TRIANGULUM INSIGHTS – PRIVACY NOTICE
Last updated: 05/07/2020
Introduction
Triangulum Insights, Inc., ("Triangulum"), "we", "us" or "our") takes the privacy and the security of data very seriously. This Privacy Notice ("Notice") explains who we are, how we collect, use and share personal information about you and how you can exercise your privacy rights.
QUICK LINKS
1. PROCESSING ACTIVITIES COVERED
2. WHO WE ARE
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
4. HOW DO WE USE YOUR INFORMATION?
5. COLLECTION OF PERSONAL INFORMATION BY THIRD PARTIES
6. WHO DO WE SHARE YOUR INFORMATION WITH?
7. INTERNATIONAL DATA TRANSFERS
8. YOUR PRIVACY RIGHTS
9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
10. WILL WE CHANGE THIS PRIVACY NOTICE?
11. CONTACTING US
1. PROCESSING ACTIVITIES COVERED
This Notice applies (unless a different Notice is displayed) to the processing of personal information collected by us in the usual course of business, including when you:
· Visit our websites (such as http://www.trianguluminsights.com/) that display a link to this Notice (the "Site" or "Sites"); visit our social media pages; visit our offices; receive communications from us, including emails, phone calls and texts; or register for, attend and/or otherwise take part in our events, tutorials or webinars (we collectively refer to all of these activities as our "Marketing Activities" in this Notice).
· Use or access the Triangulum Services as an authorized user of one of our customers who has provided you with access to Services ("Customer Personnel").
"You" may, depending on the context, be: a visitor to our Sites or social media; a recipient of our communications; or Customer Personnel.
This Notice does not apply to the personal information that we process as a processor on behalf of our customers in the course of providing our Services.
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We are Triangulum Insights, a company headquartered in the United States. We develop and provide campaign and brand health measurement systems with reporting deliverables that allow businesses to measure both online and offline advertising and marketing campaigns ("Services"). You can find out more about us and our Services here.
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If you are resident in the European Economic Area ("EEA"), UK or Switzerland, the controller of your personal information that we process for the purposes described in this Notice is Triangulum Insights, Inc.
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
The information we collect depends on the context of your interactions with Triangulum, and applicable law.
(A) Marketing Activities
Information you provide to us:
We may collect information about you in a variety of ways in connection with our Marketing Activities, such as when you:
● Communicate with us in any way (for example, through form submissions, via email or a phone call with one of our sales representatives);
● Contact us through or on our social media pages;
● Receive communications from us, including emails, phone calls and texts; and
● Register for, attend and/or otherwise take part in our events or webinars.
The personal information we collect may include:
● Business contact information (such as your name, phone number, email address).
● Professional information (such as your job title, institution or company).
● Nature of your communication.
● Financial Information (such as your credit card, or bank account information in the process of completing transactions)
● Marketing information (such as your contact preferences).
● Any information you choose to provide to us (including any notes or questions).
If you ever communicate directly with us, we will maintain a record of those communications and responses.
Information we collect automatically:
When you visit our Site or interact with our emails, like most websites, we use cookies and similar technologies such as web beacons, tags and JavaScript, alone or in conjunction with cookies, to automatically collect certain technical information from your browser or device. In some countries, including Switzerland and countries in the EEA, this information is considered 'personal data' under data protection laws.
The information we collect may include:
Device data - such as your IP address, your operating system, your browser, device information, unique device identifiers, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called the “exit page”), information about other websites you have recently visited, browser (software used to browse the internet); and
Usage data – such as information about how you interact with our emails and our Site, including the time and data of your use.
This information is used to analyze overall trends, to help us provide, improve and personalize our Marketing Activities and to guarantee their security and continued proper functioning.
For further information about our use of cookies and similar tracking technologies in connection with our Marketing Activities, please see the section "Cookies and Similar Technologies (Marketing Activities)" below
Information we collect from other sources: In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information may include mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), IP addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising, event promotion and optimizing our Sites, Services and Marketing Activities.
(B) Services
In general, we provide our Services to our customers and collect personal information on their behalf. As a result, for much of the personal information that we collect and process about individuals (such as survey respondents or end users of our customer's advertisements) through the Services, we act as a processor. This means, it is primarily our customers that control what personal information we collect through our Services and how we use it. Therefore if you have any privacy related questions about the practices or choices the relevant customers has made to share your information with us or any other third party, you should contact the relevant customer or review their privacy notice.
Information you provide to us:
If you are Customer Personnel, you (or your team administrator) may provide certain personal information to us to enable you to access and use the Services. For example – when you (or your team administrator) signs up to an account for the Services, when you consult customer support or send us an email or communicate with us.
The personal information we collect may include:
● Business contact information (such as your name, job title, organization, phone number, email address and country);
● Account log-in credentials (such as your email or username and password);
● Troubleshooting and support data (which is data you provide or we otherwise access in connection with support queries we receive from you. This may include, for example, contact or authentication data, the content of your chats and other communications with Triangulum);
● Survey Data (this is information provided by respondents to surveys conducted by (or on behalf of) customers and which Customer Personnel (or third parties acting on behalf of the customer) provide to Triangulum in connection with the Services). As discussed above, in most cases, Triangulum processes any personal information (if any) in Survey Data as a processor acting on behalf of the relevant customer (the controller). However, Triangulum may process Survey Data for the purposes of preparing aggregate anonymized statistical training data that is not capable of identifying any individual or customer for the purposes of developing and improving its Services.
If you ever communicate directly with us, we will maintain a record of those communications and responses.
Information we collect automatically:
When you use or interact with the TI Platform, we (or our vendors) automatically collect or receive certain information through our Services (for example in log files) and through other technologies (such as cookies) about your device, the performance and configuration of the TI Platform, and your consumption of, interaction with and use of the Services. This information may include:
· Usage data, which is service-related, diagnostic, usage and performance information our (or our vendors) servers automatically collect when you access or use our Services. This data may include browser information and settings (such as the browser type, viewport or viewing pane, screen resolution, whether or not Java is enabled, and the version of Flash used) and information about your activity in the Services such as information about the pages viewed (such as the URL and title), and click-stream data.
· Location data, such as information about your device's location, based on your IP address.
Some of the data automatically collected, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this data is primarily used for the purposes of the performance of the Services (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of services to our customers (where we act as a data processor). For further information see the section "Cookies and Similar Technologies" below.
COOKIES AND SIMILAR TECHNOLOGIES
In connection with our hosted Services and Marketing Activities, Triangulum uses cookies and similar technologies such as tags and pixels.
Like many websites and services, we use cookies served by Google Analytics to automatically collect limited data about the computer, mobile device, or other devices you use to access our Sites and Services, to help us analyze how users use our Sites and Services, including making use of the demographics and interests reports services of Google Analytics. The information (including your IP address) collected by the technology will be disclosed to or collected directly by Google, who use the information to evaluate your use of our Sites. Further information on how Google collects and uses this data can be found at https://www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics by visiting https://tools.google.com/dlpage/gaoptout/
For further information about our use of cookies or other similar technologies, your choices regarding the use of cookies, and how you can block certain cookies in connection with our Marketing Activities, please read our Cookie Notice.
4. HOW DO WE USE YOUR INFORMATION?
We use and process the personal information we collect and/or receive (alone or in combination) for the following purposes and on the legal bases identified below:
● Providing and facilitating the delivery of our Services: We process your personal information to perform our contract with you for use of our Services and to fulfil our obligations under applicable terms of use/ service; or where we have not entered into a contract with you, we base the processing of your personal information on our legitimate interest to operate and administer our Services.
● Communicating with you about the Services: We may send you service, technical and other administrative or technical email, messages and other types of notifications (such as distribution and product updates and product patches and fixes) in reliance on our legitimate interests in administering the Services and providing certain features. These communications are considered part of the Services and in most cases you cannot opt-out of them. If an opt-out is available, you will find that option within the communication itself or in your account settings.
● Promoting the security of our Sites and hosted Services: If you visit our Site or access your account with us, we may process your personal information by tracking use of our Site and such Services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the Site and our hosted Services, and in protecting our rights and the rights of others.
● Handling contact and Customer support requests: If you contact us, we process your personal information to perform our contract with you and/or (if we have not entered into a contract with you) to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.
● Developing and improving our Marketing Activities and Services: We process your personal information to analyze trends and to track your usage of and interactions with our Marketing Activities and Services to the extent it is necessary for our legitimate interest in developing and improving our Marketing Activities and Services and providing you with more relevant content and service offerings, or where we seek your valid consent.
● Assessing and improving user experience: We process device and usage data as described above, which in some cases may be associated with your personal information, in order to analyze trends in order to assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving our Marketing Activities and/or Services, or where we seek your valid consent.
● Reviewing compliance with applicable usage terms: We process your personal information to review compliance with our contract with you or your organization (where applicable) to the extent that it is in our legitimate interest to ensure adherence to the relevant terms.
● Assessing capacity requirements: We process your personal information to assess the capacity requirements of our Services the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our service offerings.
● Identifying customer opportunities: We process your personal information to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their user experiences.
● Displaying personalized advertisements and content: We process your personal information to conduct marketing research, advertise to you, provide personalized information about us on and off our Site and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in supporting our Marketing Activities or advertising our Services or, where necessary, to the extent you have provided your prior consent (please see the "Your Privacy Rights" section, below, to learn how you can control how the processing of your personal information for personalized advertising purposes).
● Sending marketing communications: We will process your personal information to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters) about us when this is in accordance with your marketing preferences, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the "Your Privacy Rights" section, below, to learn how you can control the processing of your personal information by Triangulum for marketing purposes).
● Complying with legal obligations: We process your personal information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Site, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
Where we need to collect and process personal information by law, or under a contract we have entered into with you, and you fail to provide the required personal information when requested, we may not be able to perform our contract with you.
5. COLLECTION OF PERSONAL INFORMATION BY THIRD PARTIES
Some links on our Site may redirect you to third party resources, including websites and services that Triangulum does not operate. The privacy practices of these websites and services will be governed by their own policies.
We make no representation or warranty as to the privacy policies of any third parties, including the providers of third party applications. If you are submitting information to any such third party through our Site or Services, you should review and understand that party’s applicable policies, including their privacy policy, before providing your information to the third party.
6. WHO DO WE SHARE YOUR INFORMATION WITH?
We do not sell or share your personal information with third parties except as outlined below. We may disclose your personal information to the following categories of recipients:
● Service providers. In order to use our Services and undertake our Marketing Activities, it may be necessary for us to disclose your information to contracted third parties and service provider partners who perform certain functions of our service on our behalf. Examples include cloud hosting providers (to provide data storage and processing services); user authentication providers; and analytics company (such as Google Analytics) to perform analysis on the Site and usage of the Services.
● Compliance with laws. We may disclose information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or other legal process (including in response to public authorities to meet national security or law enforcement requirements).
● Vital interests and legal rights. We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Notice, or as evidence in litigation in which we may be involved.
● Business transfers. We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Notice.
● Consent. We may share your information with any other person with your consent to the disclosure.
7. INTERNATIONAL DATA TRANSFERS
Our Site and Services are hosted in the United States. Your information may be transferred to, stored, and processed by Triangulum in our facilities and by those third parties with whom we may share your personal information, in the United States, European Union, the United Kingdom and other locations where we have offices or service providers. These countries may have data protection laws that are different to the laws of your country. Regardless of where your data is located, we: (a) treat all personal information in accordance with applicable law; and (b) take reasonable steps to ensure the security of personal information.
If you are resident in or a visitor from the EEA, United Kingdom or Switzerland, we will protect your personal information when it is transferred outside of such locations by processing it in a territory which the European Commission has determined provides an adequate level of protection for personal information; or otherwise implementing appropriate safeguards to protect your personal information, including through the use of Standard Contractual Clauses or another lawful transfer mechanism approved by the European Commission.
If you require further information about our international transfers of personal information, please contact us using the contact details in the “Contact Information” section further below.
If you require further information about our international transfers of personal information, please contact us using the contact details in the “Contact Information” section further below.
Where we are acting as a controller of your personal information, and depending on your location and subject to applicable law, you may have the following rights with regard to the personal information we control about you.
● You can access, correct, update and delete your personal information by emailing us at [info@trianguluminsights.com].
● In addition, if you are resident in or a visitor from the EEA, United Kingdom or Switzerland, you can submit a request to object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. To exercise these rights, please send an email to [info@trianguluminsights.com].
● You can opt out of receiving marketing emails from us by following the unsubscribe link in the emails or by emailing [info@trianguluminsights.com]. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or other transactional, non-marketing purposes.
● If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
● You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. If you are resident in the EEA or the United Kingdom, the contact details for data protection authorities are available here.
9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We retain your personal information where we have an ongoing legitimate business need to do so and for a period of time consistent with the original purpose as described in this Notice. We determine the appropriate retention period for personal information on the basis of the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiration of the applicable retention periods, we will either delete or anonymize your personal information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information.
10. WILL WE CHANGE THIS PRIVACY NOTICE?
Each time you use our Site, or interact with us, the current version of the Notice will apply. Each time you interact with us, you should check the date of this Notice (which appears at the top of this Notice) and review any changes since the last version.
If we make material changes to this Notice, we will notify you either by prominently posting a notice of such changes prior to implementing the changes or by directly sending you a notification. We encourage you to review this Notice frequently to be informed of how Triangulum is protecting your information.
To contact us with your questions or comments regarding this Notice or the information collection and dissemination practices of the Site or our Services, please email us at [info@trianguluminsights.com]. Alternatively, you can contact us in writing at PO Box 111, Fairfield, CT 06824.