1. What Personal Information Is Collected?‍

When you visit the Platform, sign up to become a Member of Trelli, when you enter any promotion or sweepstakes, or when you conduct any other activity on the Platform, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information for Members may include, but is not limited to:

• Contact Information: Your name, email address, postal address, telephone number, business contact information, or any other similar information.
• Identification and Demographics: Date of birth, gender, nationality, ethnicity, interests, lifestyle information, an accurate and authentic photo of yourself, height, geographic location, sexual orientation, sexual preferences, and other required and optional demographic information.
• Content: Member photos, videos, reviews, and other information you may submit, such as comments on the Platform, online forums, and social media platforms.
• Research and Feedback: Reviews and comments that you send through the Platform and social media platforms, by email, over the phone, or by mail.
• Device Information and Identifiers: IP addresses, cookie IDs, browser types and language, operating systems, platform type, and device type.
• Connection and Usage: Domain names, browsing activity, scrolling and keystroke activity, advertisements viewed, forms or fields you complete or partially complete, search terms, whether you open an email, content you view and duration, quality of the service, and interaction with the content, logs, and other similar information. If these events occur while you are offline, they may be logged and uploaded when you next connect.
• Geolocation: City, state, and ZIP code associated with your IP address or derived through Wi-Fi triangulation. Trelli will ask for your permission before using your precise location from GPS-based functionality on your mobile devices.
• Social Media Information: If you interact through a Third Party Platform, as defined below, or social media website using your social media credentials, depending on your social media settings, Trelli may have access to your information from that social network such as your name, email address, friend list, photo, age, gender, location, birthday, social networking ID, current city, your comments, and the people and other websites you follow.
• Phone Contacts: If you allow such collection, the Platform may have access to and collect your phone contacts. Such access allows Members to add friends to their Team.
• Additional Information: Any additional information you provide either directly through the Platform or through your participation, support request, interaction through Trelli’s social media accounts, or any other communications.

2. When Is Personal Information Collected?

Generally, you are not under any statutory or contractual obligation to provide Trelli any Personal Information; however, certain Personal Information may be automatically collected in order for you to use the Platform. Trelli collects Personal Information from you when you visit, enter, or use the Platform; contact Trelli; fill out an online form on the Platform; or otherwise enter any information on the Platform or Trelli’s social media platforms, which may include, but are not limited to, Facebook, Instagram, Twitter, TikTok, YouTube, Pinterest, Google, or other third party applications (together the “Third Party Platforms”).

3. Billing Information.

Trelli is a free downloadable mobile application. Trelli may offer other products and services for purchase through iTunes, Google Play, Vonage, or other external services authorized by us (each, an “External Service,” and any purchases made thereon, an “External Service Purchase”). Payments for all transactions are processed by the External Service, and not by us. We do not collect, store, or maintain any member billing information, such as debit card numbers, credit card numbers, billing addresses, and similar information (collectively, the “Billing Information”). All such Billing Information is collected and processed through such External Services pursuant to the terms and conditions of their privacy policies and terms of use.

4. Geolocational Information.

Certain features and functionalities of the Platform are based on a Member’s location. In order to provide these features and functionalities while a Member is using a mobile device, we may, with the Member’s consent, automatically collect geolocational information from that Member’s mobile device or wireless carrier and/or certain third party service providers. Such information is collectively called the “Geolocational Information.” Collection of such Geolocational Information occurs only when the Platform is running on a Member’s mobile device or computer. Members may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to that Member.

5. Other Information.

In addition to the Personal Information noted above that you voluntarily provide to us and the Geolocational Information that we automatically collect with your consent, we may collect additional information (collectively, the “Other Information”, and together with Personal Information, Billing Information, and Geological Information, the “Information”). Such Other Information may include:

From You. Additional information about yourself that you voluntarily provide to us, such as hobbies, personal interests, number of children, photos and/or videos of yourself, and other information that does not identify other people personally. By adding photos and/or videos of yourself to the Service, or to add other Content to the Service, you may grant Trelli access to your camera or photo albums. In certain jurisdictions, information such as your racial or ethnic origin or religion is considered “sensitive” or “special” information. We understand and acknowledge this information may be extremely personal but by voluntarily sharing this Personal Information on the Services you consent to our use of this information. At times we may ask you to participate in surveys or focus groups, or to provide us with your feedback. When you choose to participate, you are providing us with your insights and opinions into our products and services, and responses to our questions and testimonials. We collect information that you enter or use to register for promotions, events, or contests. When you contact our customer service team, we collect the information you provide us during the interaction. To improve our quality and training phone calls with our customer service team may be monitored or recorded to ensure high quality of service. When you ask us to communicate with other people, for example when you ask us to send an email on your behalf to someone who may or may not be a member of Trelli, we collect information about that person you give us, in order to complete your request. Lastly, we process your Trelli and private chats with other members as well as the content you publish to our Services.

From Your Activity. Information that we automatically collect when you use the Platform and/or the Services, including, without limitation:

• IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website Visitors visit, etc.;
• Information about a mobile device, including universally unique ID (“UUID”), Platform type and version (e.g., iOS or Android), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G, 5G); and
• Activity and usage information occurring via the Services, including purchase information, tagging data, favorites, survey responses, preferences, session lengths; and similar data.
• From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer or mobile device’s hard drive so that your computer or mobile device will “remember” information about your visit. We have an entire Cookie Policy, which you should read before creating an account on Trelli. You may access our Cookie Policy here.
• From Other Sources. Information that we collect or receive from TikTok, Facebook, Twitter, Instagram and/or other third party social media sites on which you have used the Services in accordance with their terms of use and privacy policies. We may collect information about you from other members of Trelli. For example, if a user contacts us about you as they use our Service, we may collect information about you that that member provides us with. Additionally, we may receive information about you from our partners and affiliates. This may occur when Trelli ads are published on a partner’s website or other platform and when we receive details regarding a Trelli campaign’s success.

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1. How Do We Get Your Consent?

When you provide any Information on the Platform, verify, or change your Information, complete a contact form, verify, or change your credit/debit card information, comment on a forum, or anything of the like, you are automatically consenting to the collection, storage, and use of such Information for your benefit and to improve Trelli’s offerings and your experience.

2. How Do You Withdraw Your Consent?

If you change your mind, you may withdraw your consent for the continued collection, use, or disclosure of your Information at any time by contacting Trelli directly. Trelli reserves the right to retain any information previously collected for the purposes of resolving any disputes, as well as for obtaining and/or analyzing its aggregated data analytics.

3. How Is Your Information Used?

We use your Information to provide and improve the Platform and the Services, process transactions, solicit your feedback, inform you about our products and services and those of our third party marketing partners, and administer our rewards and promotional programs. Trelli may use such Information in any of the following ways:

• To personalize your experience on the Platform.
• To provide and implement the Services.
• To maintain and improve the Platform to better serve you and provide a more seamless experience across all devices.
• To quickly process your transactions.
• To send periodic emails regarding products, services, events, or subscriptions, as they become available.
• To investigate and help prevent security issues, abuse, or violations of law or the Terms.
• Displaying content you generate, such as video, audio and comments on the Platform or on Third Party Platforms.
• Compliance with laws, regulations, and ethical business conduct.

4. How is your Personal Information Shared and Disclosed?

Trelli may share and disclose your Personal Information for the following reasons:

• Customer Instructions: You can determine your own policy for the sharing and disclosure of your Personal Information and Trelli does not control how you choose to share or disclose your Personal Information. Trelli will share and disclose your Personal Information in accordance with your instructions and in compliance with applicable law.
• Compliance with Applicable Law: If Trelli receives a request for information, Trelli may disclose Personal Information if it reasonably believes disclosure is in accordance with or required by any applicable law, regulation, or legal process.
• To Enforce Our Rights, Prevent Fraud, and For Safety: To protect and defend the rights, property, or safety of Trelli or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• Third Party and other disclosures of your Personal Information: Trelli may share your non-Personal Information with related Third Party Platforms, companies, advertisers, social networks, service providers, research companies, search engines, law enforcement, hosting partners, and other parties who assist Trelli in operating the Platform, conducting business, or otherwise servicing you. Trelli may also release your Personal Information under certain circumstances when Trelli believes it is appropriate to comply with the law, enforce its policies, and/or protect Trelli or others' rights, property, or safety. Trelli may also be required to disclose your Personal Information if required by law or in response to a valid request by a public authority (e.g., a court or governmental agency).
• With Consent: Trelli may share Personal Information with third parties when it has consent to do so.

5. Does Trelli Collect Information from Minors?

Trelli does not want to, and does not knowingly, collect any data from individuals under the age of eighteen (18). If Trelli learns that it has collected any such data, Trelli will take all reasonable measures to delete such information and will not use it for any purposes. If you become aware of any Information that Trelli has collected from a child under the age of eighteen, please contact Trelli immediately.

6. How do I opt-out, remove, or modify any Personal Information I have provided?

You can request to have your Information removed by contacting Trelli directly. Please note that Trelli may retain information about individual sales transactions in order to complete said transactions and for record keeping purposes.

7. How Is My Personal Information Protected?

Trelli takes the security of your Personal Information very seriously. Trelli implements a variety of security measures when you use the Platform, engage Trelli for the Services, or otherwise enter or input your Personal Information. You must prevent unauthorized Personal Information by selecting and protecting your sign-on mechanisms appropriately. Your Personal Information is accessible only to a limited number of persons who have the authority to access it, including but not limited to, contractors or agents Trelli may employ to perform tasks, fix bugs, and/or monitor the Platform on behalf of Trelli.

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Trelli may share your Personal Information with other companies, advertisers, partners, social networks, service providers, research and management companies, search engines, law enforcement, hosting partners, and other parties who assist in operating the Platform, conducting its business, or otherwise servicing you. Similarly, if Trelli is involved in a merger, collaboration, or acquisition, your Personal Information may be transferred. However, Trelli will provide you with notice before your Personal Information is transferred and becomes subject to a different privacy policy.

We may also share Information about your activity on the Platform with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Platform and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Information for such purposes. Pixel tags enable us, and these third party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

Trelli may also release your Personal Information under certain circumstances where Trelli believes release is appropriate to comply with the law, enforce its policies, and/or protect Trelli or others' rights, property, or safety. Trelli may also be required to disclose your Personal Information if required by law or in response to a valid request by a public authority (e.g., a court or governmental agency).

Behavioral Advertising

Trelli may use your Personal Information to provide you with targeted advertisements or marketing communications Trelli believes may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at https://thenai.org/about-online-advertising/faq/

If you have created an account on the Platform, you may access, review, and make changes to your Personal Information and certain Other Information in the Platform by following these simple instructions:

To make changes to the Personal Information and certain Other information on your account:

1. Select “Account” on the bottom of your screen
2. Tap Personal Stats
3. Edit the Personal Information you wish to change
4. Tap “Done” on the top right corner of the screen

In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Trelli marketing email.  Members cannot opt out of receiving transactional emails related to an active account.  We will use commercially reasonable efforts to process such requests in a timely manner.  You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

When a Member’s account is deactivated, Trelli will make reasonable efforts to make sure the account is no longer viewable on the Platform. It is not possible to restore a Member’s account if it was accidentally or wrongfully deactivated. After 30 days, Trelli may begin the process of deleting member’s account from our systems. Trelli is not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of a member’s account. To prevent abuse and/or misuse by a Member following termination or deletion of a profile/account, Trelli shall retain information as deemed necessary in its sole discretion to ensure that Member does not open a new profile in breach of our Terms of Use and to ensure compliance with all laws and regulations. Even after a member removes information or deletes their account, copies of that information may still be accessed to the extent such information was previously shared with others, copied or stored by others and Trelli cannot control this use and therefore does not accept any liability for this.

Trelli’s policy is to not disclose Members’ registration information unless the Member provides consent or as needed with certain trusted third parties that perform functions and services for Trelli (such as companies supporting Trelli’s services, managing payment processing, moderating content, or as needed for legal purposes). Trelli ensures that such third parties adhere to strict data protection and confidentiality provisions in line with this Privacy Policy.

Trelli is headquartered in the United States; however, Trelli may transfer your information to service providers and other third parties located outside of your country of residence, including in the United States. This may be necessary to provide its Services and for the purposes outlined in this Privacy Policy. Data privacy laws vary from country to country and may not be equivalent to, or as protective as, the laws in your home country. Trelli takes steps to ensure that reasonable safeguards are in place with the aim to ensure an appropriate level of protection for your Information, in accordance with applicable law. These measures include data transfer agreements. By providing Trelli with your Information you acknowledge and agree to any such transfer, storage or use.Some Services can only be provided if Trelli has your Personal Information, therefore deletion of your Information may result in termination of such Services. Trelli will take reasonable steps to verify your identity, including authenticating you through your email address. Trelli may require further documentation before granting access to your Information.

California

1. Special Notice to California Residents

Trelli shall not market or advertise to minors specified products or services that minors are legally prohibited from buying. Trelli shall not market or advertise any products based on the Personal Information provided that is specific to any minor, nor shall it knowingly use, disclose, compile, or allow a third party to do so. Under California's Privacy Rights for California Minors in the Digital World Act, any minor may request and obtain removal of Personal Information posted on the Platform.

2. Your California Privacy Rights.

California residents are entitled once a year, free of charge, to request and obtain information regarding Trelli’s disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. To obtain this information, please send an email to Trelli directly.

3. California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of Personal Information, as well as the right to access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

4. “Do Not Sell My Personal Information” (California Residents only)

California residents may opt-out of the “sale” of their Personal Information. California law broadly defines “sale” in a way that may include allowing third parties to receive certain information such as cookies, IP address and/or browsing behavior to add to a profile about your mobile device, browser, or you.

Depending on how you use the Platform, Trelli may share the following categories of information for such advertising which may be considered a sale (as defined by California law):

• Identification and demographics; device information and identifiers, such as IP address, and unique advertising identifiers and cookies; connection and usage information, such as browsing history; geolocation information, such as city; and inference data.

If you would like to opt-out of the use of your Personal Information for such purposes (to the extent this is considered a sale), you may do so as by contacting Trelli directly.

5. Third Parties’ List – Shine the Light (California Residents only)

California residents can also request a list of all the third parties to which Trelli has disclosed certain Personal Information (as defined by California’s Shine the Light law) during the preceding year for those third parties’ direct marketing purposes. You will need to attest to the fact that you are a California resident. Trelli will not accept requests by telephone, email, or facsimile, and Trelli is not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Nevada

Nevada law requires Trelli to post the following: certain Nevada consumers may opt-out of the sale of “Covered Information” for monetary consideration to a person for that person to license or sell such information. Covered information includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

Virginia

Virginia Consumer Data Protection Act (Effective January 1, 2023)

Under the Virginia Consumer Data Protection Act (“VCDPA”), certain businesses must give consumers the ability to access, control, and delete personal data that the business collects about them, or that consumers have otherwise provided. Consumers have the right to obtain a copy of data the consumer has previously provided, in a usable format “to the extent technically feasible.

Virginia consumers can opt out of targeted advertising, the sale of their personal data, or profiling those results in the business providing or denying “financial and lending services, housing, insurance, education enrollment, criminal justice, employment opportunities, health care services, or access to basic necessities, such as food and water.

Utah

Utah Consumer Privacy Act (Effective December 31, 2023)

The Utah Consumer Privacy Act (“UCPA”) provides Utah residents with the right to (1) confirm whether a controller is processing the consumer’s personal data and to access that personal data; (2) delete the consumer’s personal data that the consumer provided to the controller; and (3) obtain a copy of the consumer’s personal data that the consumer previously provided to the controller.

The UCPA defines “Personal Data” as information that is linked or reasonably linkable to an identified or identifiable individual. Data that cannot be linked to a consumer and publicly available information and the processing of personal data for purely personal or household purposes are excluded from the UCPA. Data controllers must provide consumers with reasonable, accessible, and clear privacy notice. Controllers must establish and maintain reasonable administrative, technical, and physical data security practices to protect the confidentiality and integrity of personal data and reduce reasonably foreseeable risks of harm to consumers relating to the processing of personal data.

Connecticut

Connecticut Data Privacy Act (Effective July 1, 2023)

The Connecticut Data Privacy Act (“CTDPA”) defines “Consumer” as a Connecticut resident and excludes persons acting in a commercial or employment context. The “Sale of Personal Data” refers to the exchange of personal data for monetary or other consideration by the controller to a third party.

Personal data excludes any deidentified data or publicly available information, where publicly available information means information that is lawfully made available through government records or widely distributed media and a controller has a reasonable basis to believe a consumer has lawfully made available to the general public.

Under the CTDPA, Connecticut consumers are provided with (1) the right to access; (2) right to correct; (3) right to delete; (4) right to data portability; and (5) right to opt out of the sharing of any Personal Data.

Colorado

Colorado Privacy Act (Effective July 1, 2023)

Under the CPA, “Consumers” are defined as residents acting in their individual or household contexts and excludes individuals acting in a commercial or employment capacity, job applicants, and beneficiaries of someone acting in an employment context from its definition of “consumer.” “Personal Data” is defined to mean information that is linked or reasonably linkable to an identified or identifiable individual. The CPA does not extend to deidentified data or publicly available information.

Under the CPA, businesses will need to provide consumers with clear privacy notices and conduct data protection assessments for any personal data processing that presents a heightened risk of harm to consumers. Consumers are afforded the right to opt out of the processing personal data for targeted advertising or for the sale of personal data and provides a “user-selected universal opt-out mechanism.

The Platform may contain links to third party websites. Trelli has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third party websites. You should check the applicable third party privacy policy and terms of use when visiting any other websites.

You acknowledge and agree that to the fullest extent allowed by applicable law, under no circumstances will you hold Trelli liable for consequential, indirect, incidental, special, exemplary, punitive, or enhanced damages, that are caused or alleged to be caused in connection with your use of the Platform, or your purchase or engagement with any of its Services. For clarity, under no circumstances will you hold Trelli liable for any damages caused by or related to the Platform and/or your use of the Services.

This Privacy Policy is effective as of November 7, 2019. We may change this Privacy Policy from time to time. By accessing the Platform and/or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Personal Information, the Geolocational Information, and the Other Information is governed by the Privacy Policy in effect at the time we collect the information. Please refer to this Privacy Policy on a regular basis so you can remain an informed consumer.

If you have questions about this Privacy Policy, please send us an email at socialteam@Trelli.com

Last revised on December 12, 2022