Trend Micro Incorporated is a global cybersecurity leader whose mission is to help make the world a safer place
to exchange digital information.
Trend Micro Incorporated, its subsidiaries and affiliates (collectively, “Trend Micro” or “we”) provide this Privacy
Notice to help you understand: 1) the types of personal information that you provide to Trend Micro whether as
users of our websites, including support portals and any applications or sites that link to this Privacy Notice
(“Websites”) or users of our products and services (“Products”); 2) what we do with that information; 3) how we
maintain that information; and 4) how we protect that information.
This Privacy Notice does not apply to situations where we act as a “processor” or “service provider” in relation
to the data our customers submit, manage, use, or process through or as part of our Products (“Customer Data”).
For additional information about our data processing activities in our role as a processor or service provider,
please visit our Trust Center; https://www.trendmicro.com/en_us/about/trust-center.html which contains
details of all our privacy information including but not limited to our data privacy addendum; privacy certifications
and data collection notices. When acting as data controllers, our customers are responsible for making their own
disclosures concerning the rights of individuals (e.g., “data subjects” under the GDPR) with respect to personal
information and other information regarding data collection and use, in accordance with applicable law.
Should you have any questions or concerns regarding how we use, collect, maintain or protect your personal
information, then please contact us using the contact details as provided at the bottom of this Privacy Notice. If
you are a job applicant, please refer to our Recruitment Privacy Notices:
https://www.trendmicro.com/en_us/about/trust-center/privacy.html.
For California residents, our California Consumer Privacy Act Disclosures; for residents of the European Economic
Area, Switzerland, and the United Kingdom (“EEA+”), and/or persons located in the Rest of the World where
there are additional and/or differing laws, rights and requirements relating to personal information please see
our Supplemental Notices: https://www.trendmicro.com/en_us/about/trust-center/privacy/notice.html.
Trend Micro’s Websites and Products are not directed at children and so excepting the Trend Micro Internet Safety
for Kids initiatives as detailed below, for which Trend Micro requires parental consent, Trend Micro does not
knowingly process personal information from individuals under the age of 16; are considered minors or children,
or considered under the age of consent; dependent upon the applicable laws in the differing regions to which
Trend Micro operates (“Minors”).
This Privacy Notice is structured as follows:
- What is Personal Information and What Personal Information Does Trend Micro collect?
- Legal Basis of Processing
- Sharing personal information
- International Data Transfers
- Data Retention
- Protection and security of personal information
- Communication preferences
- Individual data protection rights
- Changes to this Trend Micro Privacy Notice
- Contact us
2 - WHAT IS PERSONAL INFORMATION AND WHAT PERSONAL INFORMATION DOES TREND MICRO
COLLECT?
When used within this Privacy Notice, “personal information” means: information that identifies an individual;
relates to that individual, describes that individual or could be linked either directly or indirectly to an individual,
or is reasonably capable of being associated with an individual.
Dependent on where you are located there may be personal data laws that define personal information
differently and any differing interpretation as to those laws will be found in the relevant Supplemental Notice
found here: https://www.trendmicro.com/en_us/about/trust-center/privacy/notice.html
At times Trend Micro may collect personal information either directly as provided by you or automatically from
you when you interact with our Websites and Products both as more fully described below:
1.1 Website Visitors
A. What information is processed by Trend Micro when using our Website(s) and how is it used by Trend
Micro?
Information that is actively provided
Trend Micro collects personal information in many ways: when visitors download free evaluation software or
upgrades; when visitors register online; when visitors contact Trend Micro through our “Contact Us” link on our
Website; when visitors participate in a campaign or a website forum or referral promotions; when individuals
register for or otherwise participate in a competition; when visitors request online a quote or technical support;
when visitors cause information or data to be sent to Trend Micro as part of the Products; when visitors subscribe
online to Trend Micro newsletters or receive Product updates or technical online alerts; when visitors enter an
online contest, giveaway, promotion or special offer; when visitors provide us with feedback online; or when
visitors apply for a job online with Trend Micro.
Where visitors visit our Websites and wish to download content, take part in a competition, purchase product or
request information, visitors may be requested to provide details as follows:
- Name
- Phone number
- Email address
- Postal address
- Company name
- Billing and shipping information
- Other relevant information about visitors and visitors’ systems and visitors’ company
- Date of birth (only for certain competitions)
- Parent’s or legal guardian’s name and email address (only for certain competitions where participants are
deemed minors in their country of residence).
If visitors do not provide their personal information stated above to us, their use of those sections of our Websites
could be restricted or impossible.
Trend Micro does neither wish to receive nor need any sensitive personal information, such as racial or ethnic
origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric
data, data concerning health or data concerning a natural person’s sex life or sexual orientation, or personal
information relating to criminal convictions or offences.
3
Information that is collected automatically
Trend Micro’s Website and email messages may use “cookies” and other technologies such as web beacons to
collect certain information automatically from a visitor’s device. This may also include cookies placed by third
parties in addition to Trend Micro. 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 a visitor’s IP address, device type, unique
device identification number, browser-type, broad geographic location (e.g. country or city-level location) and
other technical information. We may also collect information about how a visitor’s device has interacted with our
Website, including the pages accessed and links clicked.
Trend Micro also collects log files of traffic that visit our Website. These log files may include information such as
a visitor’s Internet Protocol (IP) address, browser information and language, domain name, date and time of
request. We use this information to track aggregate traffic patterns throughout our websites. Trend Micro may
collect and retain for a certain period IP address information in order to provide technical support, obtain geolocation information, for subscription and registration purposes and to secure our networks and systems. 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 non-personal information is
combined with personal information, we treat the combined information as personal information for the
purposes of our Privacy Notice.
For more information on the technologies used and to learn how to manage cookie preferences, please see Trend
Micro’s Website “Cookie Notice” here: https://www.trendmicro.com/en_us/about/trust-center/privacy/cookiepolicy.html.
B. How does Trend Micro use personal information?
Trend Micro Websites collect personal information to provide downloads of free evaluation software or upgrades,
newsletters, respond to requests for contact, downloads of whitepapers and to provide its Products.
We may further use and process personal information provided to us through our Websites such as by visitors
completing contact or information request forms to provide visitors with new Product information or technical
alerts and keep visitors informed about our Products, promotions and special offers.
Cookies and other tracking technologies are used on our Website for a variety of reasons including to better
understand visitor behavior and improving our Products and advertising.
To provide you with more interesting and customized information, promotions, and advertising, we disclose
personal information to third-party providers of advertising services who may use such personal information for
their own purposes or to serve other customers, including displaying our advertisements to you on sites and
services that we do not operate. This is considered targeted advertising under US state privacy laws.
We also collect and process personal information for the following other purposes: - Responding to or addressing requests, enquiries, complaints, feedback or opinion;
- Improving visitors’ experience of our Website;
- Recording visitor preferences regarding their use of our Website;
- Communicating with or notifying of, or providing visitors with updates on Trend Micro Products or benefits
available or technical news; - Participating in competitions and awarding prizes; and
- Evaluating a visitor’s interest in employment in the case of employment applications submitted by them
through our Website.
4
C. Managing own personal information
If visitors participate in a Trend Micro discussion forum or a Trend Micro competition that publishes entries online
on our Website, visitors should be aware that the information visitors provide there will be made broadly available
to others, and can be read (or watched), collected or used by other users of these forums/competition pages,
inside or outside of Trend Micro. This information can be used to send individuals unsolicited messages. Visitors
are responsible for the personal information visitors choose to submit in these instances. For example, if visitors
list their name and email address in a forum posting, that information is public. Visitors should be careful and
responsible when participating in any forum or discussion group or public competition on Trend Micro’s Website
and note that some of these forums or competitions may have additional rules and conditions. Each participant’s
opinion on a forum or competition on our Website is his or her own and should not be considered as reflecting
the opinion of Trend Micro. Trend Micro is not responsible for the personal information or any other information
visitors choose to submit in these forums or competitions.
Where visitors have a password which enables them to access their account, they are responsible for keeping this
password secure and confidential.
D. Third-party websites
Trend Micro’s Website contains a number of links to websites of Trend Micro business partners or to co-branded
websites that are maintained by Trend Micro and one or more of our business partners who are collecting visitors’
personal information pursuant to their own policies and purposes. Visitors should carefully read the privacy
policies on such websites or co-branded websites as they may differ from Trend Micro’s Privacy Notice, especially
as personal information collected on such websites are governed by the pertinent privacy policies. Trend Micro
is not responsible for the content, their Products or privacy practices or misuse of any information visitors provide
on those websites.
1.2. Product Users
A. What information is processed by Trend Micro when using our Products?
When a user orders, purchases, installs, activates or uses our Products (a “Customer”), we receive personal
information such as: - Name
- Phone number
- Email address
- Device ID
- Operating system
- License Key
We use this personal information to provide our Product, ensure that the relevant Customer’s license to our
solutions is valid and to contact our Customers regarding renewals, technical issues and new Product information.
We also obtain the personal information you provide to us during the sales and/or fulfillment process. We may
use the personal information you provide to contact you and to provide and inform you other relevant Products,
send you an invoice, ask you to fill out a survey so we can determine how our Products are being used; enhance
your customer and user experience, perform accounting, auditing and collection activities, answer questions, and
provide support or other similar services.
Trend Micro may collect and retain for a certain period IP address information in order to provide technical
support, obtain geo-location information, for subscription and registration purposes and to secure our networks
and systems.
Cookies and other tracking technologies are used on our Products for a variety of reasons including to improve
our Products.
5
The types of information and personal information that may be processed when using and interacting with our
Products, including Customer support, will depend on the particular Product used.
We may also use personal information for other business purposes, including: - Internal record keeping;
- Compliance with the law and requests from government bodies;
- Keeping existing and past Customers informed about our Products and promotions;
- Providing Customer support;
- Managing subscriptions and billing; and
- Responding to requests, questions and comments.
Information that we obtain from third party sources
From time to time, we may receive personal information from third party sources such as distributors/ reseller
or other types of partners. The types of information we receive from these third parties includes contact
information such as email addresses and telephone numbers and we use the information we receive from these
third parties to contact individuals in relation to our Products.
1.3. Prospects and Business Contacts
Trend Micro may obtain personal information from individuals who attend events; individuals who provide us
with their business contact information; individuals who contact us with enquiries and other individuals that we
send marketing to (“Prospects”).
A. What information is processed by Trend Micro, how is it used by Trend Micro and why?
Information that is actively provided
Trend Micro collects personal information in many ways, such as when Prospects: register to attend one of our
events, provide us with their business card information or when they request to receive information from us.
The personal information can include: - Contact details including name, telephone numbers, email address and postal address;
- Employer and employment information such as job title, function, seniority, department, and the
address/country/city of the individual’s office; and - Contact’s preferences and interests, for instance which newsletters they would like to be subscribed to or
what products they are interested in.
Trend Micro collects this information in order to: - Respond to correspondence and enquiries Prospects send us;
- To provide events and other services requested by Prospects or their employer;
- Obtain Prospects’ feedback;
- Send Prospects tailored information on our Products that may be of interest to them; and
- Tailor and develop our Products to ensure they are as relevant as possible.
Trend Micro does neither wish to receive nor need any sensitive personal information, such as racial or ethnic
origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric
data, data concerning health or data concerning a natural person’s sex life or sexual orientation, or personal
information relating to criminal convictions or offences.
Information that is collected automatically
Trend Micro’s 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.
6
The information we collect automatically may include information like an individual’s 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 non-personal
information is combined with personal information, we treat the combined information as personal information
for the purposes of our Privacy Notice.
Information that we obtain from third party sources
From time to time, we may receive personal information from third party sources such as lead generating
companies, event hosting companies and employers of individuals who for example, wish their employees/
individuals to attend our events.
The types of information we receive from third parties include: name, email address, contact details (and where
appropriate employment details). We use the information we receive from these third parties for lead
generation/ marketing purposes, to enable us to send Prospects tailored information on our Products (including
events) that may be of interest to them and to tailor and develop our Products.
- LEGAL BASIS FOR PROCESSING
Under the General Data Protection Regulation and /or UK GDPR we are required to only collect, use and process
personal information if we have a lawful basis to do so. Any personal information collected, used and processed
by Trend Micro will depend on the personal information concerned and the specific context in which we collected
it. Trend Micro process your personal information as follows:
- When it is necessary for the performance of a contract to which you are party, or to take steps at your
request prior to the agreement of a contract. This may also include when accepting our Global Product
Agreement; agreeing to our partner program terms and or to deliver to us a service or becoming a
contractor. Information collected where you may sign up to attend an event directly and so a contract is
formed between you and the event provider. - Where we are subject to a legal obligation to comply with laws i.e. for internal record keeping in
accordance with tax and accounting; employment obligations or business activity. - Your consent – whenever you consent to the processing of your personal information i.e. where you
register for an event; free trial, submit a survey. Here your consent is implied, meaning you consent as
you have submitted certain information to us freely. We also rely on your consent for using cookies and
other technologies on our website. Note that your default settings will depend on your location of as
rules for such technologies differ from region to region. The award of prizes and any involvement in
market research will only be based on Prospects’ consent. - Where we have a legitimate interest, whereby such interest is not overridden by your interest or
fundamental rights and freedoms. This includes but is not limited to the following:
o Response to communications from you: I.e. when you have corresponded with us and we need to
keep records in case of legal claims or complaints.
o Information collected to enable Prospects to attend our events is necessary for the performance of
the contract between such Prospects and Trend Micro for the provision of the event; or for the
legitimate interests of Trend Micro and the employers of Prospects, where Prospects attend events
on their employer’s behalf.
o Where we use and process personal information to provide new Product information or technical
alerts and to keep you informed about our Products, promotions and special offers, the processing
of personal information for such direct marketing purposes is based either on consent or on
legitimate interest grounds.
7
o If you have requests, enquiries, complaints, feedback or provide an opinion and are not a Customer
of Trend Micro, processing is necessary for the purposes of the legitimate interests pursued by Trend
Micro to address their communications to us.
o Where we process your personal information (including the use of artificial intelligence where
appropriate) to improve on your experiences of our events, to request feedback and/or to improve,
and develop our Products.
o Where we use and process personal information provided to us on account registration and/or
Product purchase/installation/activation.
- SHARING PERSONAL INFORMATION
Who does Trend Micro share personal information with?
Trend Micro is a global organization and may share personal information with its affiliated companies,
distributors, event sponsors(should you choose to register) vendors, marketplace providers or partners (including
professional service providers such as our auditors, insurance providers, financial service providers and legal
advisors) in order to run our business and to provide the high quality, localized Products or offers you have
requested, competition services you have requested, and/ or meet your needs or provide you with support. We
may also disclose your information as required to carry out corporate transactions such as a merger or sale of
assets as part of our company. Trend Micro may engage contractors to provide certain servicesin connection with
Products, such as providing technical support, hosting, marketing, conducting Customer research or satisfaction
surveys, and handling order processing or shipping Products, for example, if visitors choose to purchase a license
to a Trend Micro Product on our Website, visitors will be directed to one of Trend Micro’s e-commerce partners
(as detailed on our sub-processor webpage: https://www.trendmicro.com/en_us/about/trustcenter/privacy/subprocessors.html in order to complete the payment transaction. Trend Micro and the pertinent
e-commerce partner will need to share the relevant personal information.
Trend Micro requires that all contractors keep your personal information secure and confidential and that they
do not share such personal information with others or use it for their own marketing purposes. Whereby you
have agreed to provide your personal information via a registration or by scanning a badge at a booth whereby
Trend Micro is a joint host, or you attend a virtual event hosted by a third party platform, these scenarios may
collect additional data from you and as such the treatment of your information may be subject to additional
privacy statements as provided by those third parties.
It may be necessary by law, legal process, litigation and/or requests from public and governmental authorities
within or outside your country of residence for Trend Micro to disclose your personal information or personal
information received in relation to the registration and/or use of our Products. We may also disclose personal
information if we determine that for purposes of national security, law enforcement or other issues of public
importance, disclosure is necessary or appropriate.
Trend Micro may also disclose personal information if we determine that disclosure is necessary to enforce our
terms and conditions or protect our Products, their users, visitors or Prospects. In addition, in the event of a
reorganization, merger or sale, we may disclose or transfer any and all personal information we collect to the
relevant third party.
Information that we obtain from third-party sources
From time to time, we may receive personal information about you, including your name, email address, or other
information, from third-party sources where those parties have indicated that they have your consent or are
otherwise legally permitted or required to disclose your personal information to us. For example, we may be
provided with information about individuals interested in using our Products, joining our company, or when using
third-party authentication options to sign-up for or log-in to our Products. In these instances, we will not forward
or share any such personal information and shall only use such personal information for the purposes for which
we have been given permission by such third-party.
8 - INTERNATIONAL DATA TRANSFERS
Trend Micro is a global organization, with affiliated legal entities, business processes, management structures,
and technical systems that cross borders. We may process your personal information outside the country in which
you 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. When we share your personal information
among Trend Micro affiliates globally, we will do this on the basis of EU Standard Contractual Clauses available
at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standardcontractual-clauses-scc_en.
We may also transfer 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 Prospects’ personal information.
However, in such case the data transfer will be subject to appropriate safeguards, namely the EU Standard
Contractual Clauses, relevant technical and organizational measures, all as more fully described in our Data
Processing Addendum: https://www.trendmicro.com/en_us/about/trust-center/privacy/data-processingaddendum.html and our Trust Center: https://www.trendmicro.com/en_us/about/trust-center/privacy.html. - DATA RETENTION
Trend Micro will keep your personal information for as long as we have an ongoing legitimate business need to
do so (for example, to provide a service or information that a visitor or Prospect has requested or to comply with
applicable legal, tax or accounting requirements) and thereafter for no longer than is required or permitted by
law. When we have no ongoing legitimate business need to process your personal information, we will either
delete or pseudonymize it or, if this is not possible (for example, because the personal information has been
stored in backup archives), then we will securely store that personal information until deletion is possible. We
may retain aggregated or de-identified data indefinitely or to the extent as allowed by applicable law. - PROTECTION AND SECURITY OF PERSONAL INFORMATION
Trend Micro has taken appropriate security measures – including administrative, technical (e.g. encryption,
hashing, etc.) and physical measures – to maintain and protect personal information against loss, theft, misuse,
unauthorized access, disclosure, alteration and destruction. Access to your personal information is restricted to
authorized personnel only. For further information please see our Trust Center:
https://www.trendmicro.com/en_us/about/trust-center/security-practices.html. - COMMUNICATION PREFERENCES
Trend Micro gives you the choice of receiving a variety of information about our Products.
You can manage your communication preferences and unsubscribe by emailing the DPO email address as
provided for in the Contact Us section at the end of this Privacy Notice (and as per the contact details relevant to
your region).
Alternatively:
- If you are an Enterprise Customer, you may unsubscribe via the unsubscribe button on any marketing
type correspondence that you may receive from Trend Micro, or - If you are a Consumer Customer, you may unsubscribe via the “My Account”
https://www.trendsecure.com/MyPreferenceCentre-en_GB.html.
You should include your name, email address and specific relevant information about the material that you no
longer wish to receive.
9
- INDIVIDUAL DATA PROTECTION RIGHTS
You can contact us with data subject rights requests by using the contact information provided in the “Contact
Us” section, including with requests for the:
- Right to rectification of personal information – right to request that any inaccurate personal information
held by or on behalf of Trend Micro is corrected. - Right to access personal information – right to access your personal information held by Trend Micro.
- Right to data portability – right to receive personal information you have provided to us or to ask us to
transfer it to another person. - Right to erasure (or “right to be forgotten”) – right to request that Trend Micro delete all of the personal
information that we hold about you. - Right to restrict processing – right to restrict Trend Micro from processing your personal information,
where: (1) you believe that the personal information held by us about you is not accurate; (2) you believe
that the processing of your personal information is unlawful; (3) you believe that we no longer have any
reason to process their personal information; or (4) you object to the processing as described in this
Privacy Notice. In these circumstances we may restrict use of your personal information during the
review period. - Right to object to processing – right to ask Trend Micro to stop processing your personal information for
direct marketing purposes or other purposes on grounds relating to your particular situation. - Right to withdraw consent – if we are relying on your consent to use and process your personal
information, you are free to withdraw that consent at any time, without affecting the lawfulness of
processing based on consent before its withdrawal. - Right to opt out of targeted advertising – right to opt out of our processing of your personal data for
the purposes of targeted advertising. To provide you with more interesting and customized information,
promotions, and advertising, we disclose personal information to third-party providers of advertising
services who may use such personal information for their own purposes or to serve other customers,
including dislplaying our advertisements to you on sites and services that we do not operate. To opt out,
please use the Individual Rights processes and Contact Us. - Right to opt out of sale for money – right to opt out of the sale of your personal data. We do not sell
your personal data for money. - Right to opt out of profiling – right to opt out of profiling in furtherance of decisions that produce legal
or similarly significant effects concerning you. We do not engage in such profiling. - Right to request third party recipients – If you reside in Oregon, you have the right to request from us
a list of the specific third parties, other than individuals, to whom we have disclosed your personal data
or any personal data.
We will respond to your requests to exercise your privacy rights in accordance with applicable law. For some
requests, we may request additional information from you to verify your identity and complete your request. If
we decline to take action on a request exercising one of your rights set forth above, you may have the right to
appeal our decision. In these cases, we will notify you providing our reasons for denying the request and
instructions for how you can appeal the decision.
Please see our Supplemental Notices which will further details your specific regional rights dependant upon your
residency: https://www.trendmicro.com/en_us/about/trust-center/privacy/notice.html.