TRILLIAD GLOBAL PRIVACY NOTICE AND COOKIE POLICY
Entity: Trilliad and All Affiliated Entities
Effective Date: March 11, 2026
Last Updated: March 11, 2026
TABLE OF CONTENTS
Trilliad, LLC and its affiliated entities (“Trilliad,” “we,” “our,” or “us“) respects your privacy and is committed to protecting the personal information you share with us. This Global Privacy Notice and Cookie Policy (the “Privacy Notice“) explains how we collect, use, share, retain, and protect personal information across our global operations as a B2B marketing agency.
The data controller for personal information processed in connection with our website and direct client and business development activities is:
Trilliad, LLC
[INSERT Registered Address]
Attn: [email protected]
Jessica Troiano, General Counsel, Growth and Commercial
Where Trilliad entities in other jurisdictions act as data controllers or data processors, the applicable affiliated entity is identified in the relevant Supplemental Notice in Section 17.
The type of personal information we collect and the legal basis on which we process it depends on the nature of your interaction with us and the jurisdiction in which you are located. Please read this Privacy Notice carefully and consult the applicable Supplemental Notice for your jurisdiction.
This Privacy Notice applies to:
This Privacy Notice does not apply to:
For the purposes of this Privacy Notice, the following terms have the meanings set forth below:
“Affiliated Entity” means any subsidiary, parent company, holding company, or other entity that is directly or indirectly under common ownership or control with Trilliad.
“Consent” means a freely given, specific, informed, and unambiguous indication of agreement by a data subject — whether by a statement or by a clear affirmative action — to the processing of personal information relating to them.
“Cookie” means a small text file placed on a user’s device by a website, used to store information about the user’s browsing session or preferences.
“Data Controller” means the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of processing personal information.
“Data Processor” means a natural or legal person, public authority, agency, or other body that processes personal information on behalf of a data controller.
“Data Subject” means an identified or identifiable natural person to whom personal information relates.
“EEA” means the European Economic Area.
“Personal Information” / “Personal Data” means any information relating to an identified or identifiable natural person. This includes, but is not limited to: names, postal and email addresses, telephone numbers, IP addresses, device identifiers, cookie identifiers, location data, and any other information that can, directly or indirectly, identify a natural person. In certain jurisdictions, the definition may extend to household-level data.
“Sensitive Personal Information” / “Special Category Data” means personal information revealing or relating to racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic or biometric data processed for the purpose of uniquely identifying a natural person; data concerning health; data concerning a natural person’s sex life or sexual orientation; citizenship or immigration status; precise geolocation; government-issued identification numbers; and financial account credentials. The specific categories that constitute sensitive personal information vary by jurisdiction.
“Service Provider” means any natural or legal person that processes personal information on behalf of Trilliad pursuant to a written contract.
“Third Party” means a natural or legal person, public authority, agency, or body other than the data subject, the data controller, the data processor, and persons who, under the direct authority of the data controller or data processor, are authorized to process personal information.
“Website” means any website operated by Trilliad or any of its Affiliated Entities, including but not limited to www.trilliad.com; www.justglobal.com; www.sercante.com; www.sandler.com.
4.1 Information Collected Automatically
When you visit our Website, certain information is collected automatically through cookies, web beacons, pixel tags, server logs, and similar tracking technologies. This information includes:
This information is used for internal analytics, Website optimization, security, and — where you have provided consent — for marketing purposes. Please see Section 7 (Cookies and Tracking Technologies) for further detail.
4.2 Information You Voluntarily Provide
We collect personal information that you voluntarily provide to us when you:
This information may include your name, business email address, telephone number, job title, company name, and the content of your communications with us.
4.3 Information Provided by Clients in Connection with Services
As a B2B marketing agency, Trilliad’s clients may provide us with personal information in the form of:
When processing campaign and suppression list data, Trilliad acts as a data processor on behalf of the client as data controller. An individual’s information will appear on a campaign list only where the client represents that it holds a lawful basis for using that information for the stated marketing purposes. Trilliad’s use of such data is governed by the applicable Data Processing Agreement with the relevant client, and such data is not used for Trilliad’s own independent purposes.
4.4 Information Collected from Third-Party Sources
We may receive personal information about you from third-party sources, including:
Where required by applicable law, we will notify you of such collection.
Trilliad processes personal information only for specified, legitimate purposes and only where a valid legal basis exists. The legal bases applicable to each processing activity vary by jurisdiction. The table below sets forth our primary processing purposes, the categories of data involved, and the legal bases we rely upon.
Processing Purpose | Categories of Data | Legal Bases |
Operating and improving the Website, including analytics | Usage data, device identifiers, IP address, cookie data | Legitimate interests (analytics, security, improvement); Consent (where required by applicable cookie law) |
Responding to inquiries and communications | Name, contact details, communication content | Legitimate interests; Performance of a pre-contractual or contractual relationship |
Providing and delivering contracted services | Client contact data, service-related information | Performance of contract |
Processing campaign and suppression lists on behalf of clients | Business contact data (name, email, phone, job title, company) | Data Processing Agreement (Trilliad acts as processor); client holds applicable lawful basis |
Marketing our own services to prospective clients | Business contact data | Legitimate interests (B2B direct marketing); Consent (where required by applicable law) |
Compliance with legal obligations | As required by law | Legal obligation |
Protecting the rights, property, and safety of Trilliad, its personnel, and the public | Relevant personal information | Legitimate interests; Legal obligation |
Business transactions (e.g., merger, acquisition, asset sale) | As relevant | Legitimate interests; Legal obligation |
Defending or pursuing legal claims | As relevant | Legitimate interests; Legal obligation |
Improving data quality and maintaining records | Business contact data | Legitimate interests |
Where we rely on legitimate interests as our legal basis, we have assessed that our interests are not overridden by the interests or fundamental rights and freedoms of data subjects, taking into account the reasonable expectations of individuals in a B2B marketing context. You have the right to object to such processing in certain jurisdictions; see Section 10 for details.
Where we rely on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Instructions for withdrawing consent are set forth in Section 10 and Section 7 (for cookie consent).
We will not use your personal information for purposes that are materially different from, unrelated to, or incompatible with the purposes described in this Privacy Notice without providing prior notice and, where required, obtaining your consent.
Trilliad does not sell your personal information for monetary consideration. Trilliad does not share personal information with third parties for those third parties’ own direct marketing purposes without your consent.
We may disclose personal information to the following categories of recipients, and only to the extent necessary for the stated purpose:
6.1 Service Providers
We engage third-party service providers that perform functions on our behalf, including website hosting, analytics, IT support, marketing technology platforms, and data management. We require all service providers to process personal information only on our instructions, in accordance with a written contract that includes appropriate data protection obligations, and consistent with the privacy notice under which the information was collected.
6.2 Client Disclosure
Where Trilliad processes campaign or suppression data provided by a client, that data may be shared with downstream vendors (e.g., media platforms, publishers, demand-side platforms) in connection with executing the client’s marketing campaign. All such sharing is governed by the client’s Data Processing Agreement and Trilliad’s vendor contracts.
6.3 Affiliated Entities
We may share personal information among Trilliad’s Affiliated Entities for purposes consistent with this Privacy Notice, including service delivery, administration, and compliance. Where such transfers cross jurisdictional borders, appropriate safeguards are implemented as described in Section 8.
6.4 Legal and Regulatory Disclosure
We may disclose personal information to courts, regulators, supervisory authorities, law enforcement agencies, or government bodies where required or permitted by applicable law, including in response to a valid court order, subpoena, regulatory inquiry, or legal process. To the extent permissible and practicable, we will notify affected clients or data subjects of such disclosure.
6.5 Business Transfers
In connection with a merger, acquisition, reorganization, sale of assets, or similar corporate transaction, personal information held by Trilliad may be transferred to a successor entity. Any such transfer will be conducted in compliance with applicable data protection law, and affected individuals will be notified where required.
6.6 Protection of Rights and Safety
We may disclose personal information where we believe in good faith that disclosure is reasonably necessary to protect the rights, property, or safety of Trilliad, our personnel, clients, or the public; to detect, prevent, or address fraud; or to enforce our contractual or legal rights.
7. COOKIES AND TRACKING TECHNOLOGIES
7.1 Overview
When you visit our Website, we use cookies and similar tracking technologies (including web beacons, pixel tags, and analytics tools) to collect information about your device, browser, and interactions with our Website.
A cookie is a small text file placed on your device when you visit a website. Cookies enable websites to function efficiently and help website operators understand how their sites are used.
A web beacon (also known as a pixel tag or clear GIF) is a small electronic file embedded in a webpage or email that allows us and our service providers to track actions such as page visits or email interactions.
We use cookies and similar technologies for the following purposes:
7.2 Cookie Categories
We use the following categories of cookies on our Website:
7.3 Consent for Non-Essential Cookies
For visitors in the European Economic Area, the United Kingdom, and other jurisdictions where prior consent is required for non-essential cookies: When you first visit our Website, a cookie consent banner will be displayed. No analytics, functional, or marketing cookies will be set until you provide your affirmative consent by selecting the applicable cookie categories. You may accept all non-essential cookies, reject all non-essential cookies, or customize your preferences by category. The option to reject all non-essential cookies is presented with equal prominence to the option to accept all cookies. Your consent preferences are stored and applied to your subsequent visits to our Website.
For visitors in jurisdictions where an opt-out mechanism is the applicable standard: Non-essential cookies may be set on your device, but you may opt out at any time using the controls described in Section 7.4.
7.4 Managing Your Cookie Preferences
You may manage or withdraw your cookie consent preferences at any time using the cookie preference center accessible via the “Cookie Settings” link located in the footer of every page of our Website.
In addition, most web browsers permit you to control cookies through their settings. You may instruct your browser to refuse cookies or to delete existing cookies. Please note that disabling certain cookies may affect the functionality of our Website. Browser-specific guidance is available at:
For industry-wide advertising opt-outs, you may also visit:
https://www.youronlinechoices.eu/
8. CROSS-BORDER DATA TRANSFERS
Trilliad operates globally with offices and service providers located in multiple jurisdictions. In conducting our business, personal information may be transferred to, stored in, or processed in a country other than the country in which it was originally collected, including countries whose data protection laws may differ from those of your home jurisdiction.
Where personal information is transferred across jurisdictions, we implement appropriate safeguards to protect the information in accordance with applicable law:
Transfer Route | Applicable Mechanism |
EEA → Third Countries (including the US) | Standard Contractual Clauses (SCCs) adopted by the European Commission, Decision 2021/914/EU, as currently in force or as amended or replaced, supplemented by transfer impact assessments where required |
UK → Third Countries | International Data Transfer Agreement (IDTA) issued by the UK Information Commissioner’s Office, or the Addendum to the European Commission’s SCCs, as applicable |
Japan → Third Countries | Consent of the data subject or other mechanisms approved by the Personal Information Protection Commission (PPC) under the APPI |
We also may rely on adequacy decisions where applicable — for example, transfers of personal information to countries that the European Commission, the UK Secretary of State, or another applicable authority has recognized as providing an adequate level of protection.
A copy of the applicable transfer safeguards may be requested by contacting us at the details set forth in Section 16.
9. DATA RETENTION
Trilliad retains personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, to resolve disputes, and to enforce agreements. Retention periods may vary depending on the category of personal information and the context in which it was collected. The appropriate retention period is determined by considering:
Upon expiry of the applicable retention period, personal information is securely deleted or anonymized in accordance with Trilliad’s Records Retention and Disposal Policy. Requests regarding data retention specific to your personal information may be directed to the contact details set forth in Section 16.
10. YOUR PRIVACY RIGHTS
Subject to applicable law and jurisdiction, individuals may have the following rights with respect to their personal information held by Trilliad. Additional jurisdictional rights are described in the Supplemental Notices in Section 17.
Right | Description |
Right of Access | The right to obtain confirmation as to whether Trilliad processes your personal information and, if so, to receive a copy of that information and supplementary details about how it is used |
Right to Rectification / Correction | The right to request correction of inaccurate or incomplete personal information |
Right to Erasure / Deletion | The right to request deletion of your personal information, subject to applicable exceptions (e.g., legal obligation, legitimate interest in retaining the information) |
Right to Restriction of Processing | The right to request that we restrict processing of your personal information in certain circumstances (e.g., while accuracy is contested) |
Right to Data Portability | The right to receive your personal information in a structured, commonly used, machine-readable format and to transmit that information to another controller, where processing is based on consent or contract and is carried out by automated means |
Right to Object | The right to object to processing of your personal information based on legitimate interests (including direct marketing) or a task carried out in the public interest |
Right to Withdraw Consent | Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing |
Right to Non-Discrimination | The right not to be subjected to discriminatory treatment for exercising your privacy rights |
Right to Lodge a Complaint | The right to lodge a complaint with the applicable supervisory authority in your jurisdiction |
The specific rights available to you, and any applicable conditions or exceptions, depend on the jurisdiction in which you are located. To exercise any of the rights listed above, please submit a request using the contact details set forth in Section 16. Trilliad may need to verify your identity before processing your request.
Trilliad will respond to privacy rights requests within the timeframe required by applicable law. As a general guide:
Trilliad does not charge a fee to respond to a privacy rights request unless the request is manifestly unfounded, excessive, or repetitive, in which case a reasonable administrative fee may be charged or the request may be declined, with written explanation provided to the requestor.
11. CHILDREN’S PRIVACY
Our Website is intended for adults conducting business and is not directed to, nor does it knowingly solicit personal information from, children under the age of 16 (or the applicable minimum age in the relevant jurisdiction, which may be as low as 13 under certain laws).
If we become aware that a child under the applicable minimum age has submitted personal information to us through our Website without verifiable parental or guardian consent, we will take prompt steps to delete such information from our systems.
If you are a parent or guardian and believe that your child has provided personal information to us, please contact us at the details set forth in Section 16.
12. DATA SECURITY
Trilliad implements technically and organizationally appropriate security measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to:
Notwithstanding these measures, no method of data transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of personal information. By providing your information to us, you acknowledge this inherent risk.
To report a suspected security incident or data privacy concern, please contact us at [email protected] or via the privacy contact details set forth in Section 16.
13. DO NOT TRACK AND GLOBAL PRIVACY CONTROL
Do Not Track (DNT): Some web browsers transmit a “Do Not Track” signal to websites. There is no universally accepted standard for how websites should respond to DNT signals. Our Website does not currently modify its data collection and use practices in response to DNT signals.
Global Privacy Control (GPC): Trilliad honors valid Global Privacy Control (GPC) signals transmitted by users’ browsers as a legally recognized opt-out of the sale and sharing of personal information under the California Privacy Rights Act (CPRA) and applicable state laws that recognize GPC as a valid opt-out mechanism. Where a GPC signal is detected from a user located in a jurisdiction in which GPC recognition is required, Trilliad will treat that signal as an opt-out request and will not process the user’s personal information for sale or cross-context behavioral advertising purposes.
GPC does not affect processing that is strictly necessary for the operation of the Website or that is otherwise lawful on a basis other than the data subject’s consent or absence of an opt-out.
14. LINKS TO THIRD-PARTY SITES
Our Websites may contain links to third-party websites, services, or resources that are operated by parties other than Trilliad. These links are provided for convenience and informational purposes only. Trilliad has no control over, and assumes no responsibility for, the content, privacy practices, or data handling of any third-party website or service. We encourage you to review the privacy notice of any third-party site you visit before providing personal information.
15. CHANGES TO THIS PRIVACY NOTICE
The global privacy regulatory landscape is dynamic, and we may update this Privacy Notice from time to time to reflect changes in applicable law, our data practices, or our organizational structure. When material changes are made, we will update this Privacy Notice by posting the revised version on our Website.
Where required by applicable law, we will provide more prominent notice of material changes (e.g., by email notification or a notice on our Website homepage) and, when required, we will seek your renewed consent.
Your continued use of our Website following the posting of any revised Privacy Notice constitutes your acknowledgment of such changes. If you do not agree to the revised Privacy Notice, please discontinue use of our Website and contact us to exercise any applicable privacy rights.
16. CONTACT US AND HOW TO SUBMIT A REQUEST
If you have any questions, concerns, or requests relating to this Privacy Notice or the handling of your personal information, please contact Trilliad’s Privacy function using the following details:
Privacy Officer / Legal Department
Trilliad, LLC
7920 Norfolk Avenue Suite 200. Bethesda, MD 20814
Email: [email protected]
Online Request Form: Click Here
For residents of specific jurisdictions, additional or alternative contact details may be set forth in the applicable Supplemental Notice in Section 17.
Trilliad will endeavor to acknowledge receipt of all privacy inquiries promptly and to respond within the applicable statutory timeframe.
17. SUPPLEMENTAL NOTICES BY JURISDICTION
The following supplemental notices apply to residents of specific jurisdictions and supplement — but do not replace — the general provisions of this Privacy Notice. In the event of any conflict between a Supplemental Notice and the general provisions of this Privacy Notice, the Supplemental Notice controls with respect to the residents of the applicable jurisdiction.
17a. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)
Effective Date: March 11, 2026 | Last Updated: March 11, 2026
This Supplemental Notice applies to all California residents (“consumers“) and is issued in compliance with the California Consumer Privacy Act of 2018 (Cal. Civ. Code §1798.100 et seq.) (“CCPA“) and the California Privacy Rights Act of 2020 (“CPRA“), as amended and implemented by regulations of the California Privacy Protection Agency (“CPPA“). Any terms defined in the CCPA or CPRA have the same meaning when used in this Supplemental Notice.
Categories of Personal Information Collected
In the preceding twelve (12) months, Trilliad has collected the following categories of personal information:
Category | Examples | Collected |
A. Identifiers | Real name, alias, postal address, IP address, email address, unique online identifiers, cookie identifiers | YES |
B. California Customer Records (Cal. Civ. Code §1798.80(e)) | Name, address, telephone number, employment information, financial information | YES (limited to B2B business contact data) |
C. Protected Classification Characteristics | Age, race, gender, religion, disability, military status | NO |
D. Sensitive Personal Information | Government ID numbers, financial account credentials, precise geolocation, biometric data, health information | NO (except as incidentally collected via Website security) |
E. Commercial Information | Records of services purchased or considered | NO |
F. Biometric Information | Fingerprints, voiceprints, facial geometry | NO |
G. Internet or Network Activity | Browsing history, Website interaction data, advertisement interaction | YES |
H. Geolocation Data | Precise physical location | NO (approximate only, derived from IP) |
I. Sensory Data | Audio, visual, electronic, or similar information | NO |
J. Professional or Employment Information | Job title, employer name, work history | YES (B2B contact data) |
K. Non-Public Education Information | Academic records | NO |
L. Inferences Drawn from Personal Information | Profiles reflecting preferences or characteristics | NO |
Sources of Personal Information
Trilliad collects the categories of personal information identified above from the following sources:
Purposes for Collection and Use of Personal Information
We collect and use personal information for the following business and commercial purposes:
Disclosure of Personal Information for a Business Purpose
In the preceding twelve (12) months, Trilliad has disclosed the following categories of personal information for business purposes:
Sale and Sharing of Personal Information
Trilliad does not sell your personal information for monetary consideration within the meaning of CPRA §1798.140(al).
Trilliad may share personal information (specifically, online identifiers and internet activity data) with advertising technology partners for purposes of cross-context behavioral advertising. California residents have the right to opt out of such sharing at any time; see “Your CPRA Rights” below.
Your CPRA Rights
California residents have the following rights under the CPRA:
Exercising Your CPRA Rights
To exercise any of the rights described above, you or your authorized agent may submit a verifiable consumer request by:
We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt. If we require additional time (up to an additional 45 days), we will notify you in writing within the initial 45-day period and provide the reason for the extension.
We will verify your identity before fulfilling any request. The verifiable consumer request must provide sufficient information for us to reasonably confirm that you are the person about whom we collected personal information. You may authorize an agent to submit a request on your behalf; we may require written authorization and verification of the agent’s identity.
Contact for California Privacy Inquiries
17B. SUPPLEMENTAL NOTICE FOR EEA RESIDENTS
EU General Data Protection Regulation (GDPR)
This Supplemental Notice applies to residents of the European Economic Area (“EEA“) and is issued in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council (the “GDPR“).
Identity and Contact Details of the Data Controller
For personal information collected in connection with our Website and EEA-based business activities, the data controller is:
Trilliad, LLC
706 Giddings Ave Suite 400 Annapolis, MD 21401
Data Protection Officer (if appointed): not required. Privacy contact: [email protected]
If you have any questions about our data protection practices or wish to exercise your rights under the GDPR, please contact: [email protected]
Lawful Bases for Processing
Trilliad processes personal information of EEA residents on the following lawful bases under GDPR Article 6:
For processing of Special Category Data (GDPR Article 9), Trilliad relies on explicit consent (Art. 9(2)(a)) or another applicable basis enumerated in Article 9(2).
International Transfers
Transfers of EEA personal data to countries outside the EEA that do not benefit from an adequacy decision by the European Commission are conducted pursuant to the Standard Contractual Clauses adopted by the European Commission (Decision 2021/914/EU), supplemented where required by a Transfer Impact Assessment. A copy of the applicable SCCs may be requested by contacting [email protected]
Rights of EEA Data Subjects
EEA residents have the following rights under the GDPR:
To exercise any of these rights, please contact us at [INSERT EEA PRIVACY CONTACT EMAIL]. We will respond within thirty (30) days of receipt, extendable by a further sixty (60) days for complex or numerous requests, with written notice of the extension provided within the initial 30-day period.
17C. SUPPLEMENTAL NOTICE FOR UNITED KINGDOM RESIDENTS
UK GDPR / UK Data Protection Act 2018 / Privacy and Electronic Communications Regulations (PECR)
This Supplemental Notice applies to residents of the United Kingdom (“UK“) and is issued in compliance with the UK General Data Protection Regulation (as retained in UK law pursuant to the European Union (Withdrawal) Act 2018) (the “UK GDPR“), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (as amended) (“PECR“).
Identity and Contact Details of the Data Controller
For personal information collected in connection with our Website and UK-based business activities, the data controller is:
Trilliad, LLC
706 Giddings Ave Suite 400 Annapolis, MD 21401
Lawful Bases and Rights
The lawful bases for processing personal information of UK residents are materially the same as those described in Section 17B (EEA Residents), applied under the UK GDPR. UK residents hold materially the same data subject rights as EEA residents as described in Section 17B, subject to any modifications introduced by UK law, including the Data (Use and Access) Act 2025 (DUAA) to the extent in force at the applicable effective date of this Privacy Notice.
Cookies (PECR)
Under PECR, we are required to obtain prior informed consent before placing any non-essential cookies on the devices of UK Website visitors. Our consent mechanism complies with applicable PECR requirements and UK GDPR consent standards. Strictly necessary cookies are exempt from this consent requirement. Please see Section 7 for full details of our cookie practices and consent controls.
International Transfers from the UK
Transfers of UK personal data to countries outside the UK that do not benefit from UK adequacy regulations are conducted pursuant to the International Data Transfer Agreement (IDTA) issued by the UK Information Commissioner’s Office, or the Addendum to the European Commission’s Standard Contractual Clauses, as applicable. Transfers to EEA countries are made under the UK-EU adequacy decision (subject to its continuation).
Supervisory Authority
The supervisory authority for UK data protection matters is the Information Commissioner’s Office (ICO). You have the right to lodge a complaint with the ICO at any time:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: https://ico.org.uk
Helpline: 0303 123 1113
17D. SUPPLEMENTAL NOTICE FOR JAPAN RESIDENTS
Act on the Protection of Personal Information (APPI) (Act No. 57 of 2003, as amended 2022)
This Supplemental Notice applies to individuals located in Japan and is issued in compliance with the Act on the Protection of Personal Information (個人情報の保護に関する法律) (“APPI“), as amended effective April 2022, and the guidelines issued by the Personal Information Protection Commission (“PPC“) (個人情報保護委員会).
Business Operator Information
Trilliad, LLC
706 Giddings Ave Suite 400 Annapolis, MD 21401
Privacy Contact: [email protected]
Collection, Use, and Purpose Specification
Trilliad specifies, in advance, the purposes for which personal information of Japan residents is used (APPI Article 17) and handles such information only within the scope necessary to achieve those purposes. We will notify or publicly announce the purposes of use at the time of collection (Article 21).
Sensitive Personal Information (Yōhairyo Kojin Jōhō)
Trilliad does not collect or use sensitive personal information (including information relating to race, creed, social status, medical history, criminal records, or other categories designated by Cabinet Order) without the prior, explicit consent of the data subject (APPI Article 20(2)).
Third-Party Provision
Trilliad will not provide personal information to a third party without your prior consent, except as permitted by the APPI (e.g., as required by law, within the scope of entrustment, or between group companies for shared use). Where Trilliad provides personal information to a third party, we maintain records of such disclosures as required by Articles 29–30 of the APPI.
Opt-Out of Third-Party Provision
Where Trilliad intends to provide personal information to a third party on an opt-out basis (as permitted by APPI Article 27(2)), we will notify the PPC in advance and publicly announce the categories of personal information subject to such provision, the method of third-party provision, and the procedure for opting out.
Rights Under the APPI
Japan residents have the right to request that Trilliad:
Requests should be submitted using the contact details above. We will respond within a reasonable period in accordance with PPC guidance. A reasonable fee may apply for disclosure requests.
PPC Complaints
Complaints regarding Trilliad’s handling of personal information may be directed to the Personal Information Protection Commission:
Website: https://www.ppc.go.jp
Information You Provide to Us. We may collect personal information about you. For example, when you access and use our Site, you may be prompted to provide personal information which could personally identify you, such as your name, postal address, email address, telephone number, date of birth, limited location information, or any other identifier by which you may be identified online or offline. You directly provide us this information when you email us or contact us through our online portal located on the Site.
Information We Collect When You Use the Site. When you use or interact with our Site, we may use a variety of technologies that collect information about how the Site is accessed and used. This information may include:
Cookies (also known as browser and mobile cookies). A cookie is a small file placed on your device (computer, smartphone, tablet, etc.) which automatically collects and stores information. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related statistics about our Site (for example, recording the popularity of certain services content and verifying system and server integrity); and
Information from Third Party Analytics. We may use third-party analytics services, such as Google Analytics, to evaluate your use of the Site, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information related to the Site. Google Analytics is a web analytics service provided by Google, Inc. (“Google”). We may use the information we receive from Google Analytics to improve our site. Google Analytics collects only the IP address assigned to the date you visit our Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Site is restricted by the Google Analytics Terms of Use: http://www.google.com/analytics/terms/us.html.
HOW WE USE COLLECTED INFORMATION
We use information that we collect about you or that you provide to us, including any personal information, in order to present our Site and its contents to you, to provide you with information, products, or services that you request from us, to fulfill any other purpose for which you provide it, to notify you about changes to our Site or any products or services we offer or provide through it, in any other way we may describe when you provide the information, to improve the Site and any services offered through it, for any other purpose with your consent, or for purposes as generally permitted under applicable law. However, other than the specific uses listed above, we will not disclose, sell, share, lease, or rent your contact or personal information to any third party.
Third Party Goods and Services. We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at [email protected].
Advertisements. We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Online Behavioral Advertising. Online behavioral advertising is used to deliver advertisements that are catered to your interests based on your browsing history. We may engage our service providers to display ads on our behalf on the Internet, and our service providers may use information about you to provide you with our ads. We may also engage our service providers to track and report performance of advertising and marketing campaigns to and from us.
You can opt out of online behavioral advertising from certain ads on third party websites by visiting http://youradchoices.com. Furthermore, certain of our ads on third party websites may display an advertising options icon that you can click to learn about your choices. This icon will only appear on certain platforms. Keep in mind that these opt-outs work using cookies, so if you delete your cookies, then you will need to opt out again. Also, as you use different devices or browsers, you will need to opt out on each browser and device, individually. You can also help limit the amount of online and mobile advertising that you can receive by opting out of advertising from Network Advertising Initiative member companies at http://www.network advertising.org/choices.
The information we collect automatically does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or personal information we receive from third parties. It helps us improve our Site and to deliver a better, more personalized experience, including by enabling us to: (a) estimate our audience size and usage patterns; (b) store information about your preferences, allowing us to customize our Site according to your individual interests; (c) speed up your searches; and (d) recognize you when you return to our Site.
We may share your information, including your personal information with the following parties: our subsidiaries and affiliates; our subcontractors, service providers and other third parties we use to support our business; a buyer or other successor in the event of or during a merger, divestiture, restructuring, dissolution or other sale or transfer of some or all of Sercante’s assets or equity, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Sercante is among the assets transferred; for any other purposes disclosed by us when you provide the information; or with your consent.
We may also share your personal information to comply with any court order or legal obligation, including responding to any lawful government or regulatory request, or if we believe disclosure is necessary to enforce or protect our rights, property, or safety, or that of our customers or others.
You ultimately control what personal information we receive from you. We strive to provide you with information and choices regarding the personal information you provide to us and/or that we collect, including:
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, when you access our Site. Information on deleting or controlling cookies can be found at www.aboutcookies.org. If you disable or refuse cookies in your browser, please note that some parts of our Site may then be inaccessible or may not function properly.
Opt-Out. You may opt-out of receiving future communications from us any time we request your personal information. You can opt-out by using the unsubscribe process at the bottom of the email or by emailing us at [email protected] with “Unsubscribe” in the subject line. We will use commercially reasonable efforts to process such request in a timely manner.
Third Party Links. Our Site may contain links to websites operated and maintained by third parties, over which we have no control of the privacy policies or content. We are not responsible for the content or privacy practices of these other websites, and these links do not imply an affiliation between Sercante and the website owner, or any endorsement, approval or verification of any content contained on other websites. Privacy policies on such linked websites may be different from our privacy policy. You access such links at your own risk. You should always read the privacy policy of a linked website before disclosing any of your information on such website.
Social Media. We may interact with users both with, and without, an online account with us via social media. Please note that any content you post to social media platforms is subject to the specific social media platform’s terms of use and privacy policy.
The Site does not respond to “do not track” requests. All traffic is treated as equal and processed the same. If you desire to have your browsing be private, we suggest that you use your web browser’s private or incognito function, or similar options.
California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marking purposes. To make such a request, please send an email to [email protected].
Our Site is not intended for anyone under the age of 13, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under the age of 13, without parental consent, we will delete that information and otherwise comply with the requirements of any applicable law including the Children’s Online Privacy Protection Act. If you believe that we might have any information from or about a child under the age of 13, please contact us at [email protected].
We endeavor to put in place reasonable measures to secure your personal information from unauthorized acquisition, use, and disclosure; however, please keep in mind that the transmission of information over the internet and on mobile platforms is not always secure, which means we cannot guarantee the security or confidentiality of any personal information we obtain as part of our Site. Therefore, notwithstanding anything to the contrary within this Policy or the Terms of Use www.jobs.spotforpardot.com/terms, the Site is offered to you “AS-IS, WHERE-IS” and your use of our Site is at your own risk.
We may update this Policy to reflect changes in the manner in which we deal with personal information, whether to comply with then-applicable regulations and self-regulatory standards or otherwise. The Policy posted here will always be current. We encourage you to review this statement regularly. If we make a material change to the Policy, post a notification on the Site. Your continued use of this Site after we make changes is deemed to be acceptance of those changes.
To ask questions or comment about this Policy or our Terms of Use, or to remove or change your contact information in our database, or to not receive future mailings or other communications, as well as other inquiries, please contact us at any time at [email protected].