Privacy Policy
Effective Date: May 25, 2018
Introduction
This privacy policy tells you how Trilio Data, Inc. uses your data when you visit our website, interact with us, and buy our software and services. It also tells you about your privacy rights and how the law protects you.
We want to make sure you’re informed on:
- What information we collect about you
- How we use the information that we collect
- What information do we share and how
- How we store and secure your information
- How to access and control your information
- How we transfer information we collect internationally
You must read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.
If you have any questions or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact Trilio about privacy below.
Our website
Our website at Trilio.io contains information about our data protection software and services, which are aimed at business users – from start-ups to enterprise organizations. This website is not intended for children and we do not knowingly collect data relating to children.
Trilio Data, Inc. is the data controller responsible for this website and any handling of personal data carried out by or on behalf of Trilio Data, Inc. (which we may refer to as “Trilio”, “we”, “us” or “our” in this privacy policy).
Personal data that we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect a variety of information about our customers and visitors when you provide it to us, when you use our services, or when other sources provide it to us. This personal data falls into these categories:
- Identity Data includes title, first name, last name, username, or similar identifier. If you interact with us through social media, this may include your social media user name.
- Contact Data includes billing address, company address, email address, and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website.
- Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
- Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used by this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.
How your personal data is collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by mail, phone, email, or through chat or social media.
This includes personal data you provide when you:
- Sign up to receive the Trilio newsletter
- Make inquiries or request information be sent to you, including product whitepapers and datasheets
- Order our products or services
- Ask for marketing to be sent to you
- Engage with us on social media
- Enter a competition, promotion, or survey
- Contact customer support
Automated technologies or interactions. As you interact with us, including via the Trilio.io website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our advertisements (including those shown on third-party websites).
Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:
- Technical Data and/or Tracking Data from analytics providers, advertising networks, and search information providers;
- Contact, Financial, and Transaction Data from providers of payment and fraud prevention services;
- Identity and Contact Data from data partners; and
- Data from any third parties who are permitted by law or have your permission to share your data with us, such as via social media or review sites We will only use your data when the law allows us to. Most commonly, we will use your data in the below circumstances.
How your personal data is collected
How we use the information we collect depends, in part, on any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
- Where do we need to perform the contract we are about to enter into or have entered into with you? For example, when you purchase our products, that’s a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the purchase process.
- Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
- For customer support, to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve our products and services.
- To market, promote, and drive engagement with our products and services. We may send you promotional communications that we think are of interest to you, including by email and by displaying Trilio advertisements on other companies’ websites, as well as on platforms like LinkedIn and Google.
- With your consent, to otherwise communicate with you in a way that we have not outlined above.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent at any time.
See Explaining the legal bases we rely on to process personal data to find out more about the types of lawful basis that we will rely on to process your personal data.
Legal bases for processing personal data
The table shows you a description of all the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your data for more than one lawful ground depending on the specific purpose for which we are using your data.
Identity Contact Financial Transaction Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (including to recover debts due to us)
Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring) Necessary to comply with a legal or contractual obligation to share personal data for law enforcement
| Purpose/Activity | Type of Data | Lawful Basis for Processing |
|---|---|---|
| To register you as a new customer | IdentityContact | Performance of a contract with you |
To process and deliver your order, including:(a) Manage payments, fees, and charges (b) Collect and recover money owed to us | ||
| To manage our relationship | IdentityContact Profile Marketing and Communications Performance | Performance of a contract with you necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To deliver direct marketing | IdentityContact Profile Usage Marketing and Communications Tracking Technical | For most direct marketing communications, we rely on consent, however, there are situations in which it is in our legitimate interests to use your data in this way (Please see Advertising, marketing, and your communications preferences below) |
| To enable you to take part in a prize draw, competition or complete a survey | IdentityContact Profile Usage Marketing and Communications | Performance of a contract with you necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data) | IdentityContact Technical Tracking | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | IdentityContact Profile Usage Marketing and Communications Technical Tracking | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences | TechnicalTracking Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | IdentityContact Technical Usage Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To prevent and detect unlawful acts | IdentityContact Financial Transaction Technical Tracking | |
| To resolve legal claims or disputes involving you or us | All relevant data categories, depending on the nature of the allegation or claim | Necessary to bring or defend a claim |
If you ever have any questions about this, all you have to do is ask. See How to contact Trilio about privacy below.
Advertising, marketing and your communications preferences
We may use your Identity, Contact, Technical, Tracking, Usage, and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you and tell you about them. This is what we call direct marketing.
We may carry out direct marketing by email, phone, text, or mail. For example, you might have the Trilio newsletter hit your inbox, or a cool promotion land on your doormat.
On our website, we always try hard to make it clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up for the newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out (but we’d be sorry to see you go, so please gives us a chance by fine tuning your preferences before really leaving us!). The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.
Of course, there are lots of different ways you’ll see advertisements for Trilio out and about, and not all of these are based on using personal data – sometimes we just buy good old-fashioned advertising space in the real world and websites and social media. If you see Trilio’s advertisements on websites and in social media, these may not be directed specifically at you, we might just have bid for the space. But here are some things we may do that may be specifically directed at you:
- Emails
- Text messages
- Promotions by mail
- Phone calls
We work with partners to promote the reach of our advertising and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.
Tracking Data and in particular, cookies, help us to deliver website and social advertising that we believe is most relevant to you and potential new customers of Trilio. The cookies used for this purpose are often placed on our website by specialist organizations – and this is also why when you’ve been on the Trilio.io website, you an advertisement for us again. This includes retargeting.
Cookies can also tell us if you have seen a specific advertisement, and how long it has been since you have seen it. This is helpful because it means we can control the effectiveness of our advertisements and control the number of times people might be shown our advertisements. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.
If you want more information about Tracking Data, in particular cookies, see Cookies below.
Almost all the cookies that relate to advertising are part of third-party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada, and the European Interactive Digital Advertising Alliance. We do not control cookies that are set by advertising networks.
Cookies
You can see from Advertising, marketing, and your communications preferences above, that cookies are a tool that we (and everyone else who operates online) use for advertising. That is just part of why cookies are used. Generally, they are pretty clever.
Cookies help Trilio.io work better and provide lots of help in the background to make the process of being a Trilio.io customer a lot easier.
Other cookies collect information about how visitors use Trilio.io, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how Trilio.io works.
Some cookies allow Trilio.io to remember choices you make (such as your language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
Some cookies collect information about your browsing habits to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing, and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
When you use Trilio.io, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. You need to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
You can see more information about the cookies we use here, including who they belong to, their ID, and why they are used. We’ve also included links to third-party websites where you can go to find out more.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Disclosures of your personal data
We may share your data with the parties set out below for the purposes set out in this privacy policy. We may also share your data if the law otherwise allows it.
We may share personal data with the following categories of third parties:
- Suppliers and service providers (such as technology service providers, payment processing, and fraud prevention providers, manufacturers, and mail and courier services);
- Auditors and professional advisers like bankers, lawyers, accountants, and insurers
- Government, regulators, and law enforcement
We share personal data with the following specific third parties:
- HubSpot: we use HubSpot to send our direct marketing campaigns to prospective and current customers. Please visit their privacy policy.
- Drift: we use Drift to handle our chat communications with current and prospective customers. Please visit their privacy policy.
We also share data with third parties connected to advertising, retargeting, and analytics. Please see the Cookies above, including the cookie list, for more information about who those third parties are.
We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your data and to treat it by the law. We do not allow our third-party service providers to use your data for their purposes and only permit them to process your data for specified purposes and by our instructions.
Payment information
Trilio currently invoices our customers, but occasionally we may accept payment via third-party payment processors including PayPal to process payments made for products and services. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. We do not currently accept payments online via our website.
International transfers
Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:
The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.
Many of our external third-party providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Third-party links
This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Data retention
We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they stop being customers for tax purposes.
We also make a promise to you that you can come back at any time in the future and re-print products you have ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws about your personal data:
- The right to be informed – that’s an obligation on us to inform you how we use your data (and that’s what we’re doing in this privacy policy);
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for a copy of the personal data we hold about you;
- The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
- The right to erasure – that’s also known as the ‘right to be forgotten where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
- The right to data portability – that’s a right for you to ask us for a copy of your data in a common format (for example, a .csv file);
- The right to object – that’s a right for you to object to us processing your data (for example, if you object to us processing your data for direct marketing); and
- Rights about automated decision-making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision-making.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the GDPR website.
If you wish to exercise any of the rights set out above, please contact us (see How to contact Trilio about privacy).
You will not have to pay a fee to access your data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
We have appointed a data privacy manager who is responsible for overseeing questions about this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details in How to contact Trilio about privacy below.
You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland, and certain non-European countries (including the US and Canada) are available here.
How to contact Trilio about privacy
If you have any questions about this privacy policy or would like to exercise any of your rights, please email us at [email protected] or write to us with your letter addressed to:
Data Privacy Manager, Trilio Data, Inc., 111 Speen Street, Framingham, MA, 01701, United States of America.
If you need help with our products and services, or this website generally, please contact us here.
How to contact Trilio about privacy
The General Data Protection Regulation is new and the commission is still issuing new guidance about how businesses should follow it. So, you may see little updates to our privacy policy over the coming months. Be sure to check in and read every now and then. Thank you.
