PRIVACY POLICY

Trinity Industries, Inc. Privacy Policy

Last Updated: December, 2023

Trinity Industries, Inc. and its affiliates and subsidiaries ("Trinity," "us," “our” or "we") value your privacy. This website privacy policy (the "Privacy Policy") describes how Trinity collects, stores, uses, discloses, and otherwise processes the Personal Information (as defined below) described in this Privacy Policy and the rights and choices individuals have regarding such Personal Information. Trinity is primarily a business-to-business entity providing industrial products and services to its business customers in the industrial, energy, transportation, and construction sectors.

By using our Services (as defined below), you agree that your Personal Information will be handled as described in this Privacy Policy. Your use of our Services and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, available at Terms of Use (https://legal.trin.net/), including their applicable terms governing limitation of damages. If you have additional ‎questions or would like further information on this topic, please contact us at privacy@trin.net. We periodically update our Privacy Policy, so please check back ‎here for the latest version.‎

QUICK REFERENCE GUIDE

Scope of This Privacy Policy
Personal Information We Collect
How We May Use Personal Information
How We May Disclose Personal Information
Cookies and Other Tracking Mechanisms
Your Privacy Rights and Choices
Children’s Information
Retention
Security
Changes to the Privacy Policy
Questions and Contact Information

1. Scope of This Privacy Policy

Except as otherwise described below, this Privacy Policy applies to the Personal Information Trinity collects and processes related to visitors of our websites where this Privacy Policy is posted, including www.trin.net, www.trinityrail.com, and any other websites on which the Privacy Policy is posted (the "Sites"); individuals who download and use any of our interactive features, widgets, applications, or content we make available through the Sites; current, former, and prospective business customers, agents, vendors, and business partners who interact with us; and individuals who communicate or otherwise interact or engage with us or the products or services available through the Sites (collectively referred to as the "Services").

Depending on how you interact or engage with us, we may provide you with supplemental privacy notices with additional details about our privacy practices. For example, this Privacy Policy does not apply to job applicants and candidates who apply for employment with us or to employees in the context of our working relationship with them. To the extent we provide you with different or additional privacy notices, those additional notices shall govern such data collection and use.

2. Personal Information We Collect

As further described below, we collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Information”). We may collect Personal Information directly from you, automatically through your use of the Services, and from other, third-party sources. To the extent permitted by applicable laws , we may combine the information we collect from publicly available or third-party sources.

2.1. Personal Information We Collect Directly From You

While the Personal Information we collect varies depending upon your use of our Services and our interactions with you, in general, we may collect the following Personal Information directly from you:

Contact Information and Other Identifiers. When you contact us, including if you sign up to learn more about our Services, fill out our web forms, or otherwise communicate with us, we may collect your name, phone number, address, email address, the nature of your inquiry, and any other information you choose to provide.
Account Information. You may choose to create an account on our Site as a customer or client. To create an account, we may collect account and profile information, such as your email, password, and any other information used in connection with accessing your account.
Professional and Education Information. If applicable, we may also collect professional-related information, such as related to your job title, company name, business address, business email and phone number, and certain professional licensing and qualifications. In some circumstances, we may also collect information related to your education.
Communications and Interactions. When you email, call, or otherwise communicate or interact with us and with members of our team, we may collect and maintain a record of your contact details, communications, and our responses.
Protected Classifications. To the extent voluntarily provided by you or to comply with applicable law, we may collect certain characteristics of protected classifications, such as sex, gender identity , age, and marital status.
Events and Other Requests. We also may collect information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend events we host or sponsor, we may collect information related to your registration for and participation in such event.
Preferences. We also may collect information about your preferences, including communications preferences, preferences related to your use of Services, and any other preferences or requests you provide when interacting with us.
Business Development Information. To assess and pursue potential business opportunities, we may collect and receive Personal Information about current, former, and prospective business customers, agents, vendors, and business partners, including name, company information, contact details, and communications records.

2.2. Personal Information We Collect Automatically

We and our service providers may automatically collect Personal Information related to your use of the Services through cookies, pixel tags, and other similar technologies. The Personal Information we may automatically collect when you visit our Sites or interact with our Services may include:

Device and Browsing Information. We may collect your IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique ID, hardware, mobile network information, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information.
Activities and Usage Information. We may also collect information such as page views, links and items clicked, features used, scrolling activity, time spent within the Services, and other activity and usage related.
Location Information. We may also collect device location information about you, such as through your IP address. If you choose to enable location-based sharing with us through your device settings, we may collect precise location information, such as GPS coordinates, to provide content that is more relevant to your location and to otherwise improve your interactions with our Services. You may turn off location data sharing through your device settings, although please note that turning off such sharing may impact the services you are receiving from us.

For more information about our use of cookies and other similar technologies, please see the“Cookies and other Tracking Mechanisms”section below.

2.3. Personal Information We Collect from Other Sources

In addition, we may collect and receive Personal Information about you from affiliates and subsidiaries, business partners, clients and customers, data analytics providers, social networks, Internet service providers, operating systems and platforms, government entities, public databases, information brokers, and vendors and service providers who provide services or perform functions on our behalf. For example, we may collect certain contact information, such as your name and email, from our business partners, and vendors and service providers. We also may receive certain Personal Information from our business customers and clients for the purposes of administering our Services, or data analytics and marketing providers for purposes of reaching new customers.

3. How We May Use Personal Information

We may use the Personal Information we collect or receive about you for the following purposes:

to provide and operate our Services, communicate with you about your use of the Services, respond to your inquiries, provide troubleshooting and technical support, and to otherwise run our day-to-day operations.
to provide you with information or Services that you have requested or agreed to receive;
to provide you with marketing materials or communications related to our Services;
to enable you to participate in a variety of the Services' features;
to process your registration submitted through the Services, including verifying your information is active and valid;
to conduct research and for analytical purposes, such as to evaluate and improve our Services or their functionality, to customize your experience within our Services, or to serve you specific content that is relevant to you;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services' policies;
to better understand how users’ access and use the Services and for internal business purposes;
to develop Services, provide support and improve the security of our Site and Services;
to administer surveys and questionnaires and to conduct research and further develop our Services (in some cases, this may include working with trusted third parties to perform research);
to investigate, respond to, and resolve reported complaints and security issues;
to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority;
to conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, recordkeeping and legal functions; and to maintain appropriate business records and enforce company policies and procedures;
to assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financing, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions;
to protect the Services and our business operations, to protect our rights or those of our stakeholders, to prevent and detect fraud, unauthorized activities and access, and other misuse and where we believe necessary to investigate, prevent or take action regarding illegal activities, situations involving potential threats to the safety or legal rights of any person or third party, or to investigate violations of our Terms of Use (https://legal.trin.net/) or this Privacy Policy; and
for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

4. How We May Disclose Personal Information

We may disclose the Personal Information we collect for the purposes described above and as follows:

Affiliates, Subsidiaries, and Business Partners. We may disclose the Personal Information we collect to our corporate affiliates and subsidiaries. Trinity also partners with other businesses to offer our products and Services, and we may disclose Personal Information to those business partners.
Vendors and Services Providers. We may disclose the Personal Information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, marketing and marketing research providers, customer support, data storage, payment processing providers, data analytics providers, auditors, consultants and legal counsel.
Marketing and Analytics Providers. We may also disclose your Personal Information, such as device and browsing, and activities and usage information, to marketing and advertising networks, data analytics providers, and other companies who provide marketing or analytics services on our behalf. For more information, see the “Cookies and Other Tracking Mechanisms” section below.

We may also disclose your Personal Information in the following circumstances:

Operate Our Business. To our business partners, affiliates and subsidiaries, and vendors and service providers in order to operate our business, provide our Services, and otherwise run our day-to-day operations, we may disclose Personal Information.
In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the Personal Information we have collected from you with or to the other company. We may also disclose certain Personal Information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
Security and Protection of Rights. Where we believe it is necessary to protect the Services, our rights and property, or the rights, property, and safety of others, we may disclose Personal Information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms of Use. We may also disclose Personal Information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
Legal Obligations. To comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, regulatory investigations, subpoenas, or court orders), we may also share Personal Information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others.
Aggregated and Deidentified Information. Notwithstanding anything else in this Privacy Policy, we may use, disclose, and otherwise process aggregate and deidentified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes.
Other Disclosures. We may disclose Personal Information in other ways not described above that we notify you of or that we obtain your consent for, as required by applicable laws.

5. Cookies and Other Tracking Mechanisms

We use cookies, pixel tags, web beacons, imbedded scripts, and other similar tracking mechanisms to automatically collect information about browsing activity, type of device, and similar information within our Services (collectively, “Tracking Technologies”). We use this information to, for example, analyze and understand how you access, use, and interact with our Services, to identify and resolve bugs and errors in our Services, to assess, secure, protect, optimize, and improve the performance of our Services, as well as for marketing and advertising purposes, analytics purposes, and to personalize content in our Services. We may also aggregate such information to analyze trends, administer our Services, and gather broad demographic information for aggregate uses.

5.1. Cookies

“Cookies” contain information that Trinity or our service providers transfer to your device through a web browser for tracking, performance, or functionality purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within the Services.

To prevent cookies from tracking your activity on our websites or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Sites who disable cookies will be able to browse the Websites, but some features may not function.

5.2. Pixel Tags

Pixel tags (sometimes called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these pixel tags in connection with our Services to, among other things, track the activities of users and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded so we can track response rates and gauge the effectiveness of our communications.

5.3. Third-Party Analytics

We use third-party tools, such as Google Analytics, which are operated by third-party companies to evaluate usage of our Website and Services. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Services to provide us with reports and metrics that help us evaluate usage of our Services, improve our websites, and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. . You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

5.4. Cross Device Tracking

We and our providers may use the information we collect about you within our Services and on other third-party websites and services to help us and these third parties identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Services.

5.5. Third-Party Advertising

Third-Party Advertising. We work with third-party ad networks, analytics, marketing partners, and others (“third-party ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information within our Services (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other online identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and to evaluate the success of such ads and content. You can also control how participating third-party ad companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices tool (https://youradchoices.com/appchoices) in order to help control interest-based advertising on apps on your mobile device. Opting out of participating third-party ad networks does not opt you out of being served advertising. Residents of the European Union may opt out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/. Opting out of participating third-party ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Site. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

5.6. Tracking Technologies Choices and Consent

For our users in the EEA and U.K., we obtain your consent to our collection of usage information through using Tracking Technologies by providing you with transparent information in this Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth below. Please note that we are not required to obtain your consent to our use of Tracking Technologies identified above that are strictly necessary. We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.

If you are located in California — or jurisdictions with similar notice and opt-out laws regarding the use of third-party advertising cookies — we will provide you a notice at collection and information concerning your ability to opt-out.

6. Your Privacy Rights and Choices

6.1 Your California Privacy Rights

For more information on privacy rights for California residents, please see our California Privacy Policy, available at https://legal.trin.net/Home/California

6.2 Transfer of Information to the United States, Your U.K. and European Union Privacy Rights

If you are located in the European Economic Area ("EEA") or the United Kingdom ("UK”) please be aware that the Personal Information you submit, including information provided through our Services, is being sent to a location in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By providing such Personal Information, you are consenting to (and represent that you have authority to consent to) the transfer of such information to the United States for the uses and purposes described in this Privacy Policy.

7. Children’s Information

We offer Services to businesses for the manufacture, lease, or purchase of railcars, and it is not intended for use by minors, including children under the age of thirteen (13). We do not knowingly collect Personal Information from children under the age of 13. If you are a child under 13 years of age, you are not permitted to use our Site and you should exit this Site immediately. In the event that we become aware that we have collected Personal Information from any child, we will dispose of that information. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with Personal Information, please contact us at privacy@trin.net.

8. Retention

To the extent permitted by applicable law, we will retain your Personal Information only for as long as we believe is necessary to fulfill the purposes for which it was collected, including for the purpose of meeting any legal, accounting, or other reporting requirements or obligations.

9. Security

We have implemented commercially reasonable safeguards that are intended to protect the Personal Information that we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

10. Changes to the Privacy Policy

We may add to, update, delete from or modify our Privacy Policy at any time at our sole discretion. If we make changes to this Privacy Policy that materially change how we handle your Personal Information, we may post or display notices of changes on our Site, in accordance with applicable laws. Once posted, these changes to the Privacy Policy are effective immediately. If any change that we make is not acceptable to you, you should stop using our Site or Services. If you continue to use our Services, doing so is your agreement to be bound by those changes. You should check back regularly and review this Privacy Policy so that you are aware of the most current rights and obligations that apply to your agreement with us.

11. Questions and Contact Information

If you have questions about this Privacy Policy, you may contact:

Trinity Industries, Inc.
Attn: Legal Department
14221 N. Dallas Parkway, Suite 1100
Dallas, TX 75254

If you send us an email to privacy@trin.net with questions or comments about the Services, the Privacy Policy, or the Terms of Use (https://legal.trin.net), we will share your messages ‎with those within our organization who are most capable of addressing the issues contained in ‎your message. We will keep a copy of your message until we have had an opportunity to address ‎your concerns. We may archive your message for a certain period of time or discard it, but your ‎email address will not be used for any other purpose.‎‎‎