"), we explain how TRIPLE collects, uses, discloses and protects the Personal Information you submit to us, including, for example, when you access and use TRIPLE websites, participate in any loyalty programmes you have applied for (and in which the selected retailer and financial institution also participates) or when you apply for a job.
mean TRIPLE TECHNOLOGIES LTD
and its affiliates. (ii) "Data Controller"
, for the purposes of the GDPR, other data protection laws applicable in the Member States of the European Union and other data protection related provisions, is TRIPLE TECHNOLOGIES LTD, with registered office at 20-22 Wenlock Road, N1 7GU, London, England. (iii) "Personal Information"
generally has the same meaning as personal data or personally identifiable information (PII). Personal Information is defined in the data privacy laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any person who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (e.g. IP addresses, if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. In short, this includes data that, alone or with other data in our possession or made available to us, can be used to identify you.
TRIPLE is committed to the following fundamental principles: PRINCIPLE 1. WE LIMIT HOW, AND WITH WHOM, WE SHARE YOUR PERSONAL INFORMATION.
TRIPLE will only share your Personal Information with third parties for the following purposes:
(i) At your request.
(ii) To process or review a transaction or product that you have authorised or requested. For example, this may include sharing it with the merchant or financial institution you have selected in connection with a loyalty programme you have applied for.
(iii) Where we are required by law to disclose such information to the appropriate authorities.
(iv) To companies that help us market, recruit, assign and review our products and services; for example, to support our information technology or to manage mailings on our behalf.
(vi) To our professional advisers.PRINCIPLE 2. PURPOSE AND LEGAL BASIS OF THE PROCESSING
Information that we receive:(i) Visit www.jointriple.com
(ii) Purchase any of our services.
(iii) Any other information you subsequently provide to us orally, in writing, through the TRIPLE platform: this may include your full name, mailing address, email address, loyalty program (including merchant and merchant transaction and financial institution details and bank account or credit card account to which to deposit), employer/company and professional information, job titles, phone numbers, demographic information, IP address.
(iv) Name, address, email address and other information about transactions and communications with us.
(vi) Name, address, email address and other contact information.
(vii) IP address and other information sent by your browser.
(viii) Application data, including your name, address, CV, date of birth.Purpose
Personal Information is used to fulfil your requests. For example, if you choose to:
(i) Register to receive information about our services,
(ii) Participate in any of the loyalty programs you have requested (and in which the selected merchant and financial institution also participates), (iii) Purchase other TRIPLE products or services, or (iv) If you contact us through the "contact us" section, we will use your Personal Information to fulfil your request.
Personal Information is used to process or review a transaction or a product or service that you have authorized or requested, to contact you periodically to tell you about new products and/or services that we offer or that we think may be of interest to you or to diagnose any problems with our server and to administer our website, for compliance with legal and regulatory requirements and corporate governance obligations, among othersThe processing is necessary for us to administer the employee recruitment process, including setting up an electronic HR file for job applicants, administering your application and arranging interviews. We may retain your Personal Information after your application has been unsuccessful so that we can contact you in the event of future job vacancies. We may also share your data with other TRIPLE group companies to consider your application for other job vacancies.
PRINCIPLE 3. SAFEGUARDS IN PLACE TO HELP ENSURE THE SECURITY AND CONFIDENTIALITY OF YOUR INFORMATION.
TRIPLE restricts access to your company's information to only those of our employees or partners who need it to carry out their duties. Employees with access to your information will strictly maintain the confidentiality of that information. TRIPLE maintains physical, electronic and procedural safeguards that comply with industry standards to protect your information. We routinely test our information systems and websites to help ensure that unauthorised access does not occur.
PRINCIPLE 4. WE RETAIN YOUR PERSONAL INFORMATION FOR AS LONG AS NECESSARY TO FULFIL THE PURPOSES FOR WHICH IT WAS COLLECTED.
The criteria we use to determine data retention periods for Personal Information include the following:
(i) Retention in case of enquiries
: we will retain it for a reasonable period after the relationship between us has ceased in case you make enquiries to us; (ii) Retention in case of contracting our products/services or contacting our customer service
: we will retain it for as long as necessary to deliver our product/service to you in accordance with the terms of contract, as well as to deal with your enquiries; (iii) Retention in case of complaints
: we will retain them for the period during which you can legally make claims against us; (iv) Retention in accordance with legal and regulatory requirements:
we will consider whether we need to retain them additionally due to a legal or regulatory requirement, for example to comply with the product warranty period or to comply with tax or fiscal obligations; (v) Retention in the case of job applications
: if you have applied for a TRIPLE job offer and have not been selected, your application data will be retained in our talent pool for a limited period as defined in Principle
2.Give us your feedback
We aim to protect your privacy. To tell us about any issues or to help us improve, please contact us by email (firstname.lastname@example.org). We may ask you to provide us with a copy of an identity document to validate your identity. If you believe that we are in breach of our obligations under data protection laws, you may lodge a complaint with the competent Data Protection Authority, which may be the supervisory authority in your country of residence or place of work, or in case of an alleged breach of data protection laws.
(i) Transfers outside the EU/EEA.
We may transfer the Personal Information we process to countries outside the European Economic Area ("EEA") (for example, where the service provider hosting our servers is located outside the EEA for hosting your Personal Information). We have put in place appropriate security measures with respect to the protection of your privacy, your fundamental rights and freedoms, and the exercise of your rights, e.g. we establish an adequate level of data protection, and we subscribe to EU standard contractual clauses based on the EU Commission's model clause.
(ii) Provision of Personal Information / Automated Decision Making.
Please note that the Personal Information we collect from you is necessary to provide you with the services and the website and to process your order for our services. Failure to provide us with such information may prevent us from providing you with our services, making our website accessible or fulfilling your request to purchase TRIPLE services. We do not use automated decision-making or profiling of individuals.
(iii) Your rights.
You have various rights under the data privacy laws of your country. These may include (as applicable): the right to request access to the Personal Information we hold about you; the right to rectification, which includes requiring us to correct inaccurate Personal Information; the right to request restriction of the processing of data relating to you or object to the processing of your Personal Information, the right to request deletion of your Personal Information when it is no longer necessary for us to retain it; the right to data portability, including to obtain Personal Information in a commonly used machine-readable format in certain circumstances, such as where our processing of such Information is based on consent; the right to object to automated decision-making, including profiling (if applicable) that has a legal or significant effect on you as an individual; and the right to withdraw your consent to any processing for which you have previously given such consent.
(iv) Marketing information.
With your consent, where relevant, we will retain your name, address and contact details (including telephone numbers and email addresses) on our databases and may use that information from time to time to inform you about our related products and services, as well as updates on developments in our industry generally that may be of interest to you. We may contact you in writing, by telephone or email for this purpose. If at any time you decide that you do not want your contact details to be used for these purposes, you may object or revoke your consent to receive marketing communications by following the instructions in the relevant marketing communication (for example, by clicking the "unsubscribe" button) or by contacting us (see "Tell us what you think" above).
(v) Security Statement.
We take reasonable precautions to protect your information. In particular, we implement appropriate technical and organizational measures designed to ensure a level of security appropriate to the risk, including, as appropriate: (a) pseudonymization (such as where data is separated from direct identifiers so that it cannot be linked to an identity without additional information being held separately) and encryption, (b) continuous protection of the confidentiality, integrity, availability and resilience of the systems and services used to process your Personal Information, (c) providing the ability to restore availability and access to Personal Information promptly in the event of a physical or technical incident; and (d) maintaining a process for regular verification, evaluation and assessment of the effectiveness of technical and organizational measures. When you submit information to us through our website, your information is protected both online and offline. All data transferred to/from TRIPLE's internal network from/to an external entity is encrypted according to industry standards. Please note that messages you send to us by email may not be secure. We maintain appropriate physical, electronic and procedural safeguards to ensure the security, integrity and privacy of your Personal Information within our company. Only those employees who may require such information to perform a specific job are granted access to your organization’s personally identifiable information. In addition, all employees are kept informed of our security and privacy practices.
(vii) Third Party Websites.
In TRIPLE TECHNOLOGIES, LTD.
(hereinafter, the "Website)
1. WHAT ARE COOKIES AND WHAT ARE THEY USED FOR?
A cookie is a file that is downloaded to the User's device when accessing certain content on websites, electronic media and/or applications. Cookies allow an application or website, among other things, to store and retrieve information about the browsing habits of a User or their equipment and, depending on the information they contain and the way they use their device, they can be used to recognize the User. Cookies are secure in that they can only store information used by the browser, information that the user has entered in the browser or information included in the page request. Some cookies are strictly necessary for the proper functioning of a website and/or application and cannot contain viruses or damage your device. Others serve a variety of purposes, such as facilitating navigation between pages and/or applications, storing the user's preferred language, allowing the user's preferences to be remembered, or detecting whether you have visited previously. Cookies are essential for the functioning of the internet, providing countless advantages in the provision of interactive services, facilitating navigation and usability. Cookies cannot damage your computer and the fact that they are activated helps to identify and resolve potential errors.
2. WHAT TYPES OF COOKIES ARE USED ON TRIPLE?
2.1. Depending on the entity that manages them,
the cookies used can be classified as follows:(i) First-party cookies:
these are cookies that are sent to your device and managed exclusively by us for the better functioning of TRIPLE. The information collected is used to improve the quality of our service and your experience as a user. (ii) Third-party cookies:
these are cookies deposited by a server in another domain, with the authorization of the site you are visiting, as for example, Google Analytics
. We cannot access the data stored in cookies from other websites or applications when you browse those websites or applications. In the event that cookies are installed from a computer or domain managed by TRIPLE, but the information collected through them is managed by a third party, they cannot be considered as own cookies.
2. 2. Depending on the length of time they remain activated, the following cookies can be differentiated:
(i) Session cookies:
these are temporary files that remain in the browser's cookie history until the Website or applications are abandoned, so they are not recorded on the hard drive of the user's computer or mobile device. The data obtained through these cookies are used to analyze traffic patterns and data communication. They make it possible to provide a better experience in order to improve the content and facilitate its use.
(ii) Persistent cookies:
these are stored on the hard drive and are read by the Website and applications each time a new visit is made. Despite its name, a persistent cookie has a specific expiry date. The cookie will stop working after that date. They are generally used to facilitate the various services offered by websites and applications.
2. 3. Depending on the purpose of the cookie:
(i) Registration cookies:
When the user registers with TRIPLE, cookies are generated that identify them as a registered user and indicate when they have identified themselves on the portal.
These cookies are used to identify the user account and its associated services. These cookies are maintained as long as the user does not leave the account, close the browser or turn off the device.
(ii) Analytical cookies:
cookies may be used in combination with analytical data to identify individual user preferences on TRIPLE.
(iii) Performance cookies:
this type of cookie retains user preferences for certain tools or services so that you do not have to reconfigure them each time you visit TRIPLE and, in some cases, may be provided by third parties. Some examples are volume of audiovisual players, article sorting preferences or compatible video playback speeds.
(iv) Advertising Cookies:
These are those that allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the editor has included in a web page, application or website from which the requested service is provided based on criteria such as the edited content or the frequency at which the advertisements are shown.
(v) Behavioral advertising cookies:
These cookies enable the management, in the most effective way possible, of the advertising spaces that, where appropriate, the publisher has included on a website, application or platform from which the requested service is provided. These cookies store information on the behavior of users obtained through the continuous observation of their browsing habits, which allows a specific profile to be developed in order to display advertising based on the same.
(vi) Geolocation cookies:
these cookies are used by programs that attempt to geographically locate the location of the computer, smartphone, tablet or connected television, in order to anonymously offer more appropriate content and services.
(vii) Other third-party cookies:
third-party cookies may be installed on some of our pages to manage and improve the services they offer. An example of this use are the links to social networks that allow our content to be shared.
3. HOW CAN THE USER BLOCK OR DELETE COOKIES?
Users can allow, block or delete the cookies installed on their equipment by configuring the options of their internet browser. In the event that you block them, it is possible that certain services that require their use will not be available to the user. The following links provide the user with information on how to activate your preferences in the main browsers:
(i) Internet Explorer: Tools > Internet Options > Privacy > Settings.
For more information, you can consult Microsoft support or the browser's Help.
(ii) Firefox: Tools > Internet Options > Privacy > History > Custom Settings.
For more information, you can consult Mozilla support or the browser's Help.
(iii) Chrome: Settings > Advanced Options > Privacy > Content Settings
For more information, you can consult Google support or the browser's Help.
(iv) Safari: Preferences > Security.
Users may revoke their previously granted consent to the installation of cookies at any time by deleting the cookies installed on their equipment by configuring the browser options, as indicated in the section "revocation and deletion of cookies". However, this may have an impact on the functionalities of the Website or the applications used by the User, making the User's experience less satisfactory.