Trinity Tech Co., Ltd. and its affiliates (“Trinity”, “we”, or “us”), as the owner and operator of its applications, platforms, websites and services (the “Products”), has made every effort to provide accurate information; however, errors or omissions may occur. Trinity expressly disclaims, and will take no responsibility, for any errors, omissions or for the results obtained from using the information provided in the Products or through any correspondence through its domain, emails, newsletters, content distribution platforms or similar mediums. All information on the Products or sent through any medium is provided "as is," with no express or implied warranties. By using the Products, you also agree to be bound by the Terms and Conditions which are hereby incorporated by reference and can be found on each of the Products.
Trinity deeply respects your concerns for privacy, and understands that crypto-currency and its community is built around security and privacy. Therefore, this privacy policy (“Privacy Policy”) describes the type of information we collect, how we use this information and whom we share it. Based on the services we provide and in accordance with the EU General Data Protection Regulation (“GDPR”), we may be deemed, depending on the Product, both a data processor and a data collector. The phrase “personal information” refers to information by which you or the device you are using to connect to the Internet can be identified. If at any point you have any questions or privacy requests regarding this Privacy Policy please contact us via email at the address listed in Section 10. Contact Information.
1. PURPOSE, USE AND PROCESSING OF YOUR PERSONAL INFORMATION.
Trinity’s vision for Elastos Essentials and the Products are to develop a low barrier entry to the new Elastos decentralized internet and framework to run dApps on the Elastos blockchain framework. With that vision in mind, Trinity may use your personal information to tailor and continue to develop the Products to drive the growth of the new internet and development of dApps on the Elastos blockchain framework.
In addition to our main vision statement, we may use your personal information, sometimes combined with non-personal information, in the following ways:
2. TYPES OF Information WE COLLECT.
Personal Information means information that allows someone to identify or contact you. Non-personal information means information that does not directly identify you. We collect both types of information about you.
The following provides examples of the types of data that we collect from you and how we use the information.
| Context | Types of Data and Purpose for Collection |
|---|---|
| Account Registration | We may collect your name, DID, and contact information when you create an account. |
| Demographic Information | We may collect personal information from you, such as your age or location. |
| Experience, Skill Sets and Languages | You may provide and have us collect personal information regarding your experience and employment for certain subject matter knowledge, skill sets and spoken languages for Elastos and any other blockchain frameworks. |
| Email Interconnectivity | If you receive email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners it contains. |
| Feedback/Support | If you provide us feedback or contact us for support we will collect your name and e-mail address and possibly other personal information, as well as any other content that you send to us in order to reply. |
| Mailing List | When you sign up for one of our mailing lists we may collect your email address or postal address. |
| Online Forms and Submissions | We collect information you submit to us on the Products or through online forms to process your requests. |
| Surveys | When you participate in a survey we may collect additional information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. Unless expressly indicated on the face of the survey we do not use survey information to market products or services to survey participants. If you are provided a separate privacy policy on part of a survey or study, the terms of that policy shall govern your information. |
| Third Party Tracking | The Products may participate in behavior-based advertising. This means that a third party may be allowed to use technology (e.g., a cookie) to collect information about your use of the Products so that they can provide advertising about products and services tailored to your interests. If occurring, that advertising may appear either on the Products, or on other websites. You can opt-out of receiving advertising based upon your browsing behavior from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely prevent advertising based upon your browsing behavior you should also disable the cookies on your browser. |
| Web Logs | We may collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet), domain name, click-activity, referring website, and/or a date/time stamp for your visit. Web logs may be used for things like monitoring website usage levels and diagnosing problems. |
| Device Information | We may collect information about the device accessing the Products such as MAC address, device type, and device identifiers. |
| Cookies | We may use cookies and clear GIFs. “Cookies” are small pieces of information that a website or mobile website sends to your device while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). Among other things, cookies allow us to provide you with a more personal and interactive experience and to improve our marketing efforts. Persistent cookies may be removed by following instructions provided by your browser. If you choose to disable cookies some areas or features of our websites may not work properly. |
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
3. SHARING OF PERSONAL INFORMATION.
In addition to the specific situations discussed elsewhere in this policy, we disclose personal information in the following situations:
4. YOUR CHOICES.
You can make the following choices regarding your personal information:
5. EUROPEAN & GDPR PRIVACY RIGHTS
Under GDPR, in certain circumstances, you have the right to: (a) request access to any personal information we hold about you and related information, (b) obtain without undue delay the rectification of any inaccurate personal information, (c) request that your personal information is deleted or erased provided the personal information is not required by us for compliance with a legal obligation under European or Member State law or for the establishment, exercise or defense of a legal claim, (d) prevent or restrict processing of your personal information, except to the extent processing is required for the establishment, exercise or defense of legal claims; (e) object to the processing of your personal data, and (e) request transfer of your personal information directly to a third-party where this is technically feasible.
You also have the right to complain to the ICO (www.ico.org.uk) if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with GDPR. Further you may learn more about your rights by visiting www.ico.org.uk.
You can exercise any of these rights by contacting us using the instructions described in Section 10. Contact Information.
6. What are the legal grounds for our processing of your personal information (including when we share it with others)?
We rely on the following legal bases to use your personal data: (1) Consent, (2) Legal Obligation, or (3) Legitimate Interests.
Lawful basis: Consent
The reason we use this basis: With your consent, we process information to provide you with the best possible experience for the Products. We may process information in accordance with Section 1. Purpose, Use and Processing of Your Personal Information. Types of Information we collect may vary as explained in Section 2. Types of Information We Collect. You can withdraw your consent at any time by contacting us in writing using the Contact Information below.
Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
Sharing your information: We do not share your information with third parties.
Lawful basis: Legal obligation
The reason we use this basis: Trinity may rely on this lawful basis if we need to process your personal data to comply with a common law or statutory obligation.
Data retention period: In accordance with local legislation and statutory obligation.
Sharing your information: We do not share your information with third parties.
Lawful basis: Legitimate interests
The reason we use this basis: We may process your information to provide you with the best possible experience for the Products. This includes but is not limited to, (a) fraud detection and prevention (crime prevention), (b) compliance with foreign law, law enforcement, court and regulatory bodies’ requirements, (c) industry watch-lists and industry self-regulatory schemes, (d) information, system, network and cyber security, (e) general corporate operations and due diligence, (f) website or application development and enhancement, and (g) communications, marketing and intelligence.
Data retention period: We will continue to process your information under this basis until you withdraw consent or until it is determined that a legitimate interest no longer exists.
Sharing your information: We do not share your information with third parties.
7. HOW WE PROTECT PERSONAL INFORMATION.
No method of transmission over the Internet, blockchain or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
The Products may permit you to create an account. When you do you will be prompted to create a password or mnemonic phrase. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
8. COOKIES AND OTHER WEB DEVICES.
The Products utilizing a website can send its own cookie to your web browser if your browser's preferences allow it. Cookie settings can be controlled in your internet browser to automatically reject some forms of cookies. If you view the Products without changing your cookie settings, you are indicating you consent to receive all cookies from the Products. If you do not allow cookies, some features and functionality of our site may not operate as expected.
Trinity may use Adobe Flash technology (including Flash Local Stored Objects "Flash LSOs") that allow the Products to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the site, and collect and store information about your use of the site. Some of our application, platforms, websites or emails also use pixel tags, web beacons, clear GIFs, or other similar technologies to measure the success of marketing campaigns, and compile statistics about usage and response rates, and other purposes.
Trinity may use other web devices to track website and application usage and views. Please address any questions or concerns about our cookie or web device usage using the instructions described in Section 10. Contact Information.
9. MISCELLANEOUS.
The following additional information relates to our privacy practices:
10. Contact Information.
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate email address below. We will respond to your requests in accordance with this Privacy Policy and in a reasonable time and manner. Please note that Trinity may elect not to respond to unreasonable or irrelevant requests.
Trinity Tech Co., Ltd.
Address:Trust Company Complex, Ajeltake Road Ajeltake Island, Majuro MARSHALL ISLANDS, MH96960
Phone: 086-13817106015
Email: [email protected]
Thank you from all of us for being part of the Trinity and Elastos community.