SaaS Privacy Policy

TRIFFT ME s. r. o. Privacy Policy

This Privacy Policy will explain how TRIFFT ME s. r. o., Company Identification Number: 50 948 997 with its registered office at Jozefská 17, 811 06 Bratislava, a company registered in the Commercial Register of the Bratislava I District Court, Section: Sro, File no. 120553 / B, uses the personal data collected from the TRIFFT Loyalty Cloud solution Clients, potential Clients in pre-contractual phase or its website visitors.

TRIFFT ME s. r. o. acts as a data controller and is committed to protecting the personal data of its Clients, potential Clients and website visitors under the General Data Protection Regulation (GDPR).

Please note that this Privacy Policy does not apply to personal data and other information collected from:

· Users of TRIFFT – Contests and Rewards mobile app. For this group of users a separate Privacy Policy was created.

· User of our Client's white label mobile app. The TRIFFT Loyalty Cloud solution requires the use of Personal Data of the Users, however, only our Client is in direct contact with the Users. Therefore, the consent of the Users needs to be obtained by the Client from the Client's Users before it gets to the TRIFFT Loyalty Cloud. The obtainment is the responsibility and liability of our Client. Thus, if you are using our Client's app, please refer to the Client's own privacy policy.

Our Company securely stores your data based on your prior consent given to us. To ensure protection and security, we store this information in secured networks accessible by a limited number of persons only to prevent unauthorized access.

We may share your personal information with third parties whose services we use. These third parties process personal data as intermediaries and as such are bound by our instructions in the processing of personal data.

We currently use the services of the following third parties and intermediaries:

· Hosting

· Providers providing login and verification, email address and telephone number

· Marketing and analytical tools, tools for monitoring errors in the application

· Providers of legal, accounting, tax and audit services

Personal data may be the subject of cross-border transfers to countries within the European Union, to third countries that provide an adequate level of protection, as well as to third countries that do not guarantee an adequate level of personal data protection, provided that the controller has taken measures to ensure personal data protection. In the case of a transfer of personal data to the United States, the transfer of personal data may also occur under the Privacy Shield Scheme, in which the companies participating in the scheme undertake to provide an adequate level of protection for personal data.

In general, we store personal data for as long as the purpose for which it is processed lasts. How long your personal data is kept usually depends on the legal basis on which the data is processed. The processing of personal data in the case of granting consent is possible only during the period for which the consent was granted or until the withdrawal of consent. In the case of the processing of personal data for the purpose of direct marketing on the basis of the legitimate interest of the controller, the personal data will be processed until the data subject objects to the processing in question. If your personal data is processed on the basis of our legitimate interest, we process it as long as our legitimate interest persists. If the retention period is stipulated by law, your personal data is processed for the period specified therein. In the case of processing on the basis of performance of the contract, the data are processed and stored for the duration of the contractual relationship and subsequently for the period of expiry of the limitation period. Please keep in mind that some personal data is processed on several legal bases, in which case the revocation of your consent may not necessarily result in the complete erasure of your personal data.

TRIFFT ME s. r. o. would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

The right to access – You have the right to information about the processing of personal data, you also have the right to have access to the personal data that we process about you. This includes information about what data we process about you, for what purpose, to whom your personal data was provided, whether it was transferred to a third country and for how long we will keep your personal data. You also have the right to request a copy of the personal data we process about you.

The right to rectification – If you believe that TRIFFT is processing incorrect, inaccurate or out-of-date personal data about you, you have the right to ask us to correct them. It is important for us to process the right personal data about you, so be sure to use this right whenever there is a change in any of your personal data that is important to our mutual relationship. Based on the corrected or current information provided by you, we will correct the personal data we process about you.

The right to erasure – You have the right to delete your personal data that we process about you if the following conditions are met and if legal exceptions do not apply:

· The data are no longer needed for the purposes for which they were obtained,

· You withdraw your consent to the processing of your personal data and there is no other legal basis for their processing,

· Based on your specific situation, you object to the processing of your personal data and there are no legitimate reasons for the processing, or you object to the processing for direct marketing purposes,

· Personal data were processed illegally.

We would like to inform you that if the processing and storage of your personal data is required by applicable law, TRIFFT ME s. r. o. is obliged to proceed in accordance with these and in such a case it is not possible to delete your personal data. As a rule, personal data stored in this way can only be deleted after the deadlines set out in the relevant legal regulations have expired.

The right to restrict processing – You also have the right, under certain conditions, to request a temporary processing restriction if:

· You believe that we are processing incorrect personal data about you, until the accuracy of this personal data is verified

· The processing of your personal data is illegal, and you decide to request a restriction on their processing instead of their deletion

· We no longer need personal data for processing purposes, but these are necessary for the purposes of proving, asserting or defending your own legal claims

· You object to the processing of your personal data, until it is verified whether the legitimate reasons for the processing of personal data prevail over your legitimate interests

In these cases, TRIFFT will not delete your personal data, but will mark it and restrict its processing for certain purposes.

The right to data portability – You have the right to obtain personal data that we process about you on the basis of your consent and / or contract and are processed by automated means - in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another operator. If technically possible, we will transfer your personal data directly to the operator of your choice at your request.

The right to object to profiling and automated individual decision-making– You have the right to object to the processing of your personal data, which includes automated individual decision-making or profiling, for reasons related to your specific situation. You always have the right to object to the processing of your personal data if it is processed for direct marketing purposes.

You also have the right to object if there is an automated processing of your personal data, on the basis of which a decision with legal effects may be made or otherwise significantly affects you.

In the event of an objection to the processing of your personal data, which is being processed on the legal basis of TRIFFT's legitimate interest, TRIFFT will assess the situation based of the information provided by you and will inform you whether in the particular situation TRIFFT's legitimate interest prevails and data processing will continue or whether your rights prevail, and processing will be stopped.

The right to withdraw consent– If your personal data is processed on the legal basis of your consent, you have the right to withdraw your consent at any time. Withdrawal of your consent does not affect the validity and lawfulness of the processing of your personal data until the moment of withdrawal of consent.

The right to report a complaint to the Information Commissioner's Office – You have the right to object to TRIFFT ME s. r. o.'s processing of your personal data, under certain conditions.

If you make a request, we have one month to respond to you. In justified cases, we may extend this period to 60 days, of which we will inform you. If you would like to exercise any of these rights, please contact us at our email: [email protected]

We use analytical and tracking technologies within the TRIFFT Loyalty Cloud and on our website. Tracking technologies help us manage the TRIFFT Loyalty Cloud and provide its basic functionality. It also helps us collect information from website visitors such as IP-address, country and time zone, browser type and language, operating system and system settings, unique cookie identifier, unique device identifier and device type, domain, previously visited websites, information about interactions with our website, access times and referring URLs.

We distinguish between tracking technologies according to what they are intended for:

a) necessary, which ensure the proper functioning of the TRIFFT Loyalty Cloud, for example, ensure the function of logging in to the user account, resp. memorizing the login to the user account, allows you to switch between the language versions of the application and ensures that your language choice is remembered. The legal basis of these tracking technologies is the legitimate interest of the Operator.

b) analytical, used to analyze the movement of visitors across the website, to evaluate what content is relevant to the visitor and to obtain data on the demographics of website visitors. The legal basis for processing these cookies is the consent of the website user.

c) advertising, are used to display targeted and relevant advertising. The legal basis for processing these tracking technologies is the consent of the user of the websitee.

You agree to the use of tracking technologies by agreeing to the terms of use of the website or the TRIFFT Loyalty Cloud.

We currently use the following analytical tracking technologies withing the TRIFFT Loyalty Cloud application:

· Functional Software Inc. (Sentry), 132 Hawthorne Street, San Francisco, California 94107

Our website uses Google Analytics and may use similar services to collect third party cookies that generated information about visitors' use of our website. This information is later used to evaluate your use of our website.