TRIM.co Privacy Policy

Last Updated:  May 26, 2020

TRIM.co LLC and its affiliates, subsidiaries and parent companies (collectively, “TRIM.co”) value your personal privacy, and provide this Privacy Policy to give you information on how TRIM.co collects, uses, and discloses information we obtain about visitors to our website (http://TRIM.co) (“Site”), to associated sites linked to http://TRIM.co, and to our mobile application (“App”). 

By visiting the Site, using or downloading the App, or using any of our services, you acknowledge and agree that your personal information will be handled as described in this Policy.  Your use of our Site, App, or services, and any dispute over privacy, is subject to this Policy and our Terms and Conditions of Use (“Terms of Use”), including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy.

We reserve the right to update or modify this Privacy Policy at any time.  If we modify or update this Privacy Policy in a material way, a notice will be posted on our Site and App.  We will also update the “Last Update” date above.  By continuing to access or use the Site, App, or services after we have provided you notice, you are indicating you agree to be bound by the modified Privacy Policy.

1. The Types of Information We Collect About You
We collect information about you in a number of ways, including directly from you, automatically through your use of our Site and App, and from third parties.  More specifically:

    1. Information you provide to us directly:  When you engage with TRIM.co, such as by downloading and signing into our App, we may ask you to provide us with some personal information, including but not limited to:
      1. Personal Identifiers (“PI”), such as first and last name, postal address, email address, phone number, date of birth;
      2. Transaction Information, such as credit card information, and information about the purchases you made or wish to make;
      3. Demographic information, such as general descriptive information on age, employer, gender, etc.; and
      4. Your opinions or other information, for example if you review our services or if you provide us with your resume when exploring employment prospects with us.
    2. Information that we collect automatically:  When you visit our Site or App, or otherwise engage with us digitally, we may collect certain information automatically from your computer, tablet or mobile phone (collectively “Devices” and each a “Device”), including:
      1. Other PI, including the IP addresses of your web browsers, operating system versions, and mobile ad identifiers; 
      2. Information related to unique user behavior, such as browsing history, duration of a session, specific pages accessed, and links clicked; 
      3. Geolocation data;  
      4. Unique individual identifiers that we may create in order to identify a unique, de-identified user’s device or browser; and 
      5. Hashed values that are derived from PI (such as email addresses) but have been de-identified through various means. 
    3. Information that we obtain from third parties.  
      1. We may collect information about you, including the PI listed above, from third party sites and applications, when authorized by you in accordance with the terms and conditions set forth by the third parties.  
      2. We also collect information about you when you interact with us on social networking platforms.  If you message us or tag us in a social network post, we will collect information about your message or the post we are tagged in.

As set forth below in Section 5, some of this information may be collected using cookies and similar technologies.  We may combine, link, or aggregate certain elements of the above information with each other.  

2. How We Use the Information
We may (but do not necessarily, or always) use PI and other Information we hold or collect about you for the following purposes:

    1. To provide you with the products and/or services you have requested, including providing products or services directly to you, responding to your inquiries about our products and services, and supporting back-end processes necessary for the provision of services to you, such as internal accounting and administration purposes, to process payment for purchases or other services, and to create and manage your account.
    2. To verify your identity or provide you with customer support, for example we may use your date of birth to determine that you are old enough to use our services, or your email address to determine if you already have an account with us and how to troubleshoot problems with your account.  We may use your personal information to communicate important information to you in relation to your account, such as, (i) emailing you to verify your identity when you sign-up; (ii) emailing you where you have requested a password and/or username reset; (iii) notifying you that a particular service has been suspended or terminated; (iv) letting you know that we have updated this Privacy Policy or our Terms of Use; or (v) letting you know about any products or services that you have requested or purchased. We will never contact you to ask for your password.
    3. For direct marketing communications, for example, if you choose to receive marketing communications from us, we may use your information to keep you up to date with our latest products, services, surveys, announcements, events, contests and other promotions and competitions via direct mail, email, or other communications.   
    4. For tailoring of ads and content believed to be relevant to you, for example we, or with third party vendors, may use your information to provide you with tailored advertising on third party sites, including social sites.  We may track your browsing activity across different websites, different Devices and/or different applications in order to send you offers and ads for our products and services or the products and services of partner brands, or other offers we believe may be of interest to you.  We may use your information to target “multi-channel” ads to those who have visited or logged in to our Site.  In doing so, we may combine the Information with other information we obtain from third parties or publicly available sources to further improve the relevance and effectiveness of products, services, and advertisements offered.  We often employ various de-identification and data segregation techniques to safeguard consumer privacy.  We also may use or create “Audience Segments” that help us tailor ads and content based on a particular user’s preferences.
    5. To optimize of Ad Campaigns, by limiting the frequency or adjusting the sequence of advertising shown to you.  We also may use the Information to customize ads to a particular geographic region, or to the content of a web page on which they are shown.
    6. For campaign measurement, for instance, to determine which types of ads are most likely to be seen or opened, in what circumstances, or by which types of customers, or which types of ads are most likely to lead to clicks, purchases, or other behavior.
    7. For other data services.  We sometimes use PI and other Information to perform data analyses (including market research) or provide other data services, such as (but not limited to) email and direct mail marketing services, as well as analytics services.
    8. For improving our own services.  We may use certain PI and other Information to improve, analyze, and develop our own services.  For example, we may use clickstream data to determine how much time visitors spend on each web page of our site, how visitors navigate through the site, and how we may tailor our site to better meet the needs of our visitors. 

The above is not exhaustive.  We provide them to illustrate in a general way the services we offer, and how PI and other Information is used.  

3. How We May Share Information with Third Parties
We may share Information with others that we work with or retain in order to provide certain products or services:

    1. Partners:  We may share Information with business and data partners (including Marketing Platforms) to deliver ads, to help provide more tailored advertising, and for analytical purposes, such as to measure campaigns, to inform future campaigns.  We may also share Information with our service providers, such as providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or service providers otherwise assisting us to provide, develop, maintain and improve our services.
    2. Corporate transfers:  If TRIM.co or its significant assets are purchased by another entity, our Information will be transferred to that entity.  We also may share the Information during the course of any due diligence process.
    3. Affiliates, Parents and Subsidiaries:  TRIM.co may share some or all of the Information in our possession with affiliated or subsidiary companies. 
    4. As Required by Law or to Protect Any Party:  TRIM.co may disclose Information if we believe that such disclosure is necessary (a) to comply with relevant laws or legal processes, such as to respond to subpoenas or warrants served on us; (b) to enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) to respond to claims that any content violates the rights of third parties; and/or (d) to protect or otherwise defend the rights, property, or safety of TRIM.co, our Site or App, our clients, our agents and affiliates, and/or the public.  We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, spam/malware prevention, and similar purposes.

4. Your Opt-Out Rights
You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that is required is marked as mandatory. 

If you wish to opt out of receiving marketing communications from us, you may complete the form found HERE.  You may also opt out of receiving advertising from the online Marketing Platforms that we partner with, and learn more about companies that engage in various types of online targeted and retargeted advertising, by visiting the opt-out pages offered by the Network Advertising Initiative (NAI) (here) and the DAA (here).  Opting out in this manner will not prevent you from seeing ads; it will prevent targeted ads customized to what these companies believe are most likely to be relevant and of interest to you.  In addition, opting out in this way is browser-specific, so if you change your browser, update it, or clear your cookie cache, you will need to opt out again.

5. We and Others May Use Cookies, Pixels and Similar Technologies
TRIM.co uses industry-standard technologies, including cookies and pixel tags to identify your device and “remember” the activity on a site by a particular device.  We may use cookies to, among other things, retain the history of activity on a site, track user trends, and collect information about whether and how you use our sites or interact with the advertising we deliver.  We use cookies to help provide relevant content to you and replace non-relevant ads with ads that better match your interests.

While TRIM.co cookies expire, we may retain purely aggregated versions of the Information (i.e., not tied to a cookie or device) indefinitely.  We may work with third parties to provide or enhance our services (e.g., for purposes of retargeting and tailoring ads, or placing browser cookies).  These parties may set and access their own cookies, pixel tags, and similar technologies on your device, which may have cookies with varying expiration periods.  Those parties may, likewise, collect various types of anonymous or de-identified information about your browser, device, or browsing activities through use of these cookies.  

You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies.  However, if you disable cookies in your web browser, some features or services may be difficult to use or inoperable.  We or other companies we may partner with may (but will not necessarily) work with certain third-party companies that use techniques other than cookies to recognize your computer or device and/or to collect and record information about your web browsing activity, including those integrated with our services.  These technologies may not respond to browser settings that block conventional cookies.  

6. Links  
TRIM.co’s website(s) may provide links to other websites that TRIM.co thinks users will find interesting or useful.  TRIM.co is not responsible for the privacy practices of these other sites.

7. Security and Data Integrity
TRIM.co takes various steps to protect the Information we license or maintain, and to house and transmit that Information in a secure way.  For instance, these steps may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information.  While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we take these steps in an effort to ensure this does not occur.

8. Children Under 16
TRIM.co does not actively seek to collect the personal information of children under 16 years of age, and TRIM.co’s website(s) and services are not intended for use by children.  If you have concerns about use of your child’s personal information, you may contact us at privacy@trim.co.     

9. Binding Agreement; Changes
We may revise this Privacy Policy at any time and with an associated effective date.  Any revised Privacy Policy will be posted on TRIM.co’s website(s).

10. Questions or Concerns
If you have questions or concerns about TRIM.co’s privacy efforts or data practices or services, please contact us at privacy@trim.co or by U.S. Mail to:

TRIM.co
124 N. 1st Street
Louisville, KY 40202

833-TRIM-444