Troverlo Privacy Policy

TROVERLO INC.

Effective Date: March 8th, 2022
Last Modified: March 8th, 2022

Introduction

Troverlo Inc. (“Troverlo,” “Company”, “we”, “us”, “our”) is committed to your privacy. This Privacy Policy (the “Policy”) describes the types of information we may collect from you when you visit our website https://www.troverlo.com/ (the “Website”), our web platform (the “Platform”), our mobile application Troverlo: Asset Tracking and IoT (the “Mobile Application”), or that you may provide when you use a Troverlo tag or interact with, register with, access, or any Troverlo services on the Website, Platform, or our Mobile Application (collectively with the Website and Platform, the “Services”), and our practices for using, maintaining, protecting, and disclosing that information. It is your responsibility to review the privacy practices and policies of third-party entities, including those that may link or be accessible from or on the Services, or those that utilize the Troverlo tags.

This Policy applies to information we collect:

• Through our Services;
• In email, text, and other electronic messages between you and Troverlo;
• Through other electronic communications sent through or in connection with the Services;
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

This Policy does NOT apply to information you provide to or that is collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Services.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Services, you agree to this Policy. This Policy may change from time to time (see “Changes to Our Privacy Policy” below). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Your use of the Services is also governed by our TERMS OF SERVICE which can be found via the Troverlo Platform. Please ensure you read the TERMS OF SERVICE in addition to this Policy. Unless we indicate otherwise in this Policy, defined terms will have the meanings given to them in our TERMS OF SERVICE.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including:

1. Personal Information. This includes, but is not limited to, information that we use to identify you, such as your name, mailing address, email address, telephone number, account information, and transaction/order history.
   
   
2. Non-Personal Information. This includes, but is not limited to, user behavior on our Services and aggregated generic information. This is information that is about you but individually does not identify you.
   
   
3. Usage Information. This includes, but is not limited to, information about your device including IP address, browser type and version, time zone setting, and page interaction information collected through cookies and other tracking technologies.
   
   
4. Location Information.
   1. With respect to the Mobile Application and Platform: we may collect the coordinates of your device anonymously (ie does not include any information that would allow us to identify the user associated with the mobile application or coordinates), and only when such coordinates are directly associated with the observation of a Troverlo tag (“Asset Data”). In these cases, we only collect the coordinates, timestamp, and Wi-Fi-related data at the specific time of the observation. This information corresponds to the individual user/customer that is using the Troverlo tag and is considered Personal Information.
      
      
   2. With respect to companies that we partner with to expand our global connectivity capabilities (“Observation Partners”): we also collect Troverlo tag and asset data from our Observation Partners (“Observation Partner Asset Data”). We receive this data anonymously and it does not include any information that would allow us to identify the user associated with the observing device. Observation Partner Asset Data is only accessible to users set up within the respective company and with the proper permissions assigned. Observation Partner Asset Data is only shared with the applicable company associated with the observed Troverlo tag.

We collect this information:

1. Directly from you when you provide it to us. We collect information that you provide to us, including but not limited to, information you provide by filling in forms on our Services, such as information provided at the time of registering to use our Services, posting material on our Services, or requesting further information about our Services. We may also ask for this information when you report a problem with our Services, or exercise your privacy rights and choices (see “Your Privacy Rights and Choices”).
   
   
2. Automatically as you navigate through the Website. We may collect information automatically, which may include Usage Information and Non-Personal Information as described above, through use of cookies and similar tracking technologies (“cookies”) that are deployed on the Website and Mobile Application. We use cookies to update and improve our Website. We also may use cookies, at times in connection with third-party services, to collect information about your online activities over time and across third-party websites or other online services.
   
   For example, our Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the Website analyze how users use the Website. The information generated by the Google Analytics cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity for website operators and providing other services relating to Website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
   
   You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website.

3. Automatically as you are near a Troverlo asset. We may collect information automatically, which may include anonymous location information and Non-Personal Information as described above, whenever you are within range of a Troverlo asset. We collect this data anonymously and it does not include any information that would allow us to identify the user associated with the observing device. The only information collected along with the coordinates is data about the nearby Troverlo asset.
   
   

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, for several reasons:

• To present our Services and its contents to you;
• To provide you with information, products, or services that you request from us;
• To set up, maintain and support our Services;
• To monitor the use of our Services in order to detect security incidents;
• For marketing and advertising purposes;
• To notify you about changes to our Website, or any products or services we offer or provide through the our Services;
• To enforce our TERMS OF SERVICE;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.
  
  

Disclosure of Your Information

We may disclose aggregated information about our users and information that does not identify any individual without restriction. We may disclose Personal Information that we collect, or you provide as described in this Policy:

• With affiliates or subsidiaries, business partners, service providers, or other third parties we use to provide you with the Services and its contents and functions;
• With third-party service providers that perform functions on our behalf, such as billing and payment processing;
• With third-party business partners to enable such partners to send their respective users information about products and services that may be of interest to them, consistent with users’ contextual environment;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information; and
• With your consent.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our TERMS OF SERVICE;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Troverlo, our customers, or others.
  
  

Data Transfers to Other Countries/Territories

We take appropriate measures for the cross-border transfer of Personal Information, including the use of the EU Standard Contractual Clauses or other mechanisms as required by applicable law. By using our Services, the transfer, collection, processing and use of Personal Information will occur as specified in this Policy, our TERMS OF SERVICE, and any other terms provided at the time of collection. If you do not consent to the transfer, collection, processing, or use of Personal Information according to the aforementioned terms, do not use the Services.

Retention Policy

We will retain your Personal Information only for as long as necessary to fulfil the purposes for which we collected it, and to the extent necessary to comply with our legal obligations under applicable law.

Your Privacy Rights and Choices

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some cookies or alert you when cookies are being sent. Note that some parts of the Services may then be inaccessible or not function properly if you do so.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with business partners for promotional purposes, you can opt-out by contacting us using any of the methods provided in the “Contact Us” section below.
• Promotional Offers from the Company. If you do not wish to have your information used by us to promote our own or third parties’ products or services, you can opt-out by contacting us using any of the methods provided in the “Contact Us” section below. If we have sent you a promotional email, you may opt out by using the unsubscribe mechanism available in the promotional email communication.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Certain data protection laws may provide you with more privacy rights than those listed above, depending on your citizenship or residency.

Additional Privacy Rights for Individuals in the European Economic Area (“EEA”)

Under the European Union’s General Data Protection Regulation (“GDPR”), individuals in the EEA have additional privacy rights:

• Right of Access. You have the right to know exactly what Personal Information is held about you and how it is processed.
• Right of Rectification. You have the right to correct your Personal Information if it is inaccurate or incomplete.
• Right to Erasure. Also known as ‘the right to be forgotten’, you have the right to have your Personal Information deleted or removed.
• Right to Restrict Processing. You have the right to block or suppress processing of your Personal Information.
• Right to Data Portability. You have the right to request that we transfer the Personal Information that we have collected to another organization, or directly to you, under certain conditions.
• Right to Object to Processing. In certain circumstances, you have the right to object to our processing of your Personal Information.
• Right to Withdraw Consent. You have the right to withdraw your consent to our processing of your Personal Information at any time where we relied on your consent to process your Personal Information. Please note that withdrawal of your consent does not affect our use or processing of your Personal Information prior to your consent being withdrawn.
• Rights of Automated Decision Making and Profiling. The GDPR has put in place safeguards to protect individuals against the risk that a potentially damaging decision is made without human intervention. We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

If you wish to exercise your rights under the GDPR, please contact us using any of the methods provided in the “Contact Us” section below. We will consider and process your request within a reasonable period of time. You can also lodge a complaint with your data protection authority, if you would feel that we have not acted in accordance with applicable data privacy legislation.

Additional California Privacy Rights

This section of our Policy is our privacy notice for California Residents and applies to visitors, users, and other individuals who reside in the State of California (“consumers,” or “you/your”) and use our Services, as contemplated under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (collectively, “California Privacy Law”).

If you wish to exercise your rights under California Privacy Law, please contact us using any of the methods provided in the “Contact Us” section below. We will consider and process your request within a reasonable period of time. Please be aware that under certain circumstances, California Privacy Law may limit your exercise of the available rights.

We collect different types of information from users, and we use and/or disclose this information for different business and commercial purposes. The chart below identifies the Personal Information we may collect from consumers and lists the parties with whom we may share this information and for what purposes:

Sharing Personal Information

We may disclose Personal Information to affiliates and subsidiaries, business partners, service providers and other third parties for business purposes as set forth in the chart above and in this Policy. Certain of such disclosures may be considered a “sale” of Personal Information under California Privacy Law.

Your California Rights and Choices

Subject to certain exceptions detailed in California Privacy Law and other applicable laws and regulations, as a California resident, you have the right to request: (i) access to your Personal Information; (ii) deletion of your Personal Information; (iii) information about the Personal Information about you that we have disclosed for a business purpose and/or “sold” or “shared” (as such terms are defined under California Privacy Law) to third parties within the past 12 months; (iv) rectification if we maintain any inaccurate Personal Information about you; (v) that we limit use and disclosure of your sensitive Personal Information; and (vi) to opt-out of the “sale” or “sharing” of your Personal Information.

• Do Not Sell My Personal Information. To exercise your right to opt-out of the “sale” of Personal Information, please contact us online here: www.Troverlo.com.
• Exercising Other California Consumer Rights. Should you wish to request the exercise of your other California privacy rights as detailed above, please contact us as detailed in the “Contact Us” section below. We may need to take steps, including requesting additional information from you, to verify your identity. For authorized agents submitting requests on behalf of California consumers, we may request the authorized agent provide us with a copy of a valid power of attorney or evidence of the written authorization.

We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon your request to exercise any of the rights available to you under California Privacy Law.

California “Shine the Light” Law. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident and would like to request this information, please contact us as detailed in the “Contact Us” section below.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Changes to Our Privacy Policy

It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by the email address specified in your account and/or through a notice on the Website. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Policy to check for any changes.

Contact Us

To ask questions or comment about this Policy and our privacy practices, contact us at:

Troverlo Inc.

Toll Free Phone Number:
1 (833) 317-3463

Email:
Legal@Troverlo.com