Trility

TRILITY AND PRIVACY

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:

  • We believe your personal information belongs to you.
  • We will be transparent about the data we collect from you, and how that data will be used.
  • We build privacy and security protections into the products and services we design.
  • We protect the data we collect.

 

TRILITY PRIVACY POLICY - US ONLY

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.

  • “Personal Information” is information that identifies you as an individual or could be used to reasonably identify you.  Examples of Personal Information include, but are not limited to, your name, address and contact information.
  • “Sensitive Personal Information” means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” as that term is defined in the applicable US State Privacy Law.
  • TRILITY may collect the following types of Personal Information:

    • Contact information and preferences such as name, email address, mailing address, phone number, and emergency contact information.
    • Account information such as any username, email and password that you may select in connection with establishing an account on our websites or mobile apps. 
    • Biographical and demographic information such as date of birth, age, photo, gender, ethnicity, marital status, and sexual orientation.  In certain circumstances, we may also collect Personal Information about parents and legal guardians.
    • Financial and payment information such as information we need to complete a transaction, like a credit card number.  If you apply to or participate in one of TRILITY’s patient assistance programs, we may also collect information to verify your eligibility in the program.
    • Internet and social media activity such as your Internet Protocol (“IP”) address, browsing history, your search history, social media handle and information on your interaction with TRILITY Services and our advertisements. If you are accessing TRILITY websites or apps from your mobile device, you may also choose to provide us with location data.
    • Health information relating to your health status including information related to your physical or mental health or conditions and diagnoses, genetic information, family medical history and medications an individual may take, (including the dosage, timing, and frequency) we collect in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing our products, managing compassionate use and expanded access programs and tracking adverse event reports.  
    • Other Personal Information collected online or offline to help us better identify and offer Services and information that we believe may be of interest to you or help us better understand your experience with our products.
    • Communications with TRILITY including interactions with us and contacts through social media channels.
    • Inferences drawn from any of the Personal Information described above to create a profile about an individual’s preferences, behavior, characteristics, and attitudes.

     

    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:

    • Professional credentials such as your educational and professional history, institutional and government affiliations, information included on a resume or curriculum vitae, education and work history (such as work experience, education and languages spoken).
    • Interactions with TRILITY including information about the TRILITY programs, products and activities with which you have engaged and details about our interactions with you, your prescribing of our products and the agreements you have executed with us, including remittance or other financial information.
    • Event and participant information collected in connection with TRILITY hosted events or activities you attend or participate in.
    • Publicly-available information related to your practice such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information.
    • Any information you choose to provide about yourself or your household.

     

    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:

  • Contact information and preferences such as name, email address, mailing address, phone number, and emergency contact information.
  • Account information such as any username, email and password that you may select in connection with establishing an account on our websites or mobile apps. 
  • Biographical and demographic information such as date of birth, age, photo, gender, ethnicity, marital status, and sexual orientation.  In certain circumstances, we may also collect Personal Information about parents and legal guardians.
  • Financial and payment information such as information we need to complete a transaction, like a credit card number.  If you apply to or participate in one of TRILITY’s patient assistance programs, we may also collect information to verify your eligibility in the program.
  • Internet and social media activity such as your Internet Protocol (“IP”) address, browsing history, your search history, social media handle and information on your interaction with TRILITY Services and our advertisements. If you are accessing TRILITY websites or apps from your mobile device, you may also choose to provide us with location data.
  • Health information relating to your health status including information related to your physical or mental health or conditions and diagnoses, genetic information, family medical history and medications an individual may take, (including the dosage, timing, and frequency) we collect in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing our products, managing compassionate use and expanded access programs and tracking adverse event reports.  
  • Other Personal Information collected online or offline to help us better identify and offer Services and information that we believe may be of interest to you or help us better understand your experience with our products.
  • Communications with TRILITY including interactions with us and contacts through social media channels.
  • Inferences drawn from any of the Personal Information described above to create a profile about an individual’s preferences, behavior, characteristics, and attitudes.

 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:

  • Professional credentials such as your educational and professional history, institutional and government affiliations, information included on a resume or curriculum vitae, education and work history (such as work experience, education and languages spoken).
  • Interactions with TRILITY including information about the TRILITY programs, products and activities with which you have engaged and details about our interactions with you, your prescribing of our products and the agreements you have executed with us, including remittance or other financial information.
  • Event and participant information collected in connection with TRILITY hosted events or activities you attend or participate in.
  • Publicly-available information related to your practice such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information.
  • Any information you choose to provide about yourself or your household.

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.

  • How TRILITY uses your Personal Information depends on how you interact with us and what Services you use.  For the most part, TRILITY uses Personal Information to provide our products and Services to you and make them better, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law.  We may also use Personal Information for other purposes with notice or with your consent.

Generally, we use Personal Information to:

  • Provide and develop our products and Services.  TRILITY collects Personal Information to provide our Services, maintain our websites and apps, identify customers and visitors on our sites, and better understand the interests of our customers and visitors who use our Services.  We may also use your Personal Information to customize your experience with TRILITY such as recognizing you when you visit our websites, remembering your preferences, or showing you more relevant advertisements. 
  • Conduct research.  We use your Personal Information to study, develop, and improve TRILITY’s Services, conduct research, and manage clinical trials.  Our research may involve secondary and follow up research.  If you wish to participate in one of these programs, we may use your Personal Information to determine your eligibility to participate in our programs, clinical trials, or other research activities. 
  • Process transactions.  We collect payment information to process your transactions and deliver our products and Services. 
  • Communicate with you.  We use your Personal Information to respond to your inquiries from you. We may send you administrative communications regarding TRILITY’s products or Services, your purchases and transactions.  We may also notify you about special promotions or offers, including financial incentive programs, that may be of interest to you and invite you to participate in surveys about our products or Services.
  • Security and fraud prevention.  We may use Personal Information to monitor, detect and prevent fraud and improper or illegal activity and protect you, TRILITY, other customers, and the public.  We also use data to secure our online Services including our network, websites, and apps.
  • Comply with law. We may use Personal Information to comply with applicable law, comply with TRILITY’s legal and regulatory obligations, and defend ourselves in litigation and investigations and to prosecute litigations.

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. 

  • TRILITY may disclose your Personal Information within the TRILITY family of companies.
  • We may also disclose your Personal Information to our service providers, who act on our behalf, our partners and collaborators, and at your direction.  TRILITY does not sell Personal Information or disclose Personal Information to third parties to use for their own benefit without your consent.
  • Below are more details on who TRILITY discloses data to:
  • Service providers. We may provide your Personal Information to our service providers or other third parties.  Examples of service providers include analysis firms, advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies. We may disclose or share personal information with professional consulting firms, auditors, accountants, and legal services firms.   TRILITY’s practice is to require its service providers and third parties to keep your Personal Information confidential and to use Personal Information only to perform functions for TRILITY.
  • Collaborators. Collaborators are partners or other organizations with which we jointly develop and/or promote our Services.
  • In connection with a merger, acquisition, or business transfer.  If TRILITY sells all or part of one of its product lines or divisions, your Personal Information may be disclosed to the buyer.
  • Government, regulatory and law enforcement agencies. TRILITY reserves the right to disclose your Personal Information to respond to authorized information requests from government authorities, to respond to valid judicial requests, to address national security situations, to provide security and investigate potential fraud, or when otherwise required by applicable law.  TRILITY may also disclose your Personal Information as required by law to any competent law enforcement body, regulatory or government agency, court or other third-party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, TRILITY or others, and to exercise, establish or defend TRILITY’s legal rights.
  • TRILITY does not sell Personal Information or disclose Personal Information to third parties to use for their own benefit; however, we allow certain companies to place tracking technologies like cookies on our websites. Those companies receive information about your interaction with our websites that is associated with your browser or device and may use that data to serve you relevant ads on our websites or others. Except for this kind of disclosure, we do not sell any of your Personal Information.  For more information, please see TRILITY’s Cookie Policy.
  • At TRILITY’s discretion, it may also disclose aggregated, anonymized, or de-identified information that is not personally identifiable to third parties.
  • Retention
  • We will keep your Personal Information in our records for as long as we have an ongoing legitimate business need to do so.  This includes providing you with a service you have requested from us or to comply with applicable legal requirements.  It also includes keeping your Personal Information for so long as there is any possibility that you or we may wish to bring a legal claim, or where we are required to keep your personal information for legal or regulatory reasons.  We may also retain your personal information where such retention is necessary in order to protect your vital interests or the vital interests of another natural person.
  • If you wish to receive further information regarding our record retention procedures, please contact us using the contact details provided under the “How Can I Contact TRILITY?” section below.
  • Categories of Information
  • Below are the categories of Personal Information that TRILITY collected and disclosed for a business purpose or shared with third parties in the past twelve (12) months.
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:

  • Know the categories and/or specific pieces of Personal Information collected about you, including the categories from which the Personal Information is collected, the business purpose for collecting the Personal Information, whether your Personal Information was disclosed to third parties, the categories of Personal Information, if any, that we disclosed to third parties, and the categories of third parties to whom your Personal Information was disclosed
  • Access a copy of the specific pieces of Personal Information we retain about you
  • Request deletion of your Personal Information
  • Direct TRILITY to correct inaccurate Personal Information
  • You may have the right to opt-out of sharing for cross-context behavioral advertising purposes or targeted advertising. To opt-out of TRILITY sharing your Personal Information for cross-context behavioral advertising or targeted advertising, please visit the “Global Privacy Control (GPC) Signal ” section below. You may learn more about your other privacy rights, including your right to opt-out of TRILITY sharing your information by visiting trility.co and clicking the “Your Privacy Choices” link found at the bottom of the website, and then clicking the box that reads “Opt-Out of Sharing and Targeted Advertising”.
  • You may have the right to limit how TRILITY uses Sensitive Personal Information. You can learn more about limiting 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 following the instructions on that page.

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:

  • Log data:When you use TRILITY websites and apps, our servers automatically record information (“log data”), including information that your browser sends whenever you visit a website or app or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the webpages you visited that had TRILITY features, browser type and settings, the date and time of your request, how you used websites and cookie data.
  • Cookie data: Depending on how you are accessing TRILITY’s online Services, we and our service providers may use “cookies” (a small text file sent by your computer each time you visit our sites, unique to your TRILITY account or your browser) or similar technologies, to record log data.  For more information see our Cookie Policy. We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps, and online resources.  You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • Social media plugins and data: Social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. The operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our websites, the social plugins allow that social media website to receive information that you have visited our websites. The social plugins also allow the social media website to share information about your activities on TRILITY with other users of their social media website. TRILITY does not control any of the content from the social plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.  For more
  • Linked accounts. If you choose to link your social media or Google account to TRILITY, this allows us to obtain information from those accounts (such as your friends or contacts).  The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check these policies before granting us access.
  • Device information. We may also collect information about the device you are using to access our TRILITY Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data.  To learn more about what information your device may make available to us, please also check the policies of your device manufacturer or software provider.

 

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.

  • If you have questions about your Personal Information, please contact us by clicking on the “Contact Us” link on the website you are visiting or by e-mailing us at hello@trilityhealth.com
  • Alternatively, you may send a letter to the following address:

TRILITY

Attention: Privacy Office

PO box 1707

Topanga, CA 90290

  • In all communications to TRILITY, please include the email address used for registration (if applicable), the website address or the specific TRILITY program to which you provided Personal Information (e.g. TrilityHealth.com, AcendHealth.com, etc.) and a detailed explanation of your request.  We will do our best to respond to all reasonable requests in a timely manner.
  • TRILITY reserves the right to amend this Privacy Policy at any time.  If TRILITY changes its privacy practices, a new Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth in this paragraph.  
  • This Privacy Policy was last updated on June 30, 2023 and is effective as of that date.

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Unless otherwise specified, all product and service names appearing in this Internet site are trademarks owned by or licensed to TRILITY, its subsidiaries or affiliates. No use of any TRILITY trademark, trade name, or trade dress in this site may be made without the prior written authorization of TRILITY, except to identify the product or services of the company.

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