Privacy Policy

Last updated: February 2021

Trio Rewards, Inc. (“Trio”, “we”, “us”, “our” or words of similar import) respects your privacy and is committed to protecting it. This Privacy Policy (this “Policy”) describes how we may collect, use, protect and share your Personal Information (as defined below) in connection with your use of (a) the www.triorewards.com website and any other Trio related websites (collectively, the “Website”), (b) the Trio platform, applications, mobile applications (including mobile versions of the Website) and any related services (collectively, the “Apps”), and (c) any software we make available through the Website or Apps and any other tools, modules, remote services, servers or other offerings or services of any kind owned, provided or otherwise operated by Trio (together with the Website and Apps, the “Services”). Capitalized terms used herein, which are not otherwise defined, have the meanings attributed to them in our Terms of Use, which can be found at http://triorewards.com/terms-of-use.html

To provide you with our Services and improve these Services over time, we will collect and use certain of your information as described in this Policy. This Policy also explains certain choices you have about how your Personal Information is used. By using the Services, you consent to the practices described in this Policy, unless further consent is required by applicable law. You may see other privacy notices when we collect your Personal Information for certain purposes; these notices supplement this Policy. You can access certain features of the Services (e.g., general website features of the Service) without creating an account or providing Personal Information.

Protecting Children’s Privacy Online

Our Services are not intended for children under 18 years of age, and we do not knowingly collect Personal Information from children under 18. If you are under 18 years of age, do not use or provide any information on our Services or on or through any of its features. If we learn we have collected or received Personal Information from a child under 18, we will delete that information. If you believe we might have any Personal Information from or about a child under 18, please contact us at memberservices@www.triorewards.com or by calling (855) 321-8746.

What is Personal Information?

When we say “Personal Information,” we mean “personal information” or “personal data” as defined under applicable law. Generally speaking, this is defined as information that allows someone to identify or contact you, including your unique identifiers (full name, phone number, e-mail address, user name, exact location, etc.), plus information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you. “Non-personal information,” on the other hand, is information that has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to you as an individual. “Information” means either Personal Information or non-personal information.

User Consent

By submitting Personal Information to our Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Information in accordance with this Privacy Policy. Your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country.

What We Collect

Information Automatically Collected

When you access and use our Services, computer servers may automatically collect Information from your device or browser.  In some cases, we limit this collection to non-personal information, but we may collect certain Personal Information as well.  Examples of Information we may collect include, but are not limited to:

  • Usage Information. Information about your activity through access and use of our Services. For example, we may collect Information about how you interact with the Services, including your usage patterns and resources you access and use on the Services.
  • Device Information. Information from and about the devices you use when you access and use our Services. For example, we may collect Information about your hardware and software, such as the hardware model, operating system version, device memory, unique application identifiers, unique device identifiers (to recognize usage patterns over time), browser type, language, battery level, and time zone, as well as Information about your wireless and mobile network connections, service provider and signal strength.
  • Location Information. Information about your approximate or precise location only when you use certain of our Services using methods that include GPS, wireless networks, cell towers and Wi-Fi access points. App access to location Information can be revoked by changing the permission settings, but please note that certain features of our Services may then be inaccessible to you or otherwise not function properly.
  • Log Information. Log Information may include: usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information, and other logs); content interactions (including searches, views, downloads, prints, shares, streams, and displays); and user journey history (including clickstreams and page navigation, URLs, timestamps, page response times, page interaction information (such as scrolling, clicks and mouse-overs) and download errors), advertising interactions and preferences (including when and how you interact with marketing materials, purchases or steps you make after seeing an ad) and similar data.

Some of this information is collected through the use of “Cookies,” which include a piece of data stored on a site visitor’s hard drive to help us improve your access to the Services and identify repeat visitors. Cookies can enable us to track and target the interests of our users to enhance the experience on the Website and compile aggregate data about site traffic and site interaction. Usage of a Cookie is not linked to any Personal Information, and most cookies expire after a defined period of time. You can set your device or browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that certain features of our Services may then be inaccessible to you or otherwise may not function properly.

We may contract with third-party service providers to assist us in better understanding use of and visitors to our Services. These service providers are not permitted to use the Information collected on our behalf except to help us conduct and improve our Services, and we will not provide any Personal Information to such service providers.

Personal Information

Except as set forth above or unless you provide it to us directly at your option, including as set forth below, Personal Information is not otherwise collected by our Services. If Personal Information is to be collected by any of our Services at any time in addition to what is described in this Privacy Policy, ​you will be notified of such, with the notice explaining the Personal Information being collected and its intended use. We will not collect any such additional Personal Information without your consent. At any time, you may contact us at: memberservices@triorewards.com to request access to, changes, anonymization of, removal of or editing of such Personal Information.

Information You Provide to Us

We may collect the following Information from you directly when you provide it to us (e.g. when you fill out a form on the Website or App, including at the time of registering to use any Service, participate in one of our surveys or contact us with questions or feedback), or as we process your transactions:

  • Identifiers such as name, address, email address, phone number, user name and similar information;
  • Demographic Information such as preferred language, age, birth date and similar information;
  • User Data such as Information identifying the Merchants where you shop, your purchase history within the Trio Network (including the Merchants where you have made purchases and the date and amount of each transaction), Information regarding your relationship to other Members (including whether you are a Referring Member or a Referred Member), or content in your comments, posts, communications or responses, including with respect to any requests for further services relating to use of any Service; and
  • Any other Personal Information you voluntarily provide to us.

If you decline to provide certain Information when requested, we may not be able to provide one or more Services to you, or you may not receive access to certain features of a Service.

 

Use, Retention and Sharing of Your Data

Information

We may use your Information in the following ways:

  • To develop, operate, improve, deliver, maintain and protect our Services;
  • To monitor and analyze trends and usage;
  • To personalize the Services by customizing the content we show you;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To inform Referring Members of the Earned Credits they will be granted as a result of your POS Purchases at Merchants within the Trio Network;
  • To inform Merchants of the amounts due for the settling of POS Purchases;
  • To connect to third party service providers, such as Yelp or payment processing services, in order to facilitate POS Purchases;
  • To provide and improve ad targeting and measurement, including through the use of your precise location data (again, only if you’ve consented to us collecting that location data);
  • To allow you to participate in interactive features on our Services;
  • To enhance the safety and security of our Services;
  • To use information we’ve collected from cookies and other technology to enhance the Services and your experience with them;
  • To enforce our Terms of Use and other policies applicable to your use of our Services;
  • To detect, investigate, mitigate or prevent activities that may violate our policies, threaten the security of our Services or may be fraudulent or illegal; or
  • To comply with our legal obligations.

We may also share your Information with third party service providers to provide you with the Services, conduct quality assurance testing or to provide technical support. These third party service providers are required to use your Information solely and specifically to provide the services requested by us, and cannot share your Information in any other way. You expressly consent to the sharing of your Information with our service providers for the sole purpose of providing services to you. Note that we use a third party service to process certain charges you incur through using the Services. This enables us to provide such Services to you without actually processing or storing your particular payment account Information. The Information collected by the third party payment service is subject to its own privacy policy, which you can access and read at https://stripe.com/gb/privacy.

Personal Information

In the event you provide us with any Personal Information at your option or we otherwise collect Personal Information as described herein, we may use or otherwise disclose your Personal Information for the following purposes, subject to restrictions under applicable law

  • To respond to your inquiries;
  • To provide you with certain Services or features of Services requiring such Personal Information;
  • To Referring Members, to the extent necessary to inform them of the Earned Credits they will be granted as a result of your POS Purchases at Merchants within the Trio Network;
  • To Merchants, to the extent necessary to inform them of the Earned Credits they will be granted as a result of Member’s POS Purchases at other Merchants within the Trio Network or for settling of POS Purchases at their location;
  • To contact you about products or services we think may be of interest to you;
  • To contact you with legal notices or other information that may be relevant to the Services;
  • In the event we reasonably believe we have a legal obligation to do so, to disclose your Personal Information to government authorities or other third parties when required by law or pursuant to a valid subpoena, litigation demand or court order, or to protect or defend the rights or property of Trio, including the Services; or
  • As otherwise described to you at the point of collection or pursuant to your express consent.

Non-Personal Information

We may use non-personal information for any purpose, and reserve the right to use and disclose non-personal information to third parties in our sole discretion.

Disclosures to Advertising Companies

Third parties may serve ads on certain of the Services (such third parties “Advertising Companies”). We do not send any Personal Information to Advertising Companies. If Advertising Companies select certain demographic targeting for their ads, we automatically match those ads to the appropriate audience using non-personal information. Advertising Companies only receive data reports from us with non-personal information. Any of your Information collected directly by such Advertising Companies is governed by their privacy policies, not ours, and we are not responsible for the content or privacy practices of such Advertising Companies.

Affiliates and Acquisitions

We may share some or all of your Information with our subsidiaries, joint ventures or other companies under common control with us (collectively, “Affiliates”), in which case any such Affiliate will be required to honor this Privacy Policy. If another company acquires us or our assets, that company will possess the Information collected by it and us and will assume the rights and obligations regarding your Information as described in this Privacy Policy.

We retain information as long as it is necessary and relevant for our operations.

Your Choices Regarding Your Information

If you have opted-in to receive promotional communications, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you Services related communications, including notices of any updates to our Terms of Use or Privacy Policy.

Data Security

In order to safeguard Personal Information against unauthorized access, removal, theft or disclosure, we implement and maintain security procedures and practices appropriate to the nature of the Information and reasonable in light of industry standards and our particular operations, risks and resources. We regularly assess the performance and adequacy of these procedures and practices and will adjust them when new standards, operations or risks require it. Unfortunately, in our increasingly connected digital world, no one can guarantee perfect data security, and we cannot promise that our procedures and practices will always prevent a breach of Personal Information. Should we detect such a breach, we will promptly notify affected individuals, third parties and law enforcement agencies as required by applicable law.

We encourage you to help maximize security by applying your own personal security measures. For more information about what you can do to protect your data, please see the tips and resources offered by the U.S. Federal Trade Commission at https://www.consumer.ftc.gov/topics/privacy-identity-online-security and the California Attorney General at https://www.oag.ca.gov/privacy/consumer-privacy-resources.

“Do Not Track” Signals

The web browsers and applications that you use to visit our Services may provide certain “Do Not Track” capabilities. Generally, browsers that have these features enabled send a signal to websites that inform the site operator that you do not wish for the site to track you. We do not respond to these signals because there is not yet a common understanding of how to process these signals or a consensus on what “tracking” means.

Links to Third Party Services

Our Services may contain links to third-party websites, products or services. For example, our Services may contain advertisements linking you to a third party product or service. Information collected by those third parties is governed by their privacy policies, not ours, and we are not responsible for the content or privacy practices of such other websites and third parties. We encourage you to learn about the privacy practices of those third parties.

Contact Information

We welcome your comments or questions regarding this Privacy Policy or our practices. Please e-mail us at memberservices@triorewards.com.

California Residents

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. We do not sell or share your Personal Information with third-party companies for their direct marketing purposes without your consent.

Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision, and if we make any substantial changes in the way we use your Personal Information, we will notify you by sending you an e-mail to the last e-mail address you provided to us or by prominently posting notice of the changes on our Website or App. These changes will be effective immediately for new users of our Services. Please note that at all times you are responsible for updating your Personal Information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice or the posting of such changes on our Website or App will nonetheless constitute effective notice. In any event, changes to this Privacy Policy may affect our use of Personal Information that you provided us prior to our notification to you of the changes. Continued use of our Services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

 

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