Privacy Statement

Last Updated 04/15/2019

Iris Media, Inc., an Oregon corporation doing business as Trifoia (“Trifoia” or “we”) provides certain information about the Trifoia company through its website, www.trifoia.com, (the “Site”). Visitors to the Site, including you, can use the Site to browse this information, submit questions to us, apply for careers with us, and volunteer to participate in Trifoia research studies (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) 877-343-4747
EMAIL ADDRESS: support@trifoia.com
MAILING ADDRESS:
IRIS Media Inc. dba 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.

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

• If you want to submit a message to us using the Site’s “Say Hello” feature, we will prompt you to provide:
o your first and last name;
o your email address;
o your phone number; and
o the message or question you would like to share with us.

• If you want to see if you qualify to participate in one of our research studies, you will need to provide certain information relevant to your eligibility for the particular study. This may include your age, gender, sexual orientation, and relationship status. If, based on the information you submit, you appear to qualify for a study, we may ask you to provide additional information in accordance with rules proffered by the Institutional Review Board (IRB) for Human Participants.

• If you want to comment on a blog posted on the Site or on another user’s comment on a blog posted on the Site, you may post such a comment (subject to the Terms of Use). You control the information you chose to provide in your comment.

• If you want to apply for a career with us through the Site, you will be prompted to provide:
o your first and last name;
o your email address;o your phone number;
o the position you would like to apply for;
o a message regarding your interest in the potion; and
o a resume and cover letter. You control the information you chose to provide in your resume or cover letter.

2. HOW DOES TRIFOIA USE DATA COLLECTED FROM SITE USERS?  We use data collected from you in the following ways:

2.1. TO COMMUNICATE WITH YOU.
• We will use the email address or phone number that you provide when submitting a message through the “Say Hello” feature of the Site to provide customer support or otherwise respond to your questions and comments.
• Similarly, we will use the contact information you provide when applying for a career or applying to participate in a research study to contact you if we desire to communicate with you regarding the position or study.
• We will use an email address you provide in either of the above contexts to send you emails containing product offers, notifications that a new blog has been posted on the Site, and other marketing materials; you can unsubscribe from our mailing list at any time using the “UNSUBSCRIBE” link we include in marketing messages.

2.2. TO EVALUATE YOU FOR A CAREER. We will use information you chose to provide when applying for a career with us to evaluate your qualifications for the position. If we do not feel you qualify for the particular position for which you have applied, we may retain the information you have provided so that we can evaluate you for other positions.

2.3. TO IMPROVE THE SITE. We will use data collected about your interactions with the Site 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.

2.4. 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.

3. DOES TRIFOIA SHARE USERS’ DATA WITH OTHERS? We share data collected from you through the Site with the following third-parties:

3.1. RESEARCHERS.  We share the data you submit when applying to participate in a research study with research teams.  As noted above, if you qualify to participate in a study, you will receive additional information regarding the collection and use of your information in accordance with rules proffered by the Institutional Review Board (IRB) for Human Participants.

3.2. 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.

3.3. EMAIL MANAGERS. In order to send you marketing messages, we will share your name and email address with our third party email distributor.

3.4. 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.

3.5. 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).

3.6. 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.

4. 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.

5. 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).

5.1. 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:
o the categories of sources from which we collect Personally Identifiable Information;o the business or commercial purpose for which your Personally Identifiable Information is collected or sold;
o the categories of third parties with whom we share Personally Identifiable Information; ando 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.

5.2. 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:
o Name;
o Email address;
o IP address;
o Age, gender, sexual orientation, relationship status and other information relevant to users’ eligibility for research studies;
o Phone number;
o Geolocation data; and
o 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).

6. 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 6 to users accessing the Site in the European Union.

6.1. 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 “Accept” 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.

6.2. 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.

6.3. 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.

7. 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.