Privacy Policy - Trilliant

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Privacy Policy

Last Updated: 3 January 2020

Trilliant Holdings Inc. (“Trilliant”) is committed to protecting the privacy of personal information provided to us by our customers or visitors to our website. As part of that continued commitment and commensurate with the California Consumer Privacy Act (CCPA), we’ve updated our Privacy Policy to reflect changes we’ve made to protect your privacy rights and provide greater transparency around the ways we may collect, process, use and share personal information.  This Privacy Policy explains how Trilliant Holdings Inc., or the relevant Trilliant group company/affiliate providing you with the services, collects, shares and uses personal information about you, and how you can exercise your privacy rights.  If you have any questions or concerns about GDPR compliance, CCPA compliance or other general questions regarding our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy or click here.

 

What Personal Information is collected by Trilliant and why?

The personal information that we may collect about you broadly falls into the following categories:

  • Information that you provide voluntarily

Certain parts of our website may ask you to provide personal information voluntarily or otherwise in connection with our provision of products/services, you may provide personal information.

Identifiers / Account registration. When you collect an account with us, we collect or use your contact details, such as your name, email address, contact details and other information you provide to us, as well as your User ID, password hints and similar security information required for authentication and access to our website and platform.

Enquiries. When expressing an interest in obtaining additional information about our services, Trilliant requires you to provide us with personal contact information, such as your name, company name, phone number, and email address for our business purposes. We will use the personal information provided to contact you about your interest in our services and provide services to you.

Marketing communications. If you subscribe to receive marketing communications with us, we collect the information you provide us, such as your name, job title, company name and email in order to provide you such marketing communications.

Recruitment. When applying for a position with us, we require you to provide personal information, including your name, email address, resume, professional qualifications, summary of education and work experience for our business purposes. We may use the information provided to contact you about your interest in the position indicated in your request.

Commercial information. We collect information, such as records of products purchased or considered, or other purchasing or consuming histories or tendencies. We use this category of information to receive and make payments, to improve and enhance your experience with the Trilliant platform and services, and to understand how you access, use and interact with the platform and services in order to provide technical functionality, develop new products and services, and analyze your use of them.

Customer records / Provision of products and/or services. If your organization has entered into a business relationship with Trilliant, we may collect information of one or more employees in the context of such business relationship, such as names and job titles of business contacts, as well as business contact information (e.g. professional email and phone number).This also includes the categories of information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80e), such as names, signature, postal address, employment information and payment information. Some personal information included in this category may overlap with other categories. For the avoidance of doubt, depending on the product or service that Trilliant provides to your organization, additional information may be collected in accordance with the terms of the agreement between your organization and Trilliant. This includes information such as shipping information, account number of end-users, product ID, and product location data (longitudinal/latitudinal location), which are and will be covered by the confidentiality agreement entered into between your organization and Trilliant. We use the information to provide access to and use of the Trilliant platform, to improve and enhance your experience with the Trilliant platform, and to understand how you access, use and interact with the Trilliant platform, products and services in order to provide technical functionality, develop new products and services, and analyze your use of them.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

  • Information that we collect automatically

When you visit our website, we may collect certain information automatically from your device.  In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically includes the following categories of information:

Usage Information. We automatically collect usage information, such as domain name, your browser type and operating system, web pages viewed, links clicked, IP address, the length of time on platform, the referring URL, or the webpage or other source, that led you to our site, access time, device identification numbers and other technical information. We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked.

Location Information. In addition, depending on the product or service that we provide, we may collect different types of information about your location, including general information (e.g., zip code, country, city-level location based on IP address) and in certain situations, more specific information (e.g., GPS-based functionality on mobile devices used to access the service) and may use that information to customize the service with location-based information and features. If you access the service through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this.

Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them.  We also use this information for our internal analytics purposes and to improve the quality and relevance of our website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” [link] below.

  • Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources such as:

  • Social Media Platforms. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we may receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depend on your social media account’s privacy settings.
  • Authorized Resellers, Business Partners and Distribution Partners. If you acquire any of our products or services from one of our partners, we may receive information about you from them.
  • Trade shows and conference. If the organizers of events that you attend (such as trade shows, conference or exhibitions) either have your consent to share your personal information with us, or are otherwise legally permitted to disclose your information (for example in order to organize a meeting), we may receive personal information about you.
  • Services partners with whom we offer co-branded products and services such as system integrators.
  • Marketing partners that work with us on social media and online channels to sponsor events and promotions.
  • Subscription service partners in relation to business contact details and business information in order to provide services at a business level.

In each of these cases, we collect information after we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

The types of information we collect from third parties include name, title, mailing address, email and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you.

If you choose to provide us with a third party’s personal Information (such as name, email, and phone number), you must ensure that you have the third party’s permission to do so. Examples include forwarding references or marketing material to a friend, or sending job referrals.

 

Who does Trilliant share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • to our group companies, affiliates, third party services providers and partners who provide data processing services to us (for example, in order to support the delivery of, provide functionality on, or help to enhance the security of our website and our services), or who otherwise process personal information for purposes that are described in this Privacy Policy or as notified to you when we collect your personal information.
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, (iii) collect unpaid bills or (iv) to protect your vital interests or those of any other person;
  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy;
  • to any other person with your consent to the disclosure.

Trilliant does not provide your personal information to third parties for telemarketing, e-mail or direct mail solicitation.

 

Legal basis for processing personal information (EEA visitors only)

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and 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 from you or may otherwise need the 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).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

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.

 

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

We disclose those categories of personal information to service providers to fulfill the following business purposes:

Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments and providing analytic services.

We do not sell personal information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018), nor do we share personal information with third parties for their direct marketing purposes (pursuant to California Civil Code Sec. 1798.83).

 

Use of Cookies

Cookies are small text files placed on your computer’s hard drive by web page servers. When you visit our website, for example, our server may create “cookies”, making it easier for you to use our website by verifying when you move between pages of our website. We also use cookies to understand how you navigate through our website, learn what content is popular and to save your preferences. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our website.

We do not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use our website. You may however disable certain tracking by disabling cookies in your browser. You should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may not be able to use or access certain features of our website.

 

Factors Beyond Our Control

While your personal privacy is very important to us, factors beyond our control make it impossible to always ensure that your personal information will not be disclosed to third parties. For example, despite our best efforts, third parties may circumvent our security measures to unlawfully intercept or access your personal information. You may also link to one or more third party websites from our website, and we do not control and are not responsible for the collection of your personal information by third party websites that you link to from our website; you should consult and understand their privacy policies independently.

 

How does Trilliant keep your personal information secure?

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.  Specific measures we use include encrypting your personal information in transit and at rest. Even though we have taken significant steps to ensure that your personal information is not collected, used, or disclosed by us except as set forth by this Privacy Policy, technical mistakes are possible. If such a mistake occurs, we will take commercially reasonable steps to correct it. Please be also aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure and we are unable to guarantee the absolute security of the information transmitted or collected.

 

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective.

Specifically, our website servers are located in the US and Canada, and our group companies and third-party service providers and partners operate around the world.  This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

Where applicable, we have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

 

Your data protection rights

Depending on your country or state of residence, you have certain rights regarding the personal information we maintain about you and certain choices about what personal information we collect from you, how we use it, and how we communicate with you. These rights are:

  • The right of access (known as a “data subject access request” under GDPR, or for California residents, “the right to know”) means that you have the right to request that we disclose what personal information we have collected, used and disclosed about you. You can do so at any time by contacting us using the contact details provided under the “Contact Trilliant” heading below or click here.
  • The right of deletion means that you have the right to request that we delete personal information collected or maintained by us, subject to certain exceptions. As mentioned above, you can do so at any time by contacting us using the contact details provided under the “Contact Trilliant” heading below or click here.
  • The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
  • You can also object to the processing of your personal information, ask us to restrict processing of your personal information or request the portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact Trilliant” heading below or click here.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contact Trilliant” heading below or click here.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to 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 respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

 

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

Access by Children

Trilliant feels strongly that parents should be involved in supervising internet usage by their minor children. In any event, we do not monitor the age of visitors to our website. 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 using the methods described in the “Contact Trilliant” section below so that we may take measures to investigate and address the issue.

 

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

 

Contact Trilliant

Our intention is to be diligent in protecting your personal privacy. If you would like to make suggestions or find out more about our privacy practices, please call us at +1-919-495-6111 or send us a letter or email at the addresses below.

You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your personal information.

Please use the contact details below, if you would like to:

  • Exercise your rights;
  • Learn more about your rights or our privacy practices; or
  • Designate an authorized agent to make a request on your behalf.

You may also contact us at

Trilliant Networks Inc
401 Harrison Oaks Blvd, Suite 300
Cary, NC 27513 USA
Email: info@trilliant.com
+1-919-495-6111