Trinitas Intelligence LLC Privacy Policy

1. Introduction

Trinitas Intelligence LLC (“Trinitas Intelligence,” “we,” “us,” or “our”), a subsidiary of Trinitas Ventures, issues this Privacy Policy to detail our policies and procedures regarding the collection, use, and disclosure of Personal Information from or about individuals who apply for and/or receive a scholarship from us, which is available on our Website, www.trinitasintelligence.com (“Website”) (together the “Services”).

Please note that this Policy applies to anyone who uses or accesses our Services, regardless of whether you use the Services via a computer, mobile device, tablet, or other medium (collectively, your “Equipment”).

Our Services are hosted in and directed at individuals in the United States. If you reside outside the United States, please do not use our Services. If you live outside the United States and share your Personal Information with us, it will be handled in accordance with applicable U.S. law and this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use our Services.

2. Collection of Personal Information

As you access and use the Services, we may collect your Personal Information. “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with a particular person. Personal information does not include information that is publicly available or de-identified.

You may always choose not to share your Personal Information with us. Please note, however, that if you choose not to share required Personal Information, then you may not be able to use some of our Services, including applying for and/or receiving a scholarship from us. If you have questions about what Personal Information may be required to apply for and/or receive a scholarship from us, please contact us at privacy@trinitasintelligence.com or by mail at:

2.1. What Categories of Information Do We Collect?

We collect the following information:

1. Identifying Information. Such as name, mailing address, email address, telephone number, and IP address.
2. Other Personal Information. Such as financial information, including parental and/or household income to establish financial need for a scholarship; your signature; and education information (as described below).
3. Internet or Other Electronic Network Activity Information, including, but not limited to, browsing history, search history, information regarding your interaction with our Website and advertisements, browser type, Internet service provider, the referring and exit pages to and from the Website, installed fonts, device IDs, language and time zone setting, and other information relating to your Equipment and use of or access to the Services.
4. Education Information. Such as the name of your post-secondary education school, year, major, and grades.
5. Geolocation Data. Such as city, state, and zip code.
6. Inferences drawn from any of the Personal Information we collect from our about you to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, or attitude
7. Demographic Information. Such as your age, gender, racial or ethnic origin, citizenship (to confirm U.S. citizenship for scholarship eligibility), or parental household income. Any use of this information will be consistent with applicable law.
8. Sensitive Personal Information. Such as your racial or ethnic origin, citizenship (to confirm U.S. citizenship for scholarship eligibility), or geolocation data.

Please only share with us the information we request. If you share additional information with us that we did not request, then such information is considered shared voluntarily and with your consent and may be used in a manner consistent with this Privacy Policy.

2.2. How do we Collect Information?

We collect information in the following ways:

2.2.1. Third-party partners

We may collect information about you from our third-party partners that share your information with us. For example, we may obtain directory-related information from your post-secondary educational institution and use the contact information they provide to contact you about our scholarship opportunities.

2.2.2. Directly from you through your completion of a scholarship application and/or facilitation of an awarded scholarship.

We collect information when you (i) complete the scholarship application or contact us and (ii) share any additional information to facilitate the award and implementation of a scholarship.

2.2.3. With your consent

If you opt-in to our use of your information for other purposes and/or sharing with our third-party partners, affiliates, subsidiaries, and/or parent company.

2.2.4. Automatically from your Equipment.

When you access or use our Services, information associated with you and/or your Equipment may automatically be collected or received through device-based tracking technologies such as cookies, pixels, tags, beacons, or other technology. We may also automatically collect or receive such information any time you interact with our advertising and content on other websites and platforms. Advertisers and other third parties may also collect information from your interaction with advertising on our websites, applications, or other Services.

2.2.5. From other third parties.

We may receive information about you from vendors and service providers we hire to help us run our business, including the companies that host or operate our Services, send emails for us, provide marketing, analytics, and advertising services, or host our content. We may combine that information with information we collect directly from you. We also may receive Personal Information from business partners that we engage to share consumer information with us. We may also obtain Personal Information about you from advertising networks and search information providers. Additionally, other users of our Services may provide us with your Personal Information so that we may invite you to use our Services.

2.3. Cookies and Other Automatic Data Collection Technologies

We may automatically receive and store certain types of Personal Information whenever you access, interact with, or use our Services. For example, we may use “cookies” and “web beacons” (also called “clear gifs” or “pixel tags”), to obtain certain information when you use or access our Services. We may use information collected via these technologies to:

• Estimate our audience size and usage patterns.
• Store your preferences, so that we may customize our Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Services.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services. For more information, see Interest-Based Advertising.

Cookies are small files that we may transfer to your Equipment’s hard drive or to your web browser’s memory to enable our systems to recognize your browser and to provide convenience and other features to you. We may also use cookies to provide additional features or functionality to your experience when you use our Services, for example, storing your preferences and other information about you when you use the Website.

You may block or limit the storage of cookies via browser controls or other software. You may also delete cookies manually from your device through your internet browser, operating system, or other programs you use to access the Services. Please note that some portions of our Services may not function properly or be available if you block or delete certain cookies.

Web beacons (also known as web bugs, clear GIFs, or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, or to provide other information.

To the extent any of these automated technologies are considered a Personal Information sale, targeted advertising, or profiling, under applicable laws, depending on in which state you are a resident, you may opt out from use of these automated technologies for such uses as described in Your Rights and Choices below. Please note that some Service features may be unavailable as a result.

Third-party use of technologies. Additionally, when you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your Equipment. These third parties may include advertisers, ad networks, and ad servers, analytics companies, your Equipment manufacturer, your internet or mobile service providers, etc. These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly.

3. How We Use Personal Information

3.1. For What Purposes Do We Use Personal Information?

We may use Personal Information for our business purposes including:

• To provide the scholarship application, process scholarship applications, and award and implement a scholarship and related support services.
• To personalize your user experience and tailor interactions with you.
• To analyze usage and effectiveness of the Services.
• To communicate with you about your scholarship application, and, as applicable, award and implement a scholarship. We may also contact you to complete a survey about your experience. We may also communicate with you, with your consent, regarding any of our other services, and/or services, products, or offerings from our affiliates, subsidiaries, parent company, or third-party companies.
• To license Personal Information to third parties for the purpose of offering additional services, provided that you have consented to such use.
• To respond to your requests to us, including any applicable data subject access requests.
• To deliver relevant content, advertisements, and messaging to you and to measure or understand the effectiveness of such content, advertisements, and messaging.
• To improve our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
• To improve our marketing, customer relationships, and experiences.
• To use for any purpose permitted by law, disclosed to you at the time of collection, or with your consent, as permitted by law.
• To enforce our Terms of Service, this Privacy Policy, or other applicable policies or agreements with you.
• To protect the rights, property, or safety of our business, employees, customers, or others, including for cybersecurity and fraud protection.
• To facilitate a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g., due diligence) and/or to facilitate any other activity in connection with the creation, development, offering, provision, or servicing of our products and services.

We may also de-identify Personal Information in our possession so that it cannot be linked to a person. We may use such information for any purpose.

3.2. Disclosure of Information

We may share your Personal Information with service providers, contractors, and third parties for the following purposes.

3.2.1. Service Providers and Contractors

We may use service providers, contractors, and vendors to help offer, process, and implement the scholarship and Website services. For instance, we may use service providers to help us provide applicant support, email and text message deployment, research and analytics, marketing and advertising services, data processing, management, fraud prevention, and survey administration.

3.2.2. Third Parties

With your consent, we may also disclose the Personal Information Trinitas Intelligence collects from or about you to our third-party partner(s) that provide services on our behalf and/or that may also use the information we provide for their own commercial purposes. For example, if you have opted-in, we may share your Personal Information with our parent company, Trinitas Ventures, to market their products and services to you.

3.2.3. Interest-Based Advertising

While using our Services advertisers may use Personal Information about you and your visits to the website and other sites to provide advertisements on the Website and other sites about goods and services that may be of interest to you (interest-based advertising). Such third-party advertisers may use cookies, clear gifs, web beacons, or other similar technology to track your online activities over time and across different websites and other online services.

Some of the advertisers may be members of the Network Advertising Initiative (NAI). Individuals may opt-out of targeted advertising delivered by NAI member ad networks by visiting www.networkadvertising.org. Other advertising networks may be members of the Digital Advertising Alliance. Such advertisements can be identified by the DAA icon. You can click on the DAA icon in the advertisements themselves to manage your preferences.

Note: We also use Google Analytics to analyze use of our Services. For more information about how Google uses information from sites or apps that use its services, please visit https://policies.google.com/technologies/partner-sites.

3.2.4. Required Disclosures

We may disclose your Personal Information if required by law or if such use or disclosure is necessary to protect our or our business partners’ rights, protect your safety or the safety of others, investigate fraud, or comply with law, a court order, or legal process. In addition, we may disclose, remove, or change information you provide about third parties if properly instructed by the individual who is the subject of such information.

Further, as noted, if we go through a business transition, such as a merger, acquisition, change in control, or sale of all or a portion of its assets, we may disclose, sell, transfer, or assign our rights to the Personal Information in our possession as part of such business transition.

4. Minors’ Information

Our Services not intended for individuals under 18 years of age. We do not knowingly collect, sell, or share (as those terms are defined by applicable law) the Personal Information of any individual under 18 under this Policy. If you are under 18, do not use or provide any information to us. If you believe we may have any information from or about an individual under 18, please contact us at privacy@trinitasintelligence.com or by mail at:

5. Security

The security of your Personal Information is very important to us. We use appropriate physical, electronic, and administrative safeguards designed to protect your Personal Information from loss, misuse, and unauthorized access, use, alteration, or disclosure.

5. Retention

We will retain and use your Personal information only for the period necessary for the purposes for which we collect it, with your consent, and/or and as permitted by law, including to comply with our legal obligations, resolve disputes, or enforce our agreements unless a longer retention period is permitted or required by law. Following the expiration of the retention period, Personal Information will be deleted. Therefore, any data subject rights (described below) you may have cannot be exercised after the expiration of the retention period.

6. Your Rights and Choices

6.1.1. Marketing Information

As noted, we may use your Personal Information to send you communications to promote or recommend our own products and services or third parties’ products or services. You may opt out of receiving such communications by replying to any promotional email we have sent you or following the opt-out links on that message. Such opt-out requests will not apply to information provided to us and communications sent by us to provide the requested service or other service-based transaction, such as scholarship consideration, processing, and implementation.

6.1.2. Accessing, Updating, and Deleting Your Information

You may request access to your Personal Information. You may request to review your Personal Information by contacting us as provided below. If you believe that the information we maintain about you is incomplete or inaccurate, you can request that we correct it. We will make corrections whenever possible, consistent with applicable law.

6.1.3. Cookies and Other Automatic Data Collection Technologies.

Please see Cookies and Other Automatic Data Collection Technologies above for information on how to manage these technologies.

6.1.4. Interest-Based Advertising.

Please see Interest-Based Advertising above for information on how to opt-out of interest-based advertising.

6.1.5. Withdrawing Your Consent

If we are relying on your consent to process your Personal Information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided below. However, please note that revoking consent will not affect the lawfulness of our processing of your Personal Information before your consent is withdrawn nor, when applicable law allows, will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

6.1.6. Location Data

We collect location data such as information about your Equipment’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the Equipment you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

6.1.7. Data Subject Access Rights.

Depending on in which state you are resident, you may have the following rights related to your Personal Information. These rights include:

• The right to know what Personal Information we process about you.
• The right to request certain Personal Information that we process about you be deleted.
• The right to request we correct Personal Information we have about you which you believe is incorrect.
• The right to have certain Personal Information we process about you returned to you in an accessible and useable format upon your request, if such request is technically feasible.
• The right to opt-out of having your Personal Information processed in such a way that enables us to create a profile of inferences about you or for targeted advertising purposes.
• The right to limit the use of your Sensitive Personal Information.
• The right to opt-out of the sale of your Personal Information.
• The right to opt-out of any profiling in furtherance of decisions that produce legal or similarly significant effects.
• The right to exercise your data subject rights free from discriminatory treatment, including if you are an employee, applicant, or independent contractor, the right against employment-related retaliation for exercising your data subject rights.

California Residents.

If you are a California resident, you may have additional personal rights and choices regarding your Personal Information. For example, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of a covered entity’s website that are California residents to request certain information regarding the entity’s disclosure of personal data to third parties for their direct marketing purposes.

Note: it is our policy not to disclose the Personal Information of individuals to third parties for the third parties’ direct marketing purposes if the individual has exercised an option that prevents that information from being disclosed to third parties for those purposes. As noted previously, you may, cost-free, opt out of any sharing of your Personal Information with third parties for direct marketing purposes by contacting us using the Contact Us information below.

Exercising Your Data Subject Rights

To exercise your applicable data subject rights, please submit a request using the contact information provided in the Contact Us section below.

Verification of Data Subject Rights Requests

We may require that your identity be verified prior to processing verifiable rights requests. If your request requires verification, we will verify your identity by comparing the information we have about you against the information we receive when you submit your request. If we do not have enough information to verify your identity, we may request additional information from you, consistent with applicable law. We may deny a rights request if we are unable to verify your identity.

Authorized Agents

Some states permit their residents to designate an authorized agent to submit requests to exercise certain data subject rights on the individual’s behalf. Even if you use an authorized agent to submit a request on your behalf, pursuant to applicable law, we may still require that you verify your identity depending on the nature of the request and sensitivity of the information at issue.

If you are an authorized agent submitting a request on behalf of an individual, please submit a request using the contact information provided in the Contact Us section below. You must include a copy of the written, signed permission indicating that you are permitted to act on that person’s behalf.

Appealing a Denied Data Subject Rights Request

In some circumstances, we may deny your request to exercise one or more of the rights described above. If you disagree with our decision to deny your request or any portion of your request, you may appeal our decision within sixty (60) days of receipt of notice that your request has been denied. If you submit an appeal to a denied request more than sixty (60) days after you have been notified of our decision to deny the request, we may deny your appeal. If you submit a timely appeal, we will respond within forty-five (45) days of our receipt of your appeal.

If you wish to appeal a decision, please clearly and plainly describe your disagreement with our decision by responding through the same means by which we communicated our decision or by submitting your appeal using the information provided in the Contact Us section below. We will review your appeal and either amend or uphold our decision. In either case, we will provide a written explanation of the reason for the decision. This decision will be final.

7. Material Changes

We may update this Privacy Policy from time to time, and we will provide notice of any material changes to the Privacy Policy as required by law. All changes will be effective after we post the updated Privacy Policy on our webpage. If you object to any change, please stop using the Services.

8. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us at privacy@trinitasintelligence.com or by mail at: