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PRIVACY POLICY

Last revised: July 20, 2023

  1. INTRODUCTION

Trumio Inc. (“Company,” “Us,” “Our,” or “We”) respects the privacy of the visitors and users of the Company’s website located at https://www.trumio.ai  and if applicable  (“Site”). This privacy policy (“Policy”) is an agreement between Company and You, as the user of the Site (“You”) and governs Our collection of information from You. 

  1. AGREEMENT TO TERMS OF PRIVACY POLICY AND TERMS OF USE

All of Your activities on the Site are voluntary.  You are not required to provide any personal information unless You choose to access features on this Site which require such information to be provided. If You do not agree with the terms of this Policy or Our Site Terms, then You should immediately exit the Site and discontinue using the Site.  Our Site Terms are expressly incorporated herein by reference and made a part of this Policy. By using the Site, You signify that You agree to the terms of this Policy as well as to Our Site Terms.  

  1. CHANGES TO PRIVACY POLICY

This privacy policy is effective as of the inception of this domain and will remain in effect except with respect to any of its provisions that are changed thereafter by Company. All revisions to this Policy will become effective on the date they are posted on the Site or the date that We notify You of the revisions, whichever is earlier. We reserve the right to change this Policy at any time.  You should check this Policy periodically as its terms may change from time to time. Your continued use of the Site modifications to this Policy will constitute Your agreement to abide and be bound by the modified Policy terms.  

  1. POLICY APPLICABLE TO ONLINE ACTIVITIES

The Policy applies to Your activities on the Site, and is not to be applied in any manner contrary to applicable law or governmental regulation.

  1. PERSONAL INFORMATION WE MAY COLLECT

The information we collect varies based on how you interact with us, which services you use, and the choices you make. We collect and process information about you with your consent and/or as necessary to provide the products and services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

We collect information about you in various ways when you use our services, including information you provide directly, information collected automatically, and information collected via third-party data sources.

When you are asked to provide information, you may decline. But if you choose not to provide information that is necessary for certain products or features, those products or features may not be available or function correctly.

The table below sets forth how we may collect and use your personal information.

CATEGORY OF PERSONAL DATA

PROCESSING PURPOSE

Information You Provide to Us

We collect information you provide directly to us, as follows:

Account Information
includes personal information we collect when you create an account, create or edit your profile. Account information includes your name and email address  and any other account-related information you choose to provide.

We use this information to

  • create and register your account on the Company Site;
  • enable communications between you and other users;
  • send you technical notices, updates, security alerts and support and administrative messages;
  • present you with content that is relevant to you;
  • communicate with you about products, services, offers, promotions, rewards, and events offered by Company and others, and provide news and information we think will be of interest to you.

Communication Information
includes the content of any communications you send and receive, such as messages or reviews (including private reviews), communications you send and receive when you participate in any other interactive features of our services, or your communications to or from Company.

We use this information to

  • provide, maintain and improve our services;
  • detect, investigate and prevent fraudulent transactions and other illegal or unauthorized activities and protect the rights and property of Company and others;
  • respond to your comments, questions and requests and provide customer service.

Identification Information
We may collect certain personal information from you for purposes of verifying your identity or assisting with your creation of an account.  

We use this information to

  • detect, investigate and prevent fraudulent transactions and other illegal or unauthorized activities and protect the rights and property of Company and others;
  • create a payment disbursement account with our third-party payment processor on your behalf.

Information Collected Automatically When You Use our services

When you access or use our services, we may automatically collect information about you, as follows:

Usage Information
We collect log information about your use of our services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our services, and information regarding your interactions with our sites and applications.

We use this information to

  • present our services to you on your device;
  • select a language and region in which to present our services to you;
  • provide, maintain and improve our services;
  • send you technical notices, updates, security alerts and support and administrative messages;
  • detect, investigate and prevent fraudulent transactions and other illegal or unauthorized activities and protect the rights and property of Company and others;
  • communicate with you about products, services, offers, promotions, rewards, and events offered by Company and others, and provide news and information we think will be of interest to you;
  • link or combine with information we get from other sources to help understand your needs and provide you with better service.

Device Information
We collect information about the computer or mobile device you use to access our services, including the hardware model, operating system and version, unique device identifiers, Company app version, mobile network information, and whether notification and location permissions are enabled.

Location Information
We may collect information about the location of your device each time you access or use certain features of our mobile applications or otherwise consent to the collection of this information. For more details, please see “Your Choices” below.

Cookie Information
We use various technologies to operate our services and collect information, including cookies and web beacons (collectively, “Cookies”). Most browsers are set to accept cookies. To learn more about how we use Cookies and how to manage your preferences, please read our Cookie Policy.

Inferences
We infer new information from other information we collect, including using automated means to generate information about your likely preferences or other characteristics. For example, we infer your city, state, and country location based on your IP address.

All Information Set Forth Above

All Information Set Forth Above

We use this information to

  • provide, maintain and improve our services;
  • detect, investigate and prevent fraudulent transactions and other illegal or unauthorized activities and protect the rights and property of Company and others;
  • defend ourselves from potential litigation or legal claims;
  • comply with any applicable legal obligations;
  • carry out any other purpose described to you at the time the information is collected.

 

5.1 ADDITIONAL INFORMATION WE MAY COLLECT

  1. TYPES OF INFORMATION COLLECTED. There may be other instances in which We collect information from You that is more general in nature (“General Information”). General Information may include Your Internet Protocol (IP) address, which enables Us to identify Your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, which includes the World Wide Web. Your computer has an IP address, which is required in order for You to communicate with others via the Internet. Such General Information may be collected from You whenever You access the site, whether or not You provide Us with any Personal Information.
  2. CLICK STREAM DATA. When You visit Our website We may also collect click stream data, including but not limited to server address, domain name, and other items (“Click Stream Data”). This information can be combined with information You have provided to Us by registering, for example, which will enable Us to analyze and better customize Your visits. We may use Click Stream Data for traffic analysis or e-commerce analysis of the Site, to determine which features of Our Site are most or least effective or useful to visitors and users.
  3. WEB BEACONS. A web beacon is an object that is embedded in a webpage or email that is usually invisible to and allows website operators to check whether the user has viewed a particular page or email (“Web Beacon.”) We may use Web Beacons on the Site or in Our emails to You to determine users who have visited particular pages, viewed emails, and to obtain other related information. Personal Information is generally not collected through the use of Web Beacons. Users generally do not have the ability to decline web beacons, but they can be rendered ineffective through use of the apparent browser modification settings to notify You each time a web cookie is tendered, which will permit You to decline all such cookies on an individual basis.
  4. MOBILE DEVICE DATA. If You access Site or services using a mobile device, the information relating to Your mobile device, including the device ID, model, manufacturer, operating system, version information, and IP address, may be collected.
  5. GEO-LOCATION INFORMATION. Information relating to Your location, and the location from which You are accessing Our services may also be collected, including general location data, the geographic location of the point of productivity, and Your IP geolocation information.
  6. PUSH NOTIFICATIONS. We may send You push notifications to Your mobile device, if You choose to receive them. To opt out of these types of communications, You may turn them off in Your device’s push notification settings.

  7. USES OF YOUR INFORMATION. 

We may share the personal information we collect with third parties as follows or as otherwise described in this Privacy Policy:

  • when you sign up for and participate in the interactive areas of our services
  • in response to a request for information if we believe disclosure is in accordance with, or required by, applicable law, regulation or legal process;
  • if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property or safety of Company, its employees, its users or the public;
  • in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, divestiture, bankruptcy, dissolution, or other transaction or proceeding involving sale, transfer or divestiture of all or a portion of our business or assets to another company, to the extent permitted under applicable law;
  • between and among Company and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;
  • on an aggregated and anonymized basis; and
  • with your consent or at your direction.
  • We may share aggregated information about You that does not include Personal Information (“Aggregate Information”) and We may otherwise disclose it with third parties for industry analysis, demographic profiling and other purposes. Any Aggregate Information shared in these contexts will not contain Your Personal Information.

BY REGISTERING WITH OUR SITE OR USING THE SITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION.  Certain Personal Information of Yours may be disclosed as a matter of course as a result of Your use on the Site, such as interactions You engage in. YOU ASSUME ALL RESPONSIBILITY FOR ALL PRIVACY DISCLOSURES OR OTHER HARM RESULTING FROM YOUR VOLUNTARY DISCLOSURE OF YOUR PERSONAL INFORMATION. 

6.1          ADDITIONAL USES OF PERSONAL INFORMATION PROVIDED.  We may use the Personal Information You provide and any General Information We receive from You to provide products and services to You and other visitors and/or users, including, but not limited to, the following:

  1. To administer a content promotion and provide You with relevant products or services.
  2. To send You information or materials via e-mail about products, offers, and news that might interest You. This information may relate to products, offers, and news of the Company or its licensees or selected commercial partners. If You no longer wish to receive any e-mails from Us, or if You want to modify Your Personal Information to alter or unsubscribe from these emails, You may unsubscribe at any time using the links provided in the emails.  
  3. To analyze visits to the website and learn about the interests of Our visitors and users in aggregate and also on a personal level to better understand Your interests and needs, so We can improve Our products and services and deliver to You the type of content, features and promotions that You are most interested in.
  4. Unless You opt to receive marketing materials, We may provide Your email information to third parties they can contact You about potential additional services and products. Even after opting out, You may continue to receive marketing emails from third parties with whom We already provided Your email information. You will be responsible for directly contacting such third parties to request the discontinuance of further marketing emails.
  5. We may also share Your information, including Personal Information, which may include Your name and contact information, email address, with Our service providers that provide services on Our behalf, such as our merchant processors.

6.2          OTHER USES.  To the extent that You provide Your information or other details with other users, including on elements or aspect of Our Site that are created by other users, Your information will also be shared with them.

6.4          ACCESS AND RECTIFICATION.  You have the right to access and to rectify Your Personal Information submitted to us, (in some circumstances, a fee may be payable to do so).  You may do so by sending an email to support @ trumio.ai. 

  1. DO NOT TRACK POLICY.

We do not track users or customers across third party websites to provide targeted advertising and therefore our Site does not respond to Do Not Track (DNT) signals.  However, some third party sites may keep track of Your browsing activities when they serve You content, which enables them to tailor what they present to You. If You are visiting such sites, Your browser may allow You to set the DNT signal on Your browser so that third parties (particularly advertisers) know You do not want to be tracked.   

Third parties that have content placed or embedded on Our website msuppay set cookies on Your browser and/or obtain information about the fact that a web browser visited a specific website from a certain IP address. Third parties cannot collect any other Personal Information of Yours from Our website unless You provide it to them directly.

  1. PROTECTION OF YOUR PERSONAL INFORMATION AND GENERAL INFORMATION

9.1.         RISK OF INTERCEPTION.  Whenever You give out Personal Information online there is a risk that third parties may intercept and use that information. While Company strives to protect Your Personal Information and privacy, We cannot guarantee the security of any information You disclose online. By using this site, You expressly acknowledge and agree that We do not guarantee the security of any data provided to or received by Us through this Site and that any Personal Information, General Information, or other data or information received from You through the Site is provided to Us at Your own risk, which You expressly assume.

9.2          LAW ENFORCEMENT. We reserve the right to disclose all information We may have obtained about You to law enforcement, to prevent fraud or abuse, or to protect Our legal rights.

9.3          SHINE THE LIGHT LAWS.  If You are the resident of a State that permits its residents to request and obtain information about Personal Information (if any) that have been disclosed to third parties for direct marketing purposes in the preceding calendar year, please contact us in writing to our privacy officer listed below.

  1. NO USE OF THIS SITE BY PERSONS UNDER 18 PERMITTED

10.1.       REGISTRATION DECLINED. Only persons who are 18 years or older are permitted to use this website. Personal registration information submitted by a person under the age of 18 will not be accepted.   Company is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We encourage parents and guardians of children under 18 to regularly check and monitor their children’s use of e-mail and other activities online.

10.2.       NOTICE CONCERNING CHILDREN.  PLEASE NOTE: We are a general audience site, and do not direct any of Our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If We learn or have reason to suspect that a Site user is under age 13, We will promptly delete all Personal Information in that user’s account. If You are a parent or guardian of a child under the age of 13 has become a member of the Site has otherwise shared Personally Identifiable Information with us, please contact Us using Our contact information below to have the child’s account terminated and deleted.

  1. THIRD PARTIES

11.1.      WHO MAY HAVE ACCESS TO YOUR INFORMATION. Other than to the companies belonging to or collaborating with Company for the purposes set out herein or as otherwise set forth herein, We do not sell, trade, or otherwise transfer Your Personal Information or General Information to third parties. We provide some of Our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “Service Partners”). Our service partners may use Your Personal Information to operate Our sites and to deliver their services. For example, Your data may be transferred to website hosting partners and other parties who assist Us in designing and operating the website, executing services, or helping Us analyze collected data. These parties will only use Your data for the purpose of carrying out the work as agreed with Us and will be required to keep the information confidential. We will encourage Our service partners to adopt and post privacy policies. However, the use of Your Personal Information by Our service partners is governed by the privacy policies of those service partners and is not subject to Our control.

11.2.       RELEASE OF INFORMATION. Company will release Personal Information or General Information without Your consent for security purposes, when required by law, requested by law enforcement, and/or to prevent imminent harm to any person or entity. We will disclose Personal Information or General Information upon receipt of a court order or subpoena in any civil matter, criminal matter and/or administrative, legislative, or other proceeding of any type or nature, and will to cooperate with a law enforcement investigations, which may include responding to requests and court orders from jurisdictions outside the United States. We fully cooperate with law enforcement agencies in identifying those who use Our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that We in good faith believe to be unlawful, as determined in Our sole discretion. Release of Your Personal Information or General Information to any person or entity under any circumstances shall be based on a determination made solely by us, exercising Our own discretion, permission for which is expressly granted by You to Us in accordance with this policy.

11.3.       Links to Third Parties. For Your convenience and to improve the usage of the website We may insert links to third parties on the Site. This Policy does not apply to such third party websites. Links to third party sites may take You outside Our service and off the Company’s Site and are beyond Our control. This includes links from partners that may use Company’s logos as part of a co-branding agreement. The sites may have their own separate privacy policies, and Company is not liable for the content and activities of those sites. Your visits and access to such sites is at Your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit Personal Information; and the privacy policies of those sites may collect greater, lesser, different, or other types of information than our Site may. 

  1. CALIFORNIA PRIVACY RIGHTS AND NOTICES

If the processing of your personal information is subject to the California Consumer Privacy Act (the “CCPA”), you have certain rights with respect to that information:

  • Right to Know. You can request access to the personal information we collected about you in the last 12 months. You can also request information about the categories of personal information we collected, the sources of collection, the purposes for collection and sharing of this information, the categories of information we shared, and the categories of third parties with whom we shared this information. Note that we have provided much of this information above in this Privacy Statement.
  • Right to Request Deletion. You can request that we delete personal information under certain circumstances, subject to a number of exceptions.
  • Right to Opt-Out. You can opt-out from any sharing of your personal information with third parties to the extent that such sharing constitutes a “sale” of that data under the CCPA.  
  • Right to Non-Discrimination. You will not be discriminated against by Company for exercising rights set out in the CCPA.

In the past 12 months, we have disclosed, for a business purpose, data from each of the categories of personal information we maintain to our business partners and vendors, as described in the table above.

The CCPA defines the “sale” of personal information very broadly, and some of our use of third-party cookies and tracking technologies as described in this Privacy Statement may be considered a “sale” under that definition. Specifically, in the past 12 months, we have allowed our advertising and analytics providers to collect IP addresses, cookie IDs, and mobile IDs through our sites and apps when you use our online services. We do not otherwise “sell” personal information.

We do not knowingly collect or sell personal information of minors under 16 years of age.

If you wish to exercise your California privacy rights, please contact us at support @ trumio.ai.  Please note that we need to verify your identity and request to the degree of certainty required by law before taking further action on your request. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting a request from an agent, we will require the agent to provide proof that you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

  1. EU SAFE HARBOR COMPLIANCE.

Company complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information from European Union member countries and Switzerland. Company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor.In compliance with the US-EU and US-Swiss Safe Harbor Principles, Company commits to resolve complaints about Your privacy and Our collection or use of Your Personal Information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Company as described below.

  1. DELETING OR MODIFYING PERSONAL INFORMATION

You may cancel Your registration at any time, and You may opt out of receiving any e-mails from Company. Additionally, You can choose to have all Your Personal Information deleted from Our database. You may opt out, or delete or modify Your Personal Information, by visiting Our website registration page and following the instructions provided. We encourage You promptly to update Your Personal Information when it changes.

  1. QUESTIONS OR COMMENTS

If You have any questions or comments relating to Our website or the privacy policy, send an e-mail to support @ trumio.ai. 

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