Last updated: February 2021
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 firstname.lastname@example.org 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.
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.
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.
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
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 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.
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.
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 retain information as long as it is necessary and relevant for our operations.
Your Choices Regarding Your Information
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.
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.