Privacy Policy 2018-05-28T14:00:06+00:00

Privacy Policy

The Triumph app and its accompanying services are designed to maintain the private nature of your personal journal. This privacy policy outlines what information is collected and stored by Triumph.

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

In the course of using the Sites and Services, we collect both personal and anonymous information. “Personal Information” in this Privacy Policy refers to information that allows someone to identify or contact you. Examples of Personal Information include your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing information. “Anonymous Information” is information not associated with or inherently linked to your Personal Information. Anonymous Information does not enable identification of or contact with individual persons.

Personal Information

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.

Anonymous Information

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.

Log Files: As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Information.

Cookies: Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.

We use Google Analytics to help analyze how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics only to improve our Site and Services. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other Personal Information. We do not combine the information generated through the use of Google Analytics with your Personal Information. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Site, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

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:

We may combine any of the foregoing Anonymous Information with your Personal Information, in which case we will consider it to be Personal Information under this Privacy Policy.

How We Disclose Information

Personal 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;
  • To a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy;
  • 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.
  • In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.
  • 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.

If you publish certain of your content, it will be made publicly available. This means that anyone may see it on the Site along with certain of your related profile information. Please be thoughtful about the entries you publish. In addition, our Apps and Services may enable you to post content to SNSs (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

Anonymous Information

We reserve the right to disclose Anonymous Information publicly without restriction.

Controlling Your Information

You can review and/or change certain of your Personal Information by logging into the Site or the App and accessing your account. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us.

Upon your request, we will close your Account. We may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law.

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

This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the Sites and Services. If you disclose information to others, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

The Services may contain content or links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Services and go to another site. During this process, another entity may collect Personal Information or Anonymous Information from you. The Site may also contain links to other websites controlled by us but which operates under different privacy policies. Please review the privacy policy of any new site you visit.

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.

A Note to Users Outside of the United States. If you are a non U.S. user of the App or Services, by visiting the Site and/or providing us with information, you acknowledge and agree that your Personal Information may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your information, you consent to such transfer.

Changes to this Privacy Policy

This Privacy Policy is subject to revision from time to time on a going-forward basis. We will post any revised version of the Privacy Policy on this page. If we make any material changes to it, we will also send you notice to the last email address you have provided to us, if any. Continued use of our Services following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Questions about the Privacy Policy

If you have any questions or concerns or complaints about our Privacy Policy or our information collection or processing practices, or if you want to report any security violations to us, please contact us at hello@triumphhq.com.

ADDITIONAL INFORMATION FOR EUROPEAN UNION USERS

Personal Information
References to “Personal Information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

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:
(1) You, the Data Subject, have given consent to the processing of your personal information for one or more specific purposes, for example by consenting to terms and conditions on our website, and consenting to the terms of this privacy policy;
(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 may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.

Retention
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.

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:

  • 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.

You can submit these requests by email to hello@triumphHQ.com. 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 response to your requests regarding your personal information, you may contact us as described in Section 13 of our Privacy Policy or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

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.

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