INTRODUCTION AND COMMITMENT
This policy is effective as of April 4, 2023, and is incorporated into, and subject to, Trillion's Terms of Service.
By using any product or service offered by Trillion, its parent company, or subsidiaries, you acknowledge that you have read and agree to this policy.
WHAT IS IN THIS PRIVACY DOCUMENT?
The Trillion Platform which enables clients to purchase digital advertising and the Above.com Platform which allows users to monetize domain names (collectively, “The Platform” or “Trillion Platform”). This document aims to provide information on these platforms and our policies regarding data collection and utilization. Additionally, it describes the type of data that we collect and utilize when serving ads and/or landing pages to individuals.
At Trillion, we believe in giving you the power to make informed decisions about the advertisements you see online. As such, we offer you the opportunity to opt out of personalized ads based on your interests, previous website visits, and data stored in your web browser or mobile device.
If you opt-out, you will still see the same number of ads. However, these ads will no longer be tailored to your interests and are likely to be less relevant. We will also dissociate any information we have collected from your device, preventing its use. If you are located in the European Economic Area and choose to opt out, we will treat your request as a request for the cessation of processing your personal data on the Trillion Platform.
To opt out, please email us at firstname.lastname@example.org with your opt out request. Please title your email “Trillion Data Opt Out Request”.
TRILLION PLATFORM PRIVACY PRACTICES
What is the Trillion Platform?
The Trillion Platform facilitates the purchasing of direct-to-advertiser landing page redirects and ad space on websites, mobile sites, and applications by advertisers and media buyers. To achieve this, the platform collects pseudonymous information from these sources and supplements it with data from third parties. Advertisers and media buyers utilize the Trillion Platform for various advertising techniques such as retargeting, interest-based advertising, real-time (programmatic) advertising, contextual advertising, and location-based advertising. In addition, the platform offers various tools to buyers, including the ability to measure the effectiveness of their ads, which streamlines the process of purchasing direct-to-advertiser ads and other digital advertising space.
What information does the Trillion Platform collect?
The Trillion Platform utilizes various types of data, which includes data generated by the platform itself and data obtained by clients from external sources and then used on the platform.
Various Pseudonymous information about internet users’ browsers and devices is collected, such as:
- the type of browser and its settings
- information about the operating system of the device
- cookie information
- information about other identifiers assigned to the device
- the IP address used to access a client's website or mobile application
- information about whether an Internet user has visited a Trillion's advertiser's website, based on web beacons placed on the site by advertisers or partners.
Additionally, information about the domain names, websites (i.e., the page URLs) and mobile applications upon which advertisements are served, as well as the geographic location of the device when it accesses a website or mobile application, may also be collected.
Inferences or information about users’ interests that are created, acquired, bought, sold, or used by clients may also be included.
Trillion may also receive audience segments from third parties, which may include or be based on the aforementioned information and can be used on the Trillion Platform.
How does the Trillion Platform use the various information that it collects?
The information we collect is used to serve targeted ads and landing pages to individuals. Our Trillion Platform allows users to utilize this information to:
- Determine which ad or landing page to display to an individual, including behaviorally targeted ads and serve it to them.
- Tailor ads to specific audience types.
- Personalize ads to the type of web page an individual is viewing.
- Analyze the effectiveness of served ads.
- Gain insights into their own customers.
- Limit ad frequency for individuals.
- Detect fraudulent activity.
- Troubleshoot platform or campaign issues.
To enable the above uses of information, we may need to transfer it to third-party partners. It's important to note that such transfers may be classified as data sales under the laws of Australia.
How long is the information stored and kept by Trillion?
Trillion Platform stores data collected through browsers and stored in cookies for an endless time frame. Meanwhile, for data collected through mobile application advertising and stored via mobile advertising IDs, the Trillion Platform stores this data for an endless time frame. Our systems automatically reset the retention period each time we encounter the same user.
How does the Trillion Platform collect this information?
To enhance and refine digital ad campaigns, Trillion and/or Trillion Advertisers utilize various technologies, such as cookies, beacons, mobile SDKs, tags, and others, to gather data associated with specific web browsers or devices. This data is collected by the Trillion Platform and utilized accordingly.
Does the Trillion Platform use web beacons (aka clear GIFs or web bugs)?
Yes. Web beacons are small images with a unique identifier, typically a single transparent pixel, that are served to users as part of a web page or other document. They may be used for various purposes in some parts of our services, including site traffic reporting, advertising auditing and reporting, unique visitor counts, and personalization.
For further information on web beacons, please refer to http://www.allaboutcookies.org/faqs/beacons.htm.
How does Trillion use the information provided by Trillion Platform advertisers?
At Trillion Platform, we use any information provided by our advertising customers for various service-related purposes. These purposes include:
- Providing, operating, managing, maintaining and enhancing the Trillion Platform.
- Internally performing statistical and other analysis on information we collect, such as usage data, device data, referral data and information from page tags. This analysis helps us to understand user behavior and trends, how people use our services and to monitor, troubleshoot and improve our services.
- Assisting in the enforcement of our Terms of Service
- Preventing potentially illegal activities and screening for undesirable or abusive activity.
- Contacting you about your service or account. We occasionally send transactional communications (e.g. service-related announcements, billing-related matters, changes to our services or policies, welcome emails when you first register, etc.) which are necessary for us to effectively provide our services to you. Opting out of these communications is not possible.
- Contacting you for marketing purposes.
- Responding to legal requests and preventing harm. In the event of a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- Creating new services, features, or content. Any information you provide us (e.g. via email or through our ticketing system) may be used to create and provide new services, features, or content.
Will Trillion share the information collected via the Trillion Platform?
- At Trillion Platform, we share aggregate information collected from our platform for marketing purposes. An example of this is when we issue a press release to announce that users who have visited travel sites have a higher click-through rate on finance-related web pages.
- Trillion may share customer platform data with partners and service providers in order to provide and improve our services. This includes operating, managing, maintaining, or enhancing the Trillion platform, as well as ensuring the safety and security of the platform and the online industry. Additionally, we may share data as required by law.
- At Trillion, we may enlist the help of trusted agents and service providers to aid us in billing and account maintenance for our clients. However, we ensure that these companies are contractually obligated to only use the information as directed by Trillion, and are prohibited from selling it. For instance, if you choose to fund your platform account with a credit card, we may utilize a credit card processing company to bill you for the services and share your address and billing details with them to facilitate the transaction. These service providers do not keep, share, store, or utilize that information for any other purposes.
- In order to interact with our ad delivery partners, we may share information inclusive of hashed/obfuscated user data, and engage in "cookie sync" with our suppliers, which may include data companies, other advertising platforms, and ad exchanges. This is in accordance with the information noted above.
As a Trillion Platform customer, what communications can I expect to receive from Trillion?
At our company, we offer various types of communications and services to our users, as outlined below:
- Special Offers and Updates – If you opt-in on our registration page, we will periodically send you information on products, services, special deals, and promotions. If you no longer wish to receive this type of communication, you can easily opt-out using the link provided in the email communication.
- Surveys or Contests – We may offer you the opportunity to participate in surveys or contests on our site from time to time. Your participation in these is completely voluntary and you have the choice whether or not to disclose any personally identifiable information. We use the information you provide to notify contest winners and award prizes, as well as to process and analyze survey results. These surveys or contests are conducted by a third-party service provider who is prohibited from using our users’ personally identifiable information for any other purpose.
- Service-related Announcements – We may send you strictly service-related announcements on rare occasions, such as when our service is undergoing temporary maintenance. These communications are not promotional in nature and cannot be opted-out of. If you do not wish to receive them, you can deactivate your account.
- Customer Service – Based on the personally identifiable information you provide, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you through our ticketing system, via email, and by phone.
Unsubscribing from Promotional Communications - If you no longer wish to receive our promotional communications, you can easily unsubscribe by following the instructions included in each communication.
Web Beacons - We use web beacons in our HTML-based emails through our partners to track which email recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
Supplementation of information - To provide certain services to you, we may supplement the personal information you submit to us with information from third-party sources. This may include information for credit decisions and verification of any information provided.
TRILLION'S BUSINESS OPERATIONS
What information does Trillion collect pursuant to running its business, and how is it used?
Aside from operating our website, as described below, we gather specific information as part of our business operations. This includes keeping records of our business partners, service providers, and customers. For those individuals who require access to our systems in order to view reports, we provide login credentials and process their email addresses and passwords to enable login. Additionally, we collect billing and payment information from our partners, service providers, and customers so that we can properly bill for and collect payment for our services. We use this information solely for its intended purpose and do not sell it to any third parties.
TRILLION.COM WEBSITE VISITORS
What information does the Trillion website collect, and how is it used?
Whenever you interact with our websites, we collect usage data about you, such as which pages you visit, what you click on, and when you perform those actions. Our web servers also keep log files that record data each time a device accesses them, including data about the nature of each access and originating IP addresses. Additionally, we collect data from the device and application you use to access our services, such as your IP address and browser type. Based on your IP address, we may also infer your geographic location. If you arrive at our website from an external source (e.g. a link on another website or in an email), we record information about the source that referred you to us.
We use third-party tracking services that utilize cookies and page tags (also known as web beacons) to collect pseudonymous data about visitors to our websites. It's important to note that their collection of data may be considered a sale under California and/other US State law. This data includes usage and user statistics but not personally identifiable information.
Yes. Cookies are alphanumeric identifiers generated by web servers and stored on a user's web browser for future access. Cookies are unable to view or retrieve data from other cookies, nor can they capture files or data stored on a user's computer. At our website, we do not link the information stored in cookies to any information that could be used to determine a user's real-world identity.
We use both session ID cookies and persistent cookies to enhance a user's experience on our site. Session ID cookies make it easier for users to navigate our site, and they expire when a user closes their browser. Persistent cookies remain on a user's hard drive for an extended period of time and enable us to track and target our users' interests. We also use persistent cookies to store users' passwords, so they don't have to enter them more than once.
If a user rejects cookies, they can still use our site, but their ability to access some areas of our site may be limited. Users can remove persistent cookies by following the directions provided in their web browser's "help" file. For more information on cookies, please visit http://www.allaboutcookies.org/faqs/cookie-file.htm.
GENERAL PRIVACY INFORMATION
How do I access my information?
As a user, you have the right to access, update, and correct any inaccuracies in the personal information we hold, subject to certain exceptions as prescribed by law. To request access, updating, or corrections of any inaccuracies in your personal information under our custody or control, please email us at email@example.com. For the purpose of verifying your identity, we may require specific personal information before granting access or correcting your personal information records. In case of any changes to your personally identifiable information or if you wish to deactivate our Service, you can email us at firstname.lastname@example.org. to correct, update, delete, or deactivate it.
Is my information secure?
We take the security of your sensitive and confidential information seriously, and have implemented measures to ensure that the portions of our website (and our other services) that handle such information are secure. Our commitment to maintaining the security of your information includes protection against the loss, misuse, and alteration of the information under our control.
To achieve this, we employ industry-standard techniques to protect our systems from unauthorized intrusion, and our data center uses state-of-the-art physical security measures to prevent unauthorized access to the facility. Additionally, all information is stored in a secure location behind firewalls and other sophisticated security systems, with limited administrative access to those with a need to know.
All of our employees who have access to, or are associated with, the processing of personal information are contractually obligated to respect the confidentiality of your information and adhere to the privacy standards we have established. However, we acknowledge that no security measures are perfect or impenetrable. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Will my information ever be tranferred from Trillion to another party?
Trillion may transfer data processed by our Platform to our advertisers, their ad agencies, or their data management platforms, and such transfers may constitute a sale of data. We may also share information with trusted third-party agents, such as billing and payment processing vendors and hosting providers for the Trillion website and Trillion Platform. These third-party contractors are prohibited from using the information for purposes other than performing services for Trillion.
Other third-party service providers used by Trillion may include cloud computer, data storage and file storage providers, email marketing providers, website and B2B sales analytics providers, customer relationship management, contact database vendors, data hygiene vendors, survey vendors and project management software providers, customer billing systems partners, login authentication providers to ensure that the logins to our systems are working efficiently, social media platforms for advertising and marketing purposes, outsourced computer programmers helping ensure our systems are operating properly, auditing, debugging, and security vendors. These agents work on our behalf and use data only as directed by us, provided that such third-party agents provide at least the same level of privacy protection as we do.
However, we may disclose any of the information we collect when we believe that we have a legal obligation to do so or to protect the safety, property or rights of Trillion or any third party. Additionally, in the event of a business transition such as a merger, acquisition, or sale of all or a portion of its assets, your personally identifiable information may be among the assets transferred.
Please note that this website may contain links to other websites that are not owned or controlled by Trillion. As such, we cannot be held responsible for the privacy practices of such sites. We encourage you to exercise caution and to read the privacy statements of all websites that collect personally identifiable information when you leave our site. Please be aware that this privacy statement applies solely to information collected by Trillion.
You may contact us at the address below:
6-8 East Concourse
BEAUMARIS, VIC 3193