PRIVACY POLICY FOR TRICERION LIMITED

Policy Updated: January 2019

1 PRIVACY POLICY FOR TRICERION LIMITED

1.1     Tricerion Limited, a company registered in England & Wales with company number 5175970 whose registered office is at Reading Enterprise Centre, University of Reading, Earley Gate, Whiteknights Road, Reading, Berks, RG6 6BU United Kingdom (“Tricerion/ We/ Us/ Our”) is committed to protecting and respecting your privacy.

1.2     This policy, together with the Terms and Conditions for www.tricerion.com and any other site We might list (“Our Sites”), sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it. By visiting Our Sites and giving Us information you acknowledge the practices described in this policy.

1.3     We are registered with the Information Commissioners Office (“ICO”) as both a Data Controller and a Data Processor in accordance with applicable data protection laws, Our ICO registration number is Z9501543 and you can access Our data protection register entry here.

1.4     Our Sites may, from time to time, contain links to and from the websites of Our group companies and partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

2 INFORMATION WE MAY COLLECT FROM YOU

1.1     We may collect and process the following information in accordance with applicable data protection laws and/ or statutory regulations:

1.2     We may use information you give to Us or that We collect from you:

1.2.1          to provide other products and services, administer user accounts and run Our business:

·           We have a legitimate interest in the processing of the personal data of Our users in order to provide Our products and services, administer users and accounts and run Our business;

1.2.2          to inform individuals about Our products and services:

·           We may use personal data to inform individuals of information, promotions, suggestions, recommendations about Our products and services that may be of interest (unless you opt-out), We are legally permitted to do so or where an individual has consented to receiving direct marketing from Us (or a company similar to us). Individuals may be contacted by email, post, telephone or such other means as We regard as appropriate and as legally permitted;

·           We have a legitimate interest in the processing of the personal data of Our contacts, customers and users for direct marketing purposes to provide Our products and services and to run Our business and rely on consent as a basis for direct marketing where We are legally required to do so.

1.2.3          to communicate with you:

·           We have a legitimate interest in the processing of the personal data of Our contacts, customers and users in order to respond to enquiries, requests, complaints or comments that may be submitted to Us;

1.2.4          to administer, maintain and improve and Our Sites:

·           We use “cookies” to monitor user traffic patterns and site usage. This helps Us to understand how Our contacts, customers and users use Our Sites so that We can develop and improve the design, layout and functionality of Our Sites. A cookie is a piece of information that is stored on your device or your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options to you based upon the stored information about your last visit. You can normally alter the settings of your browser to prevent acceptance of cookies. If you do not want Us to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie on your computer. However, rejecting cookies may affect your ability to use Our Sites and some of our products and services; and

·           We have a legitimate interest in the processing of the personal data of Our contacts, customers and users in order to administer, maintain and improve Our Sites;

1.2.5          to notify you about changes to Our Sites, products and services;

1.2.6          for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We have a legitimate interest in the processing of the personal data of Our contacts, customers and users for Our internal operations;

1.2.7          to allow you to participate in interactive features of Our Sites, products and services;

1.2.8          as part of Our efforts to keep Our Sites safe and secure. We have a legitimate interest in the processing of the personal data of Our contacts, customers and users and to keep Our Sites safe and secure;

1.2.9          to comply with any legal or regulatory obligations to which We or regulators or law enforcement agencies are subject. This processing is necessary for compliance with a legal obligation to which We, Our contacts, customers and users or the regulator/ law enforcement agency are subject; and

1.2.10      to measure or understand the effectiveness of any advertising We may serve to you and others, and to deliver relevant advertising to you. We have a legitimate interest in the processing of the personal data of Our contacts, customers and users for promotion and advertising purposes.

1.3     If you have any questions about how We use your data please contact Us by email at info@tricerion.com.

3 PURPOSES OF PROCESSING

1.1     Any personal data We process will be used in accordance with applicable data protection laws and/ or statutory regulations. We have described below Our purposes for processing personal data.

1.2     We may use information you give to Us or that We collect from you:

1.2.1          to provide Our products and services, administer accounts and run Our business:

·           We have a legitimate interest in the processing of the personal data of Our contacts, customers and users in order to provide Our products and services, administer accounts and run Our business;

1.2.2          to inform individuals about promotions and Our products and services:

·           We may use personal data to inform individuals of information, promotions, suggestions, recommendations about Our products and services that may be of interest (unless you opt-out), We are legally permitted to do so or where an individual has consented to receiving direct marketing from Us (or a company similar to us). Individuals may be contacted by in App promotion, email, post, telephone or such other means as We regard as appropriate and as legally permitted;

·           We have a legitimate interest in the processing of the personal data of Our contacts, customers and users for direct marketing purposes to provide Our products and services and to run Our business and rely on their consent as a basis for direct marketing where We are legally required to do so.

1.2.3          to communicate with you:

·           We have a legitimate interest in the processing of the personal data of Our contacts, customers and users in order to respond to enquiries, requests, complaints or comments that may be submitted to Us;

1.2.4          to administer, maintain and improve Our Sites , products and services:

·           We use “cookies” to monitor user traffic patterns and site usage. This helps Us to understand how Our contacts, customers and users use Our Sites so that We can develop and improve the design, layout and functionality of Our Sites, products and services. A cookie is a piece of information that is stored on your device or your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options to you based upon the stored information about your last visit. You can normally alter the settings of your browser to prevent acceptance of cookies. If you do not want Us to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a web site tries to put a cookie on your computer. However, rejecting cookies may affect your ability to use Our Sites and some of our products and services; and

·           We have a legitimate interest in the processing of the personal data of Our contacts, customers and users in order to administer, maintain and improve Our Sites, products and services;

1.2.5          to notify you about changes to Our Sites, products and services;

1.2.6          for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We have a legitimate interest in the processing of the personal data of Our contacts, customers and users for Our internal operations;

1.2.7          to allow you to participate in interactive features of Our Sites, products and services;

1.2.8          as part of Our efforts to keep Our Sites, products and services safe and secure. We have a legitimate interest in the processing of the personal data of Our contacts, customers and users and to keep Our Sites, products and services safe and secure;

1.2.9          to comply with any legal or regulatory obligations to which We or regulators or law enforcement agencies are subject. This processing is necessary for compliance with a legal obligation to which We, Our contacts, customers and users or the regulator/ law enforcement agency are subject; and

1.2.10      to measure or understand the effectiveness of any advertising We may serve to you and others, and to deliver relevant advertising to you. We have a legitimate interest in the processing of the personal data of Our contacts, customers and users for promotion and advertising purposes.

1.3     If you have any questions about how We use your data please contact Us by email at info@tricerion.com.

4 DISCLOSURE OF YOUR INFORMATION

1.1     We may share your personal information with any member of Our group, which means Our subsidiaries, Our ultimate holding company and its subsidiaries, as defined in section 1159 of the United Kingdom’s Companies Act 2006.

1.2     We may share your information with selected third parties including:

1.2.1          business partners and sponsors; and

1.2.2          suppliers and sub-contractors for the performance of Our products and services and running of Our business, for example, to validate the email address that you provide Us with We may disclose your email address to Our third party suppliers and/ or sub-contractors.

1.3     We may disclose your personal information to third parties:

1.3.1          in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets or if Tricerion Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets;

1.3.2          if We are under a duty to or permitted to disclose or share your personal data in order to comply with any legal or regulatory obligations, or in order to enforce or apply the Terms of Use for products and services or the Terms and Conditions for Our Sites, or any other agreements; or to protect the rights, property, or safety of Tricerion Limited, Our contacts, customers or users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5 WHERE WE STORE YOUR DATA

1.1     We may transfer your personal data outside of the UK to set up and support Our Sites, products and services, for example, where We use third party suppliers and sub-contractors. In addition to other countries We currently use third party suppliers with servers and operations located in the US. If We sell or buy any business or assets and would be required to disclose your personal data to the prospective buyer or seller of such business or assets, or if We or substantially all of Our assets are acquired by a third party, We may, to the extent that any of these situations occur, be required to transfer your personal data outside of the UK.

1.2     Where the transfers are not to countries that provide an adequate level of protection, We put appropriate safeguards in place to cover transfers of your personal data including, for example, signing standard contractual clauses/ data protection clauses adopted by the European Commission, or where applicable, relying on Privacy Shield certification where Our suppliers are located in the US. Please click here for a link to the standard contractual/ data protection clauses and click here for more information about the Privacy Shield for US companies.

6 RETENTION OF YOUR DATA

We take appropriate measures to ensure that any personal data is kept secure. We will store your personal data for the duration of your use of Our Sites, products and services. If you delete your account with Us for any of our products and services, We will continue to store your personal data for a period of time in line with legal, regulatory, financial and business requirements. We will also keep a record of any correspondence in line with legal, regulatory, financial and business requirements.

7 ACCESS TO INFORMATION AND YOUR RIGHTS

1.1     As a result of Us collecting, controlling and processing your information, you have the following legal rights:

1.1.1          to access personal data held about you;

1.1.2          to request Us to make any changes to your personal data if it is inaccurate or incomplete;

1.1.3          to request your personal data is erased where We do not have a compelling reason to continue to process such data in certain circumstances (please note that this is likely to result you being required to remove any of Our products and services from you devices);

1.1.4          to receive your personal data provided to Us as a Data Controller in a structured, commonly used and machine-readable format where Our processing of the data is based on:

·           your consent;

·           Our necessity for setting up and supporting Our Sites, products and services you may be required to approve specific Terms of Use to acknowledge and agree by clicking on “Accept Terms & Conditions” when the relevant Site, product or service is downloaded; or

·           steps taken at your request prior to entering into any agreement with Us and the processing is carried out by automated means;

1.1.5          to object to, or restrict, Our processing of your personal data in certain circumstances;

1.1.6          to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you;

1.1.7          where Our processing of your personal data is based on your consent, you have the right to withdraw consent at any time by contacting us; and

1.1.8          to lodge a complaint with a data protection supervisory authority. The supervisory authority in the UK is the ICO.

1.2     To exercise any of your rights as set out above, please contact Us at info@tricerion.com or contact our Data Protection Officer at info@tricerion.com or call them on +44 20 7720 8000, or write to them at Reading Enterprise Centre, University of Reading, Earley Gate, Whiteknights Road, Reading, Berks, RG6 6BU.

8 CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time and, where appropriate, you will be notified of changes We make to this Privacy Policy. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

9 CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be sent to info@tricerion.com