Last modified October 31, 2023
Hi! Welcome to one of Trinsic’s exciting legally required notices! Find our other legal documents here.
Trinsic is a company that enables the easy integration of self-sovereign identity technology into software applications, including mobile, web-based, and desktop applications. We also help consumers easily manage their self-sovereign identity.
We’ve done our best to make our terms reasonable, complete, readable, and understandable, but you may still have additional questions. We get that. So, feel free to contact our support team by clicking here or write to us at the addresses below:
Trinsic Technologies Inc.
2261 Market Street #4395
San Francisco, CA 94114 (Attn: Legal)
1.1 Information Collection.
Trinsic collects your information during your access or use of the Services, including (i) any websites or web application provided, published, developed or made available by the Company; (ii) any mobile or online applications provided, published, licensed, developed or made available by the Company; and (iii) any feature, content, software, hardware, services or other products available on or through the Services or otherwise provided by the Company. Your access and use of the Services is conditioned on your providing us with any requested User Information.
2.1 Digital Credentials
Digital identity technology and digital wallets are designed to provide a secure method for consumers and businesses to access and exchange identity-related information (“Digital Credentials”). These digital credentials can be stored on the end-user’s device or in the cloud. When credentials are stored on the end-user’s device, even Trinsic can’t access that information. When cloud storage is used, we may host these Digital Credentials through third-party cloud service providers and hold encryption keys relating to these Digital Credentials.
2.2 Personally Identifiable Information.
Company may collect any personally-identifiable information that you provide in connection with any Services, including, without limitation: your name, email address, mailing address, phone number, photograph, birthdate, passport, driver’s license, government-issued identification numbers, and other similar information provided with respect to your business or its employees, officers, representatives or affiliates, and certain historical, contact, and demographic information about you.
2.3 Device Information.
Company may access, collect, monitor, and/or remotely store information about your device when you access any Services, including hardware model, operating system and version, unique device identifier, mobile network information, and information about the device’s interaction with the Services.
2.4 Payment Information.
2.6 Usage Information.
Company may collect information and data about how you use the Services, including access time, Services accessed, browser type and language, Internet Protocol (“IP”) address, webpages and applications viewed and used, time spent on webpages and applications, links clicked, and conversion information (e.g., transactions entered into).
2.7 Aggregated Data.
Company may collect aggregated data about you or your use of Services, or any other aggregated form of the other types of User Information set forth above. Aggregated data that we collect cannot be specifically associated with you individually.
2.8 Data from Clients
During the course of data hosting services for our clients, we receive encoded data relating to our clients and clients’ customers. This data enables our clients to identify and interact with their customers when using our Services or Apps. The encoded data may be any of the User Information defined above.
2.9 Do Not Submit Sensitive Personal Information.
We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.
3.1 Given by You.
You provide certain User Information when you register for your account with the Services, as you use the Services, or as you engage with Company through its Services.
3.2 Automatic Collection.
User Information can be recorded and collected by software or processes that run automatically on your computer or device or on Company’s servers as you use the Services.
3.3 Analytics information.
User Information may be collected by sending cookies to your device. Cookies are small data files that are stored on your hard drive or in your device memory when you use the Services. A cookie may also convey information to us about how you use the Services (e.g., the pages you view, the links you click and other actions you take) and allow us or our third-party analytics tools We use to track your usage of the Services. There are at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent use of the Services. Persistent cookies can be removed by following your Web browser’s directions for removal of cookies. A session cookie is temporary and disappears after you close your browser. You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how the Services are provided.
You can find out more about cookies and how to manage them by visiting www.AboutCookies.org. You can understand which third parties have currently enabled cookies for your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
3.5 Web Beacons.
User Information may also be collected by using web beacons. Web beacons are electronic images that may be used in connection with the Services. Company may use web beacons to deliver cookies, track the number of visits to the Offerings, understand Service usage and effectiveness, and determine whether an email has been opened and acted upon.
3.6 From Third Parties.
3.7 Do Not Track.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
4.1 Providing Services.
User Information is stored and used so that you can verify your identify using the Services. User Information is also used to save your preferences, user profile and information in connection with creating, using and accessing your account with the Services, and to deliver, operate, provide, maintain, enhance, personalize, tailor and facilitate your use of the Services.
4.2 Improving Services.
User Information is also used to develop new products and Services, provide optimization, statistical analysis, and improvements for existing Services, and to improve web design and functionality.
4.3 Communication Purposes.
User Information is used to deliver technical notices, security alerts, support messages, administrative notices and alerts, and communications relevant to your use of the Service, as well as to inform you about software compatibility issues, send news or information, conduct surveys and collect feedback. User Information is also used to communicate with you about products, services, contests, promotions, discounts, incentives, gift cards, loyalty programs, and rewards, based on your communication preferences and applicable laws.
4.4 Facilitate Payments.
Using and storing your User and Payment Information is necessary for us to be able to process or record payment transactions or money transfers.
4.5 Track and Display Consumer Behavior.
User Information is stored so that the Services can track historical transactions, payments, invoices, receipts and past order information. User Information is also used to display current, ongoing, pending or requested transactions or orders.
4.6 Legal Compliance.
User Information is stored so that we can comply with applicable laws and regulations, including the privacy laws and anti-money laundering laws.
4.7 Aggregated Data Collection.
User Information is collected and aggregated to monitor aggregate usage and web traffic routing of all users of the Services, as well as to generate aggregated statistics about purchasing behavior of different demographics and populations.
4.8 Dispute Resolution; Contract Enforcement.
4.9 Use for New Purposes.
5.1 Facilitate Third Party Services.
We, like many businesses, sometimes engage third parties to perform certain business-related functions and will share certain User Information for such parties in order for the third party to perform such functions. These third-party services may include anonymous site metrics, analytics services, payment processing, point of sale services, task management services, order fulfillment and shipment/delivery of products and Services to users, mailing services, maintaining databases and other features or services included in or necessary for the Services. When we employ another party to perform a function of this nature, we only provide them with the information that they need to perform their specific function and use commercially reasonable measures to obligate any such third parties to maintain the confidentiality of any User Information we share with them.
5.2 For Legal and Safety Purposes.
5.3 Business Transfers.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, User Information may be part of the transferred assets.
5.4 Affiliated Entities.
We may also share your User Information with our affiliated entities for purposes consistent with this Policy.
6.1 Protective Measures.
Company takes commercially reasonable measures, including administrative, technical, and physical safeguards, to (i) protect User Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction, (ii) ensure the security, confidentiality, and integrity of the User Information, (iii) protect against any anticipated threats or hazards to the security or integrity of the User Information, (iv) protect against unauthorized access to, or unauthorized use or disclosure of, the User Information, and (v) take such security measures required by any applicable privacy laws.
6.2 Third Party Partners and Employees.
Company may, by itself or using third-party service providers, hold, process and store User Information, including in the United States, Japan, the European Union and other countries. Company restricts access to User Information to those employees, contractors, and agents who need to know that information for purposes of performing their obligations to Company or to you, and who are subject to contractual confidentiality obligations, and who may be disciplined or terminated if they fail to meet these obligations. Company third-party service providers store and transmit User Information in compliance with appropriate confidentiality and security measures.
6.3 Security Breach.
We maintain reasonable technical safeguards to protect the security, integrity and privacy of your User Information. However, no method of internet transmission or electronic storage is 100% secure or error-free, so it is never possible to guarantee absolute security.
If required by law, Company shall give prompt notice to you of any unauthorized access to User Information and shall immediately commence a thorough investigation into any such incident.
6.4 Company Not Liable for Breach.
Company will not be liable for any damages, claims, liability, or causes of action that arise as a result of any unauthorized access or use of your User Information.
7.1 Unsolicited Information.
This Policy shall not apply to (i) information posted by you to any public areas of the Services, such as bulletin boards, chat room, community pages or comment areas, (ii) any ideas for new products or modifications to existing products, and (iii) other unsolicited submissions (collectively, “Unsolicited Information”). Unsolicited Information shall not be considered User Information and by submitting Unsolicited Information to us, you hereby grant us a license to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
8.1 Data Retention.
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
8.2 Contact Information and Choices.
Our services are not directed to children and/or persons under the age of majority in their respective jurisdictions and are intended for use by adults and/or persons at or over the age of majority only. We do not knowingly collect personal data from individuals under eighteen (18) years of age. If you are under the age of eighteen (18), please do not submit any information through our Services or other offerings and do not provide your consent for the use of your data unless your parent or guardian has approved.
8.4 Interest-Based Ads.
9. NOTICE TO RESIDENTS OF EUROPE AND THE UNITED KINGDOM.
9.1 General Information.
Trinsic recognizes the importance of protecting the privacy of our customers and the users of the Services. As such, we will always ensure that we have a lawful basis for processing your Personal Data. Trinsic’s offices are located at Trinsic Technologies Inc., 2261 Market Street #4395, San Francisco, CA 94114 (Attn: Legal). Trinsic is the data controller of all Personal Data collected from residents of the European Economic Area (EEA) or the United Kingdom. “Personal Data” shall mean any information or User Information which is related to an identified or identifiable natural person.
9.2 Our Legal Basis for Collecting, Storing, and Processing Your Personal
We will collect and process your Personal Data based on one of the following legal bases:
· Consent. We may process your Personal Data with your consent. You have the right to withdraw your consent at any time.
· Performance of a Contract. We may process your Personal Data if it is necessary for the performance of a contract to which you are a party.
· Comply with a Legal Obligation. We may process your Personal Data if it is necessary to comply with a legal obligation to which we are subject.
· Legitimate Interests. We may process your Personal Data if doing so is necessary for our legitimate interests and those legitimate interests are not overridden by your interests or fundamental rights and freedoms.
9.3 Your Legal Rights.
Under the GDPR and the UK GDPR, you have the following rights related to Trinsic’s use of your Personal Data.
Description of your right
A right to access Personal Data held by us about you, as well as information about how we are using your data.
A right to require us to rectify any inaccurate Personal Data held by us about you.
A right to require us to erase Personal Data held by us about you, and where the Personal Data has been made public, for other controllers processing the Personal Data to also erase links to, or copy or replication of, such Personal Data. This right will only apply where (for example): we no longer need to use the Personal Data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your Personal Data based on your consent; or where you object to the way we process your data (in line with the right to restrict use below).
A right to restrict our processing of Personal Data held by us about you. This right will only apply where (for example): you dispute the accuracy of the Personal Data held by us; or where you would have the right to require us to erase the Personal Data but would prefer that our processing is restricted instead; or where we no longer need to use the Personal Data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Data Portability and Transfer
A right to receive Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organization, at your request.
Object to Processing
A right to object to our processing of Personal Data held by us about you (including for the purposes of sending marketing materials to you).
9.4 International Data Transfers.
Trinsic is located in the United States, as such, your Personal Data may be processed by us or our service providers in the United States. In such case, we have endeavored to establish and provide appropriate safeguards for EEA residents, and provide EEA residents the ability to enforce their data subject rights and provide EEA residents effective legal remedies as set forth in GDPR Article 46.
For any transfer of Personal Data from the EEA, Switzerland, or the United Kingdom that we make, we use appropriate safeguards to ensure for the lawful processing and transfer of the Personal Data. When appropriate, we may use standard contractual clauses approved by the European Commission. Please contact us through one of the methods provided in the “Contact Us” section below and put “Safeguards” in the subject line to receive more information on the safeguards we have put in place.
9.5 Make a Complaint.
If you have any concerns or complaints regarding our processing of your Personal Data, please contact us through one of the methods provided above and put “Complaint” in the subject line.
If you have any concerns regarding our processing of your Personal Data or are not satisfied with our handling of any request by you in relation to your rights, you have the right to make a complaint to your local supervisory authority (EU Data Protection Authorities, Information Commissioner’s Office).
10.1 Notice to California residents.
10.2 Notice to Nevada Residents.
Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to us through one of the methods provided in the “Contact Us” section below and put “Nevada Opt-Out” in the subject line.
10.3 Notice to Utah residents.
We do not disclose your personal information to any third party for such third party’s direct marketing purposes.
11.1 Changes to this Policy.
This Policy is subject to occasional revision, and if we make any substantial changes, we may notify you through the Services, by sending you an e-mail to the last e-mail address you provided to us (if any), and/or by prominently posting notice of the changes on our Services or through your account. You are responsible for providing us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.
11.2 Effectiveness of Changes.
Any changes to this Policy will be effective upon the earlier of fifteen (15) calendar days following our dispatch of an e-mail notice to you (if applicable) or fifteen (15) calendar days following our posting of notice of the changes on our Services. These changes will be effective immediately for new users of the Services.
11.3 Acceptance of Policy.
Continued use of the Services following notice of changes to this Policy shall indicate your acknowledgement and acceptance of such changes and agreement to be bound by the updated Policy.
11.4 Last Revision Date.
This Policy was last updated on the date indicated above. Please review this policy periodically, and especially before you voluntarily provide any User Information.