Privacy Policy

TRIONAID ASSOCIATES, INC. PRIVACY POLICY 

Last Updated: March 11, 2021 

The following explains what personal data is collected by Trionaid Associates, Inc.  (“Trionaid”) and how it is used. This includes information provided on a Trionaid Website  (“Website”), and information collected from third-parties and other sources associated  with Trionaid’s services such as employment, tenant, or occupational health screening. 

The use of Trionaid Websites indicates your agreement to Trionaid’s privacy policy.  Trionaid may revise this online privacy policy from time to time. If Trionaid makes any  material changes, Trionaid will notify you by posting a prominent announcement on this  Website. If Trionaid is going to use your personally identifiable information (“PII”) in a  manner different from that stated at the time of collection, Trionaid will notify you via  email if an email address has been provided and is available. You will have a choice as  to whether or not to allow Trionaid to use your information in such a different manner. 

PRIVACY VISION 

Trionaid is committed to the responsible use of information and protecting individual  privacy rights. Trionaid strives to provide services to mitigate risk, facilitate more  informed decisions, and make the world safer, in ways that protect consumer privacy. 

Trionaid aspires to protect consumer privacy through the design of its processes, by  credentialing, monitoring, and/or auditing its clients as appropriate, and through other  information security safeguards. Trionaid also strives to promote transparency through  appropriate opportunities for consumer choice, access, and correction with respect to  personal information about the consumer. 

DATA PROTECTION ADVOCATE 

The Trionaid Data Protection Advocate for the United States and globally is John Ryan. 

To request information or receive help with data protection issues, contact Trionaid’s  Data Protection Advocate at [email protected] 

Direct: +1-732-998-8406 

TRIONAID WEBSITE 

Please carefully read Trionaid’s privacy policy to understand how Trionaid will treat the  information you provide while visiting our Websites. As previously stated, this policy  may change from time to time. Please check the policy each time you use a Trionaid Website for the most current information. This policy only applies to Trionaid and its  affiliated entities. Trionaid’s Websites are not intended for children and Trionaid does  not knowingly collect any information about children. Nevertheless, Trionaid is  committed to complying with applicable laws and requirements, such as the United  States’ Children’s Online Privacy Protection Act (“COPPA”).

Trionaid also applies this privacy policy in the offline context in those limited cases  where Trionaid requires a consumer to provide his/her PII in order for the consumer to  order an information product by mail or telephone. 

Trionaid offers clients a comprehensive portfolio of products, services and tools to help  them make informed decisions in a timely manner. Trionaid recognizes that it has an obligation to protect the privacy and confidentiality of PII that it may obtain about  individuals through Trionaid’s Website. Safeguarding the privacy of information Trionaid may receive on its Websites is a top priority for Trionaid, its clients and consumers. 

HOW TRIONAID COLLECTS AND USE INFORMATION ON IT’S WEBSITES 

Trionaid follows the below privacy principles when you visit its Website. In general, you  can visit a Trionaid Website on the World Wide Web without telling Trionaid who you  are or revealing any information about yourself. Trionaid Web servers automatically  collect the domain names, not the e-mail addresses, of visitors. This information is used  to measure the number of visits, average time spent on the site, pages viewed and  similar information. Trionaid uses this information to measure the use of its Website and  to develop ideas to improve the content of its Website. 

PII 

This Website only collects PII from you if you choose to provide this information to  Trionaid. PII collected with your consent may include name, mailing address, e-mail  address, telephone number, date of birth, credit card number, social security number,  driver’s license number, user name and password, any response you provide to survey  questions, information relating to any orders you place, or any inquires you may make  through our web site. Also, Trionaid may request this type of information if you place an  order by mail or telephone. 

COOKIES 

“Cookies” are small pieces of information that are stored by your browser on your  computer’s hard drive. This site uses first and third-party cookies, however personally  identifiable information is not collected through the use of cookies. Cookies allow  Trionaid to store your User ID during your visit to keep track of reports you have ordered  or any updates to those reports. Cookies also help Trionaid detects potential fraud or  misuse of its system. 

While most browsers are set to accept cookies by default, you can set yours to refuse  cookies or to alert you before accepting them. Your browser manufacturer has  information on changing the default setting for your specific browser. However, be  aware that if you do not accept cookies from our Websites, you will not be able to use  some of the features of the Websites, such as those for ordering reports. 

NON-PERSONALLY-IDENTIFIABLE INFORMATION 

Trionaid’s Website also collects non-personally-identifiable information. For example, as  you browse this Website, Trionaid may collect information about your visit, but not about  you personally. Via web server logs, for example, Trionaid may monitor statistics such 

as: the number of people that visit its Website, which page(s) are visited on its Website,  from which domain visitors come (e.g., google.com, msn.com, etc.), and which  browsers people use to visit this Website (e.g., Google Chrome, Microsoft Internet  Explorer, etc.). This Website may use an outsourcing program to assist Trionaid in  analyzing this data to better tailor Trionaid’s Website. 

INFORMATION USE AND CONSUMER CHOICE 

The information collected by our Websites is used only for responding to your inquiries  and otherwise corresponding with you, for processing transactions you request,  maintaining your account (if you have one), and for the administration, review and/or  improving the content of Trionaid Websites. Trionaid does not share, sell, rent or trade  PII with third-parties for their promotional/marketing purposes. 

Trionaid may contact you in response to your comments or inquiries, as part of the  maintenance of your account with us (if you have one), or in order to complete a  transaction that you requested. 

Trionaid may also contact you to inform you of other products or services Trionaid believes may be of interest to you, but Trionaid always offer you an opportunity to opt  not to receive such communications. 

If you decide that you do not want to receive further e-mails regarding your inquiry from  Trionaid, you can e-mail Trionaid’s Data Privacy Office at  

[email protected] with a request that Trionaid does not continue to e-mail  you. Trionaid does not use outside data sources to enrich marketing data obtained  online. 

Trionaid website users have the option to request that Trionaid not use information  previously provided, correct information previously provided, or remove information  previously provided to Trionaid. Individuals who would like to correct or suppress  information provided to Trionaid should contact the Trionaid Consumer Advocacy Group  at [email protected]. The inquiries should include the individual’s name,  address, and other relevant contact information (phone number, email address), as well  as the nature of the request. Except as required by law, Trionaid is free to deny such  requests. If Trionaid decides to grant such a request, it will use all reasonable efforts to  honor such requests as soon as practicable. 

ONWARD TRANSFER 

Trionaid may disclose information you provide to Trionaid to third-parties in order to  complete a transaction that you requested. For example, it may be necessary to  disclose information you provide about yourself or third-parties in order to obtain the  information product you requested. Trionaid may engage third-parties in processing  services requested by customers, such as screening for employment, tenant, and  occupational health. Trionaid enters into service agreements with these third-parties  and requires that the companies acting on Trionaid’s behalf abide by Trionaid privacy  policy and institute safeguards to protect the confidentiality of your information.

Finally, please note that Trionaid may disclose personal information when required by  law or in the good faith belief that such action is necessary in order to conform with the  law or to comply with a legal process. 

ACCESS AND CORRECTION 

As an information service company, Trionaid understands the importance of  comprehensive data. Trionaid will provide you (whether you are a consumer or a client)  with access to PII you provide through our Websites for as long as Trionaid maintains that information in a readily accessible format. Similarly, Trionaid permits and  encourages you to correct inaccuracies in the information submitted to Trionaid through  this Website. 

If you wish to access information held on you by Trionaid or request the correction of  information you feel is incomprehensive, please use the mechanisms provided by the  Website, or send an e-mail to [email protected] The access and correction  provisions of this online privacy policy only apply to PII collected from you through  Trionaid Websites. Individuals that are interested in information about how to access  and/or request the correction of personal information Trionaid maintains about them for  potential inclusion in information products and services can contact us directly. 

SECURITY

Trionaid takes steps to protect against the loss, misuse, or unauthorized alteration of PII  collected through this Website and otherwise subject to this policy. Trionaid recognizes  the importance of security for all PII collected on its Website. Once Trionaid receives  PII, Trionaid takes steps to protect its security on its systems. In the event Trionaid requests or transmits sensitive information, such as credit card information or Social  Security Numbers through this Website, Trionaid uses industry standard, secure socket  layer (SSL) encryption. 

Trionaid limits access to PII to those employees or service providers who need access  in order to carry out their job responsibilities. 

When Trionaid disposes of PII collected through our Websites, Trionaid uses  procedures to dispose of personal information by means such as shredding documents  and erasure of electronic media that information cannot be practicably read or  reconstructed. 

HOW TRIONAID USES AND COLLECTS DATA IN IT’S BUSINESSES

A number of services offered by Trionaid are Consumer Reports (“Consumer Reports”),  as the term is defined under the federal Fair Credit Reporting Act (“FCRA”), and when  providing Consumer Reports to its Clients, Trionaid acts as a Consumer Reporting  Agency (“CRA”) as the term is defined under the FCRA, operating in accordance with  the requirements of the FCRA. The FCRA establishes the following principles for all  CRAs:

Privacy: Information about you may only be furnished to third-parties that have a  permissible purpose to request such information. In general, these deal with credit,  employment, insurance, rental or banking transactions initiated by you, or where the  object is to make a firm offer to you. CRAs must credential their clients to make certain  that they have a permissible purpose to receive the requested information. 

Access: Consumers may receive a copy of information the CRA maintains about them.  Such reports can be obtained nationally free of charge once per 12 months, twice in  some states, or for a reasonable fee for additional disclosures. Please contact Trionaid at [email protected] or call 1-732-998-8406 if you need more information. 

Accuracy: CRAs must follow reasonable procedures to assure accuracy of the  information they maintain and/or furnish. When you obtain a copy of your information,  you have a right to dispute and have the information reinvestigated and corrected in the  CRAs database. 

Fairness: Information is obtained from various sources including public records sources.  However, certain information over a specified time period may not be reported. 

Accountability: The Federal Trade Commission is in charge with overseeing the  operations of CRAs that provide consumer reports for employment and residential  screening purposes and enforcing the FCRA requirements. 

When Trionaid provides Consumer Reports on U.S. residents, it is subject to the FCRA  and operates within FCRA framework. If you would like to obtain a report about the  information Trionaid maintains about you, please contact us directly. 

For credit reports from the credit bureaus, please  

visit: https://www.annualcreditreport.com/cra/index.jsp. 

Privacy Notice: Preparation and Processing of Investigative Consumer Reports This notice is provided to California residents. Under California law, an “investigative  consumer report” is a consumer report containing information on a consumer’s  character, general reputation, personal characteristics, or mode of living. Trionaid may  provide investigative consumer reports about individuals and in such case, it provides  them to business for employment screening, resident screening, and similar purposes. 

Personal Information Disclosure: United States or Overseas 

In connection with its preparation and processing of consumer reports and investigative  consumer reports, Trionaid may transfer personal information about you to Trionaid authorized service providers and affiliates outside the United States and its territories. In  such case, the transfer will be conducted in accordance with all applicable laws and  regulations. 

To obtain additional information about the privacy practices and policies of Trionaid in  connection with its preparation and processing of consumer reports, please 

contact: [email protected]. For additional information about privacy or  consumer reporting, visit the following websites: 

California Office of Privacy Protection: www.privacy.ca.gov 

Consumer Data Industry Association: www.cdiaonline.org 

Consumer Financial Protection Bureau: www.consumerfinance.gov Equifax: www.equifax.com 

Experian: www.experian.com/consumer/credit_education.html 

Federal Trade Commission: www.ftc.gov 

TransUnion: www.transunion.com 

INTERNATIONAL COLLECTION & CROSS-BORDER TRANSFER OF PERSONAL  INFORMATION 

Trionaid may transfer your personally identifiable information to other countries outside  of your home country, including to the United States (“U.S.”), by whatever means is  determined to be appropriate in order to perform a background check that you  authorized. Your information may also be processed and stored in other countries  where Trionaid’s service providers are located. Your information may be subject to U.S.  or other laws for disclosure and may be accessible to foreign law enforcement, national  security agencies, or courts. Note that the laws regarding personal information in some  of the jurisdictions involved may be different or less stringent than the laws of the  country in which you reside. Please be aware that Trionaid may be required to disclose  an individual’s personal information in response to a lawful request by public authorities,  including to meet national security or law enforcement requirements. 

1. Notice 

The scope of this Notice covers consumer report data that Trionaid has obtained on  behalf of employers and other businesses by manually or electronically contacting the  appropriate sources of the data (court records, references, licensing bureaus, etc.).  Trionaid also performs services related to corporate litigation and investigative services  as requested by Trionaid’s clients. 

Information about how Trionaid collects and uses EU, UK, and Swiss Personal Data  also follows below. 

Trionaid gathers consumer and other data which it provides to employers or their agents  (such as recruiters or staffing firms) for use in making employment-related decisions,  such as who to hire, retain, promote, or re-assign. Trionaid also gathers consumer and  other data which it provides to entities including landlords. Note that Trionaid does not  engage in any of the decision-making activities for any data subjects. Below is an  illustrative list of common ways in which employers use the data provided by this  service: 

∙ Performance of applicant and employee background checks 

∙ Verification of the credentials of job applicants and current employees

∙ Investigation into a suspicion of work-related misconduct or wrongdoing ∙ Investigation into matters of employee compliance with employer policies, or ∙ Investigation into matters of employee compliance with Federal, State, or local  laws and regulations 

Trionaid customers who are processing EU, UK, and Swiss Personal Data are  contractually required to provide a legally compliant Notice to their data subjects, prior  to submitting screening requests to Trionaid. 

More information regarding the nature and scope of Trionaid’s data processing is  available by contacting Trionaid in writing or by e-mail at the addresses listed on the  Contact Us page or by writing to the contact listed below. 

2. Choice 

The information obtained by Trionaid is only used for the original purpose to which the  data subject has consented, unless a new consent is obtained. A data subject may  request Trionaid stop the processing of data they had previously consented to by  contacting Trionaid directly. In such case, Trionaid will make every attempt to stop the  processing as quickly as possible. 

3. Accountability for Onward Transfer 

Trionaid may engage agents to perform functions on our behalf, in order to provide  services requested by customers or data subjects. Trionaid enters into service  agreements with these agents and requires that the companies acting on Trionaid’s  behalf abide by the Trionaid privacy policy and institute safeguards to protect the  confidentiality of your information. In cases of onward transfer to agents of data of EU,  UK, or Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy  Shield, Trionaid is potentially liable. 

Trionaid may disclose EU, UK, or Swiss Personal Data to clients, or their agents who  enter into a written agreement with Trionaid, in which the client agrees to comply with  the FCRA, if applicable. These Trionaid customers are contractually required to provide  a legally compliant Notice to their data subjects prior to submitting screening requests to  Trionaid. 

4. Security 

Trionaid takes reasonable procedures to protect EU, UK, and Swiss Personal Data from  loss, misuse and unauthorized access, disclosure, alteration and destruction. 

5. Data Integrity and Purpose Limitation 

The information obtained by Trionaid is only used for the original purpose to which the  data subject has consented or the legal grounds for processing allow this access,  unless a new consent is obtained or another legal ground for processing has been met.  Trionaid processes EU, UK, and Swiss Personal Data in ways that are compatible with  the purposes for which it has been collected (as identified in the Notice section above)  or subsequently authorized by the individual. To the extent necessary for those 

purposes, Trionaid takes reasonable steps to ensure that EU, UK, and Swiss Personal  Data collected are comprehensive, complete, current, and reliable for their intended  use. 

6. Access 

A data subject, whose information is or was processed by Trionaid under the Privacy  Shield, has the right to access all personal data collected and maintained about him or  her by contacting us directly. Trionaid affords the data subject a reasonable opportunity  to correct, amend, or delete information that is incomprehensive or incomplete, except  where the burden or expense of providing access would be disproportionate to the risks  to the individual’s privacy, or where the rights of persons other than the individual would  be violated. In cases where the information is subject to the Fair Credit Reporting Act  (“FCRA”), Trionaid complies with the FCRA’s requirements regarding access and  correction rights of data subject. 

Trionaid reserves the right to engage in reasonable efforts to confirm the identity of the  individual requesting their personal data. This is done to ensure the information is  provided only to the subject of the data. If we are unable to provide the individual with  access to his or her EU, UK, or Swiss Personal Data or to correct the data, we will notify  the individual. To request information relating to his or her personal data, or to request  processing be halted, a data subject may contact Trionaid at: 

John Ryan 

United States 

+1-732-998-8406 

7. Recourse, Enforcement, and Liability 

Trionaid is subject to the investigatory and enforcement powers of the Federal Trade  Commission (FTC). 

In compliance with the US-E.U. and Swiss-U.S. Privacy Shield Principles, Trionaid commits to resolve complaints about your privacy and our collection or use of your  personal information. European Union, United Kingdom, or Swiss individuals with  inquiries or complaints regarding this privacy policy should first contact Trionaid at: 

John Ryan 

United States 

732-998-8406 

Trionaid has further committed to refer unresolved privacy complaints under the EU U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution  mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better  Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if  your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU privacy-shield/for-eu-consumers for more information and to file a complaint. Trionaid

will cooperate with the EU Data Protection Authorities and the Swiss Federal Data  Protection and Information Commissioner and will comply with the advice of such  authorities with respect to Human Resources data transferred from the European  Economic Area and Switzerland in context of the employment relationship. 

Please note that if your complaint is not resolved through these channels, under limited  circumstances, a binding arbitration option may be available before a Privacy Shield  Panel.