A. Introduction
Trellance, Inc. (“Trellance,” “us,” “we,” or “our”) collects and processes information about you as described in this Privacy Notice (“Notice”). Our collection and processing of information that alone or in conjunction with other information may identify you (“Personal Information”) may be either for our own purposes, or on behalf of other entities to whom we provide services. If you have any questions regarding the collection and processing of Personal Information performed by us on behalf of another entity please consult that entity’s privacy policy. We are committed to protecting the privacy of those with whom we interact. This Notice contains details about how we collect, use, and share Personal Information that we obtain from and about you when you interact with us on our website (the “Website”), via email, and in other online and offline interactions. For the purpose of this Notice, Personal Information shall by interchangeable with Personal Data, and each shall have the meaning assigned to it by applicable laws, including, but not limited to, information that directly or indirectly, on its own or in conjunction with other information, identifies an individual. Please read this Notice carefully.
This General Privacy Policy, should be read alongside the section Information Specific to Personal Information of California Residents, which is specifically for residents of California.
Applicability:
We collect information in several contexts as described below. This policy also does not apply to information we collect in connection with providing services to our business clients, where we act as a service provider and process Personal Information in accordance with their instructions. Such information is subject instead is subject to the Privacy Policies of this other financial institutions.
Changes:
We may update this Notice from time-to-time. The current Notice will be effective when posted. Please check this Notice periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will seek affirmative consent from you before making material changes to the way we handle Personal Information previously collected from you. If you do not provide such consent, Personal Information will continue to be used in a manner that is consistent with the version of this Notice under which it was collected.
Links to Other Websites and Applications:
This Notice applies only to Trellance operated services and applications, including our online services and Website. Our Website may contain links to other websites that are not operated or controlled by Trellance. Trellance does not control such third-party websites or their privacy practices. Any personal information you choose to give to third-party websites is not covered by this Notice.
B. Categories of Personal Information
We collect or process the following categories of your Personal Information for our own use or on behalf of our credit union customers:
- Names and contact information
- Commercial information
- Credit Union members’ account and other financial information
- Online identifiers
- Demographic information or other characteristics of protected classes
- Internet or other electronic network activity information including browsing history, search history and information about your interactions with our online services and Website
- Professional or employment information
- Inferences drawn from other information to create a profile about your preferences or characteristics
C. Purpose of Personal Information Collection and Processing
We collect and process Personal Information for the following purposes for our own use or on behalf of our credit union customers:
- To provide products and services to our business customers—credit unions and community banks
- To provide predictive analytics products and services to our business customers
- To answer your questions or respond to other requests
- For support your professional relationship with us—including employment relationships and client account relationships
- For security and fraud prevention
- To comply with applicable law or protect the rights and property of Trellance, our customers or others
D. Online Collection Activities
We collect information, via cookies, web beacons, pixels, tags, or other tracking technologies (“Tracking Technologies”), such as your Internet Service Provider and IP address, the date and time you access our Website, the pages you accessed while visiting our Website, and the Internet address from which you accessed our Website.
We may permit third parties to place Tracking Technologies on our Website to allow these third parties to directly collect Personal Information from you. These third parties may also use Tracking Technologies to serve you advertisements tailored to interests you have shown by browsing on this Website and other sites, applications, destinations, and services you have visited, and for other lawful business purposes. In doing so, these third parties may collect your Personal Information, including for example the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your computer, mobile or other device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.
Cookies that are placed on your device may only last a single session or may be persistent over multiple sessions over time. These Tracking Technologies may be used to track you across devices and websites over time.
To provide you with more relevant and interesting experiences, we may work with third party companies to display ads or customize the content on this Website and on other digital properties and websites. These companies may use cookies and similar tracking technologies as described in this Notice to gather information about your visits to our Website, as well as your visits elsewhere on the Internet. These companies use this information to provide you with more relevant advertising known as interest-based advertising. For more information about third-party advertisers, please visit http://www.networkadvertising.org/choices/. This is a site offered by the Network Advertising Initiative (“NAI”) that includes information on how consumers can opt-out from receiving interest-based advertising from some or all of NAI’s members. The Digital Advertising Alliance (“DAA”) also offers a choice mechanism with respect to certain types of data collection and use by third parties available at www.aboutads.info. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.
Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. We do not honor DNT signals from website browsers at this time. However, you may refuse or delete cookies. If you refuse or delete cookies, some of our Website functionality may be impaired. If you change computers, devices, or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies.
E. Third Party Sharing
We may share your Personal Information with other companies that support or partner with us in our business practices. Additionally, we may disclose information about users (i) if it is required to do so by law or legal process; (ii) as may be required to law enforcement authorities or other government officials, (iii) when it believes disclosure is necessary or appropriate to prevent physical harm, financial loss or in connection with an investigation of suspected or actual illegal activity, or (iv) to respond to claims by third parties.
F. Collection of Personal Information from Children
Our Website is intended for individuals 18 years of age and older. It is not directed at, marketed to, nor intended for, children under 18 years of age. We do not knowingly collect any information, including Personal Information, from children under 18 years of age. If you believe that we have inadvertently collected Personal Information from a child under the age of 18, please contact us at the email address in Section G below, and we will take immediate steps to delete it.
Should you have any questions regarding this Notice you may contact us at [email protected].
G. Inquiries/Contact Us
Information Specific to Personal Information of California Residents
This section of the Notice does not apply to information about individuals who are encompassed by the business-to-business exception in the California Consumer Privacy Act (“CCPA”). This section is also solely applicable to our website activities that involve Personal Information that are conducted for our own purposes. If you are engaging with our services because we support your credit union, please refer to that entity’s privacy policy for information on the collection and processing of your Personal Information.
For purposes of this section of the Notice, Personal Information includes information about both consumers and households.
H. Personal Information We Collect and Have Collected in the Past 12 Months Sources and Categories
In the 12 months preceding the date of this Notice, we may have collected your Personal Information when you visited our Website, requested information about our services, registered for mailing lists, submitted comments or otherwise interact with the Website, emailed or called us, or when you voluntarily provided information to us through an email or phone call. We will continue to collect Personal Information from the same sources.
The categories of Personal Information we may have collected from these sources during the 12 months preceding the date of this Notice, and will continue to collect, includes the following:
- Personal identifiers, email address, address of the property for inspection, your home or billing address, telephone numbers, customer number, account password, and IP address or other unique identifier.
- Personal information subject to the California Customer Records Act, such as signatures.
- Internet or other electronic activity information, such as your device and browser type, your browsing and search history on our Website, and information regarding your interaction with our Site and our advertisements.
- Audio and visual information, such as recordings of customer service calls for quality assurance purposes.
- Professional, employment, or education information, such as job title, employer, business address and contact information, employment history, other professional information, or education history.
- Education information, information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act.
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
I. Purposes for Collection of Personal Information
We use your Personal Information to provide you with the information you request and services that are ordered by you or on your behalf. We may also use the information you provide us to contact you from time to time to provide you with customer support and required notices.
We also use Personal Information about your use of our Website to monitor or improve our Website; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.
J. Disclosure of Personal Information For Business Purposes in the Past 12 Months
Categories of Consumers’ Personal Information
| Categories of Consumers’ Personal Information | Categories of Consumers’ Personal Information |
|---|---|
| Personal identifiers: name, email address, address of the property for inspection, home or billing address, telephone numbers, customer number, account password, and IP address or other unique identifier. | 1) Service Providers, who support our business operations and efforts 2) Our parents, subsidiaries, and affiliates 3) Companies to whom your data is shared at your direction |
Personal information subject to the California Customer Records Act, e.g., signatures. | 1) Service Providers, who support our business operations and efforts 2) Our parents, subsidiaries, and affiliates 3) Companies to whom your data is shared at your direction |
| Internet or other electronic network activity information: device and browser type, browsing and search history on our Website, and information regarding interaction with our Website and our advertisements. | 1) Service Providers, who support our business operations and efforts 2) Our parents, subsidiaries, and affiliates 3) Companies to whom your data is shared at your direction |
| Audio or visual information: recordings of customer service calls for quality assurance purposes, and photographs of yourself that you voluntarily provide in connection with reviews of our services. | 1) Service Providers, who support our business operations and efforts 2) Our parents, subsidiaries, and affiliates 3) Companies to whom your data is shared at your direction |
| Professional, employment, or education information: job title, employer, business address and contact information, employment history, other professional information, or education history. | 1) Service Providers, who support our business operations and efforts 2) Our parents, subsidiaries, and affiliates 3) Companies to whom your data is shared at your direction |
| Education information: information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act. | 1) Service Providers, who support our business operations and efforts 2) Our parents, subsidiaries, and affiliates 3) Companies to whom your data is shared at your direction |
| Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | 1) Service Providers, who support our business operations and efforts 2) Our parents, subsidiaries, and affiliates 3) Companies to whom your data is shared at your direction |
Additional Information About How We May Share Personal Information
We may share any of your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share any of your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. We may transfer any of your Personal Information to a third party in the event of a sale, merger, reorganization of our entity or other restructuring.
K. Rights Related to Your Personal Information
Additional Information About How We May Share Personal Information
If you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to personal information, subject to certain legal limitations and applicable exceptions. In particular, you can request the following:
- Specific Pieces of Information
- The specific pieces of your personal information that we’ve collected about you in the past 12 months.
- Categories of Information
- The categories of your personal information that we’ve collected in the past 12 months.
- The categories of sources from which we collected personal information.
- The business or commercial purposes for which we collected or sold personal information.
- The categories of third parties with which we shared personal information in the past 12 months.
- The categories of third parties to whom we’ve sold personal information in the past 12 months, and the category or categories of personal information sold to each.
- The categories of personal information that we’ve shared with service providers who provide services for us in the past 12 months, like processing your bill, and the category or categories of personal information sold to each.
Your Right To Request Deletion of Personal Information We Have Collected About You
Upon your request, we will delete the Personal Information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.
Your Right to Ask Us Not to Sell Personal Information We Have Collected About You
You have a right to request that we do not sell Personal Information that we have collected about you. However, we do not knowingly sell Personal Information, including Personal Information of individuals under the age of 16.
I. Exercising Your Rights and How We Will Respond
To exercise any of the rights above, or to ask a question, contact us at (888) 930-2728 or [email protected].
For requests for access or deletion, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Our Commitment to Honouring Your Rights
If you exercise any of the rights explained in this Notice, we will continue to treat you fairly. If you exercise your rights under this Notice, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
M. Verification of Identity Access or Deletion Requests
We will ask you for identifying information and attempt to match it to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
N. Ensuring Veracity of Opt-Out Requests
If we have a good-faith, reasonable belief that a request to opt-out of the sale of Personal Information is fraudulent, we may deny
O. Authorized Agents
You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. You will be required to verify your identity by providing us with certain Personal Information as described above, depending on whether you hold an account with us or not and the nature of the information your require, which we will endeavour to match the information submitted to information we maintain about you. Additionally, we will require that you provide us with written confirmation that you have authorized the agent to act on your behalf. The agent will be required to provide us with proof of the agent’s identity and status as an agent, under penalty of perjury. Information to identify and verify your agent can be submitted through our verification portal.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
P. Requests for Household Information
There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify the identity of each member of the household using the verification criteria explained above and will also verify that each household member is currently a member of the household.
If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.
Q. California Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about certain categories of Personal Information a business has disclosed to third parties for direct marketing purposes in the preceding calendar year. Trellance has not disclosed Personal Information to third parties for their own direct marketing purposes in the past year.