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PRIVACY POLICY
[Last modified: July 23, 2025]
INTRODUCTION
Trinity Audio Ltd. ("us", "our", "we" or "Company") is the owner and developer of proprietary
technology and integration intended to convert articles and similar content to audio
("Technology"). The technology is implemented by Company's business partners in their websites
or other digital assets ("Business Partners" and "Digital Assets" respectively), enabling their Digital
Assets' end user ("Users") to listen to the content available therein. The Company also allows for
third party advertisers ("Advertisers") to provide advertisements ("Ads") through its Technology
(collectively with the Technology, "Services").
This privacy policy ("Privacy Policy") governs our privacy and data collection practices with respect
to the data we collect from individuals who access and use our website available at: trinityaudio.ai
("Visitors"), our Business Partners who use and register for our Services and their Users interacting
with the Technology. Each of the Business Partners, Users, and Visitors shall also be referred to
herein as "you".
This Privacy Policy will explain what information we may collect from our Visitors, Business Partners
and their Users, how such information may be used or shared with others, how we safeguard it and
how each of the aforementioned individuals may exercise their rights related to their Personal Data
(as such term is defined below) in accordance with applicable data protection laws including, but
not limited to, the EU General Data Protection Regulation ("GDPR") and the California Consumer
Privacy Act ("CCPA"). We highly encourage you to read the Privacy Policy carefully and use it to
make informed decisions before you access our Website or use any of our Services.
If you are a California resident, the CCPA may apply to you as well. Please review our CCPA Privacy
Notice to learn more.
For additional privacy information for certain United States residents - please review the
“Additional Notice for US Residents” paragraph of this Privacy Policy.
This Privacy Policy will include, but is not limited to, the following information:
(i) Our lawful basis for processing your Personal Data;
(ii) What type of data we collect and how we use such data;
(iii) Cookies and how we collect your data;
(iv) With whom we share your data and for what purpose;
(v) Your privacy rights;
(vi) Our data retention practices;
(vii) Our direct marketing practices;
(viii) How we protect your data;
(ix) International transfer of your data;
(x) Children;
(xi) Additional Notice for US Residents
(xii) How to contact us;
WHAT TYPE OF DATA DO WE COLLECT?
If you are a Visitor, User or Business Partner, we may collect one or both of the following types of
data from you when you use or access our website, the Services or when you interact with the
Technology, as applicable.
The first type of data is aggregated, non-personal, non-identifiable information pertaining to your
use of the website or interaction with the Technology (“Non-personal Data “). We are not aware
of the identity of the individual from which the Non-personal Data is collected. NonPersonal Data
may include your aggregated usage information and technical information transmitted by your
device, including certain software and hardware information about your device (e.g., the device
you use, the type of browser and operating system your device uses, language preferences, access
times and the website's domain name from which you accessed the Services, etc.), in order to
enhance the functionality of the Services and for security and functionality purposes. We may also
collect information about your activity on the Services (e.g., clicks, ads shown, etc.).
The second type of information is individually identifiable information, namely information that
identifies an individual or may with reasonable effort identify an individual (“Personal Data“).
For the avoidance of doubt, if we combine Personal Data with Non-personal Data, the combined
data will be treated as Personal Data as long as the data types remain combined.
We act as a Processor of a User's Personal Data that we process on behalf of our Business Partners.
We are considered to be the Controller of the Personal Data we collect from our Business Partners
and Visitors.
The types of data that we collect as well as our reasons for processing such data are specified in
the tables below.
Data We Collect from Business Partners and Visitors:
DATA SET PURPOSE AND OPERATIONS LAWFUL BASIS
Data We Collect From Business Partners And Visitors
We will use this data solely for the We process such Contact
Data Provided Voluntarily:
purpose of responding to your Information subject to our
If you voluntarily contact us in any inquiries and to provide you with the legitimate interest.
manner, whether via our contact support or information you
form on our website, request a requested. We will retain our We may keep such
demo, via email, etc., you may be correspondence with you for as long correspondence if we are legally
asked to provide us with your as we find necessary, subject to required to.
contact information such as your applicable law.
full name and email address as well
as your Company name and job
title.
We will use this data to provide the Processed for the purpose of
Business Partner’s Registration:
Services and designate your account. fulfilling our contract obligations
If you wish to partner with us and Your contact details will be used in with you.
integrate the Technology within order to send you needed information
your Digital Assets you will be related to our Services and our
request to register and create an business engagement (e.g., send you
account. During the registration a welcome message, notify you
you will be requested to provide regarding any updates to our Services,
your contact details such as your send inquiries regarding your use of
name, email address, phone our Technology and Services for
number and company name. example where we detect you have
You may also provide us with your failed to complete the download or
email address through registration otherwise reached the offered cap,
or other means of communications send applicable invoices, etc.) and
if you choose to download our additional occasional
Technology through third- parties' communications and updates related
plugin or app marketplace.
to the Services, as well as provide you
with tips related to our Services, and
promotional and marketing emails.
We may also use the information in
order to verify your identity, including
by send you a text massage for
password verification purposes.
We use third-party payment
processor to process the payments in
consideration for our Services. We will
not obtain your payment details other
than as needed for validation.
purposes (e.g., 4 digits, BIN, expiry
date). The processing of your
payment details will be subject to the
applicable third-party processor's
policies
Newsletter & Marketing List We process such information
We use this data solely in order to
Subscription: based on your request and
provide you with the content that you
consent. You can unsubscribe at
If you voluntarily subscribe to our requested to receive. The Company any time using the unsubscribe
newsletter through our Website, or uses MailChimp for its email option within the body of the
otherwise agree to receive our marketing services. Please review applicable email
updates and content, you may be MailChimp's privacy policy here: correspondence or by contacting
requested to provide us with your https://mailchimp.com/legal/privacy/ us directly.
contact information such as your for more information.
name, email address and company
name.
We use this data for our legitimate process the Online Identifiers
IP and Technical Data:
interests of: (i) operating, providing, and Usage Data through third
When you access our website or maintaining, protecting, managing, party cookies based on consent
interact with our Services, we may which is provided through the
customizing and improving our
collect certain online identifiers cookie notice and consent
website and the way in which we offer
(e.g. your IP address) as well as manager. You may withdraw
technical Non-Personal Data (e.g. it; (ii) enhancing your experience; (iii) consent at any time by using the
the type of operating system, type auditing and tracking usage statistics cookie preference settings
of browser, device type, access and traffic flow; and (iv) protecting available on our website. First
time and date, directing URL and the security of our website. party cookies are strictly
your approximate geographical necessary and processing of
location). We will obtain your consent, if we are Online Identifiers is subject to
required to do so in accordance with our legitimate interest.
applicable law when we use third
party cookies on our website.
Data We Collect From End-Users
Online Identifiers & Technical We use this data for (i) operating, We process the End User Data
Usage Personal Data: providing, maintaining, protecting, upon consent provided through
managing, customizing and improving the consent string, TCF string.
The Company may collect
information regarding a User's our Services and the way in which we
interaction with the Services. Such offer them as well as. In some cases, Otherwise, the aggregated data
information may include Online to provide Users with personalized is used in our legitimate interest
Identifiers such as the User's IP Ads; (ii) enhancing your experience; in providing the Service, and
address, Advertising ID and IDFA. and (iii) auditing and tracking usage conducting research for
We may also assign a unique ID to statistics and traffic flow as well as improving the Service, all as
your browser. The Company may
calculating payments related to the detailed in the Legitimate
also collect technical Data, such as,
the type of operating system used, Services, we provide to Business Interest Claim below.
the type of browser, device type, Partners.
access time and date, certain Where required under applicable law, In certain aspects of our Service,
browsing data (e.g. directing URL) we will require our Business Partner we act as the “data processor” or
and the User's approximate to obtain your consent to collect such “service provider”, in which we
geographical location data and share it with us. will rely on our publishers to
obtain the necessary lawful basis
Note that, we use Google Ad Manager
for processing the end user
to operate our advertising campaigns.
personal data
Google may use and retain certain
types of data subject to its policies.
Additional information can be found
HERE.
Please note that the actual processing operation per each purpose of use and lawful basis detailed
in the table above may differ. Such processing operation usually includes a set of operations made
by automated means, such as collection, storage, use, disclosure by transmission, erasure, or
destruction. The transfer of personal data to third-party countries, as further detailed in the Data
Transfer Section, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities,
fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to
enforce the Terms, as well as to protect the security or integrity of our databases and the Services,
and to take precautions against legal liability. Such processing is based on our legitimate interests.
OUR LEGITIMATE INTEREST CLAIM (DISCLOSURE AS REQUIRED BY TCF 2.2):
In addition to the information provided above, we would like to further clarify the legitimate
interest grounds under which we may process certain categories of End User Data, in accordance
with the requirements of the Transparency and Consent Framework (TCF) v2.2. While the majority
of our data processing activities—especially those related to delivering personalized, cross-
contextual advertising experiences—are conducted based on your consent (as outlined in the
consent table above), there are specific instances where we rely on legitimate interest as our legal
basis under Article 6(1)(f) of the GDPR. Specifically, we may process limited types of Personal Data,
including Online Identifiers (such as IP address, cookie ID, or device ID), for purposes such as
collecting and storing your consent and privacy preferences, ensuring the secure and functional
delivery of advertisements, conducting measurement and analytics to improve our services, and
maintaining the technical integrity and efficiency of our platform. This processing is essential for
enabling us, our publishers, and our advertising partners to meet compliance obligations under the
accountability principles set forth in Articles 5(2) and 24 of the GDPR. Without this foundational
processing, we would be unable to provide publishers and advertisers with the tools needed to
respect user privacy choices or uphold service quality.
HOW WE COLLECT DATA
Depending on the nature of your interaction with the website or the Services, the abovementioned
data may be collected as follows:
• Voluntarily - In the event you choose to provide us with information, e.g., when you contact
us or if you are a Business Partner and you choose to share other information with use via
your use of the Services.
• Automatically - Your data may be collected automatically including via cookies (as
explained below) and other similar tracking technologies.
We will ask for your consent to collect Personal Data and offer you the choice to opt-out of such
collection if we are required to do so in accordance with applicable law.
COOKIES
We or our third-party affiliates (including Advertisers) may use cookies and other similar tracking
technologies or methods of web and mobile analysis to gather, store, and track certain information
related to your access of, activity and interaction with the Technology and website, as applicable.
A "cookie" is a small piece of information that a website assigns to your device while you access
such website. Cookies are very helpful and may be used for a variety of different purposes. These
purposes include, among other things, allowing you to navigate between pages efficiently, enabling
automatic activation of certain features, remembering your preferences and making the interaction
between you and the Services quicker, easier and smoother. Cookies are also used to help
customize your experience and for advertising purposes (including personalized advertising). You
can find out more information about cookies at www.allaboutcookies.org .
In general, there are several types of cookies that may be used on our website or in our website
and Services including the following:
• Essential, Functionality, Operation & Security Cookies. These cookies are essential for
enabling user movement around the website, for the website and Technology, as
applicable, to function properly, and for security purposes (i.e., used to authenticate users,
prevent fraudulent use, and protect user data from unauthorized parties). This category
of cookies either cannot be disabled, or if disabled, certain features of the website or
Services may not work.
• Analytical, Measurement & Performance Cookies. These cookies are used to collect
information about how our website and Services are being used, in order to improve our
Services and the way we offer them, as well assess performance of the content and the
way it is displayed on our website. These cookies enable us, for example, to assess the
number of users who have viewed a certain page as well as their country of origin.
• Targeting & Advertising Cookies. These cookies are set by our third-party service
providers, business partners, or Advertisers, as applicable. They may be to build a profile
of your interests and show you personalized content and advertisements. They work by
uniquely identifying your browser and device.
The third parties’ cookies used in our website are as follows:
Cookie Purpose Privacy Policy and Opt-Out
Analytical, Measurement & www.google.com/policies/privacy/partners
Google Analytics
Performance Cookies https://tools.google.com/dlpage/gaoptout
HubSpot Functionality & Operation https://legal.hubspot.com/privacy-
policy? ga=2.48898406.1547561739.15800
54069-1042704558.1573974857
MailChimp Functionality & Operation https://mailchimp.com/legal/privacy/
The third parties’ cookies used in our Technology are as follows:
Cookie Purpose Privacy Policy and Opt-Out
Analytical, Measurement & www.google.com/policies/privacy/partners
Google Analytics
Performance Cookies https://tools.google.com/dlpage/gaoptout
AdsWizz Targeting & Advertising https://www.adswizz.com/our-privacy-
Cookies policy/
https://www.adswizz.com/cookie-policy/
Triton Targeting & Advertising https://www.tritondigital.com/website-
Cookies privacy-policy
https://www.tritondigital.com/privacy-
policies
Targetspot Targeting & Advertising
https://www.targetspot.com/privacy- policy/
Cookies
ID5 Targeting & Advertising
https://id5-sync.com/privacy/
Cookies
In addition to the above, our Technology may include cookies placed by Advertisers, and will include
Company's cookies required for functionality and operation.
Additional Tracking Tools
Our website, and our partners website may enables third-party companies to serve ads, collect
pseudonymous personal data and/or use tracking technologies and are hereby providing you with
a privacy notice and opt-out choice as required under privacy and data protection laws. These
tracking technologies are designed to help recognize your computer or device and collect
information about your web surfing activity including your activities on this website. Please keep in
mind that browser settings designed to block cookies may have no effect on such
techniques. When you visit or enter your email address (either to log in, to sign up for a newsletter,
or otherwise) on our website, we may share personal data or other information that we collect
from you, such as your email (in hashed, pseudonymous form), IP address, and/or information
about your browser or operating system with these companies, acting as controllers, and these
companies use this information to create a pseudonymous ID for the purpose of recognizing you
on your devices. This ID does not contain any of your identifiable personal data. We may place this
ID in our first-party cookie or use a partner that places a third-party cookie and allows it to be used
for online and cross-context advertising. This ID may be sold/shared by us or on our behalf with our
advertising partners and other third-party advertising companies globally for the purpose of
enabling interest-based content, profiling and/or targeted advertising throughout your online
experience (e.g. web, email, connected devices, in-app, etc). One such third-party company is ID5.
Detailed information on ID5's data processing activities in connection with this ID and ID5’s opt-out
is available here and in ID5’s platform privacy policy here: https://id5.io/platform-privacy-
policy. You have the right to opt-out of ID5’s sale or sharing of your data at any time.
Cookies Opt-Out:
You can change your cookies settings at any time to control cookies placement through limiting or
forbidding the website under which we provide the Services to place cookies on your device and to
disable unwanted cookies already stored on your device, by changing your browser's privacy
preferences (please visit the help pages of your web browser). Please note, however, that if you
disable cookies or refuse to accept them, you might not be able to use all of the features we offer
or some of the features may not function properly. You may not be able to store your preferences
and some of our pages might not display properly. We may, at our sole discretion, delete old cookies
after a certain time which no activity had occurred from a user.
Your web browser allows you to manage the cookies and your choices. The configuration for each
browser is different. You may find more information about managing cookies on different
web browsers below:
Browser Relevant Link
Google Chrome https://support.google.com/chrome/answer/95647?hl=en;
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-
Firefox
website-preferences
Opera https://help.opera.com/en/latest/security-and-privacy/;
Internet Explorer https://support.microsoft.com/en-gb/help/17442/windows-internet-
explorer-delete-manage-cookies;
Safari https://support.apple.com/en-il/guide/safari/sfri11471/mac
https://support.microsoft.com/en-us/help/4027947/windows-
Edge
delete-cookies
You may also opt out of certain Advertisers' cookies and browser-enabled, interest-based
advertising at the Network Advertising Initiative's ("NAI") website- NAI consumer opt-out and the
Digital Advertising Alliance's ("DAA") website- DAA opt-out page. Or the European Interactive
Digital Advertising Alliance ("EDAA") website Your Online Choices page.
Our Business Partners may also provide ways for you to opt out from or limit their collection of
information from and about you for example ID5 which allow you to opt out through this link. Please
refer to the Business Partner's privacy policies. Please note, however, that we are not responsible
for the privacy practices of our Business Partners, and other third parties.
WHO DO WE SHARE DATA WITH AND WHY?
We do not share your Personal Data with third parties except as specifically mentioned herein:
• Third Party service providers - we may disclose your Personal Data to third parties that
perform services on our behalf (e.g. tracking, servers, service functionality and support,
marketing, etc.). These entities may be located in a different jurisdiction than you and are
prohibited from using your Personal Data for any purposes other than providing us with
the requested services;
• Third Party Rights - we may share your Personal Data, solely to the extent needed to
prevent harm to the rights (including intellectual property rights and other legal rights),
property or safety of us, our Visitors, Business Partners and their Users, yourself or any
other third party.
• Policy Enforcement - we may share your Personal Data, solely to the extent needed in
order to enforce our policies including investigations of potential violations thereof, to
establish or exercise our rights to defend against legal claims or to detect, prevent, or take
action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
• Legal Requirement - we may disclose or share your Personal Data, solely to the extent
needed to comply with any applicable law, regulation, legal process or governmental
request (i.e., to comply with a court injunction, etc.) or for the purpose of collaborating
with law enforcement agencies; or
• Affiliated Companies and Corporate Transaction- we may share your Personal Data with
a parent company, subsidiaries, joint ventures, or other companies under common control
with the Company ("Affiliated Companies") solely if and when applicable or necessary. In
addition, we may share information, in the event of a corporate transaction (e.g. sale,
merger, consolidation, etc.), provided however, that our Affiliated Companies or acquiring
company will be subject to the obligations detailed herein with respect to your Personal
Data.
• Online Identifiers - we may share Online Identifiers with our Business Partners and
advertising partners for the purpose of the Services, as well as to detect fraud and calculate
payments.
THIRD-PARTY COLLECTION OF DATA
Our Privacy Policy only addresses the use and disclosure of Personal Data that we collect from you.
To the extent that you disclose your Personal Data to other parties via the Services (e.g., by clicking
on a link to any other website or location) or via other websites throughout the internet, different
rules may apply to their use or disclosure of the Personal Data you disclose to them and your
Personal Data will be subject to that third-party's privacy policy.
You acknowledge that we are not responsible for third party's privacy practice related to or
integrated with our Technology, including Business Partner and Advertisers, and that this Privacy
Policy does not apply to any such third-parties' privacy practices. We strongly advise you to learn
about the privacy practices of each website that you may visit before providing any Personal Data
to such website.
YOUR PRIVACY RIGHTS
We acknowledge that different people have different privacy concerns and preferences. Our goal
is to be clear about what information we collect so that you can make meaningful choices about
how it is used. We allow you to exercise certain choices, rights, and controls in connection with
your information. Depending on your relationship with us, your jurisdiction and the applicable data
protection laws that apply to you, you have the right to control and request certain limitations or
rights to be executed.
Under applicable privacy protection laws, individuals have certain rights and controls regarding
their Personal Data we process and maintain. Depending on your relationship with us, your
jurisdiction and the privacy laws that apply to the processing of your Personal Data, the principal
rights might include:
● Right to be informed – you have the right to be provided with information regarding our
Personal Data collection and privacy practices. All is detailed under this Privacy Policy. If you
have any additional questions, please contact us at: [email protected]
● Right to access/inspect your Personal Data - you have the right to ask us to confirm whether
or not we collect and use your Personal Data, and if so, you have the right to know which
Personal Data we specifically hold about you ask for a copy of your Personal Data or access it;
● Right to correct/rectify your Personal Data - you have the right to ask us to correct or update
any of your Personal Data that is incorrect, after verifying the accuracy of the data first, taking
into account the nature of the processing and the purposes (or request deletion for inaccurate
Personal Data).
● Right to erase your Personal Data (the right “to be forgotten”) - you have the right to request
the erasure of certain Personal Data, if specific conditions are satisfied, for example, if you think
we no longer need to use it for the purpose we collected it from you, in case the process of your
Personal Data was based on your consent, where we have used it unlawfully, or where we are
subject to a legal obligation to erase your Personal Data. any request for such erasure will be
subject to our rights and obligations under applicable law (e.g., legitimate interests such as
record keeping with regards to our engagements, completing transactions, providing a good or
service that you requested, taking actions reasonably anticipated within the context of our
ongoing business relationship with you, fulfilling the terms of a written warranty, detecting
security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or
prosecuting those responsible for such activities; debugging products to identify and repair
errors that impair existing intended functionality; exercising right provided for by law; engaging
in public or peer-reviewed scientific, historical, or statistical research in the public interest, etc.).
You are not required to create an account with us to submit a deletion request;
● Right to restrict our processing of your Personal Data - you have the right to ask us to restrict
or limit the purpose for which we process your Personal Data in certain circumstances and
where certain conditions are satisfied (such as where the accuracy of the Personal Data is
contested by you, for a period enabling us to verify the accuracy of the Personal Data; where
the processing is unlawful and you oppose the erasure of the Personal Data; where we no
longer need the Personal Data for the purposes of the processing).;
● Right to object to how we use your Personal Data - you can object to any use of your Personal
Data which we have justified by our legitimate interest if you believe your fundamental rights
and freedoms to data protection outweigh our legitimate interest in using the information;
● Right to withdraw consent/opt-out - when the lawful basis for processing your Personal Data
is your consent, you may withdraw such consent at any time. You have the right to opt-out from
Direct Marketing, if applicable, by unsubscribing through the email received. We do not profile
you in a manner that has a significant effect on you or other individuals, therefore there isn’t
an opt-out option.
● Data portability right - you have the right to ask us to provide a copy of your Personal Data in
a portable format and, to the extent technically feasible, readily usable format that allows you
to transmit the Personal Data to another entity without hindrance. We will select the format in
which we provide your copy;
● Right to appeal or lodge a complaint - If we decline to take action on your request, we will
inform you without undue delay as required under applicable laws. The notification will include
a justification for declining to take action and instructions on how you may appeal, if applicable.
Under the GDPR you have the right to lodge a complaint with the applicable Data Protection
Authority in the EU or the Information Commissioner in the UK.
For California Residents, please further review our CCPA Notice, and for US residents, please further
see the “Additional Notice for US Residents” paragraph below - to learn more about your rights
under applicable US law.
Please note that, you may have different rights than those which we listed above depending on the
applicable privacy protection laws in your jurisdiction.
If you wish to exercise any or all of the above rights, please fill out the Privacy Rights Request
("PRR”) form available HERE, and send it to our privacy team at: [email protected].
Please feel free to contact our privacy team if you wish to receive more information or you would
like to raise a complaint with respect to how we may have handled your Personal Data.
If you are not satisfied with our response or believe we are collecting or processing your Personal
Data not in accordance with the applicable data protection laws in your jurisdiction, you may also
have the right to submit a complaint with the applicable data protection authority in your
jurisdiction.
DATA RETENTION
We retain the information we collect for as long as needed to provide the Services and to comply
with our legal obligations, resolve disputes and enforce our agreements (unless you instruct us
otherwise).
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our
own discretion.
DIRECT MARKETING
We may send our newsletter to our Business Partners who have registered to receive it. You can
remove your Personal Data from our mailing list and stop receiving promotional communications
from us by following the unsubscribe link located at the bottom of each communication or by
emailing us at: [email protected].
Please note that we will still reserve the right to send you service-related communications, including
service announcements and administrative messages that relate either to your account or to your
transactions with the Services, even after you have chosen to unsubscribe from receiving our
newsletter. You will only be able to opt out of receiving such messages by terminating and deleting
your account with us. If you wish to delete your account, please contact us at the email address
listed above. It is important that you are also aware, that we will still need to retain some of your
Personal Data as required under applicable law or for the legitimate purpose of our business, even
after you have chosen to delete your account.
HOW DO WE PROTECT YOUR DATA?
We take great care in implementing and maintaining the security of the Services and your data. We
employ physical, technical and administrative security measures that we believe comply with
applicable laws and are in line with industry standards. We have instituted a variety of procedures
and policies to ensure the safety of your data, and prevent unauthorized use of any such data.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts
of those who gain unauthorized access or abuse the Services, and we make no warranty, express,
implied or otherwise, that we will prevent such access.
If you feel that your privacy was not treated in accordance with our Privacy Policy, or if any person
attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at:
[email protected]. Additionally, we will make a reasonable effort to notify you and the
appropriate authorities (if required by applicable law) in the event that we discover a security
incident related to your Personal Data.
DATA STORAGE
The Company currently uses Amazon Web Services (AWS) as a cloud and storage service provider.
AWS's terms of service are available here: https://aws.amazon.com/service-terms/ and its privacy
policy is available here: https://aws.amazon.com/privacy/.
INTERNATIONAL TRANSFER
The Company provides Services worldwide and therefore, it may be necessary for us to transfer
data, including Personal Data, to countries outside of your jurisdiction, including outside European
Economic Area ("EEA"), where applicable. In these instances, we will take steps to ensure that a
similar level of protection is given to your Personal Data, including through adequate contractual
measures, as shall be required under applicable laws.
CHILDREN
The website and Services are not directed or meant to be used by children (the phrase "child" shall
mean as such term is defined under applicable law or an individual that is less than 16 years old). If
you are under 16 years old, you should not access the website, use the Services, or provide any
Personal Data to us.
We will immediately discard any Personal Data that we discover has been shared with us by a child.
Please contact us immediately at: [email protected] if you have any reason to believe that a
child has shared any Personal Data with us.
AMENDMENTS
We may revise this Privacy Policy from time to time, in our sole discretion. The revised Privacy
Policy will go into effect immediately upon its implementation on our website. The last revision
date will be reflected in the "Last modified" heading located at the top of the Privacy Policy. We
will make a reasonable effort to notify you in the event of any material changes to our privacy
practices. We encourage you to review this Privacy Policy regularly for any changes so that you
can continue to stay up-to-date with all of our current privacy practices.
ADDITIONAL NOTICE FOR US RESIDENTS
Residents of certain U.S. states (depending on the applicable state law, acting in an individual or
household context and not in a commercial or employment context or as a representative of
business), including Colorado, Connecticut, Virginia, and Utah, may have additional rights under
applicable privacy laws and be entitled to additional disclosures.
"Personal Data" under applicable US privacy laws, generally means any information that is linked or
reasonably linkable to an identified or identifiable individual (and usually does not include publicly
available information that is lawfully made available from government records, or that a consumer
has otherwise made available to the public; de-identified or aggregated consumer information; or
information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)
“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical
health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The
processing of genetic or biometric data for the purpose of uniquely identifying an individual;
Personal Data collected from a known child; Precise geolocation data.
We are required to provide you with a clear and accessible privacy notice that includes the
categories of Personal Data processed, purpose of processing, instructions for exercising consumer
rights and appealing decisions, categories of Personal Data shared with third parties, categories of
third parties with whom data is shared, and any sale of data or targeted advertising.
Categories of Personal Data & Categories of third parties with whom Personal Data is shared:
Under the paragraph “Data We Collect and Purpose of Collection and Use” of this Privacy Policy,
we describe our collection and processing of Personal Data, the categories of Personal Data that are
collecting and processing, and the purposes for which Personal Data is processed, stored or used.
Additionally, under the paragraph “Sharing Data with Third Parties” of this Privacy Policy, we detail
and disclose the categories of third parties we share Personal Data with for business purposes. We
will not collect additional categories of Personal Data or use the Personal Data we collected for a
materially different, unrelated, or incompatible purpose without obtaining your consent.
“Sale” of Personal Data:
Under US privacy laws, in principal, the term “sale” is referring to disclosing or making available
Personal Data to a third-party in exchange for monetary or other valuable consideration, including
for targeted advertising purposes. We do not “sell” information as most people would commonly
understand that term, we do not, and will not, disclose your Personal Data in direct exchange for
money or some other form of payment however, subject to the definition of the term “Sale” under
US privacy laws, we may “sell” the following categories of Personal Data when we use cookies or
other third-party advertising services:
• Identifiers – online identifiers such as IP and Cookie ID;
• Internet and electronic network activity information – such as your engagement with our
Website and ads.
• Geolocation data - derived from IP (country level).
Consumer Rights:
Residents of certain U.S. states, including Colorado, Connecticut, Virginia, and Utah, may have
additional rights under applicable privacy laws, subject to certain limitations, which may include:
● Access - the right to confirm whether we are processing their Personal Data and to obtain a copy
of their Personal Data in a portable and, to the extent technically feasible, readily usable format.
● Delete - the right to delete their Personal Data provided to or obtained by us.
● Correct - the right to correct inaccuracies in their Personal Data, taking into account the nature
and purposes of the processing of the Personal Data.
● Opt-Out - to opt out of certain types of processing, including: (i) to opt out of the “sale” of their
Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing
of Personal Data for purposes of making decisions that produce legal or similarly significant
effects.
The paragraph “Your Rights Under Privacy Protection Laws” provides additional information
regarding your principal rights.
Exercising Your Privacy Rights:
You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by
contacting us at: [email protected]
When you submit a request, we will take steps to verify your identity and your request by matching
the information provided by you with the information we have in our records. In some cases, we
may request additional information to verify your identity, or where necessary to process your
request. If we are unable to verify your identity after a good faith attempt, we may deny the request
and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.
To exercise your right to opt-out of the “sale”, you may use the cookies preference management
tool on our Website to change your preferences and opt-out of cookies.
Authorized agents may initiate a request on behalf of another individual by contacting us at
[email protected] ; authorized agents will be required to provide proof of their authorization
and we may also require that the relevant consumer directly verify their identity and the authority
of the authorized agent.
If we decline to take action on your request, we shall so inform you without undue delay, within the
timeframe set out under applicable law. Our notification will include a justification for declining to
take action and instructions on how you may appeal. Within the timeframe set out under applicable
law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the decisions. If the appeal
is denied, you may submit a complaint to the applicable authority or Attorney General of your
jurisdiction (including - Colorado AG at https://coag.gov/file-complaint/; Connecticut Attorney
General at: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318; Virginia Attorney General
at https://www.oag.state.va.us/consumercomplaintform).
CONTACT US
Please contact us if you have any questions regarding this Privacy Policy. You may contact us by
sending an email to our privacy team at: [email protected].