Privacy Policy

This policy was last modified on May 17th, 2022

Iris Media, Inc., an Oregon corporation doing business as Trifoia (“Trifoia” or “we”) creates and delivers instructional content for parents and families through its websites (together, the “Sites”):

Visitors to the Sites, including you, can use the Site to access and interact with this content (the “Services”).

We recognize your need to understand our privacy practices, especially those related to the collection and use of data that identifies you, directly or indirectly, as an individual person (“Personally Identifiable Information”). This Privacy Statement (“Statement”) is meant to inform you of those practices.  This Privacy Statement applies only to your interactions with the Site. If you link to other websites from the Site, including other websites operated by Trifoia, please be sure to carefully review the privacy statement of such other websites.

If you have questions, please contact us using any of the following methods:

TOLL FREE: (1) 877-874-3642
EMAIL ADDRESS: support@trifoia.com
MAILING ADDRESS:
IRIS Media, Inc. dba as Trifoia
1203 Willamette St. Suite 100
Eugene, OR 97401

1. What data does Trifoia collect from site users?

1.1. AUTOMATICALLY COLLECTED DATA. Each time you visit the Site, we use cookies to automatically collect the following data from you:

  • your Internet Protocol (IP) address;
  • your browser type;
  • other software and hardware attributes about the device and means you use to access the Site;
  • the date and time of your visit;
  • the webpage you leave to come to the Site and the webpage you go to next after leaving the Site;
  • the location of the device through which you are accessing the Site; and
  • your movements around the Site (such as the items you click on and the amount of time you spend interacting with a particular piece of content).

We also allow third party social media platforms with links on our Site, such as Facebook and Instagram, to use cookies to automatically collect the above categories of data from you.

1.1. REQUESTED DATA. In certain cases, we will ask to collect additional data from you.  In particular:

  • If you want to sign up to receive access to course content, we may prompt you to provide information related the course you want to access. For example, to access on a course on divorce, we may ask you to provide the state and county in which your divorce is being processed. Once you are ready to purchase access to a course, you will be directed to click the “Continue to Purchase” or a similar button, which will redirect you to a site hosted by the Talent Learning Management System. For more information about our relationship with TalentLMS see, “What is TalentLMS” below.
  • If you have purchased access to course content and want to view that content, you will be directed to click a “Login” or similar button. After clicking the button, you will be redirected to a site hosted by the Talent Learning Management System. For more information about our relationship with TalentLMS see, “What is TalentLMS” below.
  • If you want to apply for a fee waiver for one of our parenting courses, we will prompt you to provide:
    • your first and last name;
    • your phone number;
    • your email address;
    • a copy of your signed court-issued Indigent Status form or Forma Pauperis; and
    • the county and state in Indigent Status form or Forma Pauperis was issued, as well as the case number assigned to your form and the date of issuance of your form
  • If you want to contact us using the “Contact Us” or a similar button on one of the Sites and click on that button, an email message may be automatically created for you. Our email address will be automatically populated in the “To” field of the email. We will receive any information you chose to include and send to us in this manner.
  • If you want to engage in a course, we will ask you to participate in certain exercises and activities. As part of your participation, we may ask you to provide information about your relationships, parenting practices, and other personal experiences. Sometimes we may ask you to provide this information in narrative or journal form. You control what information you provided in these circumstances. We do not use this information in any way outside of the course context it is provided in.

2. WHAT IS TalentLMS?

TalentLMS is a hosting platform for learning and training content. Much of our course content is made available through the TalentLMS platform. This means that, in many cases, when you click on links with our Sites, you will be taken to Sites hosted by TalentLMS. Please keep in mind that when you interact with the content we have displayed using the TalentLMS platform, both we and TalentLMS collect information from you. In particular, we collect information from all of the categories identified in Section 1 above, for the purposes described in Section 3 below. TalentLMS decides what information to collect from you and how it will use that information. Accordingly, we encourage you to review TalentLMS’ privacy statement, terms and conditions and other documents governing your interactions with TalentLMS:

2.1. PAYPAL PAYMENTS. In certain cases, we will ask to collect additional data from you.  In particular: When making a credit card purchase for a TalentLMS course, you will be directed to a PayPal payment portal.  PayPal has its own Privacy Policy that is separate and unrelated to that of Trifoia.

3. How does Trifoia use data collected from site users?

We use data collected from you in the following ways

3.1. TO PROVIDE SERVICES YOU’VE REQUESTED. If you use the features of the Sites to purchase a product, we (subject to our Terms of Use) use the information that you provide to make the Service(s)/Product(s) available to you.

3.2. TO COMMUNICATE WITH YOU.

  • We will use the email address or phone number that you provide when submitting a message through the “Contact Us” feature of the Sites, when registering for an account through a TalentLMS page, when applying for a fee waiver, to provide customer support, or otherwise respond to your questions and comments.
  • If you submit forms on www.trifoia.com, we may use your email address to provide product offers and other marketing materials; you can unsubscribe from our mailing list at any time using the “UNSUBSCRIBE” link we include in marketing messages.
    • We will not use your email in this manner when you access any of the other Sites noted above.

3.3. TO CONFIRM YOUR ELIGIBILITY FOR A FEE WAIVER. We will use information you chose to provide when applying for a fee waiver to evaluate your eligibility for the waiver. If we are able to confirm your eligibility, we will also use the information you provide to contact you with information regarding how to create and login to a course account.

3.4. TO IMPROVE THE SITE. We will use data collected about your interactions with the Sites to look for trends in the popularity of features (so that we can improve those features), to detect security incidents and bugs, and to stop fraudulent or illegal activity.

3.5. TO EXERCISE OUR LEGAL RIGHTS. Where legally required or permitted, we will use data collected from you to respond to court orders or otherwise participate in the legal process.

Additionally, Trifoia may use de-identified or aggregated data collected about you in ways permitted by law but not described above. In general, de-identified information is information that does not directly or indirectly identify you. Aggregate information is information about a group of users, from which individual identities have been removed.

4. Does Trifoia share users' data with others?

We share data collected from you through the Sites with the following third-parties:

4.1. PAYMENT PROCESSORS. We use payment processers to handle any fees you submit to us (such as the fee you must pay in order to purchase a product). When you click to submit payment, the Site will link you to such a processor, and our Site will alert the processor that you want to submit payment to Trifoia. All payment information, such as credit or debit card details, will be submitted directly to the processor and will not be accessible to us.

4.2. WEB HOST.  We use a third party web host to host data and operate the Site. In performing its services, the host may have access to your Personally Identifiable Data. We do not authorize the host to use such data except as necessary to perform web hosting service and fulfill its other business purposes. We do not authorize the host to further collect, sell or use your Personally Identifiable Information.

4.3. EMAIL MANAGERS. In order to send you marketing messages, we will share your name and email address with our third party email distributor. The only time you will receive marketing messages from us is if you have signed up for one of our newsletters.

4.4. SOCIAL MEDIA COMPANIES. We allow third parties with links on our Site, such as Facebook and Instagram, to use cookies on our Site to collect data from the categories listed in Section 1.1 above. Collecting this data allows these third parties to target ads to you (when you are using the third party’s website or application) for goods or services that may be of interest to you.

4.5. DATA ANALYZERS. We share data with data aggregation and analytics software providers to enable us to monitor and improve the Site.  For example, these providers help us track mouse movements on the Site (so we can understand which pages on the Site are most interesting to users) and how long users stay on the Site (so we can understand how to make the Site more appealing).

4.6. MERGERS & SALES. If we undergo a merger or sale, we will share collected data if and as permitted by law.

Except as described above, Trifoia does not rent, sell, or share Personally Identifiable Information about you with other people or companies.

5. How long does Trifoia keep data?

We will retain your Personally Identifiable Information only for as long as is necessary for the purposes set out in this Privacy Statement. However, even after such Personally Identifiable Information is deleted, we may retain data that does not constitute Personally Identifiable Information (including de-identified or aggregated information) for our business purposes, such as creating internal reports that assist our development of new products and providing “traffic statistics” and “response rates” to third parties.

6. Information for users who are California consumers.

In addition to the other information provided in this Privacy Statement, Trifoia wishes to provide the information in this Section 5 to users who are California consumers. For purposes of this Section 5, a “California consumer” is a natural person who is in California for other than a temporary purpose (or who is domiciled in California and is outside of California for only a temporary purpose).

6.1. YOUR RIGHTS. If you are a California consumer, you have certain rights with respect to the Personally Identifiable Information we collect and hold about you, which rights you may exercise by contacting us using the information provided above. In particular:

  • In certain circumstances you have the right to request that we disclose to you:
    • the categories of sources from which we collect Personally Identifiable Information;
    • the business or commercial purpose for which your Personally Identifiable Information is collected or sold;
    • the categories of third parties with whom we share Personally Identifiable Information; and
    • the specific pieces of personal information we have collected about you.
  • In certain circumstances, you have the right to have Personally Identifiable Information of yours that is under our control deleted.
  • We cannot discriminate against you based on the fact that you exercise any of your rights under the California Consumer Privacy Act of 2018. In general, this means we cannot, just because you have exercised your rights, deny you goods or services; charge you a different price or rate for goods or services; provide you a different level or quality of goods or services; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

6.2. ACTIVITY IN PREVIOUS 12 MONTHS.

  • Sales. In the 12 months prior to the Effective Date, we have not sold users’ Personally Identifiable Information.
  • Collections. In the 12 months prior to the Effective Date, we have collected Personally Identifiable Information from the following categories:
    • Name;
    • Email address;
    • IP address;
    • Age, gender, sexual orientation, relationship status and other information relevant to users’ eligibility for research studies;
    • Phone number;
    • Geolocation data; and
    • Internet or other electronic network activity information, such as browsing or search history and other information about users’ interactions with the Site.

All of the Personally Identifiable Information listed in this Section 5.2 was collected from you (or your device) for the business or commercial purposes identified in Section 2 above. This Personally Identifiable Information was shared with payment processors, shipping companies, data analyzers, email distributors, and our web host (as further described in Section 3 above).

7. Information for users who are in the European Union.

In addition to the other information provided in this Privacy Statement, Trifoia wishes to provide the information in this Section 7 to users accessing the Site in the European Union.

7.1. LEGAL BASIS FOR PROCESSING. If you are in the European Union, law prohibits us from processing your Personally Identifiable Information unless we have a legal basis for doing so. When we process your Personally Identifiable Information, we have one or more of the following legal bases to do so:

  • Performing a Contract. We have a lawful basis to process your Personally Identifiable Information when such processing is necessary for the performance of a contract to which you are a party. For example, when you submit a question to us or ask us to review your qualifications for a career with us, you have given us a lawful basis to process your Personally Identifiable Information pursuant to the Terms of Use. You can decline to provide the information we need to fulfill your request; however, if you decline to provide such information, we may not be able to contact you or otherwise fulfill your requests. 
  • Consent. We have a lawful basis to process your Personally Identifiable Information when you provide us with consent to process such information for the purposes specified in this Privacy Statement. For example, you may have given consent to our use of cookies to collect Personally Identifiable Information from you when you first accessed the Site and clicked the button to signify that you “Agree” to such use. You may withdraw your consent at any time by contacting us using the contact information above. However, because we need some Personally Identifiable Information to operate the Site and provide you the Services (as described in more detail above), most features of the Site will be unavailable to you if you withdraw consent. 
  • Legitimate Business Purposes. We have a lawful basis to process your Personally Identifiable Information when such processing is necessary for the legitimate interests pursued by us or by a third party, as long as those interests aren’t overridden by your fundamental rights and freedoms or your other interests. For example, we have a legitimate interest in processing your Personally Identifiable Information when such processing is necessary to prevent fraud or to ensure network and information security. Also, in some cases, we and third parties have a legitimate interest in processing your Personally Identifiable Information when such processing is necessary for direct marketing purposes.

7.2. DATA TRANSFERS. If you are in the European Union, please be advised that your Personally Identifiable Information will be transferred to, and may be stored in, the United States. In particular, we utilize Amazon AWS as a web hosting provider. AWS is certified under the US-EU Privacy Shield Framework and uses Model Clauses to comply with European Data Protection laws.

7.3. YOUR RIGHTS. If you are in the European Union, you have certain rights with respect to the Personally Identifiable Information we collect and hold about you. In particular, in certain circumstances you have the following rights with respect to the Personally Identifiable Information we have collected about you:

  • to ask us to confirm whether we are processing your Personally Identifiable Information;
  • to access your Personally Identifiable Information;
  • to have your Personally Identifiable Information corrected or deleted;
  • to object to, or request the limiting of, our processing of your Personally Identifiable Information;
  • to receive your Personally Identifiable Information in a structured, commonly used and machine-readable format, and (where technically feasible) to have your Personally Identifiable Information transmitted to another controller; and
  • to lodge a complaint with the supervisory authority in the European Union.

To exercise these rights, please contact us using the information provided above.

8. Will this privacy statement be updated or modified?

Trifoia may update or modify this policy at any time by posting the updated policy (including an updated Effective Date) on the Site.