Privacy Policy

TRIO REWARDS, INC.

Privacy Policy

Last modified: August 1, 2016

Introduction

Trio Rewards, Inc. (“We”, “Company”, or “Trio”) operates the Trio Rewards mobile applications (the “Mobile App”), and the Trio Rewards external APIs and related services (collectively, the “Service”), which includes our website at www.TrioRewards.com (our “Website”).  Capitalized terms used herein, which are otherwise undefined, have the meanings attributed thereto in the Company’s Terms of Service which can be found at http://www.TrioRewards.com/terms-of-use.html and within the Mobile App (the “Terms of Service”).

This Privacy Policy (this “Policy”) describes our practices for the collection and use of information we may collect from you in connection with your use of the Service including downloading, installing, registering, accessing, or using the Mobile App.  It does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party; or by any third party (including our affiliates and subsidiaries).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, do not download, install, register, or use the Mobile App or any other part of the Service.  By downloading, installing, registering, or using the Mobile App or any other part of the Service, you agree to this Policy.  We may make changes to this Policy from time to time (see Changes to Our Privacy Policy, below).  Your continued use of the Service after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Children Under the Age of 18

Our Service is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Service. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Service or on or through any of its features.  If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 18, please contact us at memberservices@www.triorewards.com or by calling (855) 321 – 8746.

Our Privacy Practices

Information We Collect

When you use the Service, we may collect information about you or your use of the Service.  Such information includes (but is not limited to):

  • information by which you may be personally identified, such as name, postal address, email address, telephone number, third party login information, or payment method information (“personal information”);
  • information regarding your mobile devices, including their locations, your mobile devices on which you have installed the Mobile App, and other information related to your use of the Service;
  • information that is about you but individually does not identify you;
  • information about your wireless or mobile internet connection, the equipment you use to access our Service and usage details;
  • information about your device, such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser (e.g. Chrome, Safari), and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or unique device identifier (a number uniquely allocated to your device by your device manufacturer);
  • log information, including the apps or websites visited, the time and your time zone, network connection type (e.g., WiFi, cellular), and cookie information;
  • the geo-location of your device (using GPS or other geo-location data), when location services have been enabled for the Mobile App or browser accessing our Service;
  • non-personally identifying information that third parties have collected and share with us to help better provide the Service; and
  • Information regarding your relationship to other Members, such as whether you are the Referring Member of a Referred Member.

Information We Collect Directly

We collect this information directly from you when you provide it to us, or as we process your transactions, for example:

  • information that you provide by filling in forms on our Service, including information provided at the time of registering to use our Service, information identifying the Merchants where you shop, or requesting further services relating to the Service or your use of the Service;
  • records and copies of your correspondence (including email addresses), if you contact us;
  • your responses to surveys that we might ask you to complete for research purposes; and
  • your purchase histories within the Trio Network, including the Merchants where you have made purchases and the date and amount of each transaction.

We use a third party service to process any charges you incur though using the Service.  This allows us to provide the Service 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 read at https://stripe.com/gb/privacy.

Information We Collect Through Automatic Data Collection Technologies

As you interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  • details of your use of our Service, including traffic data, location data, logs and other communication data and the resources that you access and use on the Service; and
  • information about your device and Internet connection.

The information we collect automatically is statistical data and does not include personal information.  It helps us to improve our Service and to deliver a better and more personalized service, including by enabling us to:

  • estimate our audience size and usage patterns;
  • store information about your preferences, allowing us to customize our Service according to your individual interests; and
  • recognize you each time you use the Service.

We may use third party analytics services to provide us with analytic data collection and reporting.  We will not provide any personally identifiable information to such third parties.

How We Use the Information We Collect

We use the information we collect to provide and improve our Service.  For example, we use such information to process your electronic signatures and account for electronic delivery of documents, and to optimize and improve our technologies and delivery of our Service.  We use information that we collect about you or that you provide to us, including any personal information:

  • to present our Service and its contents to you;
  • to provide you with information, products or services that you request from us;
  • to fulfill any other purpose for which you provide it;
  • 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 notify you about changes to our Service or any products or services we offer or provide though it;
  • 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 providers, such as Yelp and payment processing services, in order to facilitate POS Purchases;
  • to allow you to participate in interactive features on our Service;
  • in any other way we may describe when you provide the information;
  • for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the order form or registration form) or adjust your user preferences in your account profile, or by sending us an email stating your request to memberservices@TrioRewards.com.  If we have sent you a promotional email, you may select the “unsubscribe” link at the bottom of the email and follow the opt-out instructions. This opt-out does not apply to information provided to the Company as a result of your participation in the Service,  POS Purchases, the grant of Earned Credits, or other transactions.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Service and visiting your account profile page.  You may also send us an email to privacy@TrioRewards.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

General Provisions

How We Respond to “Do Not Track” Signals

Your web browser may provide a “Do Not Track” browser setting, requesting the website operator not track your online activities. We do not respond to such signals. Further, blocking or deleting cookies will not stop all such tracking.

The activities of any third parties are subject to their own privacy policies and are not covered by this Policy.  If you have opted out of tracking by various third parties and you get a new computer, install a new browser, or otherwise change or update your browser or its cookie files, you may also clear cookies from such third parties related to your opt-out request.

Data Collection Technologies

The technologies for data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Service.
  • Other Technologies. The Mobile App, certain web pages on our Website, and our emails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Stored Information and Files. The Mobile App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information.

Third-party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on our Service or on other websites or mobile applications are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. Your device manufacturer and network service providers may also collect information about your use of their devices or services.  These third parties may use cookies alone or in conjunction other tracking technologies to collect information about you when you use our website.  The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.  They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Policy:

  • to fulfill the purpose for which you provide it;
  • to our subsidiaries and affiliates;
  • to Referring Members only 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 only 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 and for the settling of POS Purchases at their location;
  • to contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about end users or our Service users is among the assets transferred;
  • for any other purpose disclosed by us when you provide the information; or
  • with your consent.

We may also disclose your personal information:

  • to comply with any court order, law or legal process, including to respond to any government or regulatory request;
  • to enforce or apply our Terms of Service and other agreements, including for billing and collection purposes; or
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

Choices About Tracking Technologies and Advertising

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 some parts of this site may then be inaccessible or not function properly.

 

When you install the Mobile App, you will be asked to allow us access to certain information on your device, including your address book, contact data information, SMS messages, SD card contents, location and other system tools. If you do not want us to have access to this information, please do not install or use the Mobile App. If you block the use of location information, some parts of the Mobile App may then be inaccessible or not function properly.

Your California Privacy Rights

California Civil Code Section 1798.83 permits users of the Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to memberservices@TrioRewards.com.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We will use commercially reasonable efforts to safeguard the information that you submit to us.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Service.

Changes to Our Privacy Policy

We will post any changes we make to this Policy on this page.  If we make what we believe is a material change to this Policy, we will notify our registered Service users by email to the email address specified in each user’s account or through a notice on the Service home page.  The date this Policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at memberservices@TrioRewards.com.