, and data relating to your use of our Services (such as browsing actions, usage patterns, and technical data). Anonymous or anonymized data (including aggregated data) is not considered personal data under this policy.

What are Our Services?

The Services that we provide and that are covered by this policy include:

• Our website at www.trpscout.com
• Our web applications and associated webpages (collectively, “Websites”)
• Our web-based services, resources, and other online products, services, and applications

This policy describes how we handle your personal data when you interact with these Services.

What Is Our Role?

For purposes of this policy, TRPscout acts as a “data controller,” which means we determine the purposes and means of processing your personal data. We may also use service providers (“data processors”) to process your data under our instructions.

How Do We Collect Your Personal Data?

We may collect your personal data:

• Directly, when you provide it to us (e.g., through registration, forms, or communications).
• Indirectly, through automated means such as cookies, device data, and tracking technologies.
• From publicly available sources or third parties, such as business intelligence providers.

What Are Our Obligations to You?

We are committed to protecting and safeguarding your personal data with security measures that comply with applicable privacy laws. We follow principles of legality, fairness, accountability, accuracy, transparency, data minimization, and confidentiality.

Can You Choose Not To Have Your Data Collected?

Yes. You may opt out of communications at any time by clicking “manage preferences” or “unsubscribe” in our emails. You may also request that we stop collecting or processing certain data; however, this may limit your access to some Services or features.

What Types of Personal Data Do We Collect?

• Profile data: name, email, contact details, employer, business address, job title, login credentials, images, and other details you choose to share.
• Usage data: pages visited, actions taken, time/date of visits, time spent, device identifiers, searches, and frequency of use.
• Technical data: IP address, browser type/version, operating system, internet provider, mobile carrier.
• Performance data: assessments, results, or related records if you use learning or compliance modules.

If you provide data about others, you confirm that you are authorized to do so.

How Do We Use Your Personal Data?

We use personal data for purposes such as:

• Providing, maintaining, and improving our Services
• Customer support and relationship management
• Security and technical troubleshooting
• Notifications of updates or changes
• Referrals to partners with your consent
• Fulfilling contracts, billing, and compliance
• Marketing, promotions, and event participation (with your consent)
• Legal obligations and regulatory compliance

We may also create anonymized and aggregated data sets that are no longer personal data.

How Do We Use Cookies?

We use cookies and similar technologies to operate and improve our Services. Categories may include:

• Essential cookies: core functionality (e.g., secure login, session management)
• Marketing cookies: delivering relevant promotional content (with consent)
• Personalization cookies: customizing your experience (with consent)
• Analytics cookies: understanding site performance and usage (with consent)

You can manage cookie preferences via our cookie banner/tool or browser settings. Rejecting cookies may limit certain features.

Do We Store or Transfer Your Data?

Your personal data is stored on secure servers and may be processed in jurisdictions outside your own. When transferring data internationally, we ensure appropriate safeguards are in place.

How Do We Protect Your Data?

We implement physical, technical, and organizational safeguards to protect your personal data against unauthorized access, loss, or misuse. While no system is 100% secure, we strive to maintain the highest level of protection possible. You are responsible for safeguarding your account credentials.

Do We Share Your Personal Data?

We do not sell personal data. We may share data with:

• Affiliates and trusted partners (with consent or direction)
• Courts, regulators, and law enforcement where legally required
• Auditors, advisors, or consultants under confidentiality obligations
• Service providers that support our operations
• Acquirers or investors in the event of a corporate transaction

How Long Do We Keep Your Data?

We retain personal data only as long as necessary for its purpose, or longer where required by law, regulation, or for dispute resolution. Specific retention periods vary depending on the type of data.

Your Rights (GDPR & CCPA)

• GDPR: If you are located in the EU/EEA, you have rights such as access, correction, deletion, restriction, portability, and objection to processing.
• CCPA: If you are a California resident, you have rights to access, delete, and know what data we collect. We do not sell your data.

You can exercise your rights by contacting us (details below).

Links to Other Sites

Our Services may include links to third-party websites or services. We are not responsible for their privacy practices. Please review their policies before sharing your data.

Children’s Privacy

Our Services are not intended for children under 18, and we do not knowingly collect their data. If you believe we have collected such data, please contact us, and we will remove it.

Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on our website, and continued use of the Services means you accept the revised policy.

Data Breach Notification

In the event of a data breach that may impact your personal information, TRPscout will notify affected individuals and relevant authorities within 72 hours, where legally required, in accordance with applicable data protection laws.

Sub-Processors

TRPscout uses select third-party service providers (sub-processors) to support its operations. A list of approved sub-processors, including hosting and analytics providers, is available upon request or published at www.trpscout.com/subprocessors.