Privacy Policy
Date Created: 02/28/2023
Last Updated: 06/30/2023
Every day, you trust us with your health and well-being – probably the most personal areas of your life. At TRILITY, that is a responsibility we take incredibly seriously.
Technology is transforming healthcare and the opportunities to learn how to better manage health, wellness and human performance through data are limitless. It is a privilege for us to learn from you and your experience with our products – and every day we hope to understand the science and our customers a little bit better than the day before.
At TRILITY:
Our Privacy Policy is part of our approach to transparency and protection of your personal information.
This Privacy Policy describes how TRILITY collects, uses, and shares your personal information when you use our products, visit our websites and apps and interact with us offline (collectively, the “Services”) . If you are a resident of another country, we do not currently sell or market outside the US. For information on how to exercise your privacy rights, please see our “Your Privacy Rights and Choices” section below.
TRILITY may offer certain products, programs or services that have unique or additional terms, privacy notices and/or consent forms that explain how TRILITY processes information. For details on any product-specific features, notices, or terms, please review the terms for those products and services.
Please take a moment to familiarize yourself with our Online Terms and Conditions and this Privacy Policy and contact us if you have any questions through the “How Can I Contact TRILITY” section below. You can also download a copy of our Privacy Policy and Cookie Policy.
Please be aware that if you are using a third-party device (for example a voice-controlled intelligent personal assistant device or service) to access an TRILITY website or application, the third-party device supplier may collect information, including Personal Information, via the device, even when TRILITY does not, and you will need to contact that third party device supplier directly to obtain any such information.
TRILITY may collect the following types of Personal Information:
TRILITY’s research and clinical trials. TRILITY also collects Personal Information when you participate in a clinical trial or other research TRILITY conducts. This may involve collecting data from you, healthcare providers, contract research organization, and clinical trial investigators. Please note, when TRILITY’s collects Personal Information to conduct research or clinical trials, we provide you with more information about how your Personal Information will be used.
If you are a healthcare professional, we may also collect:
Sensitive Personal Information
Some of the Personal Information TRILITY collects may be considered “Sensitive Personal Information” or “sensitive data” under certain data protection laws, such as but not limited to, financial and health information. TRILITY may use Sensitive Personal Information for a specific purpose such as processing transactions.
If you are a California resident, you have the right to request that we limit how we use and disclose your Sensitive Personal Information for certain purposes under California law, including inferring characteristics about you. For choices about your Sensitive Personal Information, please scroll down to the footer, click the “Your Privacy Choices” link, then click the box that reads “Opt-Out of Sharing and Targeted Advertising” and follow the instructions on that page.
For more information about how TRILITY collects, discloses, and shares Sensitive Personal Information, please see our “Categories of Information” section below.
Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any Sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the website, in webforms or otherwise to us.
TRILITY may collect the following types of Personal Information:
TRILITY’s research and clinical trials. TRILITY also collects Personal Information when you participate in a clinical trial or other research TRILITY conducts. This may involve collecting data from you, healthcare providers, contract research organization, and clinical trial investigators. Please note, when TRILITY’s collects Personal Information to conduct research or clinical trials, we provide you with more information about how your Personal Information will be used.
If you are a healthcare professional, we may also collect:
Sensitive Personal Information
Some of the Personal Information TRILITY collects may be considered “Sensitive Personal Information” or “sensitive data” under certain data protection laws, such as but not limited to, financial and health information. TRILITY may use Sensitive Personal Information for a specific purpose such as processing transactions.
If you are a California resident, you have the right to request that we limit how we use and disclose your Sensitive Personal Information for certain purposes under California law, including inferring characteristics about you. For choices about your Sensitive Personal Information, please scroll down to the footer, click the “Your Privacy Choices” link, then click the box that reads “Opt-Out of Sharing and Targeted Advertising” and follow the instructions on that page.
For more information about how TRILITY collects, discloses, and shares Sensitive Personal Information, please see our “Categories of Information” section below.
Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any Sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the website, in webforms or otherwise to us.
Generally, we use Personal Information to:
Some of our applications and mobile-optimized sites may have location-based features. To deliver these features, we may collect and use location data provided by your mobile device. When you use such applications, you are asked to consent to the collection and use of your mobile device location data for purposes of delivering these location-based features.
We may use Personal Information collected from any of the sources listed in the “How Does TRILITY Collect Personal Information?” section of this Privacy Policy for our internal business purposes, such as data analysis, audits, developing new products, enhancing our Services, identifying usage trends and determining the effectiveness of our promotional campaigns. We may also use inferences drawn from Personal Information to create a profile reflecting your preferences.
We may aggregate, anonymize and/or de-identify data we collect about customers and site visitors and use it for any purpose, including product and service development and improvement activities. We may also combine information we gather about you on our TRILITY websites and Services with our offline records, as well as records provided by third parties. We use this consolidated information to help us better design TRILITY websites, products, and services to communicate information to you, to enhance our marketing and research activities, to serve you more relevant advertising and for other purposes, as disclosed to you from time to time.
Categories of Personal Information we may collect, disclose, or share. | Purposes for collection / use | Applicable Individuals | Categories of third parties to whom Personal Information may be disclosed or shared |
Name, contact details, and other demographic information (e.g., name, email address, mailing address, phone number, age, or gender) | Provide you with our Services, process transactions, and communicate with you | Prospective consumers, consumers, website visitors, healthcare providers | TRILITY family of companies, service providers, collaborators, co-promoters, and government/law enforcement where necessary |
Account information (e.g., username, email, and password on your TRILITY account) | Provide you with our Services, process transactions, and communicate with you | Prospective consumers, consumers, healthcare providers, | TRILITY family of companies, service providers, collaborators, and co-promoters |
Financial and payment information (e.g., information used to complete a transaction) | Provide you with our Services, and process transactions | Consumers, healthcare providers | TRILITY family of companies, service providers, collaborators, and co-promoters |
Sensitive Personal Information including certain financial information (e.g., financial information related to certain patient or consumer assistance programs, physical health information) | Provide you with our Services, and conduct research, and comply with law | Potential consumers, consumers and participants in certain TRILITY programs | TRILITY family of companies, service providers, collaborators, co-promoters, and government/law enforcement where necessary |
Usage Data / Internet Activity (e.g., IP address, browsing and search history) | Provide you with our Services, conduct research, and to prevent fraud | Website/mobile app visitors | TRILITY family of companies, service providers, collaborators, and co-promoters |
Employment information (e.g., credentials, participation information) | Provide you with our Services, conduct research, communicate with you, and comply with law | Healthcare providers and job applicants | TRILITY family of companies, service providers, collaborators, and co-promoters |
Inferences (e.g., inferences drawn from any of the information identified above to make a profile of a California resident, including preferences, behavior, characteristics, and attitudes) | Provide you with our Services, and conduct research | Consumers, healthcare providers, website/mobile app visitors | TRILITY family of companies, service providers, collaborators, and co-promoters |
Your Privacy Rights and Choices
Depending on where you reside, you may have certain rights and choices (with certain limitations and exceptions) regarding our processing of your Personal Information. Such rights and choices may be effectuated by submitting a request by clicking Privacy Rights Request. The potential rights include the right to:
To help protect the security of your Personal Information, TRILITY will verify your identity in connection with any requests. We take steps to ensure that only you or your authorized representative can exercise rights with respect to your Persona Information. If you are an authorized agent making a request, we may require and request additional information to protect the Personal Information entrusted to TRILITY, including information to verify that you are authorized to make that request.
There may be situations where we cannot grant your request, for example if you make a request and we cannot verify your identity, we will not be able to comply with the request. We may also be unable to comply with your request if we have a legal or regulatory obligation to keep your Personal Information, such as when you participate in scientific research. Other reasons your request may be denied are if it jeopardizes the privacy of others or would be impracticable to honor.
Where we deny your request in whole or in part, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial. If you are a Virginia resident, you have the right to appeal TRILITY’s decision to deny your request, in whole or in part. To appeal our decision click Notice of Appeal.
We may not discriminate against you if you exercise your rights as described in this Privacy Policy. For example, we may not deny goods or Services to you, or charge you different prices or rates, or provide a different level of quality of products or Services. We will not restrict or deny you access to our Services or provide a different level of quality of products or Services because of choices and requests you make in connection with your Personal Information. Please note, certain choices may affect our ability to deliver the TRILITY Services. For example, if you sign up to receive marketing communications by email, then ask TRILITY to delete all of your Personal Information, we will be unable to send you marketing communications.
You may exercise any of your rights in relation to your Personal Information by contacting us using the details provided under the “How Can I Contact TRILITY” section below, by clicking Privacy Rights Request or by scrolling down to the footer and clicking the “Your Privacy Choices” link.
Global Privacy Control (GPC) Signal
You have the right to opt out of the sharing of your Personal Information for cross-context behavioral advertising purposes. To communicate your desire to opt-out, you may configure your browser to turn on the Global Privacy Control (“GPC”) signal, which will transmit your opt-out request to TRILITY automatically.
To turn on the GPC signal, you can download one of the supported browsers or extensions. You may visit https://globalprivacycontrol.org/#download for a list of the available browsers or extensions.
Financial Incentive Programs
TRILITY may offer financial incentive programs, such as a benefit or other offering for our use of your Personal Information. TRILITY will enroll you in such programs after obtaining your informed consent, pursuant to the Terms & Conditions of each financial incentive program.
For more information on each financial incentive program, please see the Terms & Conditions that apply to the applicable program. If you need assistance finding those Terms & Conditions, please email hello@TrilityHealth.com.
You have the right to withdraw from any of TRILITY’s financial incentive programs at any time. To withdraw, please see the Terms & Conditions that apply to the applicable program.
Marketing
If you no longer wish to receive promotional marketing materials from us, you may opt-out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from TRILITY by following the instructions included in the email. We will work to comply with your request as soon as we can. Please be aware that once you have opted out of these programs, you will no longer receive any associated discounts, coupons or promotional offers that are part of the program.
However, even if you opt out of receiving such communications, we may need to continue to send you certain non-marketing communications (such as information about changes to our Privacy Policy or Terms of Use).
It is TRILITY’s practice to take steps to secure our TRILITY Services. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting Personal Information over the Internet, especially Personal Information related to your health. TRILITY cannot guarantee that unauthorized third parties will not gain access to your Personal Information; therefore, when submitting Personal Information to TRILITY websites or apps, you must weigh both the benefits and the risks. TRILITY websites or apps may link to third-party websites that are not controlled by TRILITY or subject to an TRILITY privacy policy. You should check the privacy policies of such third-party websites before submitting Personal Information.
Children’s Information
TRILITY does not knowingly collect or use any Personal Information from children (we define “children” as minors younger than 13). We do not knowingly allow children to order our products, communicate with us, or use any of our online Services. If you are a parent or guardian and become aware that your child has provided us with Personal Information, please contact us using one of the methods specified under the “How Can I Contact TRILITY” section below and we will work with you to address this issue.
Third-Party Sites
We may provide links to websites and other third-party content that are not owned or operated by TRILITY. The websites and third-party content to which we link may have separate privacy notices or policies. TRILITY is not responsible for the privacy practices of any entity that it does not own or control.
If you provide any Personal Information through a third-party site, your interaction and your Personal Information will be collected by, and controlled by the privacy policy of, that third-party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.
Cookies and Other Technologies
TRILITY’s online Services, interactive applications, and advertisements may use cookies and other technologies such as web beacons. We use this information to better understand, customize and improve user experience with our websites, Services and offerings as well as to manage our advertising. This information can make your use of our TRILITY Services easier and more meaningful by allowing TRILITY and our service providers to provide better service, customize sites based on consumer preferences, compile statistics, provide you with more relevant advertisements based on your interests, analyze trends and otherwise administer and improve our products and Services. If we have collected your Personal Information, we may associate this Personal Information with information gathered through the Tools.
Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org
You can also control Flash cookies which we may use on certain TRILITY websites and apps from time to time by clicking here. Why? Because Flash cookies cannot be controlled through your browser settings. Choices you make are both browser and device-specific.
Here are some of the types of information collected when visiting TRILITY Websites:
Interest Based Advertising
TRILITY hopes to deliver to you advertising for products and Services you need or want. TRILITY, its serviced providers and partners, use common tracking tools, such as cookies, pixels, web beacons, and similar technologies, to automatically collect Personal Information about users for purposes of enhancing their online experience and delivering more meaningful advertisements. Like many companies, TRILITY may also utilize third-party advertising vendors and other partners to collect this information. Certain laws define this as “cross-context behavioral advertising”.
Like many companies, we place advertisements where we think they will be most relevant to customers. One way we do so is by allowing network advertising companies with whom we work to place their own Tools when an individual visits TRILITY websites and apps. This enables the network advertising company to recognize individuals who have previously visited TRILITY websites and apps and to serve you ads based on your web browsing activity, purchases, interests and/or other information—a practice commonly referred to as interest-based advertising (“IBA”) or online behavioral advertising (“OBA”).
These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use.
Retargeting. One way in which we deliver more meaningful advertisements is through a common form of online advertising known as “retargeting” or “remarketing.” Retargeting works by serving ads on one site based on an individual’s online activities on a different, unrelated site. For example, if you look at an TRILITY product on an TRILITY website, you may later see an advertisement for that TRILITY product when you visit third-party sites. To do this, TRILITY or its advertising service providers may use a device ID, cookie, pixel, web beacon or similar technology placed by TRILITY or our service provider when you visit TRILITY websites or apps or third-party websites or apps. The placing of these cookies or other technologies on your device may enable you to be identified across multiple websites. You should consult the privacy policies of our service providers and other websites that you visit to understand how they collect and use your data.
Opting-Out of IBA, OBA and Retargeting Activities
As a participant of the Digital Advertising Alliance (DAA), we adhere to DAA’s Interest-Based Advertising principles by providing you enhanced notice, transparency and control of our digital marketing practices as stated at http://www.aboutads.info/principles/. Click here to opt-out of having your online behavior collected for advertising purposes and receiving behaviorally targeted advertisements from our advertising partners. Choices you make are both browser and device-specific. Also, certain versions of the iOS operating system permit you to “Limit Ad Tracking” in the system settings, and certain versions of the Android operating system allow you to “Opt-out of Interest-Based Ads” in the system settings. Options you select are browser and device specific.
TRILITY Do Not Track Policy. Some browsers have Do Not Track (“DNT”) features that allow you to tell a website not to track you. These features are not all uniform, and some browsers may not be set up to honor such requests. TRILITY honors the AdChoice DNT signals. Options you select are browser and device specific. Please be aware that limiting the ability of websites to set cookies, however, may worsen your overall user experience, and in some cases the sites will not work properly without cookies, local storage and similar technologies.
Transfer of Personal information Between Countries
Any Personal Information you provide to TRILITY may be stored and processed, transferred between and accessed from the United States, where TRILITY is headquartered, and other countries which may not guarantee the same level of protection of Personal Information as the one in which you reside. However, TRILITY will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored/accessed.
TRILITY
Attention: Privacy Office
PO box 1707
Topanga, CA 90290
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