Last Updated: April 26, 2023
1. COLLECTION OF PERSONAL INFORMATION
1.1 Personal Information We Collect. The types of personal information we may collect depend on the products and services you request from us. The following are categories (with non-exhaustive examples) of personal information we may collect about you:
CategoriesIndividual Identifiers and Demographic Information (Examples):
- Contact information, such as your name, address, phone number, and email address.
- Demographic information, such as general location information like city, state and geographic area.
- Payment information, such as your payment method, credit or debit card number, and billing address.
- Profile and account information, such as your account name and password, subscriptions, order history, reviews, and products you have purchased.
- Communications, such as email messages, phone calls, social media interactions, and other communications.
- Preferences, such as your preferences for receiving marketing and other communications and your product interests.
- Customer service call recordings, such as recordings that may be collected when you contact our customer service team.
- Device information, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
- Online activity information, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
1.2. Sources of Personal Information.
We obtain the categories of personal information listed above from the following categories of sources:
- Personal Information You Provide. We collect personal information when you voluntarily submit it to us. For example, we may collect or receive personal information when you create an account on the Platform, sign up to receive our emails, purchase a product, enroll in a new subscription, participate in our promotions, contests, or surveys, post a review, submit a request to our customer service team, interact with us on social media, or otherwise.
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Flash cookies, or locally stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
- Personal Information Obtained from Third Parties. We may also receive personal information about you from other third-party sources. For example, we receive personal information from our business and advertising partners, event sponsors, joint marketing partners, affiliates and related companies, social media sites, or companies that provide us with personal information to supplement what we already know about our customers and clients or help us identify new customers. We may merge or combine such personal information with the other types of personal information we collect about you.
- Referrals. Users of the Platform may have the opportunity to refer colleagues, friends, or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
2. USE OF PERSONAL INFORMATION
2.1 To Provide the Platform and Our Services.
We may use your personal information to:
- provide you with the products, subscriptions, content, features, and services that you request;
- set up, maintain, and monitor your account on the Platform;
- process your transactions and purchases;
- communicate with you about the Platform (including by sending announcements, updates, security alerts, and support and administrative messages);
- understand your interests, personalize your experience on the Platform, and deliver information about products and services relevant to your interests; and
- respond to your inquiries and requests for customer support, including to investigate and address your concerns and monitor and improve our responses.
2.2 For Research and Development.
We use personal information to understand and analyze the usage trends and preferences of our users to make our Platform and other offerings better, diagnose technical issues, and develop new features and functionality. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Platform and promote our business.
2.3 For Marketing and Promotional Communications
We may send you Trilliant-related or other offers, promotions, and marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Opt-out of Marketing Communications” section below.
2.5 For Compliance, Fraud Prevention, and Protection.
We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process (such as to respond to requests from government authorities);
- maintain the safety, security, and integrity of our Platform, products and services, business, databases and other technology assets;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements and internal policies;
- enforce the terms and conditions that govern the Platform; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
3. SHARING OF PERSONAL INFORMATION
3.1 Service Providers.
We share personal information with third parties and individuals who perform functions on our behalf or help us run our business and the Platform, such as service providers that help us perform email services, website hosting, maintenance services, database management, web analytics, billing, payment processing, marketing, and other purposes.
3.2 Related Companies.
3.3 Other Users and the Public.
Your personal information may be shared with other users and the public on the Platform. The Platform may provide you with the opportunity to post or make available content, messages, and other information to other users of the Platform or the public, such as when you submit a product review or communicate with us on social media. We do not control how other users or third parties use any personal information that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.
3.4 Business Transactions.
If we sell all or part of its business or make a sale or transfer of assets or are otherwise involved in a corporate divestiture, financing, merger, consolidation, acquisition, reorganization, sale, spin-off, or other disposition of all or any portion of the business or assets of, or equity interests in, Trilliant or our related companies (including, in connection with a bankruptcy or similar proceedings), we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
3.5 Legal Authorities and Others.
We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and protection purposes described above.
3.6 Advertising and Other Business Partners.
3.7 Professional Advisors.
We may disclose your personal information to our professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
4. SECURITY OF PERSONAL INFORMATION
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.
5. YOUR CHOICES
You can make the following choices with respect to your personal information.5.1 Access or Update Your Personal Information. You may review and update certain account information by logging into your account on the Platform.
5.2 Opt-out of Marketing Communications.
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at SupportDesk@victorallen.com. You may continue to receive service-related and other non-marketing emails.
Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit allaboutcookies.org.
We use Google Analytics to help us understand user activity and patterns on the Site. You can learn more about these cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available here.
5.4 Advertising Choices.
Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at optout.aboutads.info. You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online, but they may be less relevant to you.
Some of the third-party advertising companies we may work with offer their own opt-out options that you can use to limit their use of your information for interest-based advertising. Please note that we also may work with companies that offer their own opt-out mechanisms, such as Google (https://adssettings.google.com/authenticated) and Facebook (https://www.facebook.com/about/ads), or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.
5.5 Do Not Track.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
5.6 Declining to Provide Information.
We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Trilliant is headquartered in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.
7. OTHER SITES AND SERVICES
Our Platform may contain links to websites, mobile applications or other online services operated by third parties. When you click on a link to any other website, mobile application or online service, you will leave our Platform and go to another site, and another entity may collect personal information or anonymous data from you. In addition, our content may be included on other online services that are not associated with us. We have no control over, do not review, and are not responsible for, these third-party online services or for their content or actions. Other online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of other online services that you visit or use. The links to third party online services are for your convenience and do not signify our endorsement of, or affiliation with, any third party or its services.
8. CHILDRENOur Platform is not intended for use by minors under the age of 16. If we learn that we have collected personal information of a minor under 16 without the consent of the child’s parent or guardian as required by law, we will delete it as soon as possible. If you believe that we might have any personal information collected online from a minor under 16, please contact us at SupportDesk@victorallen.com.
9. NOTICE FOR CALIFORNIA RESIDENTS
This section applies only to California residents. It describes how we collect, use and share personal information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.
9.1 Personal Information Collected and Purposes of Collection and Use.
- the categories of personal information we may have collected about you in the preceding 12 months in the section above called “Collection of Personal Information”;
- the categories of sources from which we collect your personal information in the section above called “Sources of Personal Information”; and
- the business and commercial purposes for which we collect this personal information in the section above called “Use of Personal Information.”
To the extent we collect sensitive personal information (as such term is defined in the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to provide the Platform, detect security incidences and prevent fraud, and to verify and maintain the quality of the Platform). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.
9.2. Personal Information “Sold,” “Shared,” or Disclosed for Business Purposes.
9.3 Retention of Personal Information.
We will retain each of the categories of personal information listed above for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
9.4 Your California Privacy Rights.The CCPA provides California residents with the rights listed below:
- Right to Access/Know. You have the right to request that Trilliant disclose certain information to you about our collection and use of your personal information over the past 12 months, including:
- The categories of personal information we collected about you.
- The categories of sources of the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- Right to Erase/Delete. You have the right to request that Trilliant delete any of your personal information that we collected from you and retained, subject to certain exceptions.
- Right to Correct. You can ask us to correct inaccurate personal information that we maintain about you.
- Right to Opt-Out of Sales or Sharing. If we “sell” or “share” your personal information, you can opt-out.
- Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
Please note, these rights are not absolute and in some cases, we may not be able to respond your request, such as when a legal exemption applies or if we are not able to verify your identity.You can request to exercise the California privacy rights above using the following methods:
- Access/Know, Correction and Deletion Rights. To exercise the access, correction, and deletion rights described above, please submit a request to us and provide the information we request that is required to verify your request by:
- Visiting our privacy portal at https://victorallen.com/pages/ccpa-compliance
- Emailing us at SupportDesk@victorallen.com, or
- Calling us at 1-800-619-7063.
- Right to Opt-Out of the “Sale” or “Sharing” of Personal Information. Under California law, some of the data we share with our advertising partners may qualify as a “sale” as defined under the CCPA. To exercise your right to opt-out of such “sale”, please:
You may also broadcast the Global Privacy Control (GPC) signal when visiting the Site to opt-out of cookie-based “sales” or “sharing.” Note that due to technological limitations, if you visit our Site from a different computer, device, or browser, you will need to rebroadcast the GPC signal.
If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You may also designate an authorized agent to make a request on your behalf. If you do so, we may require the requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
9.5. California Notice of Financial Incentive.
We may offer certain financial incentive programs that can result in different price or service levels, provided that such programs are reasonably related to the value of your personal information to us. For example, we may offer additional content to users who sign up for our mailing list, or giveaways, sweepstakes, contests, or other similar promotional campaign. We typically ask you to provide your email address or other contact information in order to participate in these programs or campaigns.
We offer these programs and campaigns because, among other things, the value of your personal information to us is related to the value of the free or discounted services, or other benefits that you obtain or that are provided as part of the applicable program or campaign. This value is based on the expense related to offering those services and benefits to participants, along with other factors such as whether and to what extent you take advantage of (or opt-out from) any offerings and whether we are able to use the data we collect from you.
When we offer any program or campaign, there is no obligation to opt-in, and you may withdraw at any time by contacting us using the designated method set forth in the applicable program rules or in the “Contacting Us” section below. Please review the applicable program or campaign offering or terms to view full details, including how to join.
10. Notice To Nevada Residents
11. CONTACTING USYou may contact us via email at SupportDesk@victorallen.com or by writing to us at the address below:
Trilliant Food & Nutrition, LLC
Attn: Privacy – Legal
1101 Moasis Dr. PO Box 307
Little Chute, WI 54140