Privacy Policy

Online Privacy Policy

Trintech Inc., (“Trintech,” “Company,” “we,” “us”) respects the privacy of individuals with whom we interact (“you”).

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.trintech.com (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In e-mail, text and other electronic messages between you and Us.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• Information that we collect pursuant to the marketing and provision of our services.

This policy does not apply to information collected by:

• Any other website operated by the Company or any third party including our affiliates and subsidiaries.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. This policy may change from time to time (see Changes to our Privacy Policy).

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@trintech.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website or individuals with whom we otherwise interact, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, business, title, or any other identifier by which you may be contacted online or offline (“personal information”);
• your professional information necessary to market and deliver our services;
• that is about you but individually does not directly identify you, such as browser information, general location of access (on a city-specific level); and/or
• about your internet connection, the equipment you use to access our Website and usage details.

Information You Provide to Us

The information we collect on or through our Website or elsewhere may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further information about our products or downloading information contained on this site. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.
• When you correspond with us about our service or otherwise.
• In the course of providing services
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, and other tracking technologies.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept a variety of cookies through the Cookie Settings displayed through the Cookie Banner on the Home Page. However, if you reject certain cookies, you may be unable to access certain parts of our Website. Unless you have adjusted your Cookie Settings so that it will refuse certain cookies, our system will issue cookies when you direct your browser to our Website. These are stored in your browser and allow websites to remember some information between page views and visits. If you wish to disable cookies, you can disable them through the Cookie Settings displayed through the Cookie Banner.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices about How We Use and Disclose Your Information.

We may tie this information to personal information about you that we collect from other sources or you provide to us.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions.

Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

How We Use Your Information

The below chart summarizes our use of personal information:

We do not rent, sell or share personal information about you with other people or nonaffiliated companies.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our or an affiliate’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information which may be presented to you when you visit the website. In addition, you may use the following processes to control cookies:

• Cookie Banner. You can set your “Cookie Settings” through the Cookie Banner displayed on the Home Page. In the Cookie Settings, you can enable or disable your consent preferences for a variety of cookies.
• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your e-mail address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by clicking the link to unsubscribe or update your communication preferences in our initial email contact with you or by sending us an e-mail stating your request to info@trintech.com.
• We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users.

Rights under General Consumer Privacy Laws

Residents of states that have enacted general consumer privacy laws, including California, may have specific rights. Please note that we will seek to verify your identity when we receive an individual rights request in order to ensure the security of your information and that you may assign an authorized agent make a request on your behalf.

Such residents may have the right to request the deletion of personal information, but Trintech may not delete some or all requested personal information as required or allowed by applicable law. Such residents may also request to receive details about how we collect, use, and share your personal information. Specifically, you may request to receive the specific pieces of personal information that we have collected about you. Such residents may also have the right to correct any inaccurate personal data maintained by Us. Such residents may also have a right to opt-out of the sharing of their personal information.

We do not sell personal information and do not discriminate against you for exercising any general consumer privacy rights granted by state laws, such as the access, deletion, and correction rights described above. If we choose to offer a product enhancement or financial incentive that is contingent on you sharing personal information, we will ensure that the value provided to us by that collection is reasonably related to the value of the product enhancement or financial incentive.

If you would like to exercise any of your rights as described in this section, you can email us at privacy@trintech.com.

Data Retention

We will not retain your personal information for longer than necessary for us to perform the purposes set out in the chart above. Records containing your personal information are deleted after a set retention period according to our internal retention policies, as long as such records are not subject to a legal dispute, litigation, investigation, or tax audit.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.

Do not Track Requests

Certain State laws require that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Privacy Policy and do not monitor or follow any Do Not Track browser requests.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address provided to us or through a notice on the Website. The date the privacy policy was last revised is identified at the top of the page.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at privacy@trintech.com.

International Considerations

We may store, process and transmit information in the United States and locations around the world – including those outside your country. All transfers to other countries will be performed in furtherance of the purpose(s) disclosed on the chart above.

Trintech puts in place appropriate safeguards or identifies an applicable derogation, each in accordance with applicable legal requirements to provide adequate protections for any transferred personal data. For example, we may use Commission-approved “Standard Contractual Clauses” or “Model Clauses”.

European Union Supplement

If you are a resident of the EEA or a resident of the United Kingdom (“UK”) or a resident of Switzerland, this Supplement explains what personal data we collect about you, how it is used, with whom it is shared, and rights you may exercise in relation to your personal data.

1. Legitimate Interest

We may process your personal data for the purposes of our legitimate interests, provided that such processing does not outweigh your rights and freedoms. Where we rely on legitimate interests, you have the right to object. Please keep in mind that if you object this may affect our ability to perform certain services for your benefit. We process your personal data based on legitimate interests in order to:

• Protect you, us, or others from security threats by enhancing the security of our network and information systems;
• Identify and prevent fraud;
• Comply with applicable laws and industry regulations; and
• Enable or administer our business and to provide services thereunder.

2. Other Legal Bases for Processing Personal Data

We will only collect and process personal data about you where we have a legal basis. Other than legitimate interests, legal bases include consent (where you have given consent), contract (where processing is necessary for entering into or the performance of a contract with you and the provision of personal data is required for that contract), and compliance with a legal obligation. Where we rely on consent, you retain the right to withdraw consent at any time.

3. Data Subject Rights

You can also exercise the following rights:

Deletion. You can ask to erase or delete all or some of your personal data.

Object to, or Limit or Restrict, Use of Data. You can ask to stop using all or some of your personal data (e.g., if there is no legal right to keep using it) or to limit use of it (e.g., if your personal data is inaccurate or unlawfully held).

Access Your Data. You can ask for a copy of your personal data provided in a machine-readable form.

Correction You also have the right to correct any inaccurate personal data maintained by Us

If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time.

4.Automated Decision-Making

We do not make use of automated decision-making. As defined under current data protection laws, automated decisions are defined as decisions about individuals that are based solely on the automated (i.e., no human involvement) processing of data and that produce legal effects or that significantly affect the individuals involved.

5.Retention Period

We retain the personal data that we collect from you where we have an ongoing legitimate business need to do so (for example, to provide services or to comply with an applicable legal requirement).

6.Complaint

You have the right to register a complaint with a European data protection or supervisory authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

If you would like to exercise any of your rights as described in this Supplement, you can email us at privacy@trintech.com.

Effective Date: January 1st, 2024.
Revision: January 1st, 2025.