Privacy Policy

Privacy Policy. Last Updated April 13, 2021. (“Policy”)

This Privacy Policy describes the Company’s policies and procedures on the collection, use and disclosure of Your information when You use the Site and tells You about Your privacy rights and how the law protects You.  The Company uses Your Personal Data to provide and improve the Site. By using the Site, You agree to the collection and use of information in accordance with this Privacy Policy.

Defined Terms.  When capitalized, the following terms have the meanings given to them below.

“Company” refers to Troo Co., 234 10th Avenue #20626, New York, NY 10011.

“Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

“Country” refers to the United States of America.

“Data Privacy Trust” means a separate legal entity formed for the purpose of holding and protecting Personal Data for the benefit of the individuals to whom the Personal Data relates.

“Device” means any device that can access the Site such as a computer, a cellphone or a digital tablet.

“Personal Data” is any information that relates to an identified or identifiable individual.

“Site” refers to this website, accessible from https://www.troo.co.

“Site Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Site, to provide the Site on behalf of the Company, to perform services related to the Site or to assist the Company in analyzing how the Site is used.

“Usage Data” refers to data collected automatically, either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit).

“We” means the Company, Troo Co.

“You” or “Your” means the individual accessing or using the Site, or the company, or other legal entity on behalf of which such individual is accessing or using the Site, as applicable.

Collecting and Using Your Personal Data

Types of Data Being Collected.  We are collecting Personal Data in the form of your email address, if you furnish it.  We also receive Usage Data.

Personal Data.  While using the Site, You may provide us with your first name and email address.

Usage Data. Usage Data is collected automatically when using the Site.  Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the Site 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 the Site by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit the Site or when You access the Site by or through a mobile device.

Tracking Technologies and Cookies.   We are not using Cookies on this Site.

The Company may use Personal Data for the following purposes:

To Invite You to Download the App: If You give us Your email address, we plan to use it to send you an invite when our App is available, and for no other purpose.  Once you begin using the App, it will have its own Privacy Policy and Terms of Service which you can read and approve before using the App.  

Retention of Your Personal Data.  The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.  The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Site, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data.   Your information, including Personal Data, is processed where the Site Provider’s facilities are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.  Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.  The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data.   We will not disclose Your Personal Data except to a Data Privacy Trust, to Law Enforcement, or when necessary to meet other legal requirements as described below.

Data Privacy Trust.  The Company is in the process of forming a Data Privacy Trust to protect Your Personal Data.  We will provide notice before Your Personal Data is transferred to a Data Privacy Trust.  

Law Enforcement.   Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements.  The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation.

Protect and defend the rights or property of the Company.

Prevent or investigate possible wrongdoing in connection with the Site.

Protect the personal safety of Users of the Site or the public.

Protect against legal liability.

Security of Your Personal Data.  The security of Your Personal Data is important, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy. the Site does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.  If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Changes to this Privacy Policy.  We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.  We will let You know via email and/or a prominent notice on the Site, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.  You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us.  If you have any questions about this Privacy Policy, or if you would like us to delete Your Personal Information, You can contact us by email at contact@troo.co

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