RCCI Group, Inc. (“RCCI Group,” “we,” “us,” or “our”) operates the Triumph application and related websites (each, an “App” or a “Site”, respectively) and several related services (all such services, “Services”).
If you are visiting us from the European Union or European Economic Area, please be sure to read to section entitled “Additional Information for European Union Users” for information on how we comply with privacy laws applicable to you.
What Information We Collect and How We Use It
We will use your Personal Information to:
- Provide you with Services and customer support;
- Market our products and services to you that we believe may be of interest to you;
- Respond to your requests, resolve disputes and/or troubleshoot problems;
- Improve the quality of the Sites and the Services; and
- Communicate with you about the Sites and the Services.
We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.
We will communicate with you primarily in the form of push alerts and emails. You can manage the frequency and/or opt out of receiving these communications by changing your settings on the App and/or clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you Site and Services related communications (e.g., emails related to your account or the App).
We collect the following types of Personal Information:
Device Information: When you download the App, we may collect your device type, your wireless carrier, and your individual device ID and we associate this with your Personal Information, though we primarily use this information to support your account and provide you with Services.
Account Information: To use our Services, we may require you to register through the App with our Services and open an “Account” with us by providing your information including name, username, email address, and a password. We retain information on your behalf, such as entries, pages and messages that you store using your Account.
Journal Information: The most important thing we store is your journals. By default, your journals are private. Individual entries may be shared (see “Published User Content” below).
Published User Content: We may provide users with the ability to share their journal entries and other Personal Information (together ‘Published User Content’) with others. Our display of Published User Content is subject to the privacy settings you establish for them. When you publish or share content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) as part of our Services, other users may be able to see it, including anonymous visitors to the Site. Please remember this and be thoughtful about what you publish.
Transactional Information: When you order Services through our App, we may collect information necessary to complete and record the transaction, though some of this information may go directly to our payment provider. If you tell us where you are (e.g., by allowing your mobile device to send us your location when you publish), we may collect, store and use that information. If you want to deactivate this feature, you can either reinstall the App(s) or deactivate location services on your mobile device. Of course, your location may also be apparent from your entries.
Other Information: We collect your other Personal Information that you submit to us voluntarily as you use our App, Site and Services. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. You can choose not to provide us with certain information, but this may limit the features of the Services you are able to use.
We will use your Anonymous Information to:
- Keep track of logins and personalize your experience (including by tailoring content to you)
- Enhance the Sites or Services
- Improve the content of our software
- Customize the App, Sites or Services to you
- Contact you and/or market our products and services to you on our Sites or through our Services
We collect the following types of Anonymous Information:
Information Collected by Our Servers: To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Mobile Services: We may also collect non-personal information from your mobile device if you have downloaded our App(s) to your mobile device. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the App(s), and information about the type of device you use. In addition, in the event our App(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
Combining Anonymous and Personal Information:
How We Disclose Information
We also disclose certain Personal Information:
- To third party vendors who help us provide the Services or the Sites;
- To third parties to whom you ask us to send Personal Information;
- In connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.
- If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Service; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity, in which case we can (and you authorize us to) disclose Personal Information without subpoenas or warrants served on us; or (c) protect and defend our rights or property or the rights and property of you or third parties.
We reserve the right to disclose Anonymous Information publicly without restriction.
Controlling Your Information
You can stop all collection of information by the App(s) by uninstalling the App(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
Information Disclosed to Third Parties
Child Usage Restrictions
Our Services and App are not directed to children and children are not eligible to use our Services. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years of age, and no part of our App or Services is designed to attract people under 13 years of age. If we later learn that a user is under 13 years of age, we will take steps to remove that user’s Personal Information from our databases and to prevent the user from utilizing the Sites and the Services.
ADDITIONAL INFORMATION FOR EUROPEAN UNION USERS
Controller and Data Protection Officer
RCCI Group, Inc. is the controller of your personal information for purposes of European data protection legislation. You can contact our Data Protection Officer at hello@triumphHQ.com.
Lawful Basis for Data Processing
We will only collect, store, and process your personal information where a lawful basis for such processing exists, which will typically fall under one of the following scenarios:
(2) Processing is necessary for the performance of a contract to which you, the Data Subject, are party;
(3) Processing is necessary for compliance with a legal obligation to which RCCI Group, Inc as a Controller is subject;
(4) Processing is necessary for the purposes of the legitimate interests pursued by us as the Controller, or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you, the Data Subject, which require protection of your personal information.
Use for new purposes
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Information) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
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:
- Opt-out. Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.
- 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.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation.
This Policy was last revised: May 25, 2018.