Privacy Policy

Effective date: 06/30/2022

Trancy Technologies Ltd. and its affiliates (“Trancy,” “we,” “us,” or “our”) have prepared this Privacy Policy to explain what Personal Data (defined below) we collect, how we use and share that data,and your choices concerning our data practices. Through our software, we allow individuals (“Users” or “you”) to control your tools in a simple, fast and delightful way. The App and https://trancy.org/ (the “Site”) are referred to collectively in this Privacy Policy as the “Service”.

This Privacy Policy is incorporated into and forms part of our Terms of Service.

Before using the Service or submitting any Personal Data to Trancy, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.

1. Google API Services User Data Policy

Trancy app use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Trancy does not share any user data with third-party tools, including AI models.

2. Personal data we collect

We collect the following categories of information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”):

Account Data: If you create an account, we will collect the information needed to authenticate your access to the Service, including your name and email address.

Financial Data: To the extent any features of the Service are available for a fee, we may collect the financial information necessary to process your payments, such as your payment card number and authentication details.

Communication Data: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing this information is optional to you.

Social Media Data: We have pages on social media sites like Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

3. How we use personal data

Under data protection law, we can only use personal data if we have a proper reason for doing so, for example:

• to comply with our legal and regulatory obligations;

• for the performance of our Terms of Service with you;

• for our legitimate interests or those of a third party; or

• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by your own rights and interests.

About AI Model Data Usage

• We will not use this personal information in our artificial intelligence (AI) training.

• We are simply using the capabilities of AI, without doing any training.

We use Personal Data for the following purposes:

• To process payments. Reason: For the performance of our Terms of Service with you

• To respond to your inquiries, comments, feedback, or questions. Reason: For the performance of our Terms of Service with you

• To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies. Reason: For the performance of our Terms of Service with you. Reason: For the performance of our Terms of Service with you

• To analyze how you interact with our Service. Reason: For our legitimate interests or those of a third party, ie to be as efficient as we can in our delivery of the Service to you

• To maintain and improve the content and functionality of the Service. Reason: For our legitimate interests or those of a third party, ie to enable us to improve our delivery of the Service to you

• To develop new products and services. Reason: For our legitimate interests or those of a third party, i.e. to enable us to improve our delivery of the Service to you

• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks. Reason: For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you to comply with our legal and regulatory obligations

• To comply with legal obligations and legal processes. Reason: To comply with our legal and regulatory obligations

• To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties. Reason: For our legitimate interests or those of a third party, i.e. to protect our commercial interests and assets

• To tell you about products or services we believe may be of interest to you. Reason: For our legitimate interests or those of a third party, i.e. to promote our business to you

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. We have a legitimate interest in processing your personal data for promotional purposes (see table above). This means we do not usually need your consent to send you promotional communications. However, where consent is needed (for example because you are based in the United Kingdom or European Union), we will ask for this consent separately and clearly. We will always treat your personal data with the utmost respect and never sell it with other organizations outside the Trancy’s group companies for marketing purposes. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. To the extent you create an account you can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, as applicable, other administrative matters, and to respond to your requests.

Sharing and disclosure of personal data

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.

• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

4. Update your information

If you have created an account, you can log in to your account or contact us if you need to change or correct your Personal Data.

5. Additional information for UK and EU users

The data controller responsible for your personal data is Trancy Technologies Ltd. which you can contact online or by writing to the address set out in the contact us section below.

Where your personal data is held

Your personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Sharing and disclosure of personal data’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept

We will not retain your personal data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Generally, we store data until it is no longer necessary to provide our services or until your account is deleted – whichever comes first.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

Transferring your personal data out of the EEA

To deliver Services to you, it is sometimes necessary for us to share your personal data outside the United Kingdom and European Economic Area (EEA), for example:

• with our offices outside the UK and EEA, including the United States of America;

• with your and our service providers located outside the UK and EEA;

• if you are based outside the UK and EEA.

These transfers are subject to special rules under European and UK data protection law.

These countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.

If you would like further information please contact us.

Your rights

You have the following rights, which you can exercise free of charge:

• Access: The right to be provided with a copy of your personal data

• Rectification: The right to require us to correct any mistakes in your personal data

• To be forgotten: The right to require us to delete your personal data—in certain situations

• Restriction of processing: The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data

• Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

• To object: The right to object:—at any time to your personal data being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.

• Not to be subject to automated individual decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under data protection laws.

If you would like to exercise any of those rights, please:

• contact us and

• let us have enough information to identify you [];

  (eg your full name, address)

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

• let us know what right you want to exercise and the information to which your request relates.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information. Data protection laws also gives you right to lodge a complaint with a supervisory authority, in particular in the United Kingdom or EU member state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: [phone].

6. Children

Our Service is not directed to children who are under the age of 16. Trancy does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Trancy through the Service please contact us and we will endeavor to delete that information from our databases.

7. Links to other websites

The Service may contain links to other websites not operated or controlled by Trancy, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

8. Security

You use the Service at your own risk. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Trancy via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

9. Your choices

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. If you have created an account, you can contact us to ask us to update or correct your Personal Data.

10. Changes to privacy policy

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

11. Contact us

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: [e-mail]