Last Updated: 20 March 2023

Objectives

Trilliant Holdings Inc. (“Trilliant”) and its affiliates are committed to protecting the privacy of personal information provided to us by our customers, employees and visitors to our website and work to continue improvements to and transparency around the ways we may collect, process, use and share personal information.

Trilliant works with its global customers and partners to comply with regional data privacy rules. In particular we have addressed at the end of this policy special rules applicable to persons from the European Economic Area (EEA) and data privacy rules in Colombia, the home of recently-established Trilliant Networks Colombia S.A.S. If you have any questions or concerns or other general questions about our use of your personal information, please contact us as detailed below or click here.

Scope and Applicability

This policy shall apply to employees at all our offices globally and will be assigned as required reading to all employees.

Core Practices

What Personal Information is collected by Trilliant and why?
We may collect personal information that falls into four broad categories: what you provide voluntarily, information collected automatically, data from third parties, and other sources such as your visits to a Trilliant office or event. Each is discussed below.

1. Information that you provide voluntarily

A number of Trilliant operations will ask for contact information in order to provide information and services. “Contact Information” as used in the policy may include the following: name, job title, email address, phone, company affiliation, company address. Importantly, Trilliant never sells Contact Information.

Identifiers / Account registration. When you create a customer support ticket, we collect and use the contact details you supply to respond to the ticket. Contact Information as well as any User ID, password hints and similar security information required for authentication and access to our customer support platforms.

Enquiries. Visitors to www.trilliant.com, our public facing website, who use the “Contact Us” feature to request information are asked to supply Contact Information that we use to respond to the question (and for no other purpose).

Recruitment. Job applications can be submitted on the Trilliant website and will include the applicant’s Contact Information, professional qualifications, summary of education and work experience. This information is used only to review and respond to the application.

Commercial and customer information. Trilliant collects Contact Information about its customers, vendors and other business partners in the normal course of contracting, product ordering and delivery, customer support, invoicing and similar commercial activities. Such information is used to conduct Trilliant commercial operations.

Information that we collect automatically
www.Trilliant.com. Prior to 2023 Trilliant did not automatically collect information via its website. Beginning in 2023, website visitors will be asked to accept or decline cookies. Cookie information is stored in the visitor’s browser and performs functions such as recognizing a visitor returning to our website and helping Trilliant understand which sections of the website are most interesting and useful.

Trilliant products do NOT collect personal information. Trilliant provides networks enabling wireless communication of data, such as electricity usage, between the consumer and utility. The Trilliant system only collects meter id numbers and electricity quantities. The utility matches that data (which may include personal information) in its data base to generate bills and provide other services such as remotely “turning on” electricity service at a customer’s location. The Trilliant network does not collect any data identifying the customer or the customer’s address. If it is necessary to perform technical troubleshooting, a utility may provide Trilliant’s services team access to the data in the utility’s system but such data is transferred to Trilliant’s control.

Information from third party sources
From time to time, Trilliant receives personal information from third party sources such as:

• Social Media Platforms. If you interact with us on social media, such as your Facebook or Twitter accounts, we may receive Contact Information about you, depending on the privacy settings you’ve selected for that account.

• Authorized resellers, distributors and other business partners may provide us with customer information such as names and contact information for the customer’s staff who may need to interface with Trilliant.

• If you attend trade shows and conferences where Trilliant participates, the event organizers may your Contact Information with us for purposes of the meeting. We expect meeting organizers to have your consent before they share.

In each of the cases just described, we will collect information only where we are satisfied that you consented or that the third party is legally permitted or required to disclose your information to us.

Should you choose to provide us with a third party’s personal Information, we ask that you ensure that you have the third party’s permission to do so.

Other: Office Visitors
We may collect personal information if you visit one of our offices, for example, via security cameras, sign in processes and identification checks. These steps are taken to safeguard visitors and employees, as well as Trilliant assets.

Who does Trilliant share my personal information with?
Trilliant does not share your personal information with third parties for telemarketing, e-mail or direct mail solicitation. We never sell your data.

We may disclose your personal information as follows:

• to our affiliates, third party services providers and partners who provide data processing services to us (for example, in order to support our website or enhance its security and our services);

• to any law enforcement, regulatory, government agencies, or other official bodies where we believe disclosure is required by law, is necessary to exercise our legal rights or to protect your vital interests;

• to investors and financial institutions that have a legitimate need to review the data for due diligence purposes, in which case we protect the data via written nondisclosure agreements.

Sharing With Third-Party Service Providers for Business Purposes
During the preceding 12-months, we have shared the following categories of personal information for a business purpose to provide features and services:

• Personal identifiers, such as name, work address, email address, phone numbers, government-issued identification;

• Internet or other electronic network activity information, such as IP address, type of browser, version of operating system, carrier and/or manufacturer, device identifiers.

Such disclosures are made only when necessary to enable the third party to perform services for Trilliant, such as maintaining or servicing accounts, delivering customer service, processing or fulfilling orders, processing payments and providing analytic services.

Again, we do not sell personal information to third parties or share it to enable direct marketing.

Factors Beyond Our Control
Sometimes factors beyond our control make it impossible to ensure that your personal information is not be disclosed to third parties; no method of internet transmission or electronic storage is 100% secure. For example, third parties may circumvent our security measures to unlawfully intercept or access your personal information. You may also link from our website to a third party websites where we have no control over or responsibility for information collection. You should consult and understand their privacy policies independently.

How does Trilliant keep your personal information secure?
We use technical and organizational measures to protect personal information designed to provide security appropriate to the risk of processing your personal information. Specific measures include encrypting your personal information in transit and at rest. Even though we take significant steps to ensure that your personal information is not collected, used, or disclosed by us except explained in this Policy, technical mistakes are possible. If a mistake occurs, we will take commercially reasonable steps to correct it.

International data transfers
Our business is global, and so we transfer personal information across borders. Your personal information may be processed in countries other than the country in which you reside. However, we have taken measures safeguard your personal information including implementing the European Commission’s Standard Contractual Clauses (SCCs) for transfers of personal information between our group companies, which require those companies to process information in accordance with European Union data protection law. Those SCCs also comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

Your data protection rights
Depending on your country or state of residence, you have certain rights regarding the personal information we maintain about you, the information we collect from you, how we use it, and how we communicate with you. You can exercise these rights, which are summarized below, by using the “Contact Trilliant” link below.

• The right of access (known as a “data subject access request” under GDPR) means that you have the right to ask us to tell you what personal information we have collected,used and disclosed. We will respond to such requests within 45 days from the receipt, and we may inform you that we need up to 45 additional days to respond.

• The right of deletion means that you may request that we delete your personal information, subject to certain exceptions. We will reply to such a request within 1 month of its receipt and may notify you that we need up to 2 more months, based on the number of deletions at issue.

• The right to object means that you can ask us to restrict processing of your personal information or to request the portability of your personal information.

• The right to opt-out of marketing communications at any time. At present, Trilliant doesn’t electronically distribute marketing materials. If we do so in the future, you will be able opt out through an “unsubscribe” link.

• You may withdraw a previous consent to our collection of your personal information at any time. Withdrawing your consent will not affect the lawfulness of any collection
prior to your withdrawal, or processing of your personal information based on a lawful processing grounds other than consent.

• You may complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

• We will respond to your requests to exercise data protection rights under applicable data protection laws.

• Finally, you have our assurance that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

You can exercise your rights yourself or designate an authorized agent to do so on your behalf. We may need to verify your identity or that of your agent in connection with such a request

Privacy rights for data processed in Colombia and the EEA are discussed at the end of this policy.

Data retention
We keep your personal information only where we have an ongoing legitimate business need to do so (for example, to provide you with a requested service or to comply with applicable legal, tax or accounting requirements). Beyond this, records containing personal information are retained in accordance with internally-established document and data retention policies, which must be reviewed at least once annually and on which employees receive training.

Access by Children
The website and its content are directed to people who are at least eighteen years of age or older. If you are under the age of eighteen, you should not submit your personal information to us without the consent of your parent or guardian. If you believe that we may have collected personal information from someone under 18, please let us know by emailing as explained below.

Updates to this Privacy Policy
We update this Privacy Policy in response to changing legal, technical or business developments. The last update is displayed at the top of the Policy.

Contact Trilliant
For questions or to make suggestions about this Policy, please use one of the means below. at:

Mail to: Trilliant Holdings Inc.
401 Harrison Oaks Blvd, Suite 300
Cary, NC 27513 USA

Email: info@trilliant.com

Phone: +1-919-495-6111

Disclosures required in the European Economic Area (EEA)

Our basis for collecting and using the personal information under EEA regulations follow.

We will normally collect personal information only with your consent, where we need the information to perform a contract with you, or where we have a legitimate interests in the information that is not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information to protect your vital interests or those of another person (e.g. government regulatory authority mandate such as a mandatory survey).

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Trilliant” heading below or click here.

Colombia – For data processed in Colombia.

1. Responsible Party: For information collected in Colombia the Responsible Party is: Trilliant Networks Colombia SAS, address Carrera 7 # 156-68 Piso 4 del Edificio Northpoint Torre III de Bogotá-Colombia., cellphone number 3229453932. (“Trilliant”)

2. Contact: If you have any claim or query regarding the privacy of your personal information, please send it to the following email: info.colombia@trilliant.com

3. Your Rights: Under Colombian legislation, you may exercise the following rights through the contact email indicated above:

a) Discover, update and correct personal data;
b) Request proof of the authorization granted for the data at issue;
c) Request information regarding the use of your personal data;
d) Complain to the Superintendency of Industry and Commerce for violations of these Colombian legal regulations;
e) Revoke the authorization and/or request the deletion of the data;
f) Obtain free access to your personal data that has been processed by Trilliant.

4. Use of Information: Trilliant will use your information only for these purposes:

• Suppliers and Partners: Trilliant may process personal data provided by its Suppliers to adequately select contractors (due diligence) and to perform a contract (e.g., ordering, invoicing, payment) in a correct and timely manner.

• Clients or Potential Clients: Trilliant may process personal data of clients and potential claims to execute the contracting process and perform the contract after signature. The data may be used in processes such as billing, issuance of licenses, generation of executable files, commercial follow-up, service delivery, sales promotion, customer relations, among others.

• Employees and Applicants: Trilliant may process personal data relating to employees for: (i) entry and exit from facilities; (ii) monitoring for compliance with schedules and commitments; (iii) payment of salaries and delivery of other personal and/or family benefits; (iv) medical records solely as you may voluntarily provide them to us; (vi) delivery of data required by government entities or judicial or extrajudicial processes; (vi) other activities as need to comply with contractual and legal obligations to employees. In the job application process, including recruitment, Trilliant may collect personal data to evaluate job applications, consider and verify qualifications, experience and academic records and to communicate with the applicant. With respect to contractors engaged by Trilliant, personal data may be collected and processed for the same purposes as for employees and applicants.

• Visitors: Trilliant processes personal data regarding Trilliant visitors to control entry, transit and safe exit of visitors, whether occasional or frequent, and to protect the security of Trilliant’s employees and assets.

• Recording Systems: The cameras located at Trilliant facilities may record clients, suppliers, collaborators, applicants, visitors or any person at the facility, in order to protect employees and visitors, as well as prevent loss, theft, damage or misuse of Trilliant resources. However, Trilliant will refrain from collecting, disclosing and/or using material from video that exposes the privacy and/or dignity of people, only if strictly necessary to fulfill the identified purposes and if it is necessary, it will be conducted in a discreet and restrictive manner to avoid putting at risk the dignity and privacy of the person and/or their relatives.

• Internet or Digital Media: The information that is currently or in the future required through your visits to our website or other digital mechanisms will be collected and used for the purpose of processing your request or query. Visitors to the website will be asked to accept or refuse cookies.

Claims and Queries: For claims, please contact email indicated above and describe the facts that give rise to your claim. This will include your address/email, and any accompanying documents that support the claim. If the claim is incomplete, you will be required to provide missing information. If you do not submit such required information within 2 months from the date of your original claim, we will understand that you have withdrawn the claim. Trilliant will respond to your claim within 15 business days its receipt by us and will inform you if we need more time to response, including the reason for delay, and the date by which the claim will be addressed according to the law.

For queries, please use the email indicated above, and we will respond within ten (10) business days.