Privacy Policy

Last Updated: July 12, 2023

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Please see our Privacy Snapshot for a high-level overview of our privacy practices.

This Privacy Policy describes the privacy practices of Penny AI Technologies Inc. (“we”, “us”, or “our”) and how we handle personal information that we collect through the Trnd.io website and platform, and any other sites or services that link to this Privacy Policy (collectively, the “Service” or “Services”). 

We collect personal information pertaining to website visitors, representatives of the brands, retailers, or merchants with which we partner (“Brands”), social media creators and influencers who sign up to use the platform (“Influencers”), and individuals who purchase goods from Influencers’ virtual storefronts (“Consumers”) (collectively, “users”).

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Personal Information We Collect

Users may provide information about themselves or about other users of the Services (e.g., Brands may provide information about their Influencers). This information may include:

• Contact details, such as your first and last name, email and mailing addresses, phone number, and social media handles.
• Account and profile information, such as the username and password you use to access our Services and any information you upload to your profile.
• Payment and transaction information needed to complete payments and transactions with us and other users of the Services. This information may include purchase history, payment card information, and billing and shipping information. Payment card information is processed either directly by Brands or by our payment service provider, Stripe, which may handle your payment information in accordance with its own privacy policy (https://stripe.com/privacy). We do not have access to your full payment card information.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, and information you provide when you use any interactive features of the Services.  
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Services, online resources and our communications, such as:

• Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings and general location information such as city, state or geographic area.
• Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access and whether you have opened or otherwise engage with our communications, such as our marketing emails or clicked links or files within them.

We use the following tools for automatic data collection:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Information we obtain from other sources: 

• Third-party accounts and services. When you link the Services to a third-party platform, such as Facebook or Instagram, we may collect certain information from your account, depending on the privacy permissions you have configured within that account. We do not, however, have access to login information you use to connect your account to the Services. Further, we may maintain pages on social media platforms, such as Facebook, Twitter, and LinkedIn. When you visit or interact with our pages on those platforms, you or the platforms may provide us with information through the platform.
• Other sources. We may obtain personal information from other third parties, such as marketing partners, publicly-available sources, and data providers. 

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:

Provide our Services. We use personal information to operate, maintain, and provide you with our Services. In particular, we use personal information to perform our contractual obligations under our terms of use.

Communicate with you about our Services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, in-app notifications, updates, security alerts, and support and administrative messages.

Improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes: 

• Understanding your needs and interests, and personalize your experience with the Services and our communications.
• Troubleshooting, testing and research and to keep the Services secure.
• Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business. 

• Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt out of our marketing communications as described in the “Opt-out of marketing communications” section below.

Except where consent is required, we undertake such marketing on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time. 

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:

• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
• Audit our internal processes for compliance with legal and contractual requirements and internal policies.
• Enforce the terms and conditions that govern the Services.
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
• Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Personal Information

We may share personal information with the following individuals or entities:

Other users of the Services, in order to facilitate transactions and other interactions on our platform. For example, we may share a Consumer’s contact and shipping information with a Brand to facilitate the Consumer’s purchase from the Brand through an Influencer’s storefront. This Privacy Policy does not apply to users’ subsequent use of your information. 

Affiliates. Our affiliated companies for purposes consistent with this Privacy Policy.

Service providers. We may from time to time employ or engage other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Services. We reserve the right to use customer data to improve our products and services and to provide such third parties with the Personal Information that they need to perform their specific function. This includes third party companies and individuals employed or engaged by us to facilitate our products and services, including the Sub-Processors listed here, and businesses who engage our Services (to the extent provided for above).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests (including, in connection with a bankruptcy or similar proceedings).

Privacy Rights and Choices

Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You may continue to receive Services-related and other non-marketing emails.

Online tracking opt-out. You can opt out of third-party cookies as described in our Cookie Policy.  

Personal information requests. We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information: 

• Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
• Additional rights, such as to object to and request that we restrict our use of personal information.

To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

Do Not Track. Some Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.

Security

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

Children 

Our Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Services from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

International Data Transfers

You will provide personal information directly to our Services in the United States. We may also transfer personal information to our partners and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information.

Retention of Personal Information

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable). 

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 personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements. 

Job Applicants

When you visit the careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics and to respond to surveys. We may also use this information to provide improved administration of the Services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or our terms of use.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website. 

How to Contact Us

Responsible entity. Penny AI Technologies Inc. is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law).

Contact us. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at privacy@trnd.io.