Privacy Policy

Last Updated June 30, 2020

We at Triblio (Triblio, Inc.) are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Triblio on our websites (“Websites”) including www.triblio.com, or through other channels as described below where we may be considered to be a “Controller”. It also describes your choices regarding use, access, and correction of your Personal Data.

We may periodically update this Privacy Policy. While we will notify you of any material changes to this Privacy Policy by posting a notice on our Website, prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically.

1. Information We Collect

When You Visit our Websites

When you visit our Websites, we may request that you provide Personal Data in order to access certain content, register for events etc. You are free to explore the Websites without providing any Personal Data. However, we do collect Navigational Information, which means navigation patterns of a given visitor on a Website. Navigational Information includes being able to identify the content that a particular visitor may interact with while on the Website, and such Navigational Information may be considered Personal Data. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches. We do not ask for any Sensitive or Special Category Data.

Log Files

When you view content provided by us on our Websites, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by us to collect general statistics regarding use of the Websites. For these purposes, we do link this automatically collected data to Personal Data you have provided or that we have collected from third parties such as your name, email address, address, and phone number.

Information we collect from third parties

From time to time, we may receive Personal Data about you from third party sources including partners with which we engage in joint marketing activities.

Information About Children

The Websites and the associated Subscription Services, provide content and information for a professional audience, and are not intended for or targeted at children under the age of 13, and we do not knowingly or intentionally collect Personal Data about children under 13. If you believe that we have collected Personal Data about a child under 13, please contact us by going to the Questions, Concerns, and Complaints section here, so that we may delete the information.

Triblio’s Use of the Subscription Service when you Visit our Websites

Please note that Personal Data Triblio processes on behalf of our customers (“Customer Data”) in our capacity as a processor, is covered by and subject to the Triblio Subscription Service (the “Subscription Service”) Terms and Conditions between the Customer and Triblio. The Subscription Service is made available to Triblio customers via a separate subscription agreement whereby Triblio licenses its commercial platform application.

We use the services we provide via our own Subscription Service to personalize content experience and serve advertising on our Websites for visitors from specified organizations or groups of organizations.

We collect information about the Subscription Services that you use and how you use them. This information includes but is not limited to:

IP Address information. We may collect and process IP addresses in the use of the Subscription Service. When a visitor visits a website that uses the Subscription Service, the IP address of the visitor may be captured and processed to identify the organization that the visitor is coming from and to personalize the website content to be relevant to the visitor.

Navigational information. We may record the navigation patterns of a given visitor on a website that uses the Subscription Service. This includes being able to identify the content that a particular visitor may interact with while on the website.

Local storage. We may collect and store personal data locally on your device using mechanisms such as browser web storage and application data caches.

Cookies and similar technologies. We use various technologies to collect and store personal data when you visit our Websites, and this may include using cookies or similar technologies to identify your browser or device. A cookie is a text file that is placed on your hard disk by a Web server. Cookies are uniquely assigned to you and can only be read by a Web server in the domain that issued the cookie to you. Please see our Cookie Policy here.

2. How We Use Information We Collect

Sale of Personal Data

We do not ‘sell’ the Personal Data we collect from you from your interaction with our Website(s). However, given the broad definition of ‘sale’, our sharing of your Personal Data with our marketing partners and other third parties, as described in this Privacy Policy, may be considered a sale under the California Consumer Privacy Act (“CCPA”). For more information, see the section, Visitors from California, here.

Use of Personal Data

In addition to the uses described elsewhere in this Privacy Policy, we may use the Personal Data we collect to:
(a) improve your browsing experience by personalizing the Websites and to improve the Subscription Service;
(b) send information to you which we think may be of interest to you by post, email, or other means;
(c) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you (however, in those cases, we do not transfer your Personal Data to the third party);
(d) send information to you regarding changes to our Privacy Policy, or other legal agreements;
(e) other legitimate interests of Triblio; and
(f) meet compelled disclosure requirements (see Compelled Disclosure below, resolve disputes and enforce our agreements.

Security of your Personal Data

We use a variety of security technologies and procedures to protect and secure the Personal Data we collect from unauthorized access, use, and disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures. Data-at-rest is encrypted with 256bit encryption. Transmitted data is protected by Secure Sockets Layer (SSL) protocol.

If you have any questions about the security of your Personal Data, you can contact us by going to the Questions, Concerns, and Complaints section here.

Retention of Personal Data

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

3. How We Share Information We Collect

Service Providers

We employ other companies and people (“Service Providers”) to provide services to visitors to our Websites and our customers and users of the Subscription Service and may need to share your Personal Data with them in order to provide information, products or services to you. Examples may include analyzing data or performing statistical analysis, providing marketing assistance, supplementing the Personal Data you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such Service Providers, we explicitly require them to acknowledge and adhere to our privacy and customer data handling policies.

Corporate Changes

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Triblio on the Websites and the Subscription Service.

Compelled Disclosure

We reserve the right to use or disclose the Personal Data we collect if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

4. Opting out and Unsubscribing

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by contacting us by going to the Questions, Concerns, and Complaints section here.

Please check the sections Visitors from the EU/EEA and Visitors from California for other rights.

5. Questions, concerns, or complaints.

If you have questions, concerns, or complaints or wish to contact our Data Protection Officer you will find details here.

Visitors from the EU/EEA

Visitors to our Websites from the EU/EEA have additional rights under the General Data Protection Regulation (GDPR)

Legal basis for processing Personal Data (EU/EEA visitors only)

If you are a visitor to our website(s) (“Websites”) and are located in the European Union (“EU”)/European Economic Area (“EEA”), Triblio’s legal basis for collecting and using the Personal Data described in the Privacy Policy will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you (unless prohibited by law) whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

International Transfer of Personal Data

Triblio uses and complies with the European Commission-approved standard contractual clauses (“SCCs”) for the transfer of Personal Data from the EU/EEA to the United States or other countries that do not have equivalent privacy and data protection laws. We are responsible for processing such Personal Data we receive under the SCCs and for any subsequent onward transfer to a third party who provides services to us and is acting as an agent on our behalf.

How to Access & Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Data

You have the following data protection rights:

You can request access, correction, updates, or deletion of your Personal Data.

You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your Personal data.

If we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time going forward. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

To exercise any of these rights, please contact us at privacy@triblio.com or by mail to Triblio, Inc., 11600 Sunrise Valley Drive #100, Reston, VA, 20191, USA, Attention: Privacy, or see Questions, concerns or complaints below. We will respond to your request to change, correct, or delete your information without undue delay and notify you of the action we have taken. You also have the right to complain to a data protection authority about our collection and use of your Personal Data.

To Unsubscribe from Our Customers’ Communications

Our Customers are those who license our Subscription Services, as described in our Privacy Policy, are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our Customers’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.

Questions, concerns or complaints

If you have questions, concerns, or complaints or wish to contact our Data Protection Officer you will find the details here.

Visitors from California

California Privacy Notice Pertaining to Triblio’s Website(s)

This Notice for California Residents supplements the information contained in Triblio’s Website Privacy Policy and applies solely to California consumers as defined in the California Consumer Privacy Act of 2018 (CCPA).

In the below tables and sections, we describe (as required by the CCPA):

Personal Information We Collect – the types of personal information that we collect, the types of sources we collect it from.

Disclosure and Sale of Personal Information –the types of recipients to whom we disclose or sell personal information.

Your Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights).

Questions, Concerns, and Complaints – how you may contact us.

The following sets forth the categories of information we collect and purposes for which we may use California consumers’ personal information:

1. Personal Information We Collect

Triblio collects certain categories of personal information in connection with our website(s) (“Websites”). Personal information is broadly defined under CCPA as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device.

Triblio may collect about you the categories of personal information summarized in the table below. The following table also describes how we collect and use such categories of personal information.

Identifiers‍

real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers

Categories of Sources - Directly from data subject, inquiries About Triblio products and/or services, Triblio website(s)
Purpose for Collecting - Operating our Website(s), To market our products and services to you, and other operational purposes

Categories from CA Civil Code 1798.80‍

name, address, telephone number, employment information

Categories of Sources - Directly from data subject, inquiries About Triblio products and/or services, Triblio website(s), Marketing Partners
Purpose for Collecting - To market our products and services to you, and other operational purposes

Internet or electronic network activity information

‍information regarding a consumer’s interaction with a website

Categories of Sources - Triblio website(s)
Purpose for Collecting - Operating our Website(s), To market our products and services to you, and other operational purposes

Professional or employment-related information

Categories of Sources - Directly from data subject
Purpose for Collecting - To market our products and services to you, and other operational purposes

Inferences drawn from any information above to create a profile about a consumer reflecting consumer’s preferences and behavior

Categories of Sources - Triblio website(s)
Purpose for Collecting - To market our products and services to you, and other operational purposes

2. Disclosure and Sale of Personal Information

We do not ‘sell’ the personal information we collect from you from your interaction with our Websites. However, given the broad definition of ‘sale’, our sharing of your personal information with our marketing partners and other third parties, as described in our Privacy Policy, may be considered a sale under CCPA.

Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing with Service Providers: We may share personal information with our service providers to help deliver services accessed through our website(s) and to deliver content and fulfill requests made on our website(s). Service providers are contractually prohibited from using the personal information for purposes outside of providing specific services to us.

3. Your Rights and Choices

While the CCPA provides California consumers with specific rights regarding their personal information, including the right to opt out of sale, the right to access and the right to deletion, the personal information we collect, use, and disclose from your interaction with our websites is largely used for business-to-business purposes. For example, when you are acting as a representative of your company and inquiring about our products or services.

You can unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails or by contacting us by going to the Questions, Concerns, and Complaints section here.

Further, to the extent that the collection or sharing of any cookies, as applicable, constitutes a sale under the CCPA, a California consumer can exercise the right to opt out by clicking the DO NOT SELL MY DATA button at the top of this page.

4. Questions, Concerns, and Complaints

If you have questions, concerns, or complaints or wish to contact our Data Protection Officer you will find details here.

Cookie Policy

This Website collects certain information via cookies and other online technologies. This Cookie Policy, as well as the Privacy Policy and the sections for Visitors from the EU/EEA and Visitors from California describes Triblio’s policies and practices regarding its use of information collected on this Website and sets forth your privacy rights.

By using this Website and consenting to this Cookie Policy, you agree that Triblio can place cookies as we describe below, and you agree to the collection, sharing, and use of your Personal Data for personalization of advertising or other services.

What Are Cookies?

Cookies are small text files that can be stored on a User’s computer, tablet or mobile device (“Computer”) when you visit a website. A cookie will typically contain the name of the originating domain, the lifetime of the cookie, and a randomly generated unique number or other value.

Cookies used by Triblio identify you as a unique user by means of a tracking ID. The cookie itself is anonymous and does not contain any Personal Data, except when such information has been supplied by you, such as when you provide your name and email address when completing a registration form.

Why Do We Use Cookies?

Cookies improve your experience

‍We use cookies to help you access this Website faster and more efficiently. Cookies allow us to distinguish you from other users, so that we can recognize you each time you visit. Cookies also allow us to store user preferences and provide you with a positive experience when you browse this Website, including enabling you to personalize Website settings. Our marketing partners also collect web viewing data to ensure that you are seeing the most relevant advertising. Cookies are also used for the purposes set forth below.

Information Storage and Access

The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.

Personalization

The collection and processing of information about your use of this service to subsequently personalize advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, which inform future selection of advertising and/or content.

Ad selection, delivery, reporting

The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase. This does not include personalization, which is the collection and processing of information about your use of this service to subsequently personalize advertising and/or content for you in other contexts, such as websites or apps, over time.

Content selection, delivery, reporting

The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether you took any action related to the content, including for example clicking on content. This does not include personalization, which is the collection and processing of information about your use of this service to subsequently personalize content and/or advertising for you in other contexts, such as websites or apps, over time.

Measurement

The collection of information about your use of the content, and combination with previously collected information, used to measure, understand, and report on your usage of the service. This does not include personalization, the collection of information about your use of this service to subsequently personalize content and/or advertising for you in other contexts, i.e. on other service, such as websites or apps, over time.

Social Media Consents

Social Media cookies and pixels including Facebook, Twitter and LinkedIn

How Can I Opt-Out of Cookies?

Because certain jurisdictions, such as countries in the European Union, consider cookies that can identify you or the computer you are using as Personal Data, Triblio is required to obtain your consent before storing any such cookies. If we have reason to believe that this applies to you, based upon IP Address, you will be given an opportunity to opt out of any optional, non-functional cookies when you visit this Website for the first time and on occasion, as you visit the Website at other times. If this does not apply to you, you can use your browser, or third-party software to block the use of cookies when you visit our Website. To do so, please look at the menu on your browser, or visit www.allaboutcookies.org for more information about cookies and how you can turn them off. Or, you can use third-party “anonymizer” services to mask information in your cookies, or even general data such as your IP address.

GDPR and Your EU Privacy Rights

The General Data Protection Regulation (“GDPR”), (Regulation (EU) 2016/679) created some new rights for European Union residents and strengthened some existing data protection rights.

To the extent that any cookie placed by Triblio or a third party, as described above, can uniquely identify a Computer, or the person using that Computer, under GDPR, this is Personal Data. Therefore, the Privacy Policy and the section Visitors from the EU/EEA may also apply to any such Personal Data collected from its Users.

CCPA and Your California Privacy Rights

Similarly, the California Consumer Privacy Act (“CCPA”) created some new rights for California consumers with respect to data protection.

To the extent that any cookie placed by Triblio or a third party, as described above, can uniquely identify a computer, or the person using that computer, under CCPA this may be considered Personal Data. Therefore, the Privacy Policy and the section Visitors from California may also apply to any such Personal Data collected from its Users.

Cookie Policy Changes and Updates

We reserve the right to amend this Cookie Policy from time to time, as necessary. We will post a notice on this Website if there are material changes to the Cookie Policy, but you should also check this Website periodically to review the current policy.

How can we help? Getting in touch

If you have any questions, concerns, or complaints about Triblio’s Personal Data practices around cookies or this Cookie Policy, we encourage you to get in touch with our appointed Data Protection Officer (“DPO”), the details are here.

Questions, Concerns, or Complaints

To unsubscribe from any Triblio marketing communications, please email us at privacy@triblio.com.

If you have any other questions, concerns or complaints about Triblio’s Personal Data practices or this Privacy Policy, we encourage you to get in touch with our appointed Data Protection Officer (“DPO”). If you believe you have suffered harm due to a breach of your rights by Triblio under this Privacy Policy or Triblio has not handled your complaint in a reasonably efficient manner, any EU/EEA resident may also file a complaint with the applicable supervisory authority. Please see the links below.