Privacy Policy

June 27, 2018

We at Trivie, Inc. (“Trivie”, “us”, “we”, or “our”) are committed to protecting your privacy. This Privacy Policy applies to our marketing website, www.trivie.com (the “Website”) and our subscription service platform for learning and training services licensed by Trivie to you (the “Services’). This agreement (the “Privacy Policy”) governs our data collection, processing and usage practices. It also describes your choices regarding use and access of your personal data. By using the Website and/or the Services, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use the Website or the Services.

INTRODUCTION

Trivie knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. We respect the privacy rights of consumers and recognize the importance of protecting the information collected about you. We have adopted this global online Privacy Policy to explain how we store and use the personal and non-personal information we collect during your use of our Website and Services.

EU–U.S. Privacy Shield and Swiss–U.S. Privacy Shield

Trivie participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework. Trivie is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.

Trivie is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Trivie complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Trivie is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Trivie may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Framework, Trivie commits to resolve any complaints about our collection or use of your personal information. Individuals or companies with inquiries or complaints regarding our Privacy  Policy should first contact our Data Privacy Manager at: privacy@trivie.com.

Trivie further commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning personal data transferred from the EU and Switzerland. Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

WHAT IS PERSONAL INFORMATION AND WHEN DOES TRIVIE COLLECT IT?

Website Visitors

A visitor accessing the Website is not required to provide any personal data. If a visitor submits an information request or inquiry to us, we may collect and retain such personal data as supplied by the visitor to facilitate return contact and answering of the request.

Cookies

Cookies are used only for the following purposes:

  1. To collect analytical statistics about use of the Website. Trivie uses Google Analytics and other similar service to gather this information. Details of how Google use this information are available at: www.google.com/policies/privacy/partners;
  2. To further the a visitor’s experience of the Website and to provide visitors with useful information pertaining to the Website; or
  3. By our third party service provider to display advertising to visitors of the Website with advertising information based on their interest in the Website and its content. Visitors may opt-out from receiving the targeted advertisements by visiting the NAI website opt-out page here: www.networkadvertising.org/choices or the DAA opt-out page here: www.aboutads.info or, for EU users, the EDAA opt-out page here: youronlinechoices.eu.

Registered Users

A Registered User is either: (i) an individual licensed to use the Services, or (ii) an individual identified by a company who licenses the Services. Trivie shall collect and store the Registered User’s email address, first name and last name pursuant to the Registered User’s use of the Services. This is used to identify the Registered User for purposes of logging in, performance data while using the Services, technical support, product updates, and to send application notifications when action is required.

Registered Users have the right to access their personal data, and may view or delete it at any time while logged into the Services in the Help areas of their account.

Trivie Registered Website

Trivie will assign the Registered User a website URL or app from which the Registered User may access the Services via a secure login that may contain an alpha numeric code or system generated password (the “Registered Website”). If authenticated, Trivie will record that the Registered User is a member of the Registered Website. If the Services are licensed by a company, the company site administrator, in their sole discretion, may choose to apply arbitrary tags to Registered Users, such as “employee group” “region” or “country”, to facilitate grouping in reports.

Should a Registered User wish to prevent their personal data being processed with the Services, they may request to have their account removed by submitting a request inside the Registered Website, to their own company’s administrator of their Services, or by request to privacy@trivie.com. Upon removal of a user’s account, their personal data will be deleted and they will no longer have access to the Services or the Registered Website.

Onward Transfer Principle

Trivie does not share, sell, rent or trade personal information to third parties for marketing or promotional purposes. However, any information collected by us may be shared if it is necessary to investigate, prevent or prosecute illegal activities, suspected fraud, violations to the Terms and Conditions, or as otherwise required by law or a valid government request (including, but not limited to, search warrants, subpoenas or court orders) and when we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others. Trivie may also share information if it is acquired by or merged with another company. In this event, Trivie will notify you via email and or a prominent notice on our website before information is transferred and becomes subject to a different privacy policy.

We may be required to disclose an individual’s personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

We also may provide your personal data to companies that provide services to help us with our business activities such as, but not limited to, our hosting or analytics provider (e.g. Amazon and Google). These companies are authorized to use your personal information only as necessary to provide these services to us.

Trivie is potentially liable under the EU-U.S. and Swiss-U.S. Privacy Shield Principles in cases of onward transfer of data about EU and Swiss individuals to a third party acting on behalf of Trivie as its agent if the third party engages in a manner inconsistent with the Privacy Shield Principles and Trivie is responsible for the event giving rise to damages.

Trivie shall ensure that any third party to which we disclose personal data provides the same level of privacy protection as is required by the Privacy Shield Principles and agrees in writing to provide an adequate level of privacy protection. Prior to disclosing personal information to a third party that is not acting as Trivie’s agent, we will notify you of such disclosure and provide you with the choice to opt-out of the disclosure.

Processing Personal Data Under General Data Protection Regulation (GDPR)

When you use Trivie products and services, we may collect certain non-personally identifiable information for purposes including improving our products and services, troubleshooting bugs, providing services to you, facilitating the provision of software updates, dynamically served content and product support as well as communicating with you. The non-personal information collected may include information about your computer, hardware, software, platform, game system, media, mobile device, and incident data, for example. We also collect other non-personal information such as username, user ID or persona, feature usage, game play statistics, scores and achievements, user rankings and click paths as well as other data that you may provide in surveys, and your account preferences. 

If you are a resident of the European Economic Area (EEA), you have certain data protection rights, and we employ commercially reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data at any time. If you wish to be informed what personal data we hold about you, and if you want it to be removed from our systems, please contact us privacy@trivie.com

In certain circumstances, you have the following data protection rights:

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your personal data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Trivie, Inc. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Whenever made possible, you can access, update or request deletion of your personal data directly within the Help section of the Registered Website. If you are unable to perform these actions yourself, please contact us at privacy@trivie.com to assist you.

Data Security and Integrity Contact Information

We use various safeguards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Trivie uses personal information supplied by or on behalf of Registered Users solely to facilitate use of the Services by said users and, where relevant, their managers or administrators. Trivie will take reasonable steps to verify the validity of personal information supplied, for example by validating email addresses and/or the source of data supplied.

U.S. Government Agency Governing Authority

Trivie, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Contact Information

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at privacy@trivie.com or by mail to Trivie, Inc., PO Box 12801, Dallas, Texas USA, Attn: Privacy.

We periodically update this Privacy Policy, and we may update this Privacy Policy from time to time by posting a new version online. Your continued use of the Website, the Services, and/or continued provision of personal data to us will be subject to the terms of the then-current Privacy Policy.

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