“your information privacy is important to us.”

tralonet (“company”, “we”, “us”, or “our”) is committed to protecting your personal information and your right to privacy. when you visit our website www.tralonet.com (the "website"), and more generally, use any of our services (the "services", which include the website), we appreciate that you are trusting us with your personal information. we take your privacy very seriously. in this privacy policy (“policy”), we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. we hope you take some time to read through it carefully, as it is important. if there are any terms in this policy that you do not agree with, please discontinue the use of our services immediately.

we use your data to provide and improve service. by using the service, you agree to the collection and use of information in accordance with this policy. unless otherwise defined in this policy, the terms used in this policy have the same meanings as in our terms of use. our terms of use (“terms”) govern all use of our service and together with the policy constitutes your agreement with us (“agreement”).

if this policy is modified in any way, it will be updated here. regularly checking and reviewing this page ensures that you are updated on the information which may be collected, used (and under what circumstances), and if it may be shared with other parties (if at all). if we believe that the modifications are material, we will notify you of the changes by posting a notice on the website, or email you at the email address provided to us by you, and as we may deem appropriate. what constitutes a material change will be determined by us, at our sole and absolute discretion. This policy applies to all information collected through our services (which, as described above, includes our website), as well as any related services, sales, marketing or events.

DEFINITION

service means the tralonet.com website operated by tralonet. personal data means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession). Usage data is data collected automatically either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).

The user is the individual using our service. the user corresponds to the data subject, who is the subject of personal data. this includes students or anyone who is browsing our website.

WHAT INFORMATION DO WE COLLECT?

personal data

while using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“personal data”). personally, identifiable information may include, but is not limited to:

first name

last name

email id

we may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. you may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

usage data

we may also collect information that your browser sends whenever you visit our service or when you access service by or through any device (“usage data”).

this usage data may include information such as your computer’s internet protocol address (e.g. ip address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

when you access service with a device, this usage data may include information such as the type of device you use, your device unique id, the Ip address of your device, your device operating system, the type of internet browser you use, unique device identifiers and other diagnostic data.

location data

we may use and store information about your location if you give us permission to do so (“location data”). we use this data to provide features of our service and to improve and customize our service.

you can enable or disable location services when you use our service at any time by way of your device settings.

tracking cookies data

we may use cookies and similar tracking technologies to track the activity on our service and we hold certain information.

cookies are files with a small amount of data which may include an anonymous unique identifier. cookies are sent to your browser from a website and stored on your device. other tracking technologies may also be used such as pixel tags, marking tags and tag managers to collect and track information and to improve and analyze our service.

you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. however, if you do not accept cookies, you may not be able to use some portions of our service.

kindly refer to our cookie policy.

HOW DO WE USE YOUR INFORMATION?

the information collected from you may be used to operate, provide, develop and improve our services. data like personal data and other technical data is used to manage orders, provide services, process payments and communicate with you and improvise on all our services.

these purposes include:

to facilitate account creation, enrollment and login process. if you choose to link your account with us to a third-party account (such as your google account), we use the information you allowed us to collect from those third parties to facilitate account creation and the login process for the performance of the contract.

to post testimonials. we post testimonials on our website that may contain personal information. prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. if you wish to update or delete your testimonial, please contact us, and be sure to include your name, testimonial location, and contact information.

request feedback. we may use your information to request feedback and to contact you about your use of our website.

to manage user accounts. we may use your information for the purposes of managing our account and keeping it in working order.

to send administrative information to you. we may use your personal information to send you the services and new feature information and/or information about changes to our terms, conditions, and policies.

to protect our services. we may use your information as part of our efforts to keep our website safe and secure (for example, for fraud monitoring and prevention).

to enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

to respond to legal requests and prevent harm. if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

to send you marketing and promotional communications. we and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. for example, when expressing an interest in obtaining information about us or our website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. you can opt-out of our marketing emails at any time (see the “what are your privacy rights” below).

for any other purpose with your consent.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

we may process or share your data that we hold based on the following legal basis:

consent: we may process your data if you have given us specific consent to use your personal information in a specific purpose.

legitimate interests: we may process your data when it is reasonably necessary to achieve our legitimate business interests.

performance of a contract: where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

legal obligations: we may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

vital interests: we may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. more specifically, we may need to process your data or share your personal information in the following situations:

business transfers: we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

third-party advertisers: we may use third-party advertising companies to serve ads when you visit or use the website. these companies may use information about your visits to our website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honor this policy. affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

other users: when you share personal information (for example, by posting comments, contributions or other content to the website) or otherwise interact with public areas of the website, such personal information may be viewed by all users and may be publicly made available outside the website in perpetuity. if you interact with other users of our website and register for our website through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. similarly, other users will be able to view descriptions of your activity, communicate with you within our website, and view your profile.

WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

the website may contain advertisements from third parties that are not affiliated with us and which may link to other websites, and online services. we cannot guarantee the safety and privacy of the data you provide to any third parties. any data collected by third parties is not covered by this policy. we are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the website. you should review the policies of such third parties and contact them directly to respond to your questions.

we hereby disclaim liability for any information, materials, products, or services posted or offered at any of the third-party sites linked to this website. by creating a link to a third-party website, we do not endorse or recommend any products or services offered or information contained on that website, nor are we liable for any failure of products or services offered or advertised at those sites. such a third party may have a privacy policy different from that of ours and the third-party website may provide less security than this site.

HOW LONG DO WE KEEP YOUR INFORMATION?

we will only keep your personal information for as long as it is necessary for the purposes set out in this policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). no purpose in this policy will require us to keep your personal information for longer than the period of time in which users have an account with us.

when we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

we have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. however, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. although we will do our best to protect your personal information, transmission of personal information to and from our website is at your own risk. you should only access the website within a secure environment.

YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION

if you are a resident of the European union (EU) and European economic area (EEA), you have certain data protection rights, covered by GDPR.

we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data.

if you wish to be informed of what personal data we hold about you and if you want it to be removed from our systems, please contact us.

in certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you.

The right of rectification. you have the right to have your information corrected if that information is inaccurate or incomplete.

The right to object. you have the right to object to our processing of your personal data;

The right of restriction. you have the right to request that we restrict the processing of your personal information.

The right to data portability. you have the right to be provided with a copy of your personal data in a structured, machine-readable and commonly used format.

The right to withdraw consent. you also have the right to withdraw your consent at any time where we rely on your consent to process your personal information.

please note that we may ask you to verify your identity before responding to such requests. please note, we may not be able to provide a service without some necessary data.

you have the right to complain to a data protection authority about our collection and use of your personal data. for more information, please contact your local data protection authority in the European economic area (EEA).

YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

California civil code section 1798.83, also known as the “shine the light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. if you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

if you are under 18 years of age, reside in California, and have a registered account with the website, you have the right to request removal of unwanted data that you publicly post on the website. to request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. we will make sure the data is not publicly displayed on the website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

ccpa privacy policy

the California code of regulations defines a "resident" as:

every individual who is in the state of California for other than a temporary or transitory purpose and

every individual who is domiciled in the state of California who is outside the state of California for a temporary or transitory purpose.

all other individuals are defined as "non-residents."

if this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.

how do we use and share your personal information?

more information about our data collection and sharing practices can be found in this policy. you can opt out from the selling of your personal information by disabling cookies in the cookies preferences settings or clicking on the do not sell my personal information link on our homepage. you may contact us, or by referring to the contact details at the bottom of this document. if you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

your rights with respect to your personal data

right to request deletion of the data - request to delete

you can ask for the deletion of your personal information. if you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

right to be informed - request to know

depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell your personal information to third parties;

the categories of personal information that we sold or disclosed for a business purpose;

the categories of third parties to whom the personal information was sold or disclosed for

a business purpose; and the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

right to non-discrimination for the exercise of a consumer's privacy rights.

we will not discriminate against you if you exercise your privacy rights.

verification process

upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. these verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. for instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. we may also use other verification methods as the circumstances dictate.

we will only use personal information provided in your request to verify your identity or authority to make the request. to the extent possible, we will avoid requesting additional information from you for the purposes of verification. if, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. we will delete such additionally provided information as soon as we finish verifying you.

other privacy rights

you may object to the processing of your personal data.

you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.

you can designate an authorized agent to make a request under the ccpa on your behalf. we may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the ccpa.

you may request to opt-out from future selling of your personal information to third parties. upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

to exercise these rights, you can contact us, or by referring to the contact details at the bottom of this document. if you have a complaint about how we handle your data, we would like to hear from you.

CHILDREN’S PRIVACY

our services are not intended for use by children under the age of 18, without parental consent (“child” or “children”).

we do not knowingly collect personally identifiable information from children under 18 without parental consent. if you become aware that a child has provided us with personal data without the parent's consent, please contact us. if we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

MODIFICATIONS TO THE POLICY

we may update this policy from time to time. the updated version will be indicated by an updated “revised” date and the updated version will be effective as soon as it is accessible. if we make material changes to this policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. we encourage you to review this policy frequently to be informed of how we are protecting your information.