Privacy policy

You may be aware that various laws govern how businesses collect and use information from customers, app users, or website visitors. Although these laws vary, they all share the same fundamental principle: you have the right to know what information you're sharing with us, how we're using it, and why. If the information we collect can identify you or your household, it's referred to as “personal data.” Protecting your personal data is both our priority and legal obligation. Our Privacy Policy details how we safeguard this information, but it's a lengthy document. To make things easier, you can:

  1. Navigate to the section relevant to your interests;
  2. Use a keyword search to find what you're looking for; or
  3. Contact us to ask a question, request access to the data we hold about you, or ask us to delete your personal data.
1. General Information

This Privacy Policy is for Trinity Labs LLC., but throughout the document, we may refer to ourselves as “Trinity,” “the Company,” or simply use “we,” “us,” or “our.” We have a Privacy Policy for several reasons. First, it's required by law. More importantly, it helps you understand how we use your information so you can make informed choices about what you share and how we use it. Finally, the Privacy Policy establishes internal guidelines for handling data, and it holds us accountable. If we haven't disclosed a particular practice here, we won't do it without getting your explicit permission. While we aim to make this Privacy Policy clear and easy to understand, some terms have specific meanings under privacy laws. You can refer to the “Further Reading” section for a better understanding of these terms. Since we operate in multiple countries, our Privacy Policy must comply with various local laws. Instead of cluttering this document with legal jargon, we've chosen to write it as clearly as possible and included the specific international legal requirements in the “International Rights” section at the end. When we mention “GDPR art.” followed by numbers and letters, we're referring to specific articles of the General Data Protection Regulation (GDPR), a European Union law. We reference the GDPR for two reasons: (1) because it's legally required, and (2) because GDPR is recognized as one of the highest privacy standards in the world. Regardless of where you live, we aim to uphold these standards when handling your personal data.

2. About Trinity Labs LLC and This Privacy Policy

This Privacy Policy explains how TRINITY collects and processes your personal data when you use our website, app, or any services we offer, whether online or in-person (like through a survey). In short, if we're collecting personal data, this Privacy Policy applies. TRINITY acts as the “Controller” of the personal data we collect, meaning we decide how your data is collected, processed, and used. We will include links to this Privacy Policy wherever possible—on our websites, within our app, or before you participate in a survey. Please read this Privacy Policy, consider its contents, and decide if you're comfortable with it. Also review our Terms and Conditions, which govern our services, and any other notices or policies we provide to help you make informed choices about interacting with us. If we make changes to this Privacy Policy, we'll post a notice for your review. Please note, we are not responsible for any third-party sites linked to on our website or in our app. Once you navigate to a third-party site, our Privacy Policy no longer applies, and you should review their privacy policies.

3. What Data Are We Collecting About You?

Not all information qualifies as “personal data” under the law, but a significant amount does—often more than you may realize. Since we operate across multiple countries, we adopt the broadest definition of personal data to simplify our explanations. For the purposes of TRINITY, personal data includes: Any information that can identify an actual person or their household, either on its own or in conjunction with other data.

Here are the categories of personal data that we collect:

  • Basic Data: This includes your name, email address, physical address, phone number, gender identification, and verified age. Basic Data is collected only if you choose to provide it while using the TRINITY website. You may be required to supply Basic Data to access certain services, like making purchases or entering promotions.
  • Purchase and Warranty Data: This category encompasses all Basic Data along with credit card or payment details, age verification information, any identification used for age verification, your warranty number, serial number of your TRINITY device, any claims or issues reported regarding your device or warranty, and other purchase-related information. This data is gathered only if you choose to provide it while using TRINITY's website or customer support services. You may need to provide Purchase and Warranty Data to access some services, such as completing purchases or submitting warranty claims
  • Product Data: This refers to your TRINITY device's serial number, app ID, as well as any Diagnostic and Technical Data (defined below). 
  • Technical Data: This includes information collected as we operate our websites and apps, such as your IP address, mobile device identifier, browser type, operating system, mouse movement on the screen (e.g., hovers and clicks), duration of website. We don't use your IP address to track your precise location, only to determine the country and city of your login. However, since an IP address can be linked to personal identification, we treat it as personal data. Technical Data is collected automatically when you use the TRINITY websites. It does not include Usage Data.
  • Feedback and Marketing Data: This encompasses information we gather to suggest products or services you may find appealing, including surveys and questionnaires conducted through various mediums (e.g., email & website). It also includes your preferences for our communications regarding products and services and interactions with our marketing materials. Feedback and Marketing Data is collected whenever you provide feedback or engage with our marketing initiatives.
  • Third Party Data: This includes any personal data we acquire from external sources, whether purchased or received, as long as they can demonstrate that they obtained your data lawfully and are authorized to share it with us. This data often consists of publicly available information like addresses, business titles, or social media profiles.
  • Commercial Data: This refers to personal data about our partners, vendors, contractors, and others with whom we conduct business. This category does not include customer data or employee data (governed by our internal privacy policy) but pertains to information collected during business operations.

As detailed below, we may combine various types of personal data in providing our services or products to you. Additionally, we may merge your personal data with non-personal data. For instance, we might analyze the timing and location of your purchases alongside weather data to determine if rainy days influence purchasing behavior. If the combined data can identify you, we will treat it as personal information, even if some components (like weather data) are non-identifiable. Unless you have given us informed consent to participate in a survey or study, we will not solicit any sensitive personal data. This includes information about your race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health and genetic data, biometric data, or details about criminal convictions or offenses.

4. Age Verification

Our products are highly regulated and age-restricted. We are dedicated to preventing sales to minors and take measures to address this. We utilize trusted verification services to confirm the information you provide and ensure you qualify to access and purchase products from our website. This process prioritizes customer privacy, ensuring that detailed information remains secure. In some cases, we may not successfully verify your age or identity through our third-party service. If verification fails, you may be asked to upload a copy of your government ID to enable manual age verification. We only access the verification result, not the ID itself, which is not stored on our servers.

5. How We Collect Personal Data

We gather personal data through various means, depending on your interactions with us, including: Direct interactions: You may provide us with Basic, Purchase and Warranty, Product, Usage, Profile, or Feedback and Marketing Data by:

  • Purchasing our products
  • Creating an account or profile
  • Signing up for information, including marketing updates
  • Submitting warranty claims or contacting us regarding your device
  • Engaging with customer support or requesting technical assistance
  • Accessing TRINITY through social media or our websites
  • Participating in promotions or surveys
  • Engaging in commercial transactions as a business entity or contractor
  • Providing feedback or reviews

Automated technologies or interactions: While you engage with our website, we automatically collect Product Data about your device, browsing behavior, and patterns. This is done using cookies, server logs, and similar technologies. We may also receive Product Data if you visit other websites that use our cookies. Please refer to our cookie policy for more details. From third parties or publicly available sources: We may receive personal data about you from various third-party vendors and public sources, including:

  • Completing sales
  • Monitoring website activity, including user interactions and fraud prevention
  • Age verification
6. How and Why We Utilize Personal Data

As previously stated, TRINITY has several lawful reasons for processing your personal data in specific situations. We assure you that we will only use your personal data when we have a legitimate basis to do so. In some instances, the sole legal basis for processing your personal data is when you grant us your consent. If you do provide your consent, you can rest assured that it is not permanent; we will always offer you the choice to withdraw your consent at any time. Below is an outline of how we use personal data along with the legal basis for each use:

  • Age Verification: We need to verify your legal age to purchase our products, so we collect Basic Data for this purpose. This information is necessary for fulfilling our contractual obligations to you.
  • Transaction Completion: To facilitate your purchase, payment, and shipping, we collect Basic Data, Purchase and Warranty Data, and Commercial Data. This information is crucial for fulfilling our contractual obligations.
  • Customer Service: Depending on your inquiries, we utilize various categories of personal data to assist you effectively. For example, if you contact us regarding a shipment issue, we will refer to Basic Data, Purchase and Warranty Data, and Product Data to address your concerns. This is necessary to fulfill our contractual obligations and to pursue our legitimate interests in providing customer support. 
  • Product Safety and Diagnostics: We strive to ensure our products operate optimally. By understanding their functioning, we can quickly identify and address any issues. Importantly, we want to promptly detect any safety concerns that may arise.
  • Marketing: Please refer to section 7, “Marketing our Products,” for further details.
  • Website and App Management: We utilize Basic Data, Technical Data, Purchase and Warranty Data, and Profile Data to maintain our website and app effectively (including fraud prevention and site maintenance). This is essential for our legitimate interest in operating and enhancing our services, ensuring network security, and complying with legal data security obligations.
  • Data Analysis: We analyze Basic Data, Product Data, Usage Data, Profile Data, and Feedback and Marketing Data to understand customer preferences, improve our products, and identify market trends. While we may share insights with third parties, we ensure that no personally identifiable information is included. Instead, we compile aggregated data, such as demographic preferences, without linking it to individual users.
  • Internal Management and Third-Party Engagement: We utilize Commercial Data as part of our standard business operations. This data is only used for the original purposes it was provided for, and any contractual agreements will take precedence if they differ from this policy.
  • Profile Creation and Management: When you create a profile on our website, you consent to share Basic Data, Product Data, Usage Data, and Profile Data with us, allowing us to offer a customized experience (e.g., tailored metrics and recommendations). This data collection is essential for fulfilling our contractual obligations.

We also use this information to create an internal user profile to market relevant products, deliver tailored content, and gain insights into our customer base and market dynamics. We have a legitimate interest in these activities for business growth and industry understanding but we will only process this information if you have consented, which you can withdraw at any time. We will retain your personal data only for as long as necessary based on the circumstances of its collection, including any legal, regulatory, or accounting obligations. If we can fully anonymize the data (ensuring it cannot identify you), we may keep it indefinitely for statistical or analytical purposes.

7. Marketing Our Products

General Marketing Overview
We engage in marketing activities to encourage people to purchase and enjoy our products while also ensuring our business thrives. This involves various strategies such as placing advertisements, sending emails, running promotions, distributing surveys, and conducting interviews to build our brand. By sharing this information openly, we aim to clarify that marketing is a fundamental part of our strategy for growth. Understanding our customers' preferences is crucial for this growth. We seek insights into what they enjoy, dislike, and may want in the future, whether it's related to a specific device or product. By grasping our customers' interests, we can enhance our current offerings and create better products and services down the line.

Control Over Marketing
It's essential to highlight that you hold complete control over how and whether we market to you. We operate based on your consent (GDPR Article 6(1)(a)), and you can revoke that consent at any time. If you choose to share your usage details to receive tailored promotional content, that's great! Conversely, if you'd prefer us to refrain from knowing about your usage data or contacting you, that's entirely your choice—though we might need to reach out for legal reasons or if you initiate contact. Ultimately, you decide how much information to share and how we communicate with you regarding marketing efforts.

Promotional Offers
We utilize your Basic, Product, Usage, Profile, Feedback, and Marketing Data, occasionally supplemented by Third-Party Data, to develop a marketing profile that allows us to inform you about devices, products, services, or goods you may find appealing. We will only send you marketing emails or texts if you have opted in to receive such communications, which may occur via email, our website, the app, or in-person at a physical location like a store or festival.

Third-Party Marketing
To better identify our customers visiting our site, we may partner with third-party vendors. These vendors assist us in reaching out to customers who have opted in for marketing communications or in gathering more information about these individuals. We share data with them to better track customer behavior on our website, including browsing activity, image clicks, and actions taken on the site even if they have not logged into their accounts. This data helps us understand customer engagement on Pax sites, and we only use it for our internal marketing objectives; we do not sell insights or data about our customers to third parties without your permission. Some vendors may access this data, but their use will be limited to lawful purposes. Additionally, we may use third-party services for direct mail marketing to potential customers interested in our products.

Opting Out
You can request that we or third parties cease sending you marketing communications at any time by submitting a Privacy Request. Opting out of marketing messages does not affect the personal data collected as a result of product or service purchases, warranty registrations, or other transactions.

Cookies
Cookies are small files that monitor your online activity. Some are functional, helping websites load faster, while others are used for marketing purposes, tracking your interactions with websites. We use cookies for both functions, and you can learn more about them and how to manage them in our cookie policy.

Change of Purpose
We will use your personal data only in the manners specified in this Privacy Policy, unless we identify a fair and compatible reason for using it differently. If we need to repurpose your personal data, we will notify you and explain the legal basis for doing so.

Data Retention
We will delete or anonymize your personal data as soon as it is no longer necessary for the purposes for which we collected it, unless legal obligations require us to retain it. However, if you ask us to delete your data or cease contact with you, we will maintain your email address on our master do-not-contact list to honor your request and ensure we do not contact you again. For further details about the types of personal data we retain and their retention periods, please contact us at support@mytrinitypods.com

Automated Decisions
We do not rely on automated decision-making systems (such as algorithms or machine learning tools) to make decisions about you. While we may utilize a system that recommends products, we believe you'll appreciate, the choice to act on those suggestions is always yours.

8. Disclosures of Your Personal Data

Sharing Personal Data
We may share your personal data with:

  • Third-Party Vendors: As noted earlier, we collaborate with external vendors and service providers to ensure our company operates smoothly. This includes:
    • Service providers acting as processors located outside of the European Economic Area (EEA) who offer IT and system administration services, including cookies/user experience/analytics.
    • Professional advisers acting as processors, such as lawyers, bankers, auditors, and insurers based outside the EEA who provide consultancy, banking, legal, insurance, and accounting services.
    • Logistics providers who facilitate order processing and delivery and assist with post-purchase customer service issues.
    • Customer support teams that address inquiries and warranty claims.
    • Marketing agencies that help us connect with customers who have opted in to receive marketing communications or new customers via direct mail.

We will also share personal data if we engage in business transactions, such as buying, selling, transferring, or merging parts of our business.

  • Regulatory Bodies: If we are subject to audits, reviews, or inquiries from regulatory agencies (such as the Food and Drug Administration), we may be required to share relevant data, including personal data.
  • Legal Requests: We are obligated to comply with lawful subpoenas or investigative requests from courts and law enforcement agencies. To be transparent, if law enforcement or any authorized entity follows the appropriate legal procedures and requests information about you from TRINITY, we will likely have to provide that information. This may include data regarding your device usage and, depending on the device, the type and amount of product you've used. If this raises concerns, or if you'd prefer not to share Usage Data with us, we recommend that you refrain from doing so.

Legal Basis for Sharing Data
We share your personal data with third parties only to fulfill our contractual obligations to you (GDPR Article 6(1)(b)), with your consent (GDPR Article 6(1)(a)), or when required by legal or regulatory obligations (GDPR Article 6(1)(c)). These third parties are prohibited from using your personal data for purposes other than those outlined in this policy.

9. International Transfers

Global Data Transfers
We are based in the United States and may transfer data from other regions as described in this Privacy Policy.

10. Data Security

Commitment to Data Security
We are committed to safeguarding your data and ours. We employ a combination of technological, administrative, and physical measures to protect personal data against unauthorized access or misuse. However, please note that no security measures are entirely foolproof.

Breach Notification Procedures
We have established procedures to address any suspected breaches of personal data and will notify you and relevant regulators in accordance with legal requirements if a breach occurs.

11. Your Legal Rights

Understanding Your Rights
When you provide us with personal data, you have specific rights regarding its use. These rights may be outlined in various laws, including the European Union’s GDPR, Canada’s PIPEDA, or California’s Consumer Privacy Act. Generally, you have the right to:

  • Request access to your personal data.
  • Request corrections to your personal data.
  • Request the deletion of your personal data.
  • Object to the processing of your personal data.
  • Request restrictions on the processing of your personal data.
  • Request the transfer of your personal data.
  • Withdraw consent.

If you wish to exercise any of these rights, please submit a request by clicking on “Privacy Request” above. No Fees Required In most cases, you will not need to pay a fee to exercise these rights, although there may be rare circumstances where a fee is applicable.

Identity Verification To ensure that you are the rightful individual exercising these rights, we may request information to verify your identity. We will not ask for more information than is necessary for this verification.

Response Timeframe We aim to respond to all legitimate requests within one month. If your request is particularly complex or if you have submitted multiple requests, it may take longer. In such cases, we will keep you informed of the status.

12. Third-Party Services

As mentioned previously, we may provide links to third-party websites or services. This Privacy Policy does not apply to those external sites or services. If you follow a link to any third-party website or service, please be aware that they have their own privacy policies and terms and conditions, and we are not responsible for their practices.

13. Contact Us

If you have any questions regarding this Privacy Policy, please reach out to us:
By Email: support@mytrinitypods.com

14. Changes to This Policy

We may occasionally update this Privacy Policy. When we make significant changes, we will notify you in advance. We encourage you to review this Privacy Policy regularly to stay informed about our practices.