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) 877-874-3642EMAIL ADDRESS: firstname.lastname@example.orgMAILING ADDRESS:IRIS Media, Inc. dba Trifoia1203 Willamette St. Suite 100Eugene, OR 97401
1.1. REQUESTED DATA. In certain cases, we will ask to collect additional data from you. In particular:
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:
We use data collected from you in the following ways
3.2. TO COMMUNICATE WITH YOU.
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.
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.
4.5. 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.
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.
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:
6.2. ACTIVITY IN PREVIOUS 12 MONTHS.
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).
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:
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 exercise these rights, please contact us using the information provided above.
Trifoia may update or modify this policy at any time by posting the updated policy (including an updated Effective Date) on the Site.