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.
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 INFO@TRIONAIDASSOCIATES.COM
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.
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.
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
INFO@TRIONAIDASSOCIATES.COM 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 INFO@TRIONAIDASSOCIATES.COM. 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.
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.
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 INFO@TRIONAIDASSOCIATES.COM 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
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: INFOR@TRIONAIDASSOCIATES.COM. 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
FEDERAL TRADE COMMISSION: WWW.FTC.GOV
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.
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.
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.
- ACCOUNTABILITY FOR ONWARD TRANSFER
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.
TRIONAID TAKES REASONABLE PROCEDURES TO PROTECT EU, UK, AND SWISS PERSONAL DATA FROM LOSS, MISUSE AND UNAUTHORIZED ACCESS, DISCLOSURE, ALTERATION AND DESTRUCTION.
- 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.
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:
- RECOURSE, ENFORCEMENT, AND LIABILITY
TRIONAID IS SUBJECT TO THE INVESTIGATORY AND ENFORCEMENT POWERS OF THE FEDERAL TRADE COMMISSION (FTC).
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.
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.
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 Info@Trionaidassociates.com
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.
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.
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
Info@Trionaidassociates.com 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 Info@Trionaidassociates.com. 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.
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.
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 Info@trionaidassociates.com 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
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: firstname.lastname@example.org. 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
Federal Trade Commission: www.ftc.gov
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.
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.
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 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.
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.
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:
7. Recourse, Enforcement, and Liability
Trionaid is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
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.