This policy applies to any online and mobile website, application and digital service (“Services”) of Tricoya Technologies Limited and its group entities which display this policy (“Tricoya“, “we“, “us” and “our“).
It also describes your data protection rights, including a right to object to some of the processing which Tricoya carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
Summary of how we use your data
- We use your personal data to allow you to use the Services.
- If you give us permission, we will send you news and promotional material about our Services. You can change your mind about this at any time and ask us not to process your personal data for direct marketing purposes, including profiling related to direct marketing. This policy explains when we process your personal data for our legitimate interests. You can ask us to stop processing the personal data. Further details are set out below.
- We provide interactive features that engage with social media sites, such as Facebook, Twitter and LinkedIn. If you use these features, these sites will send us personal data about you.
- We disclose your personal data when you agree that we can share this information with business partners or other Tricoya affiliates. We also share your personal data with third parties we engage to process personal data on our behalf or when such sharing is required by law, or in certain other situations.
- We transfer your personal data to the United States and to other countries and have measures in place to protect personal data that we collect, store and transfer.
What information do we collect?
The following categories of personal data will be collected about you in connection with your use of the website and your interaction with us, including, but not limited to, when you fill in forms on the website, and submit user-generated reviews or ratings, engage in any social media functions on the website:
- personal identification information: such as, your name, date of birth, gender;
- contact information: such as, email address and telephone number;
- company information: such as job title;
- demographic information: such as, address;
- your marketing preferences, including any consents you have given us; and
- information related to the browser or device you use to access our website.
In addition, if you contact us by phone, email or otherwise, we may keep a record of that correspondence.
What information do we receive from third parties?
Sometimes we receive personal data about you from third parties.
When you engage with our content through social media, or other non-Tricoya, sites or applications, those sites will share personal data with us about the content you have viewed or interacted with and about adverts within the content which you have been shown or clicked on.
The privacy policies for these sites and applications will contain more detail about this and how to change your privacy settings on those sites and applications.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
- To fulfil a contract, or take steps linked to a contract. This includes:
- communicating with you and providing customer services;
- sending you information about changes to our terms or policies.
- As required by Tricoya to conduct our business and pursue our legitimate interests, in particular:
- we will use your information to provide products and services you have requested, and respond to any comments or complaints you may send us;
- we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
- we use information you provide to personalise our website, products or services for you;
- to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with applicable law;
- we use information you provide to investigate any complaints received from you or from others, about our website or our products or services; and
- we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
- Where you give us consent:
- to send you newsletters you have requested and to use technologies to check if these have been received and opened;
- we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners;
- we place cookies and use similar technologies (as set out in the “Cookies” section) and the information provided to you when those technologies are used;
- to send you content, offers, rewards, and promotional materials, by email or on other sites, apps or social media, which may be personalised based on your visits to and use of the Services and to check to see if these ads have been received and if they were of interest to you; and
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
- For purposes which are required by law:
- In response to requests by government or law enforcement authorities conducting an investigation.
Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this policy.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
Who will we share this data with, where and when?
We share your personal data:
- with service providers, licensees, distributers, manufacturers, suppliers, partners, sponsors, agents and representatives we have engaged to perform business-related functions on our behalf. For example, to: (a) conduct research and analytics; (b) create content; (c) provide customer support services; (d) conduct or support marketing; (e) fulfil orders; (f) handle payments; (g) host Services; (h) administer contests; and (i) maintain databases;
- in response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request;
- if we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets;
- with Tricoya affiliates, trading names and divisions within the Tricoya group of entities (Click here for a list of Tricoya group entities) for business purposes, customer service and other shared services functions.
We operate globally, so we do need to transfer your personal data internationally. In particular, your personal data will be transferred to and processed in the United States where many of our central databases operate and such other countries as required.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules.
Our Services do not target and are not intended to attract children under the age of 16. We do not knowingly solicit personal data from children under the age of 16 or send them requests for personal information.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us, or our Data Protection Compliance Manager using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
Where we require your personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us.