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    Latest Revision - Summary of Changes (April 30, 2017)

    We've updated our privacy policy to improve the clarity with respect to the data that we collect and why.  Here's a rundown of the changes.

    We've added clarity and specificity:

    • with regard to personal information we may collect when you use the Trov web or mobile apps;
    • relating to third parties, including but not limited to Affiliates, service providers, partners and law enforcement agencies, with whom personal data may be shared; and
    • relating to protections afforded our EU customers under the EU-U.S. Privacy Shield Framework

    -------------------------------------------

    Your privacy is very important to us and we handle your personal information with great care and discretion. We’ve developed this Privacy Policy which, together with our Cookies Policy explains to you how we collect, use, disclose, transfer and store your personal information (your “Personal Content”) when you use the Trōv Service (iOS application, Android application and website) and/or communicate with us. As the business environment changes and Trōv evolves, we may need to update this Privacy Policy. We’ll announce changes on our website, and we may also notify you by sending an email to you.


    If you have any questions or comments in relation to this Privacy Policy, please visit get.trov.help or contact: privacy@trov.com.

    What Personal Content Does Trōv Collect and Why?

    We collect and process the following data about you:

    • Information that you give us: This is information that we collect, for example, when you register with us, download the Trōv Service, use the Trōv Service, fill in forms via the Trōv Service, correspond with us (for example, by email or post), report a problem with the Trōv Service, submit a claim via the Trōv Service or make an in-app purchase;

    • Information we collect about you and your device: We automatically collect certain technical information about you when you use the Trōv Service including your device identifier and location, how you use the Trōv Service, language selection and preferences;

    • Information we receive from third parties: We collect information about you from third parties, such as insurance companies with whom we partner, business partners, analytics providers and any social media sites that you may use, such as Facebook, Twitter, YouTube and LinkedIn.  The information supplied to us by such third parties is regulated by their respective privacy and cookies policies; and

    • Cookies and other similar technologies: We collect cookies and other similar identifiers to distinguish you from other users of the Trōv Service. For detailed information about the cookies we use and the purposes for which we use them, please see our Cookies Policy.  

    Further details of the Personal Content we collect and why we collect it is set out below.

    If you register a Trōv Account:

    We May Collect

    Why We Collect It

    Your email address

    • To create and support your Trōv account.

    • To send you insights about your Trōv.

    • To communicate product news and marketing messages, unless you have opted out from receiving such information (please see the section on “Opting out of email & notifications” for further information).

    The language selected and geographic area of your device when you use the Trōv Service

    • To localize and improve the user experience of the Trōv Service.

    • To comply with local legal restrictions.

    Your device identifier

    To calculate anonymous, aggregate statistics, for product development and analytics purposes including for sharing with third parties on an anonymous, aggregated basis for the reasons described under “Information Access and Disclosure”.

    Your location information, if you elect to share it

    To quickly add your home/address to your Trōv and to provide you with localised information and alerts about items in your Trōv.

    Actions you perform, including your use of certain product features, as well as the type of device and software you are using

    To improve the features and usability of the Service.

    Anonymous logging of our HTTP API usage

    To provide better security and troubleshoot errors.

    Information regarding items that you add to your Trōv Account

    To provide the Trōv Service to you and to help us maintain a record of items that you add to your Trōv account. For more information, see “Does Trōv Share My Content” below.

     

    If you purchase Protection with Trōv:

    We May Collect

    Why We Collect It

    If you’re in Australia:

    Email, phone number (if provided), home address, age, gender, location information

     

    If you’re in the UK:

    Email, phone number, home address, age, country of residence, nationality, location information

    • To confirm your identify.

    • To personally cater a price for you.

    • Identify you and conduct appropriate checks.

    • To send you important information about protection purchased through your Trōv, including purchase receipts, billing and claims updates.

    Information about the protected item(s) in your Trōv account including photographs that you upload and the related metadata.

    • To provide appropriate pricing and protection for your item(s).

    • To validate possession, ownership and/or condition

    • For claims management purposes.

    Details related to Trōv Protection transactions, claims & other communications (email, chat, phone)

    • To ensure effective delivery of service, including support, claims and complaints.

    • For internal training & quality purposes.

    • Manage complaints and disputes, and report to dispute resolution bodies.

    Please note that Trōv Protection cannot be purchased unless you provide the above data.

     

    If you visit trov.com:

    We May Collect

    Why We Collect It

     

    Your email address, name or phone number, age, postcode, gender (if you provide it)

     

    • To provide you with a personalized quote
    • To communicate with you about relevant news, updates, and promotions related to Trōv.

    IP address, pages visited, browser type and settings, cookies, and similar tracking information

    • To improve our website and create better, more relevant content for you.
    • To calculate anonymous, aggregate statistics and to  improve the features and usability of the Trōv Service. 

    View our Cookies Policy for more details.

     

    Communications between you and Trōv

     

    To better assist you and other users with the Trōv Service.

     

     

     

     

    Marketing

    We may use your Personal Content and your marketing preferences to build a profile for you and to inform you of our products and services which we consider may be of interest to you.  You have a right to ask us not to process your Personal Content for marketing purposes and may exercise that right by opting out at any time (see “Opting out of email & notifications for further information).

    Opting out of email & notifications

    You may opt out of different types of email communications using the unsubscribe link found in the footer of the emails sent. However, if you obtain Trov Protection, for example, you will continue to receive legally required Service-related and Account-related information and documents, even if you unsubscribe from promotional emails. You may opt out of any app notifications from Trōv through personal settings on your device (iOS or Android).

    Types of Third Parties to Which We Disclose Personal Data and Why

    Does Trōv Share My Personal Content?

    Personal Content is content added to your Trōv that personally identifies you. As a rule, Trōv employees do not have access to any portion of your Trōv and we make sure that our access and use of these services is protected at the highest level. We will never share your Personal Content with third parties without your separate permission.  The foregoing is limited by the following:  

    • We may share your Personal Content with businesses that are legally part of the same group of companies that Trōv is part of, or that become part of that group ("Affiliates"), or that are contractors to Trov or its Affiliates that are contracted to . provide services on behalf of Trov or its Affiliates that are also subject to confidentiality.  Affiliates and contractors may use this information to help provide, understand, and improve the Trōv Service. These Affiliates and contractors will honor the choices you make about who can use your data.

    • Partners, such as distributors, channel partners and other third parties with whom Trōv jointly offers products or services to fulfill product or information requests, and/or to provide customers or prospective customers with information about Trōv and its products or services.

    • On rare occasions, we may be required by law, legal process, litigation, or governmental authorities, including to meet national security or law enforcement or regulatory requirements to disclose your Personal Content. In such instances, if permitted by law, we will notify you of such request, and allow for you to interject yourself into the disclosure of such information.

    • Trōv may also disclose Personal Content in special cases when we have a good faith belief that such action is necessary to protect and defend our legal rights or property, enforce website terms and conditions, or to protect the interests of our users or others.

    • We may disclose your Personal Content in connection with the sale, bankruptcy, dissolution, reorganization or other business transition such as merger, acquisition, or sale of all or part of Trōv’s business, as permitted by applicable law. We will inform you of such disclosure prior to the implementation of any of these changes, and will provide you with an opportunity to remove your personal data from the Trōv Service.

    • We may also disclose your Personal Content to enable Trōv to enforce its rights (including enforcing the Privacy Policy, the Cookies Policy and/or Terms of Use) and/or to protect the security of the system and/or other users and/protect its intellectual property and/or to prevent and detect fraud.

    • While we do not share Personal Content without your separate permission, we may publicly share aggregated, non-identifiable data, for example, anonymized reports related to categories of items owned in different geographies or other aggregate insights related to the things that people own and are protecting, for marketing and business development purposes.

    If you choose to purchase Protection

    We partner with leading insurance companies to provide Trōv Protection for items in your Trōv. If you do not purchase Trōv Protection through Trōv, then none of your Personal Content is shared with our insurance partners. If you choose to purchase Trōv Protection for an item or items in your Trōv, then your Personal Content is shared with the issuer of the product. This is required in order to effectively deliver the Trōv Protection service.

    • Trōv Protection in Australia is issued by AAI Limited.  If you choose to purchase Trōv Protection, then your Personal Content will be shared with AAI Limited. View the AAI Privacy Statement for more information about how your Personal Content is handled.
    • Trōv Protection in the United Kingdom is issued by AXA Insurance UK PLC.  If you choose to purchase protection, then your Personal Content will be shared with AXA. View the AXA Insurance UK Privacy Policy for more information about how your Personal Content is handled.

    Payment Service Providers

    Trōv uses 3rd party providers to process payments, refunds and claims. Since these organizations are separate businesses to Trōv, payment information will be managed in accordance with their privacy policy, which may differ from this one. See a list of our third party payment service providers here, along with associated privacy policies.

    App Analytics & Communication

    To continuously improve the Trōv experience, we employ third party technology providers that anonymously track actions within our Service and facilitate email communications. Some such third parties may be located in jurisdictions whose laws do not provide equivalent protection for your Content as in your location. We implement contractual and other measures with such third parties in order to ensure that your Content is treated securely and in accordance with this Privacy Policy.

    Data Storage, Transfer and Deletion

    How do I Make Changes to My Content

    You may make changes to your Content by logging into the Trōv mobile application and editing your Content.

    Where Is My Content Stored?

    When you use the Trōv Service, Content you save will be stored locally on your mobile device. It will also be replicated on our servers, either in in the United States, Australia, or Ireland, according to your region. Please be aware that regardless of your location Trov Inc is the data controller of your Content, which  is stored in our United States data centers.   Where we share your Content with our Affiliates, we will implement contractual and other measures with such Affiliates to ensure that your Content is treated securely and in accordance with this Privacy Policy.

    Trōv complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Trov has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

    How Secure Is My Personal Content?

    We take many precautions to protect your Personal Content through technology, policy and procedures. For example, we use industry standard (SSL) encryption to protect your network communications; to the extent allowed by law, we run background checks on our employees; and we architect our networks to protect access to our storage servers.  In addition to maintaining our high level of security, we are always striving to increase our security measures.

    You are an important part of securing the data in your Trōv Account. We recommend you use a strong password for the Trōv Service. You should use the security features of your devices, including passcodes, Touch ID, and lost device location services. We are not responsible for any unwanted access to your Trōv Account due to poor security of your devices or personal password.

    How do I delete Personal Content in my Trōv?

    You can delete the items in your Trōv at any time and they will be removed from our servers, if you have never purchased Trōv Protection for them. You cannot delete items that have been protected, because we are required by law to retain these records. Residual copies of your deleted Content, regardless of whether you’ve purchased Trōv Protection, may remain on our backup systems for several months due to the nature of those systems’ operations.  

    If you’d like to stop all communications related to your account, you can deactivate it through the settings menu in your Trōv. Note, deactivating your account will not delete the items in it; this needs to be done manually prior to deactivation.       

    Right to Access and to Request Correction

    Requesting Access to or Correction of Personal Content

    We take such steps as are reasonable to ensure that the personal information we collect and hold about you is accurate, up-to-date and complete.  However, we rely on the accuracy of the personal information you provide to us. You may request details of the personal information which we hold about you. If you believe that any information we are holding about you is incorrect or incomplete, please visit get.trov.help in the US, au.trov.help in Australia, uk.trov.help in the UK or contact: privacy@trov.com.

    Once we receive a request for access and/or correction, we will respond to that request within a reasonable period after the request is made and and in any event within the timescales required by law (within 40 calendar days, in the UK).  We will promptly correct any information found to be incorrect.  There are some exceptions, specified by law, where we may refuse your requests.  If one of these circumstances applies, we will provide you with a written explanation of the reasons for the refusal, unless it would be unreasonable to do so.  

    Concerns about Personal Content

    If you have any concerns about our handling or treatment of your personal information or if you believe your privacy has been breached, please contact privacy@trov.com, setting out the nature of your complaint.  We will investigate your complaint and provide you with our response within a reasonable time of receiving your complaint and in any event within the timescales required by law.

    In Australia, if after receiving our response, you still consider that your privacy complaint has not been resolved, you may refer your complaint to the Australia Privacy Commissioner at www.oaic.gov.au.  

    In the UK, if after receiving our response, you still consider that your privacy complaint has not been resolved, you may refer your complaint to the Information Commissioner’s Office at www.ico.org.uk. In compliance with the Privacy Shield Principles, commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Trōv at:  privacy@trov.com. Trōv has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints.  If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint.  The services of EU DPAs are provided at no cost to you.

    Choice and Means

    If you are in the EU, if at any time after you provide us with Personal Content, that information changes, you change your mind about receiving information from us, wish to cancel your account or request that Trōv no longer use your information to provide you services, contact us via privacy@trov.com.  Additionally, you can delete the items in your Trōv at any time and they will be removed from our servers, if you have never purchased Trōv Protection for them. You cannot delete items that have been protected, because we are required by law to retain these records. Residual copies of your deleted Personal Trōv Content, regardless of whether you’ve purchased Trōv Protection, may remain on our backup systems for several months due to the nature of those systems’ operations.  If you’d like to stop all communications related to your account, you can deactivate it through the settings menu in your Trōv. We will retain and use your information for as long as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

    Other

    Investigatory and Enforcement Powers of the FTC

    Trōv is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).  Trōv also is committed to cooperating with EU DPAs.

    Arbitration

    If you are located in the EU and have exhausted all other means to resolve your concern regarding potential violations of Trōv’s obligations under the Privacy Shield Principles, you may seek resolution via binding arbitration.  For additional information about the arbitration process please visit the Privacy Shield Website:  www.privacyshield.gov.

    Liability

    If a third party service provider providing services on Trōv’s behalf processes personal data from the EU in a manner in consistent with the Privacy Shield Principles, Trōv will be liable unless we can prove that we are not responsible for the event giving rise to the damages.

    Children’s Privacy Protection

    The Trōv Service is not directed to children, nor do we knowingly collect any personally identifiable information from children under 13 years of age through the Trōv Service or software. If we learn that we have collected personally identifiable information from children under 13 years of age, we will delete such information.

    Other Websites

    We are not responsible for the practices employed by any websites or services linked to or from the Trōv Service, including the information or content contained within them. Please remember that when you use a link to go from our service to another website or service, our privacy policy does not apply to those third party websites or services. Your browsing and interaction on any third party website or service, including those that have a link on our website, are subject to that third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your data. If you are using a third party website or service and you allow them to access your data, you do so at your own risk.

    Contact Us

    If you have any comments, questions or concerns about this Privacy Policy, please contact us at privacy@trov.com or by post at:

    Trōv, Inc.
    347 Hartz Avenue
    Danville, California 94526

    Trōv International Australia Pty Ltd
    Addisons
    Level 12
    60 Carrington Street
    Sydney NSW 2000

    Trōv International UK Ltd
    The Broadgate Tower, 3rd Floor
    20 Primrose Street
    London EC2A 2RS

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