Privacy Policy
Last updated on April 29, 2019 . This Privacy Policy is effective June 10, 2019 for all visitors. To review our Terms & Conditions, please click here
This Privacy Policy is designed to help you understand how Trala Inc. ( “Trala”, “we”, “us” or “our” ) collects, uses and shares your personal information if you visit our website at www.trala.com or another website to which we post this Privacy Policy (the “Sites”), use our mobile applications (together with the Sites, the “Service” ) or otherwise interact with us.
Personal Information We Collect
Information you give us.
Personal information you may provide through the Service or
otherwise communicate to us includes:
•Contact information.
Your contact details (such as your name and email address).
•Account information.
If you use features of the Service that require a user
account, we collect the information you provide to allow us to
create and administer your account, which may include your
email address and your name.
•Practice information.
We may collect information that you provide about your
practice sessions, such as recordings of your practice and
details of your performance during your practice.
•User generated content.
We may collect content or other information that you provide
or create when you interact with the Service, such as the
practice recordings you upload or comments on our blog.
•Correspondence.
We may collect information about you that you provide when you
request information from us or otherwise correspond with us.
•Job applications.
Our Sites may provide you information on how to submit
applications for employment opportunities with Trala.
Application materials that you submit may include your resume,
cover letter and other personal information.
•Other information.
We may collect other information about you that is not
specifically listed here and will use it in accordance with
this Privacy Policy.
Information automatically collected.
Our servers and third party service providers may
automatically record certain information about how you use the
Service and the computers or devices you use to access the
Service, such as your Internet Protocol (IP) address, device
identifier, mobile carrier, domain name, device and browser
type, operating system, Internet service provider,
referring/exit pages, clickstream data, the pages or features
of the Service that you browse and the time you spend on those
pages or features, the frequency with which you use the
Service, the links that you click on or use and other
statistics. We also record whether emails we send you are
delivered and opened and whether links within the email are
clicked. We collect this information in server logs and/or by
using cookies, web beacons and similar tracking technologies.
See our Cookie Policy for more information.
Sensitive personal information.
We do not intentionally collect any sensitive personal
information (e.g., social security numbers, information
related to racial or ethnic origin; political opinions,
religion or other beliefs; health, biometrics or genetic
characteristics; criminal background or union membership)
through the Service or otherwise, but if you provide it to us,
you must consent to our use of this information as described
in this Privacy Policy.
How We Use Your Personal Information
We use your personal information for the following purposes
and as otherwise described in this Privacy Policy or at the
time of collection:
To operate the Service.
We use your personal information:
•
to provide, operate and improve the Service;
•
to communicate with you about the Service, including by
sending you announcements, updates, security alerts, and
support and administrative messages;
•
to understand your needs and interests, and personalize your
experience with the Service; and
•
to respond to your requests, questions and feedback related to
the Service.
For research and development.
We analyze use of the Service to study trends and users’
movements around the Service, gather demographic information
about our user base, improve the Service and develop new
products and services.
To send you marketing communications.
We may send you marketing communications but you may opt out
of receiving these communications as described in the Opt out
of marketing section below.
To create anonymous data.
We may create aggregated and other anonymous data from our
users’ information. We make personal information into
anonymous data by removing information that makes the data
personally identifiable. We may use this anonymous data and
share it with third parties to understand and improve the
Service, promote our business and for other lawful business
purposes.
For compliance, fraud prevention and safety.
We may use your personal information and share it with
government officials, law enforcement or private parties, as
we believe appropriate:
•
to protect our, your or others’ rights, privacy, safety or
property (including by making and defending legal claims);
•
to protect against, investigate and deter fraudulent, harmful,
unauthorized, unethical or illegal activity;
•
to comply with applicable laws; court orders, subpoenas and
other legal process; and requests from government authorities;
and
•
where permitted by law in connection with a legal
investigation.
With your consent.
In some cases we may specifically ask for your consent to
collect, use or share your personal information, such as when
required by law.
How We Share Your Personal Information
We do not share your personal information with third parties
without your consent, except in the following circumstances or
as described in this Privacy Policy:
Affiliates.
We may share your personal information with parent companies,
subsidiaries and affiliates for use consistent with this
Privacy Policy.
Service providers.
We may share your personal information with third party
companies and individuals as needed for them to help us
provide the Service or support our business activities (such
as website and mobile application analytics, email delivery,
marketing/advertising, IT providers, technical support, and
legal and other professional advice).
For compliance, fraud prevention and safety.
We may share your personal information for the compliance,
fraud prevention and safety purposes described above.
Business transfers.
We may sell, transfer or otherwise share some or all of our
business or assets, including your personal information, in
connection with a business deal (or potential business deal)
such as a corporate divestiture, merger, consolidation,
acquisition, reorganization or sale of assets, or in the event
of bankruptcy or dissolution.
Your Choices
Opt out of marketing.
You may opt out of marketing-related emails from us by
following the unsubscribe instructions in the email. You may
continue to receive Service-related and other non-marketing
emails.
Cookies and similar technologies.
See our Cookie Policy for your choices regarding limiting the
information collected by cookies and similar technologies.
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.
Other Important Privacy Information
Third party sites and services.
The Service may contain links to other websites and services
operated by third parties. These links are not an endorsement
of, or representation that we are affiliated with, any third
party. We do not control third party websites, applications or
services, and are not responsible for their actions. Other
websites and services follow different rules regarding their
collection, use and sharing of your personal information. We
encourage you to read their privacy policies to learn more.
Security practices.
The security of your personal information is important to us.
We employ a number of organizational, technical and physical
safeguards designed to protect the personal information we
collect. However, security risk is inherent in all internet
and information technologies and we cannot guarantee the
security of your personal information. If you have a user
account for the Service, you are solely responsible for
maintaining and protecting the confidentiality of your account
password and other account information in your possession.
International data use.
We are headquartered in the United States and have affiliates
and service providers in other countries, and your personal
information may be collected, used and stored in the United
States or other locations outside of your home country.
Privacy laws in the locations where we handle your personal
information may not be as protective as the privacy laws in
your home country.
Children.
The Service is not directed at, and we do not knowingly
collect personal information from, anyone under the age of 13
or otherwise under the age of consent in the country where
they live. If we learn that personal information of someone
under the age of 13 or otherwise under the applicable age of
consent has been submitted to us, we will take appropriate
steps to delete it.
Privacy Policy Changes.
Trala may change its Privacy Policy from time to time, and in
Trala's sole discretion. If we make changes to this
Privacy Policy, we will post them on the Sites and indicate
the effective date of the change. If we make material changes
to this Privacy Policy, we will notify you by email or through
the Service.
How to Contact Us
Please direct and questions or comments about this Privacy
Policy to:
Trala, Inc.
2093 Philadelphia Pike #1930
Claymont, DE 19703
email: privacy@trala.com
Notice to European Users
The following applies to individuals in the European Economic
Area and the United Kingdom.
Controller.
Trala, Inc. is the controller of your personal information
covered by this Privacy Policy for purposes of European data
protection legislation.
Legal bases for processing.
Our legal basis for processing the personal information
described in this Privacy Policy will depend on the type of
personal information and the specific context in which we
process it. However, the legal bases we typically rely on are
set out in the table below. We rely on our legitimate
interests as our legal basis only where those interests are
not overridden by the impact on you (unless we have your
consent or our processing is otherwise required or permitted
by law). If you have questions about the legal basis of how we
process your personal information, contact us at
privacy@trala.com.
Processing purpose - Legal basis
•To operate the Service
You have entered a contract with us for the provision of the
Service and we need to process your personal information to
provide services you have requested or take steps that you
request prior to providing services. If we have not entered
into a contract with you, we process your personal information
based on our legitimate interest in providing the Service you
access and request.
•
For research and development
•
To send you marketing communications
•
To create anonymous data
These activities constitute our legitimate interests.
•
For compliance, fraud prevention and safety
These activities constitute our legitimate interests or, in
some cases, processing is necessary to comply with our legal
obligations.
•
With your consent
Processing is based on your consent. Where we rely on your
consent you have the right to withdraw it anytime in the
manner indicated when you consent or in the Service.
•
To share your personal information as described in this
Privacy Policy
This sharing constitutes our legitimate interests, and in some
cases may be necessary to comply with our legal obligations.
Retention
We retain personal information where we have an ongoing
legitimate business need to do so (for example, to provide you
with a service you have requested; to comply with applicable
legal, tax or accounting requirements; to establish or defend
legal claims; or for fraud prevention). When we have no
ongoing legitimate business need to process your personal
information, we will either delete or anonymize it or, if this
is not possible for technical or other operational reasons
(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.
Your rights
European data protection laws give you certain rights
regarding your personal information. You may ask us to take
the following actions in relation to your personal information
that we hold:
•Access.
Provide you with information about our processing of your
personal information and give you access to your personal
information.
•Correct.
Update or correct inaccuracies in your personal information.
•Delete.
Delete your personal information.
•Transfer.
Transfer a machine-readable copy of your personal information
to you or a third party of your choice.
•Restrict.
Restrict the processing of your personal information.
•Object.
Object to our reliance on our legitimate interests as the
basis of our processing of your personal information that
impacts your rights.
You may submit these requests by email to
privacy@trala.com
or our postal address provided above. We may request specific
information from you to help us confirm your identity and
process your request. Applicable law may require or permit us
to decline your request. If we decline your request, we will
tell you why, subject to legal restrictions. If you would like
to submit a complaint about our use of your personal
information or our response to your requests regarding your
personal information, you may contact us or submit a complaint
to the data protection regulator in your jurisdiction. You can
find your data protection regulator here.
Cross-Border Data Transfer
If we transfer your personal information from the European
Economic Area to a country outside of it and are required to
apply additional safeguards to your personal information under
European data protection legislation, we will do so, for
instance, by entering into standard contractual clauses for
the transfer of data as approved by the European Commission.
Please contact us for further information about any such
transfers and the safeguards applied.