Privacy Notice

Introduction

Trinetix Inc., a Wyoming corporation, with its principal place of business at 30 N Gould St STE 4722, Sheridan, WY 82801, USA and its affiliated companies (herein together referred to as “Trinetix”, “we”, “us”, “our”) is committed to respecting and safeguarding your privacy. We understand the importance of protecting your personal information and strive to ensure your privacy rights are fully upheld.

Our top priority is to protect the personal information entrusted to us and to process it only in ways that meet your expectations, as outlined in this Privacy Notice. This document is designed to inform you about how we collect, use, share, and protect your personal information (hereinafter referred to as "personal data"), as well as to inform you of your rights under applicable data protection laws.

Trinetix acts as the Data Controller of your personal data. This means that we are legally responsible for determining the purposes for which, and the manner in which, your personal data is processed. We are committed to processing your personal data lawfully, fairly, and transparently, as required by data protection regulations, including the General Data Protection Regulation (GDPR) in the EU, the California Consumer Privacy Act (CCPA) in the US, and relevant privacy laws in other jurisdictions where we operate.

By using this website, you acknowledge and agree to this Privacy Notice, which applies to all interactions with Trinetix, whether online or offline. In addition, this Privacy Notice may also apply in situations where we make specific reference to it, such as:

• When we receive your personal data from third parties and are legally required to notify you.
• When we first communicate with you via email or other means.
• During our events, or those organized by our partners, where we process your personal data.

What personal data we collect

We may collect personal data through various channels, including but not limited to direct communications, your interactions with our website, and publicly available sources. The types of personal data we collect will depend on your relationship with us, such as whether you are a job applicant, client, contractor, vendor, or partner.

Candidates

If you are a candidate applying for a position at Trinetix, we may collect and process the following personal data, either provided directly by you or obtained from public sources (such as LinkedIn): 

• Name
• Phone number
• Email address
• Location
• Information provided in your CV or LinkedIn profile
• Communications between you and Trinetix

We process this data for recruitment purposes, including assessing your suitability for the role, conducting interviews, and facilitating the onboarding process if you are hired. This processing is carried out based on our legitimate business interest in hiring the best talent, or based on your consent, when you provide your data through direct communication or engagement at events. We ensure that all recruitment-related data processing adheres to the principles of fairness, transparency, accuracy, and confidentiality, providing candidates with control over their data.

Clients and Potential Clients

If you are a contact person at a company that is an existing or potential client, we may collect and process the following personal data, either directly provided by you or obtained from public sources or referals:

• Name
• Phone number
• Email address
• Location
• LinkedIn profile information
• Role or position
• Employment history
• Communications between you and Trinetix

We process this data to facilitate our business relationships, including proactive client acquisition, maintaining effective communication on projects, organizing business trips and visits, and addressing any issues pertinent to successful cooperation. This processing is necessary for Trinetix’s business operations, growth, and development, and is grounded in our legitimate interests in maintaining strong relationships with clients, as well as the performance of contracts when data is used to manage communications throughout the contract lifecycle.

Vendors and Suppliers

If you are a contact person at a company that is an existing or potential vendor, supplier or partner, we may collect and process the following personal data, either provided by you or from public sources (such as LinkedIn or your company website):

• Name
• Phone number
• Email address
• LinkedIn profile information
• Role or position
• Communications between you and Trinetix

We process this data for the primary purpose of procuring goods and services necessary for our operations or for doing business together. This processing is essential for contract performance, ensuring that we can conduct business effectively and efficiently. We rely on our legitimate business interests in managing resources and maintaining strong supplier and partner relationships.

Please note that we DO NOT collect personal data that is, by its nature, particularly sensitive. Sensitive personal data refers to information such as genetic data, biometric data, data revealing racial or ethnic origin, information about political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, trade union membership or other sensitive information

Purpose of Collecting your Personal Data

At Trinetix, we collect and process your personal data for a variety of purposes. These purposes are tailored to meet our business needs and to ensure that we fulfill our obligations to you in a lawful and transparent manner.

First, we use your data to communicate with you about our products, services, and relevant opportunities. This includes informing you about services we or our partners offer, as well as vacancies that might interest you. We also use your data to respond to inquiries and provide updates regarding any changes that could affect you.

Your personal data helps us improve the user experience on our website by analyzing how visitors interact with our content, allowing us to make enhancements. Additionally, we use your information to refine our customer service, ensuring that we address your concerns promptly and effectively.

For clients and vendors, we process data to manage and administer contractual relationships, ensuring that obligations are met and communications are clear throughout the duration of our collaboration.

We also process personal data to comply with legal obligations, such as tax or regulatory requirements, and to protect the vital interests of our users, partners, or the public, particularly in emergency situations.

Your personal data will be added to our internal secured CRM system or other internal secured databases.

Lawful Basis for Processing

We rely on several lawful bases for processing personal data depending on the nature of the data and the purpose of processing.

With your explicit consent, we may use automated decision-making tools or software, which may include profiling based on aggregated data. This helps us to offer personalized services or advertising materials. You have the right to object to such processing, and we will provide you with further details should automated decision-making be used.

Marketing Communications

Where you have opted in to receive marketing communications from us, we may use your personal data to send you information about our services, job opportunities, exclusive offers, promotions, and new features. These communications may be delivered via email or other electronic means.

In all instances, our use of your personal data for marketing purposes is based on your consent. You retain full control over your preferences, and each marketing communication we send includes an option for you to opt-out or unsubscribe from future messages. We will respect your decision and promptly remove you from our marketing lists if you choose to withdraw your consent.

Rest assured, we do not engage in intrusive marketing practices, and we aim to ensure that any marketing communications you receive are relevant and beneficial to you. Your consent can be withdrawn at any time without affecting the lawfulness of any processing based on your consent before its withdrawal.

Safety of Your Personal Data

We are fully committed to ensuring the security of your personal data. To protect your data from unauthorized access, alteration, disclosure, or destruction, we have implemented comprehensive organizational, technical, and security measures. These include:

• Data encryption during transmission and at rest.
• Access controls to ensure only authorized personnel can access your data.
• Regular security audits to identify and mitigate potential risks.
• Secure data storage systems that comply with industry standards and legal requirements.

Your personal data will be stored only for as long as necessary to fulfill the specific purposes for which it was collected, or to comply with applicable legal obligations, resolve disputes, or enforce our agreements. In the event that you withdraw your consent, we may still retain certain personal data as required by law or for legitimate purposes, such as legal compliance or dispute resolution.

We are committed to maintaining these security measures and continuously reviewing and enhancing our practices to stay ahead of evolving security risks.

Data transfer

As a global company, it is sometimes necessary for us to transfer your personal data to other countries where Trinetix affiliate companies, clients, or service providers are located, including countries outside the European Economic Area (EEA), such as the United States, Ukraine, and Argentina.

In all cases, we take measures to ensure that your data is protected in accordance with applicable data protection laws. These measures may include:

• Adequacy decisions issued by the European Commission, confirming that certain non-EEA countries provide an adequate level of data protection.
• Standard Contractual Clauses (SCCs) or other legally-approved mechanisms that contractually oblige our third-party partners to protect your personal data according to the same standards required in the EEA.
• Binding Corporate Rules (BCRs) or other approved transfer mechanisms where appropriate.

In cases where none of these mechanisms are available, we will not transfer your personal data to third countries unless an alternative lawful basis is available, and we have ensured that your rights and freedoms are adequately protected.

By interacting with us, you consent to the transfer of your personal data to countries where Trinetix, its affiliates, or service providers operate, recognizing that such transfers are necessary to fulfill the purposes described in this Privacy Notice.

Sharing of your personal data

We may share your personal data with a range of recipients to facilitate the delivery of our services and to support the operations of our business. These recipients include:

• Affiliated Companies. We may share your data with companies within our corporate group to provide essential business services, such as storage, security, research and development, analytics, and customer support.
• Professional Advisors. This includes legal, financial, and other professional advisors who assist us in complying with regulatory obligations or provide specialized expertise.
• Third-Party Service Providers. We engage service providers to help us maintain and improve our business operations and website. These providers may offer services such as cloud hosting, content delivery, customer and technical support, recruitment and HR services, background checks, immigration services, insurance services, marketing, analytics, and event hosting. We only share your data with these providers to the extent necessary for them to deliver their services to us in compliance with applicable data protection laws.
• Partners and Contractors. We may share personal data with our partners and contractors to facilitate business activities, product delivery, or joint services.
• Team Members. Access to your personal data is granted to authorized team members who need such access to fulfill their responsibilities.

Additionally, we may disclose your personal data to law enforcement agencies, regulatory bodies, government authorities, courts, or other third parties where required by law. Such disclosures are necessary for compliance with legal obligations, to protect your vital interests or the vital interests of another individual, or where it is in the public interest.

We ensure that all third parties who process your data on our behalf are contractually obliged to provide an adequate level of protection in compliance with applicable privacy laws.

Children’s privacy

Our services and products are not designed for, nor intended to be used by, children. We do not knowingly collect or process personal data from children under the age of 13, or under the age of 16, depending on the jurisdiction within the European Union or other applicable regions.

If we become aware that we have inadvertently collected personal data from a child, we will promptly delete the information from our systems. If you are a parent or guardian and believe that your child’s personal data has been provided to us, please contact us using the details provided in the “Contact Information” section, and we will ensure the prompt removal of such data.

Information tracking

This website may automatically collect information about you in several ways, which includes tracking your activities through your IP address, computer settings, most-recently visited URL, operating system, date and time, your preferences and choices and saved options subject to your browser settings. This website uses your IP address to help diagnose problems with its server, and to administer the website.

Third Party Links

Our website may contain links to external websites operated by third parties. While we strive to include only trusted links, Trinetix is not responsible for the privacy practices or content of these third-party websites.

We strongly recommend that you review the privacy policies and terms of service for any third-party sites you visit, as their practices may differ from ours. Trinetix assumes no liability for the actions or policies of these external sites.

Changes to the Privacy Notice

We may update this Privacy Notice periodically to reflect changes in our data practices, legal requirements, or for other operational reasons. Any modifications to this Privacy Notice will be posted on our website, and the "last modified" date at the beginning of this document will be updated accordingly.

We encourage you to review this Privacy Notice regularly to stay informed about how we collect, use, and share your personal data. For significant changes that impact how your personal data is handled, we will make reasonable efforts to notify you directly via email (if we have your contact information) or through other appropriate communication channels.

By continuing to use our website after any changes to this Privacy Notice, you acknowledge and agree to the updated terms.

Cookie Policy

Our website uses cookies and similar technologies to enhance your browsing experience and to provide personalized services.

Cookies are small text files stored on your device when you visit our website. These files help us recognize your device during subsequent visits, enabling us to:

• Provide a personalized browsing experience.
• Improve the performance of our website.
• Analyze how visitors interact with the site and make improvements accordingly.

There are two types of cookies we use:

• Session Cookies. These are temporary cookies that are erased when you close your browser. They allow us to track your navigation during a single session.
• Persistent Cookies. These remain on your device until they expire or are deleted. They are used to remember your preferences for future visits.

For more details on how we use cookies and how you can manage or disable them, please refer to our Cookie Policy.

Remarketing

Cookies are also used to display remarketing advertisements, based upon the user’s previous visits to our website, across the internet.

Remarketing advertisements are displayed through the Google Display Advertising Network. Users may opt out of Google’s use of cookies at any time by visiting the Google Ads Preferences Manager.

Third-party services

We may use third-party analytics and tracking tools to gain insights into user behavior on our website. These tools help us:

• Measure traffic and user engagement.
• Analyze website usage trends.
• Understand the demographics and behaviors of our users.

Third-party analytics services, such as Google Analytics, may collect information such as your IP address, browser type, device information, and the pages you visit on our site. This data helps us improve the functionality and user experience of our website.

We also use retargeting cookies to serve personalized ads based on your browsing behavior. These cookies collect information about your online activities across various websites to display ads that align with your interests. The data collected is used solely for improving ad targeting and measuring the effectiveness of our marketing campaigns.

For more details on how these third-party services collect and process data, please review their respective privacy policies. You can also adjust your browser settings to limit the use of cookies or opt out of tracking altogether.

We currently use: LinkedIn Insight; Google Ads Remarketing code; Google Ads Conversion code; Google Tag Manager; Google Analytics; Global Site Tag.

Data Storage

We ensure that the personal data are not retained longer than necessary in relation to the purpose for which they are processed. In order to ensure compliance with this principle, we define the retention periods applicable to each processing operation. The following elements are considered when determining the retention period:

• legal obligations;
• recommendations of supervisory authorities;
• best practices;
• our operational needs

Different retention periods apply for different types of personal data. The criteria applied to determine the data retention period will depend on the legal requirements of specific jurisdictions. Following the end of the relevant retention period, we will delete or anonymize your personal data.

Your Privacy Rights

Your principal privacy rights include the right to be informed about collection and use of personal data, right to access your personal data, right to rectification, right to erasure, right to restrict processing, right to object to processing, right to data portability, right to complain to a supervisory authority and right to withdraw consent.

To exercise your rights, please contact us (see “Contact Information” section below). When you send us a request to exercise a right, you are asked to specify as far as possible the scope of the request, the type of right exercised, the personal data processing concerned, and any other useful element, in order to facilitate the examination of your request. In addition, in case of reasonable doubt, you may be asked to prove your identity.

We will do our best to answer to your requests as soon as possible or within a reasonable period taking into account the complexity of the request, but in case we are processing a large number of requests the answer may take us longer than you might expect.

If at any point you believe the information we process on you is incorrect or incomplete you can submit a request to see this information and even have it corrected, ported to you or deleted by contacting us.

At any time you may withdraw your consent or object to data processing by contacting us. In case you withdraw your consent, it will not affect the lawfulness of processing based on consent before its withdrawal.

Contact Information

If you have any questions regarding this Privacy Policy, please contact us directly:

• Name: Trinetix Inc.
• Postal address: 157 Archbishop Street, office 3.4, Valletta VLT 1440, Malta
• Email: legal@trinetix.com
• Data Protection Officer: Taras Lytovchenko, email: legal@trinetix.com

How To Complain

Please contact us if you have any query or concern about our use of your information (see below “Contact Information”).

For official legal escalation you have the right to lodge a formal complaint with official bodies.

Notice For California Residents

In addition to the abovementioned, if you are a resident of California, you are entitled to specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These laws provide you with greater transparency and control over the collection and use of your personal data. The following section outlines your rights and our obligations in relation to your personal data.

Your Rights Under the CCPA and CPRA

As a California resident, you have the following rights concerning your personal data:

1. Right to know what personal information we collect. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the sources from which that information was collected, and the purposes for which we collect it. Additionally, you can request details regarding the categories of third parties with whom we share your personal information.
2. Right to know with whom we share your personal information. You have the right to know whether we share your personal information with any third parties. We may share your personal information with trusted service providers who assist us in running our business, such as cloud hosting, analytics, and other essential operational services.
3. Right to know whether your personal information is sold or shared for cross-context behavioral advertising. Under the CCPA and CPRA, you have the right to know whether your personal information has been sold or shared with third parties. We do not sell your personal information or share it for cross-context behavioral advertising purposes, and therefore, we do not offer an “opt-out” mechanism for the sale of data.
4. Right to access and receive personal information. You have the right to request access to the specific pieces of personal information we have collected about you in the preceding 12 months. Upon receiving a verifiable request, we will provide you with a copy of the information in a readily usable format, as required by law.
5. Right to request deletion of your personal data. You have the right to request the deletion of your personal information from our systems, subject to certain exceptions. For example, we may retain your data if it is necessary to complete a transaction, detect security incidents, protect against fraud, or comply with legal obligations.
6. Right to correct inaccurate information. You have the right to request that we correct any inaccurate personal information we hold about you. Once we verify the accuracy of the request, we will correct your information as needed.
7. Right to limit the use of sensitive personal information. Under the CPRA, California residents have the right to limit the use and disclosure of sensitive personal information. You can instruct us not to use your sensitive personal data for purposes beyond those authorized by law, such as providing core services.
8. Right to non-discrimination. We will not discriminate against you for exercising any of your rights under the CCPA or CPRA. This means we will not deny you services, charge different prices, or provide a different quality of service based on your exercise of these privacy rights.

Submitting a Verifiable Consumer Request

To exercise any of the rights described above, please submit a verifiable consumer request by contacting us through the “Contact Information” section below. The request must:

• Provide sufficient information that allows us to verify you are the person about whom we have collected personal information or an authorized representative.
• Clearly describe your request, including which specific rights you wish to exercise, to enable us to understand, evaluate, and respond accordingly.

Please note that we may not respond to your request if we cannot verify your identity or authority to make the request. All requests must be labeled as “California Resident Request” in the email subject line or clearly marked as such when submitted through other communication channels.

Verification Process

Upon receiving your request, we will take steps to verify your identity. This may include asking for additional information to confirm that the requestor is the individual whose personal data we have collected or their authorized representative. We will use the personal information provided in a verifiable consumer request solely to verify the requestor’s identity or authority to make the request.

Response Timeline

We will acknowledge your request within 10 business days and aim to respond to verifiable consumer requests within 45 days from the date of receipt. If we require more time (up to an additional 45 days), we will inform you of the reason for the delay and the extension period in writing.

Responses will be delivered electronically, unless you request another format. We will provide the requested information free of charge unless your request is excessive, repetitive, or manifestly unfounded, in which case we may charge a reasonable fee or refuse to comply with your request.

Applicability of Other State Laws

While this section pertains to California residents under the CCPA and CPRA, we are committed to complying with privacy regulations in other US states. If, for example, you are a resident of another state with applicable data protection laws (such as for example Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia), please reach out to us to exercise your rights under those state-specific privacy laws.

For more information about your rights or to submit a request, please see our “Contact Information” section.