Last modified: December 19, 2018
At Treble (the “Company” or “We”) our mission is to empower our users to improve their business development and career development networking and to allow our users to extract actionable business intelligence for their real life networking efforts. Our mission inherently requires that some personal and professional information be shared from user to user. Our application is however designed to allow you, the user, to control who can see your information through the use of N= only those in your network, N+1 = only those connected directly to those users to whom you are directly connected and T= entire Treble network filters and other settings. Treble will also contain a DealFeed feature that will allow limited, curated business and networking related advertising to be seen by the user. This advertising can be rendered invisible by de-selecting the DealFeed filter in your activity stream. These advertisers will not directly be provided with personal information about you but can generally by categories (not using individually identifiable data) choose to have advertisements appear in your DealFeed based on the personal information you provide and interests selected in your Treble profile. In the future, Treble may share your personal information with potential outside third-party advertisers on an aggregated, no identifier basis, but your personally identifiable information will not be shared with them without your prior consent. IF YOU USE THIS APPLICATION YOU ARE HIGHLY LIKELY TO RECEIVE EMAILS AND OTHER COMMUNICATIONS FROM OTHER USERS. IF YOU DO NOT WISH TO RECEIVE THESE COMMUNICATIONS DO NOT DOWNLOAD AND USE THIS APPLICATION. At Treble, we respect your privacy and we are deeply committed to protecting it through our compliance with this policy. This policy describes:
The types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use Treble through its mobile application or website (the “Platform”).
Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect in this Platform and in email, text, and other electronic communications and, if permitted, location information sent through or in connection with this Platform.
This policy DOES NOT apply to information that:
We collect offline or on any other Company apps or websites, including websites you may access through this Platform.
You provide to or is collected by any third party (see below).
Our website and other apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Children Under the Age of 16.
The Platform is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email below.
Information We Collect and How We Collect It.
We collect information from and about users of our Platform:
Directly from you when you provide it to us, contact other members through the Platform, or create User Contributions through the Platform. Automatically when you use the Platform.
Information You Provide to Us.
When you download, register with, or use this Platform, we may ask you to provide information:
By which you may be personally identified, such as name, postal address, email address, telephone number, job title, organization or company you work for, your educational background, geographies and industries in which you are interested in networking, organizations you belong to and credit card information. (”personal information”).
That is about you but individually does not identify you, such as educational background, organizations you belong to and interests.
This information includes:
Information that you provide by filling in forms in the Platform. This includes information provided at the time of registering to use the Platform, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you report a problem with the Platform.
Records and copies of your correspondence (including email addresses and phone numbers) with us, if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through the Platform.
Your search queries on the Platform.
Activity you understate within your business network through the Platform.
Credit card information.
You may provide information to be published or displayed (”Posted”) on membership-only areas of the Platform (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to interact or share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
To the extent that any information we collect about you constitutes “sensitive” or “special category” data under applicable laws or regulations, we will seek your consent for the processing of such data.
Automatic Information Collection and Tracking.
When you download, access, and use the Platform, it may use technology to automatically collect:
Usage Details.When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including traffic data, logs, and other communication data and the resources that you access and use on or through the Platform.
Device Information.We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
Stored Information and Files.The Platform also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Location Information.This Platform may collect real-time information about the location of your device and/or desktop.
If you do not want us to collect this information do not download the Platform or delete it from your device or you may control the information accessed through your privacy settings and through location settings. For more information, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION,” below. Note, however, that in order for you to get the greatest benefits from the Platform your information must be shared with other users and, further that, opting out of the Platform’s collection of location information will cause its location-based features to be disabled.
We also may use these technologies to collect information about your activities over time. We have no intention of collecting information about your activities on third-party websites and other online services. As a result, we have no mechanism for allowing you to opt out of behavioral tracking on or through this Platform.
Information Collection and Tracking Technologies.
The technologies we use for automatic information collection may include:
Cookies (or mobile cookies).A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our Platform.
Web Beacons.Pages of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Platform statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity).
Third-Party Information Collection.
When you use the Platform or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
Advertisers, ad networks, and ad servers.
Your mobile device manufacturer.
Your mobile service provider.
Our cloud based server provider.
App store providers (like Apple and Google).
Wireless network providers.
The National Security Agency, the Central Intelligence Agency and other government agencies.
These third parties may use tracking technologies to collect information about you when you use this Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. Except as previously noted, we do not intend to use behavioral advertising within our Platform. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information.
We use information that we collect about you or that you provide to us, including any personal information, to:
Provide you with the Platform and its contents, and any other information, products or services that you request from us.
Connect you with other users.
Track your interactions with other users in order to provide you and other users with actionable business and career development intelligence, system generated recommendations and reminders to assist you with your networking efforts.
Fulfill any other purpose for which you provide it.
Give you notices about your account/subscription, including expiration and renewal notices.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection or to defend against legal claims.
Notify you when App updates are available, and of changes to any products or services we offer or provide through it.
Contact you or your company to purchase our enterprise version when it becomes available.
Send you advertisements based on your usage of the Platform.
The usage information we collect helps us to improve our Platform and to deliver a better and more personalized experience by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Platform according to your individual interests.
Speed up your searches.
Recognize you when you use the Platform.
We may also use your information, name, likeness or appearance in connection with our own marketing, advertising or promotion of the Platform.
In the future, we may use location information we collect to facilitate your networking by advising you when other Treble users are at an event you are attending, located nearby or are located in the geography you are in.
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. We will not however disclose personal identifiable information about you to third party advertisers without your prior consent. We may, however, contact you or communicate with you to request that consent. For more information, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION”, below.
Treble is based in the United States. No matter where you are located, your personal information will be processed in the United States. The laws of the United States and other countries governing data protection may not be as comprehensive or as protective as the laws in the country where you live.
Disclosure of Your Information.
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose personal information that we collect or you provide:
To our subsidiaries and affiliates.
To Treble users, including users located in countries other than the United States and European Union.
To contractors, service providers, and other third parties 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 Treble’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Treble about our Platform users is among the assets transferred.
To third parties to market their products or services to you if you have consented to these disclosures. For more information, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION,” below.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the referral or introduction feature of our Platform, we will transmit the contents of that email and your email address to the recipients.
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.
To enforce our rights arising from any contracts entered into between you and us, including the Platform terms and conditions see “TREBLE’S TERMS OF SALE OF GOODS AND SERVICES,” and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Treble, our employees, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
To cooperate with law enforcement.
In connection with efforts to investigate, prevent, report or take other action regarding illegal activity, fraud, or other wrongdoing.
Lawful Basis for Processing Your Personal Information.
The laws in some countries require us to tell you about the lawful grounds we rely on to collect, use, disclose, and otherwise process your Personal Information. To the extent those laws apply, our lawful basis for processing your Personal Information is because it furthers our performance, or preparation for performance, of a contract or agreement to provide services to you through the Platform.
Your Choices About Our Collection, Use, and Disclosure of Your Information.
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
Location Information.You can choose whether or not to allow the Platform to collect and use real-time information about your device’s location through the device’s location settings. If you block the use of location information, some parts of the Platform may then be inaccessible or not function properly.
Targeted Advertising by the Company.If you do not want us to use information that we collect or that you provide to us to see advertisements according to our advertisers’ target-audience preferences, you can opt-out by hiding DealFeed notifications in your activity screen.
Privacy Settings.Our Platform is designed to allow you, the user, to control who can see your information through the use of N= only those in your network, N+1 = only those connected directly to those users to whom you are directly connected and T= entire Treble network settings. Treble will also contain a DealFeed feature that will allow limited, curated business and networking related advertising to be seen by the user. This advertising can be rendered invisible by de-selecting the DealFeed filter in your activity stream. These advertisers will not directly be provided with personal information about you but can generally by categories choose to have advertisements appear in your DealFeed based on the personal information you provide and interests selected in your Treble profile. In the future, Treble may share your personal information with potential outside third-party advertisers on a aggregated, no identifier basis, but your personally identifiable information will not be shared with them without your prior consent.
IF YOU USE THIS APP YOU ARE HIGHLY LIKELY TO RECEIVE EMAILS AND OTHER COMMUNICATIONS FROM OTHER USERS. IF YOU DO NOT WISH TO RECEIVE THESE COMMUNICATIONS DO NOT DOWNLOAD AND USE THIS APP.
Disclosure of Your Information for Third-Party Advertising and Marketing.
If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by declining consent when we contact you.
European Union Data Rights.
If you are within the European Union, you have the right to request access to your personal information and the rectification of inaccurate personal information from Treble. If you are within the European Union, you also have the right to obtain from Treble the erasure or the restriction of processing of your personal information in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when Treble is required by law to maintain or otherwise process your personal information, for the establishment, exercise, or defense of legal claims, or the protection of the rights of another person. If you are within the European Union, you also have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work, or place of alleged infringement of the applicable law. If you would like to submit a data access, correction, restriction, or deletion request, you can do so by contacting us at email@example.com and we will process such request with respect to any personal information that we are able to link to you individually based on the information that you can provide to us. Exercising any of these rights is a guarantee to be afforded a process and does not guarantee any particular outcome.
California Privacy Rights.
California Civil Code Section 1798.83 permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the address below.
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.
Retention of Your Personal Information.
We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us. If you choose to close your account, your profile will generally stop being visible on the Platform within one week. The data you provided, aside from your name, will be deleted within 30 days in accordance with the retention schedule for our backup systems. Information you have posted or shared with other users, and records of your interactions with other users through the Platform, will remain visible even after you have closed your account or deleted that information from your own profile. We do not control which data other users share or copy outside the Platform.
Accessing and Correcting Your Personal Information.
You can review and change your personal information by logging into the Platform and visiting your account profile page.
You may also send us an email at the address below to request access to, correct, or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We take data security very seriously. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls and we periodically review our security policies and implementations to incorporate appropriate technologies and practices to address new and emerging threats.
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 Platform, 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 semi-public areas of the Platform like wish lists or in referral or introduction emails. The information you share in member-only areas may be viewed by any user of the Platform.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.