Effective date: 22.4.2024
Version: 2.0

This Privacy Policy (hereinafter as “Privacy Policy”) describes the way TRINIS EUROPE, SE, seated Tomášikova 1973/32, 831 04 Bratislava, Company ID: 54027462,  registered with the Slovak Commercial Register of  District Court Bratislava III, Insert No. 8755/B (further as “Trinis”) collect, process and protect your Personal data. Trinis hereby undertakes to protect your Personal data in accordance with the applicable legal regulations in the area of data protection, such as Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of Personal data and on the free movement of such data (“GDPR”).This Privacy Policy applies to the processing of Personal data on all services, applications, and websites operated or provided by Trinis, in which Personal data is processed and in which this Privacy Policy is contained or referenced. This Privacy Policy also applies to processing Personal data of website visitors, service users, and also representatives of our business partners or individuals that contact us via our website. This Privacy Policy also applies to cases where Trinis processes Personal data as a controller.In case of any discrepancy between this Privacy Policy and the specific privacy policy applicable to any product or service provided by Trinis, the specific privacy policy shall prevail. The provisions of this Privacy Policy shall apply from the effective date stated above.

Trinis is an innovative logistic platform designed to  connect drivers, spediters and companies (collectively referred to as “Users”). By using Trinis, our Users can gain access to a variety of tools that help them  efficiently resolve their transport needs. Whether it's managing transport assignments, coordinating drivers and fleets, or tapping into the freight exchange, Trinis empowers Users to efficiently navigate their logistical challenges.Trinis offers its services via its website application https://app.trinis.eu (further as “Trinis platform” ) and  mobile application Trinis Driver App (“Trinis App”). For further inquiries and assistance, visitors can connect with us via our representative website at https://trinis.eu/sk (“Trinis website”).

TRINIS AS A DATA PROCESSOR
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Trinis operates Trinis App and Trinis platform, a solution created for drivers, spediters and companies in order to help them manage their transport needs. When you conclude an Agreement with Trinis for the provision of Trinis services and entrust your Personal data to Trinis, Trinis will process this Personal data as data processor.

TRINIS AS A DATA CONTROLLER
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Anytime, when you are in a direct relationship with Trinis. For example, when you subscribe to our newsletters or you contact us via our website Trinis acts as a data controller.

INFORMATIONS WE COLLECT WHEN YOU ARE USING TRINIS FOR YOUR COMPANY OR AS SPEDITERS
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When you create an account with us and use Trinis we may process and collect the following categories of Personal data:

• full name,
• company name,
• industry,
• Contact details, such as address, phone number, e-mail address
• billing data,
• payment data,
• communication and correspondence records (when you engage with our in-app chat (send a message)),  
• information about your use of Trinis services and
• any further information you decide to share with us.

By accessing and using Trinis services, you enter into an agreement for provision of Trinis services. The legal ground for processing this data is performance of contract or precontractual relations.

INFORMATIONS WE COLLECT WHEN YOU ARE USING TRINIS AS DRIVER
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When you receive an invite to register into Trinis App as a driver and you create an user account with us, we may process following categories of your Personal data:


• full name,
• company name,
• industry,
• Contact details, such as address, phone number, e-mail address,
• communication and correspondence records (when you engage with our in-app chat (send a message)),
• information about your use of Trinis services and,
• any further information you decide to share with us.

The legal ground for processing this data is performance of contract or precontractual relations.In order to ensure the safety of transport we will monitor your location when you deliver the freights that have been assigned to you. Your location will be only shared with the authorized companies and spediters  who have access to the fleet you belong to. Location will be monitored via the device you use to access your User account in Trinis App. You don't have to worry, we do not process your location all the time. You have full control over your location sharing settings, allowing you to toggle them on or off at your discretion. This means we only track your location during freight deliveries, ensuring and respecting your privacy. The legal ground for processing your location data is your consent.

OTHER PERSONAL DATA PROCESSING CONCERNING USERS AND WEBSITE VISITORS

Website browsing
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When you browse Trinis websites, we collect and process your data to provide you with relevant content, to improve the content of our website, to remember your preferences and enable automatic filling of your details. We process several data about you through cookies, you can find out more about our use of cookies in our Cookie Policy or section 4.Use of Cookies of this Privacy Policy. The legal ground for such processing is your consent and our legitimate interest to operate Trinis website.

Product testing and improvement of our products
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We may ask for your opinion about our products and services. How you use them, or we may provide you with the option to test our products. We do so in order to provide you with the best possible experience. In such cases we will process your identification details, contact details, content of your feedback and technical information related to your use of services. We process this information on the legal ground of our legitimate interest to test and develop Trinis products.

Customer support

‍You might experience some obstacles when you are using our Services. In such cases you might contact our customer service and support for assistance. We will process Personal data necessary  to provide  you with service or handle your request. The legal ground for such processing is contract performance between Trinis and you as its customer.  

‍Newsletter
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When you sign up for our newsletter Trinis may use your Personal data for marketing purposes. In such cases we will process your identification and contact details, information about the newsletters you signed up for. Legal basis for such processing is your consent.

Push notifications
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While using Trinis App, we may need to send you push notifications for various reasons. When we send you push notifications we may process your device information, your User behavior and your personal information such as your identification data. We will send you these notifications only when you grant us your consent to do so.

Legal Obligations

‍In some instances, legal regulations impose obligations on us under which we are obliged to process Personal data, such cases are for instance tax and accounting laws, AML laws and provision of some data to public authorities based on law. That means we may process your Personal data in order to ensure compliance with such obligations. Legal ground for processing such Personal data is compliance with legal obligations.
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Generally Personal data shall be kept for as long as necessary for the purpose for which it was processed. For how long Trinis will hold your Personal data will as well depend on the legal basis on which your data is processed. Shall the processing be based on legitimate interest your data will be processed for as long as the given legitimate interest of Trinisa is in place and shall be erased after. For data kept based on legal obligations the data retention period is prescribed by applicable legal regulations and shall be deleted once the legally prescribed time period lapses. For data processed based on performance of a contract the data is processed for the duration of the contractual relationship and for an applicable limitation period. This data is then erased after. Shall the processing be based on your consent your Personal data shall be erased after you withdraw your consent. Please bear in mind that the same data may as well be processed based on other legal basis in which caseyour withdrawal of consent might not mean a full erasure of your data.

Our websites use cookies to collect information about individuals who visit our website.Cookies are small, encrypted text files that are stored on your computer or other device. Cookies help us to operate our website, provide important features and functionality on our website. They help us to understand how our website is being used. At the same time, we use cookies for statistical and analytical purposes, for example to track and monitor what country, what pages and what method was used to visit our website as well as to enable personalization.
Additionally, cookies help us deliver online advertising that we believe is most relevant to you. Cookies are also used for profiling. Cookies can help us to understand how our website is being used, for example, by telling us if you get an error message as you browse. For more information about cookies please visit http://www.allaboutcookies.org.
We use the following types of cookies:
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(i) Essential (necessary) cookies, which are essential for the provision of access to our websites and for the provision of services explicitly requested by you, they enable core functionalities of the website such as marking your data inputs, network management and accessibility. (If these cookies are disabled, our website may not work properly).
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(ii) Analytical (performance) cookies help us to analyse how you navigate our websites and what content is relevant to our Users. We are able to see User navigation in our platform (we monitor automatic events, custom events, and event logging and save them in a real-time database). Analytical and performance cookies are also used for performance measurement and improvement.
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We may collect the following data via cookies:

‍IP address, gender, time zone, browser settings, operating system, information about website visits including the URL, search terms, information about what you viewed or searched on our website, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
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When you visit our websites, you shall be informed through a cookie banner placed at the bottom of the website that we collect cookies. The banner allows you to manage what kind of cookies can be collected by Trinis. You can change the settings and withdraw your consent at any time through Privacy settings provided on the bottom of our websites.
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When we collect essential cookies the legal ground for processing of this data is legitimate interest. It is not possible to disable these cookies through the Privacy settings as our websites might not function properly when you disable this type of cookies however if you still wish to do so you may follow the instructions below in the section Disabling cookies.
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When we store data or gain access to data already stored in your terminal equipment such as your PC or mobile device for analytical, functional, or advertising purposes we only do so once you have given us your consent.
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Trinis emails and/or websites and the communications generated from using and/or registering for Trinis services and/or platform, such as promotional emails, may contain electronic images known as “web beacons”. Web beacons generally work in conjunction with cookies, and we may use them in the same way we use cookies (see above).
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Disabling cookies

If you wish cookies not to be collected, you may restrict, block or delete the cookies at anytime by modifying your browser configuration. Although each browser is parameterizeddifferently, cookie configuration is normally located on the “Preferences” or “Tools” menu. Ifyou turn off cookies, the functionality of our website may be limited (in the case of essentialcookies you may not be able to access our website).
● If you wish to prevent new cookies from being installed or if you wish to deleteexisting cookies you can find the instructions on the links below. The exact proceduredepends on which browser you are using:
● Internet Explorer:http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
● Firefox:https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox#firefox:win10:fx93 /https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US#firefox:win10:fx93
● Google chrome: https://support.google.com/chrome/answer/95647?hl=en
● Safari: https://support.apple.com/sk-sk/guide/safari/sfri11471/mac

For mobile devices you can limit tracking via the privacy setting on your device (disabling theadvertising identifier), for instructions please see https://www.networkadvertising.org/mobile-choice/
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Furthermore you can use a third party tool to opt out from targeted advertising, availablethird-party opt-out tools include the Digital Advertising Alliance, the Network AdvertisingInitiative, and the European Interactive Digital Advertising Alliance (Europe only).

To opt out from receiving cross-device site advertising (i.e. tracking a User across devices)you can access your device settings or visit and employ the controls described on the NAI’sMobile Choices page.

We as well use so-called social plugins from the following social networks on our websites:(i) google.com (“plugins”), which are indicated by their logos on our websites. When you visitour websites, your browser establishes a direct connection with the servers on which theseplugins run. The content of the plugins is transferred directly by Google to your browser,which then integrates it into our website. Integration of the plugins causes Google to receivethe information that you have accessed on the corresponding page of our website. If you arelogged with Google, it will be able to assign your visit to your account on these socialnetworks. Please note that an exchange of this information already takes place when youvisit our website regardless of whether you interact with the plugin or not. If you do not wantGoogle to gather data about you via our website, you must log out of them before visiting ourwebsite.

For more information regarding how these social networks process your data in their privacypolicies:

Google https://policies.google.com/privacy?hl=en-US

If you want to find out more about our use of cookies, please refer to our Cookie Policy.

Your Personal data shall not be shared with any third party except for the following situations:
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● data is necessary for provision of Trinis services,
● based on your consent,
● entrusting of Personal data to processors who process Personal data on behalf ofTrinis,
● Trinis is obliged to provide the Personal data on the basis of law or upon order by apublic authority.
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Categories of Processors
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Trinis uses trusted third-party providers that in some instances process Personal data onbehalf of Trinis and based on instructions provided by Trinis. Trinis may use the followingcategories of providers (sub-processors under GDPR):
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● hosting, data center,
● marketing tools,
● analytical tools,
● task management and communication tools,
● IT tools / providers,
● business administration tools,
● legal, tax accounting, and audit services,
● governmental agencies.
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Transfers to Third Countries
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Trinis will transfer your data to countries outside the EU/European Economic Area only ifsuch a transfer is GDPR compliant. That means, for instance, the provider is seated in acountry for which the European Commission issued a decision that it provides an adequatelevel of Personal data protection, Standard Contractual Clauses issued by the EuropeanCommission and/or other transfer mechanisms are in place that ensure adequatesafeguards with respect to the protection of privacy and fundamental rights and freedoms ofindividuals and, if necessary, additional measures are applied to ensure that the DataSubject is granted a level of protection essentially equivalent to that guaranteed by the GDPR.
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You have a right to receive a copy of the Standard Contractual Clauses (“SCC”) we haveconcluded with our sub-processors that are established outside of the EU/EEA and that areused for transferring Personal data outside of the EU/EEA. If you wish to obtain a copy of theSCCs applicable to a particular transfer of your Personal data, please contact us viadpo@trinis.eu.

Trinis is committed to store your data securely. Therefore, we have implemented technicaland organizational security measures in an effort to safeguard the personal information inour custody and control (which do not, however, deprive you of your duty to take propersteps to secure your data).
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Technical measures
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● Data encrypted in transit. All of the passwords, tokens and keys areencrypted as well.
● We avoid storing sensitive data, like passwords in plaintext.
● Every application in our suite is logging its actions. The level of the logging can beset according to the client's needs. The log expiration time is to be decided in theprocess of contract signing. In case this clause is not enforced, it will be setaccording to our default settings. VPC (network logs) are not enabled by default.
● Application security scanning is done by several AWS services to always adhere tothe best practices. We also conclude a security patching of all our instances toensure we are always running the safe and up-to-date Operation systems.
● We enforce a strong password policy. Where possible, we use MFA authentication.Use of reliable password managers is also strongly enforced.
● We are using principles of least privilege access to only allow the least amount ofpossible rights to our systems. We are using the IAM service to limit access of ourstaff to only allow the least possible access that their role requires. In ourapplications, access to production environments is only granted to the people whoare actively working on the production support and have all the necessary clauses inthe contract.
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People security measures
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● For all of our candidates we perform background checks. The extent of these checksdepends on the role and the seniority of the candidate.
● Contracts with our contractors and employees contain necessary confidentialityclauses and they are obliged to follow our rules on data processing.
● All employees and contractors are required to use a strong password.
● All of our technical staff must undergo mandatory security training.

Under GDPR you are entitled to following rights:
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RIGHT TO ACCESS
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You have the right to obtain confirmation from us regarding the information whenever we process your Personal data. If you wish to obtain such information, please contact us at dpo@trinis.eu. If we process your Personal data, we will provide you with the following information
● purposes of processing,
● the categories of Personal data obtained,
● the recipients, or categories of recipients of Personal data,
● if possible, the period for which your Personal data will be retained, or at least the criteria that determine that period,
● the existence of the right to ask the controller to rectify or erase the Personal data or to restrict the processing of Personal data concerning the data subject or to object to such processing,
● right to file a complaint with supervisory authority
● the sources of your Personal data, if such Personal data have not been obtained directly from you
● the details of the existence of automated decision-making, including profiling.
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RIGHT TO RECTIFICATION

You have the right for any of your incomplete, inaccurate, or out-of-date Personal data to berectified

RIGHT TO ERASURE

You are entitled to the erasure of certain Personal data without undue delay. Please beaware that Trinis may be entitled or even obliged to keep some of your Personal datadespite your data deletion request. These are mainly situations where we need to processyour Personal data in order to comply with our legal obligations or to defend our legal claims.
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RIGHT TO RESTRICTION OF PROCESSING
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In the cases such as:
● if you object the accuracy of Personal data, for a period that allows us to verify theaccuracy of Personal data,
● the processing is illegal and you do not agree to the deletion of your Personal dataand request the restriction of their use,
● We no longer need your data for processing purposes, but your Personal data isnecessary to prove, exercise or defend legal claims,
● you have objected to processing in relation to profiling until it is verified that ourlegitimate grounds outweigh yours,You can ask Trinis to restrict the processing of your Personal data.

RIGHT TO DATA PORTABILITY

You are entitled to receive the Personal data that you have provided to us in a structured,commonly used and machine-readable format and ask from us to transmit that data toanother controller, if it is technically possible. We would like to warn you that this rightapplies only to the data that you have provided us with and which we process as a controllerbased on your consent or contract.

RIGHT TO OBJECT

You are entitled to object, on grounds relating to your particular situation, at any time to theprocessing of Personal data that concerns you and is carried out in the public interest or forthe purposes of legitimate interests pursued by Trinis, including profiling.The exercise of your rights may be limited shall Trinis be obliged to keep any of yourPersonal data for the purpose of compliance with legal obligations, for the establishment,exercise or defence of legal claims or any other compelling reasons as provided by therelevant data protection law.

RIGHT TO NOT BE SUBJECT TO AUTOMATED DECISION MAKINGYou have the right not to be subject to a decision based solely on automated processing,including profiling, which produces legal effects concerning you or similarly significantlyaffects you. This does not apply if the decision:
• is necessary for entering into, or performance of, a contract between you and Trinis
• is authorized by law and the law lays down suitable measures to safeguard yourrights and freedoms and legitimate interests; or
• is based on your explicit consent.Trinis does not make decisions based solely on automated processing that would havesignificant effects for Trinis user. For completeness, Trinis uses cookies and similartechnologies the use of which may amount to profiling. For information on how to withdrawyour consent for the use of cookies or disable cookies, please see chapter 4. Use of Cookiesof this Privacy Policy.

RIGHT TO FILE A COMPLAINT

If you feel that Trinis process your Personal data unlawfully, please contact us and we will tryto resolve this situation. Under GDPR you are entitled to file a complaint with the Office forPersonal data Protection, seated Hraničná 4826/12, 820 07 Ružinov.
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If you have any questions regarding the safety of your Personal data, please do not hesitateand contact us directly at dpo@trinis.eu or by the mail to the address: TRINIS EUROPE, SETomášikova 1973/32, 831 04 Bratislava

Our website, services, and applications are not intended for persons under the age ofeighteen (18). If you are under the age of eighteen, please do not provide your personalinformation to Trinis. We do not knowingly collect any personal information from childrenunder the age of eighteen on our website. Users under the age of eighteen (18) (or the ageof majority in the applicable jurisdiction) should not use Trinis's websites, services, andapplications without authorization from a parent or legal guardian.

This Privacy Policy may be amended by Trinis at any time. If we change this Privacy Policy,we will post the changes on our website and/or other places we deem appropriate. We may,but are not obligated to, send you an email or other notice of such a change, but you shouldcheck this Privacy Policy from time to time for any significant changes to its text.If for any reason, any provision herein is found void or unenforceable, it will be severed tothe extent void or unenforceable and the remaining provisions will continue in full force andeffect.