This Privacy Statement was last updated on November 20, 2023.
GreenTrail Solutions is committed to respecting the privacy of our clients and users. This Privacy Statement describes how our websites, services, and products operate, and how we collect, use, and share information.
This Privacy Statement applies to GreenTrail.com and GreenTrail Solutions websites, services, and products that collect data and display these terms, and that are owned and operated by GreenTrail Solutions and GreenTrail Solutions subsidiaries, collectively, “GreenTrail Solutions”. GreenTrail Solutions websites, services and products are referred to in this statement as “Sites”. These terms do not apply to GreenTrail Solutions sites that do not display or link to this statement or that have their own privacy statements.
1. Personal Information Users Actively Provide to Us
- Business Contact information (including Name, Street Address, Email Address, Telephone Number)
- Government issued IDs (such as tax identification number) provided by you for business purposes
- GreenTrail Solutions business user account username, password, and other information used in combination to verify identity
- Corporate financial information (including credit/debit card and bank account information, credit and repayment history, and payment default information)
- Geolocation, demographic, shipping/receiving, billing, and other information related to the purchase or delivery of GreenTrail Solutions products and services or services you access through the Sites
- Any other personal information or characteristics about an individual that identifies such individual alone or that, if used in combination with one of the above or with other non-personally identifiable information, allows someone to identify such individual, such as date or place of birth, geographic data, or photographic images
2. Personal Information that We Collect Passively from Use of the Site
Do Not Track Requests
3. Using and Retaining Personal Information
Personal information we collect through our Sites may be used to provide GreenTrail Solutions products and services pursuant to the terms and conditions of contracts with our business clients. The legal basis for our use of your Personal Information in that context is to service the business client’s contract and to carry out our legitimate business interests. We may also use your Personal Information to provide you as a client business representative with information regarding our products and services, or for marketing and promotions we believe you or your employer may find of interest. When we use your Personal Information in that context, the legal basis we use is legitimate business interest and, where required, your consent. We also may use the Personal Information you provide for our internal purposes, such as Site customization, enhancement or development, administration and operation of our Sites, data analytics, to help build, train, and improve the accuracy of our automated methods of processing, to communicate with you about your account, to fulfill any other purpose for which you provide it, and compliance with our legal obligations, policies and procedures, including performance of GreenTrail Solutions obligations under sales contracts, leases or licenses between you and GreenTrail Solutions. In such instances, the legal basis for processing your Personal Information is to perform under our business client contracts and to exercise our legitimate business interests.
Unless a longer retention period is required or allowed by law, we retain your Personal Information for the period disclosed to you at the time of collection, if any, or for the period necessary to fulfill any of the relevant purposes disclosed in this Privacy Statement
4. Sharing Personal Information
GreenTrail Solutions does not sell Personal Information to third parties. However, there are certain situations where we may share your Personal Information where permitted or required by law, for example:
- Within the GreenTrail Solutions family of businesses, among personnel whose job duties require access to your Personal Information. Our legal basis for sharing your Personal Information in this instance is our contract with our business client and our legitimate business interests.
- With third parties that perform services for us or on our behalf (such as credit card companies, credit and/or investigative reporting agencies, finance companies, transport companies, consultants, advisors and market research firms). Our legal basis for sharing your Personal Information in this instance is our contract with our business client and our legitimate business interests. or
- For marketing campaigns conducted by us or other companies or organizations that offer related products or services we believe may be of interest to our clients, subject to your rights and choices as described in this Privacy Statement. Our legal basis for sharing your Personal Information in this instance is your consent when required, and our legitimate business interests.
Our service providers are required to keep the Personal Information received from us confidential and secure in accordance with this Privacy Statement and they may not use it for any purpose other than the purpose for which GreenTrail Solutions provided it.
We may also make information available to third parties in the following circumstances:
- When we have a good faith belief it is required by law or to otherwise cooperate with law enforcement activity;
- When we have a good faith belief it is necessary to protect our rights or property from fraudulent, abusive, or unlawful activity; or
- In the event of a proposed or actual merger, acquisition, liquidation, dissolution, or sale of assets.
In these circumstances, the legal basis for sharing your Personal Information is our legitimate business interests. Although your consent will not be required in these instances, we will attempt to notify you, to the extent the law requires.
Depending upon local law, you may either opt-in or opt-out of having your Personal Information shared for marketing or other purposes. In the event you opt-in, we will use and share your Personal Information as described in this Privacy Statement. In the event you opt-out, we will share your preference with the applicable third parties as appropriate. For information on how to do this, see the Your Choices section of this Privacy Statement below.
5. Protecting Personal Information
We maintain reasonable administrative, technical, and physical safeguards to protect the Personal Information we collect and process. No data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you feel that the security of any data that we hold about you has been compromised, please immediately notify us of the problem by contacting us in accordance with the Contact Us section below.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Sites, you are responsible for securing and managing your login credentials.
6. Visiting Nonaffiliated GreenTrail Solutions Websites
7. Cross Border Data Transfer
The international footprint of GreenTrail Solutions involves transfers of Personal Information between different subsidiaries, as well as to third parties located in the countries where we or our service providers operate. We may process, store, and transfer the Personal Information we collect, in and to a country outside your own, including outside the United States. Those countries may not have the same data protection laws as the country in which you initially provided the information. By providing Personal Information or engaging with our Sites, you consent to this transfer, storing, or processing.
Some countries restrict certain transfers of Personal Information. GreenTrail Solutions complies with those restrictions by taking at least one or more of the following actions, including:
- GreenTrail Solutions Inc. and its wholly-owned U.S. subsidiaries that receive Personal Information from countries outside of the United States adhere to applicable law and regulations regarding client, partner and employee Personal Information moving across geographical and jurisdictional borders.
- Where required or permitted, GreenTrail Solutions implements Standard Contractual Clauses approved by the EU Commission, or similar clauses in other jurisdictions, where available, between our corporate entities, our partners, and our clients.
- Where applicable, GreenTrail Solutions relies on adequacy decisions, as adopted by the applicable authority or regulatory body. In particular, information about the Data Privacy Framework (DPF) and GreenTrail Solutions commitment to comply with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF may be found in the Data Privacy Framework (DPF) Notice section below.
Additional information may be found under the sections below concerning Country-Specific and State-Specific Notices for the geographies in which you are located.
8. Data Privacy Framework (DPF) Notice
GreenTrail Solutions has self-certified its commitment to comply with the EU-US Data Privacy Framework, the UK Extension to the EU-US DPF (the UK Data Bridge), and the Swiss-U.S. DPF as set forth by the United States Department of Commerce regarding the collection, use, processing, and retention of Personal Information transferred from the European Union, Switzerland, and the United Kingdom (and Gibraltar) to the United States.
GreenTrail Solutions has self-certified its commitment to comply with the EU-U.S. DPF Principles and relies on the European Commission’s July 10, 2023 adequacy decision for the EU-U.S. DPF for such transfers.
GreenTrail Solutions has self-certified its commitment to comply with the UK Data Bridge and the Swiss-U.S. DPF and will not rely on the UK Data Bridge or the Swiss-U.S. DPF to receive Personal Information from the United Kingdom (and Gibraltar) or Switzerland, respectively, until the United Kingdom’s anticipated adequacy regulations implementing the data bridge for the UK Data Bridge enter into force, or the Swiss Federal Administration’s anticipated recognition of adequacy for the Swiss-U.S. DPF enter into force. Until the respective adequacy decisions enter into force, respectively, GreenTrail Solutions will rely on other recognized transfer mechanisms from such jurisdictions for such cross-border transfers, including model contractual clauses or other measures described above in the Cross Border Data Transfer section of this Privacy Statement.
We have certified to the United States Department of Commerce that we adhere to the DPF Principles with respect to Personal Information. If there is any conflict between the terms in this Privacy Statement and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view our certification page, please visit https://www.dataprivacyframework.gov and search for “GreenTrail Solutions”.
GreenTrail Solutions is responsible for the processing of Personal Information it receives, under the DPF, and subsequently transfers to a third party acting as an agent on its behalf. GreenTrail Solutions complies with the DPF Principles for all onward transfers of Personal Information, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the DPF, GreenTrail Solutions is subject to the regulatory enforcement powers of the United States Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. DPF, the UK Data Bridge, and the Swiss-U.S. Privacy Shield DPF, GreenTrail Solutions commits to resolve complaints about your privacy and our collection or use of your Personal Information. If you believe GreenTrail Solutions processes your Personal Information beyond the scope of our DPF certification, you may direct any inquiries or complaints concerning our compliance to us at the information in the Contact Us section below.
GreenTrail Solutions will respond in a manner consistent with the DPF or applicable law. If you have an unresolved privacy or data use concerns that we have not addressed satisfactorily, please contact JAMS, our U.S-based third-party dispute resolution provider, free of charge at https://www.jamsadr.com/eu-us-data-privacy-framework.
If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you may be able to invoke binding arbitration when other dispute resolution procedures have been exhausted. Please contact or visit the DPF Program website at https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf for more information or to file a complaint. The services of the DPF Program website are provided at no cost to you.
9. Your Choices
If you are a GreenTrail Solutions customer, you may receive transactional communications about your account and the GreenTrail Solutions products and services, which you own, lease, rent, license or to which you subscribe.
In some jurisdictions, you may have to opt-in to receive marketing communications. In the event you opt-in, we will use and share your Personal Information as described in this Privacy Statement. If you wish to opt-out of receiving marketing communications from GreenTrail Solutions, you may do so by
(i) following the instructions provided in our marketing communications, or
(ii) indicating your preferences on the relevant account profile/preferences section (such as Your Account. In the event you opt-out, we will share your preference with applicable third parties as appropriate. You will continue to receive transactional communications about your account, any events that you have registered to attend, and the GreenTrail Solutions products and services which you own, lease, rent, and license or to which you subscribe.
Some of our products and services contain settings that allow users or administrators to control how the products collect information. If you wish to request changes to your Personal Information, you may do so by
(i) indicating your preferences on the relevant account profile/preferences section (such as Your Account), or
(ii) clicking here to update the physical location of a product or billing address. Please note, by electing to not share certain Personal Information with us, we may be unable to provide you with all of the functionality we offer through our Sites.
10. Your Rights
Subject to applicable exceptions, you may have the right under applicable privacy and data protection laws to request, as it relates to your Personal Information:
(iv) restriction of our processing,
(v) objection to our processing, or
(vi) a copy for data portability.
If you would like to make a request, please use the contact information listed below in the Contact Us section of this Privacy Statement. We will respond to your request in a timing and manner consistent with applicable law. We may need to verify your identity before we can act on your request. In some jurisdictions, you can designate an authorized agent to make a request on your behalf. Please provide the agent with written permission, signed by you, for the agent to submit with the request. We may contact you to verify your identity and the authorized agent’s permission before we can act on your request.
Please note that we may reject or decline requests, or limit the information we provide access to, if we determine it could risk the privacy of others, or if unreasonable or repetitive, or if it would require disproportionate effort, or for which a response is not otherwise required by local law.
As permitted by law, we may charge a reasonable fee in connection with responding in certain circumstances (such as if your request is frivolous/vexatious, repetitive, or excessive), but we do not charge for lodging a request.
Please understand that we cannot delete Personal Information in certain circumstances, such as where retention is required for our legitimate business or recordkeeping purposes, to fulfill a transaction you initiated prior to your request, or otherwise required by law (such as for fraud prevention or legal compliance). Please note that we will not unlawfully discriminate against you for exercising your privacy rights.
11. State-Specific Notices (U.S.A.)
This section applies only to individuals who reside in the state of California.
Notice at Collection
We collect the categories of Personal Information for the purposes and retention described in this Privacy Statement. Additional information about your rights and other notice is provided in this section below.
Additional Disclosures Under the California Consumer Privacy Act (“CCPA”) As Amended by the California Privacy Rights Act (“CPRA”)
The following chart includes:
(1) the categories of Personal Information, as defined under California law, that we plan to collect and have collected and disclosed within the preceding 12 months; and
(2) the categories of third parties to which we disclosed Personal Information for our operational business purposes within the preceding 12 months.
Categories of Personal Information
Identifiers, such as name, contact information, online identifiers, IP address, account identifier, or email address.
Personal information, as defined in the California customer records law, such as name, contact information, insurance
policy number, education, employment, employment history, financial information, medical information and health insurance information.
Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status.
Commercial information, such as transaction information, purchase history and financial details.
Internet or network activity information, such as browsing history, online behavior, and interactions with our and other websites, applications and systems.
Geolocation data, such as device location, your physical location, and IP location.
Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities.
Professional or employment-related information, such as employer.
Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Your Rights as a California Resident
Right to Disclosure of Information: You have the right to request that we disclose certain information regarding our practices with respect to Personal Information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:
- The categories of Personal Information we have collected about you in the last 12 months.
- The categories of sources for the Personal Information we have collected about you in the last 12 months.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information to a third party for a business purpose, a list of the Personal Information types that each category of recipient received.
Right to Delete Personal Information: You have the right to request that we delete your Personal Information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law.
Right to Correct Your Personal Information: If you find that we maintain inaccurate Personal Information, you have the right to request that we correct such inaccuracy. You may also be able to update or make corrections through your account.
Right to Limit Use of Sensitive Personal Information: You have the right to instruct us to limit our use of your Sensitive Personal Information to that which is necessary to provide the Services. You may do so by contacting us as detailed below.
Right to Opt Out of the Sale or Sharing of Your Personal Information: You have a right to opt-out of the sale or sharing of your Personal Information. You may, at any time, direct businesses that sell your Personal Information to third parties not to sell or share your Personal Information. You may do so by contacting us as detailed below.
Right to Non-Discrimination: You have the right not to be discriminated against for the exercise of your California privacy rights described above.
Your Rights Under California’s Shine the Light Act
California residents are legally entitled (at no charge and no more than once per year) to request information about how we may have shared your information with others for their direct marketing purposes. To make such a request, please refer to the instructions provided in the Contact Us section below.
How to Exercise These Rights
If you wish to submit a request to exercise one or more of the rights listed above or if you questions or concerns with respect to our Privacy Statement, please contact us using the information provided in the Contact Us. Please include your question or concerns in your letter to us, including the GreenTrail Solutions brands, Sites, products, and services relevant to your question or concern.
We will respond to verifiable requests for disclosure or deletion of Personal Information free of charge, within 45 days of receipt. We may extend the period where reasonably necessary, taking into account the complexity and number of requests, and will inform you of the extension.
To protect your privacy and the security of your information, we verify such requests by requesting identification documents and other documentation necessary to confirm your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent. In addition, we may require the individual on whose behalf you are making the request to verify their own identity or your permission to submit the request.
Additional Information About Disclosure of Personal Information of California Residents
GreenTrail Solutions does not sell your Personal Information to third parties. However, there are certain situations where we may share your Personal Information where permitted by law, for example:
- Within the GreenTrail Solutions family of businesses,
- With third parties that perform services for us or on our behalf (such as credit card companies, credit and/or investigative reporting agencies, finance companies, transport companies, consultants, advisors and market research firms), or
- For marketing campaigns conducted by us or other companies or organizations that offer GreenTrail Solutions-related products or services we believe may be of interest to our clients.
Our service providers are required to keep the Personal Information received from us confidential and secure in accordance with this Privacy Statement and they may not use it for any purpose other than the purpose for which GreenTrail Solutions provided it.
As outlined in the Your Rights section you have the right to know more about the Personal Information we have about you. To obtain this information, please refer to the instructions provided in the Your Rights section.
If you wish to opt-out of receiving marketing communications from GreenTrail Solutions or make changes to your Personal Information, please refer to the instructions provided in the Your Choices and Contact Us sections.
12. Product-Specific Statements
GreenTrail Solutions offers a wide range of products and services. In some instances, additional data collection practices and privacy statements may apply to specific GreenTrail Solutions products. Those privacy statements are provided within the product and may be found below. In case of contradictions between the general Privacy Statement of GreenTrail Solutions and the information in a product-specific statement, the information in the product-specific statement will take precedence.
13. Use of Sites by Minors
GreenTrail Solutions does not direct its Sites to minors and we do not knowingly collect Personal Information from minors. If we become aware of such processing, we will take steps to stop it and to delete such Personal Information. If you believe we mistakenly or unintentionally collected any information from a child, please notify us by using the contact information listed below in the Contact Us section of this Privacy Statement.
14. Changes to this Privacy Statement
GreenTrail Solutions may change this Privacy Statement from time to time and at its discretion. We will indicate at the top of the Privacy Statement when it was most recently updated. We will not use your Personal Information in ways that differ materially from this Privacy Statement without prior notice to you. You are responsible for ensuring we have a current and deliverable email address for you. Please check back periodically to see any updates or changes to our Privacy Statement. Your continued use of our Sites indicates your consent to this Privacy Statement and any amended version of it.
15. Contact Us About this Privacy Statement
If you have any questions or comments about this Privacy Statement, please contact us at:
Data Protection Office
c/o GreenTrail Solutions Inc.
645 N 12th St, STE 302
Lemoyne, PA 17043
Email us @ email@example.com