Last Updated June 30, 2020
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.
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.
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.
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.
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.
(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);
(e) other legitimate interests of Triblio; and
(f) meet compelled disclosure requirements (see Compelled Disclosure below, resolve disputes and enforce our agreements.
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.
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.
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.
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.
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.
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.
If you have questions, concerns, or complaints or wish to contact our Data Protection Officer you will find details here.
Visitors to our Websites from the EU/EEA have additional rights under the General Data Protection Regulation (GDPR)
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.
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.
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 firstname.lastname@example.org 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.
If you have questions, concerns, or complaints or wish to contact our Data Protection Officer you will find the details here.
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:
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.
real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers
name, address, telephone number, employment information
information regarding a consumer’s interaction with a website
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.
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.
If you have questions, concerns, or complaints or wish to contact our Data Protection Officer you will find details here.
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.
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.
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.
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.
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.
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 cookies and pixels including Facebook, Twitter and LinkedIn
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.
Similarly, the California Consumer Privacy Act (“CCPA”) created some new rights for California consumers with respect to data protection.
To unsubscribe from any Triblio marketing communications, please email us at email@example.com.
Mr. John McGill
c/o IDG Direct
Great Strand Street
Dublin 1, Ireland
IDG Communications Media AG
Munich 80807, Germany
Triblio takes fraud seriously. Report fraud or suspicious activity to Triblio’s anonymous fraud hotline 888-248-3023.