Our legal bits

Trilo's Early Bird Promotional Terms

Welcome to Trilo’s early bird promotion - an amazing opportunity for early Trilo adopters to receive a special something for giving us a go! As with any promo, there are a few rules to make sure everyone plays fair! 


Who is eligible to participate in the Promo? 

There are two groups of Trilo users; merchants (stores which allow you to pay with Trilo) and end-users (those who chose to pay with Trilo).


End-users

All you need to do is sign up with your name, email address, and bank account sort code and account number, and you will be shown your position in the queue along with everyone else who enters the promotion. You will also be given a link to share with friends which can be used to sign up to Trilo, and for every friend who joins you will climb ten places in the queue. 

For every friend who signs up and uses the Trilo platform once launched, you will receive £1 to spend at Trilo merchants! (Capped at £10 per person). The top referrers in the Trilo Early Bird promotion will receive their cashback once Trilo is launched. 

 

When a friend joins the early bird promotion using your link we will notify you of this, with the title “Your friend {NAME} has joined Trilo”.

 

For us to do these things we need your consent to process some data. What data will we process? Your name, email address, and bank account sort code and account number. Why do we need to process this data? So that we can sign you up to the Trilo promo, show you your position in the queue, and let you know when a friend signs up using your link, or let a friend know you signed up to the promotion using their link. What is our legal basis for processing this data? Your consent! So by entering this promotion you expressly agree that you have read these terms in full, along with our End-user Terms, and Privacy Policy, and agree to these.

Merchants 

All you need to do is sign up with your business name, business email address, the full name of a contact at the business, and you will be shown how many free transactions you will receive when Trilo launches (see below). You will also be given a link to share with friends which can be used to sign up to Trilo. 

 

When your business joins Trilo, you will receive 5 free transactions. For every business you refer, you will receive 50 free transactions, and the new business will receive 10 instead of 5 as a bonus for being invited. For every customer who joins with your link, you will receive 2 free transactions

 

When a business joins the early bird promotion using your link we will notify you of this, with the title “{businessName} has joined Trilo”.

 

When a customer joins the early bird promotion using your link we will notify you of this, with the title “One of your customers has joined Trilo”; we will not mention the name of the customer in this notification. 

 

For us to do these things we need your consent to process some data. What data will we process? The name of your business, the business email address, and the full name of a contact at the business. Why do we need to process this data? So that we can sign you up to the Trilo promo, show you your free transactions, and let you know when a business or customer signs up using your link, or let a business know you signed up to the promotion using their link. What is our legal basis for processing this data? Your consent! So by entering this promotion you expressly agree that you have read these terms in full, along with our Merchant Terms, and Privacy Policy, and agree to these.

When do I get these benefits? 

Once Trilo officially launches, and both you and your referees begin using Trilo, provided that neither of your bank accounts have been registered with Trilo before. 

 

How long does the promotion last for? 

The promotion will last up until Trilo is ready to launch, and a notification will be made informing everyone at the time. 

 

Other legal bits to consider 

This Trilo promotion is organised by Trilo Group Ltd, company registration number 11684530. 

We may, at our sole discretion, suspend, terminate or change the terms and requirements of this promotion by its end date. 

 

Details of how to enter form part of the terms and conditions. It is a condition of entry that all rules are accepted as final and that the entrant agrees to abide by these rules. The decision of Trilo as promotion administrator is final and no correspondence will be entered into. Trilo’s standard Terms and Conditions apply to the use of any of Trilo’s products and services. 

 

To the extent permitted by law, these Trilo promotional terms shall be exclusively governed by and construed in accordance with the laws of England and Wales. Any disputes arising out of or in connection with these terms shall exclusively be submitted to and dealt with by the courts in England and Wales. 

  

If you have any questions or concerns, please kindly contact us at: support@trilo.io 

Trilo Group Limited is a company incorporated and registered in England (company number 11684530) whose registered office is at Bath House Bath Street, Redcliffe, Bristol, England, BS1 6HL. Trilo Group Ltd is pending authorisation from the FCA.




Trilo’s Privacy Policy

Version 1: April 2020

1. Our Privacy Policy

1.1. At Trilo, we are committed to respecting and protecting your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information. The terms set out should be read together with our Terms.

1.2. By using the service offered by Trilo you confirm that you accept the terms of this Privacy Policy and that you agree to be bound by them in your use of the service. If you do not agree, please do not use the service.

2. Data Controller (Or Owner)

2.1. For the purposes of this Privacy Policy, the Data Controller is Trilo Group Ltd (“Trilo”, the “service” or “us”) of Bath House Bath Street, Redcliffe, Bristol, England, BS1 6HL.

2.2. We are also registered with the Information Commissioner under registration number: ZA742740.

2.3. You may contact us at: privacy@trilo.io

 

3. 1. Data Processor

3.1. Amazon Web Services (AWS). AWS is an appointed Data Processor by Trilo. AWS provides the processing service of the Data collected through the use of the service. The processing of Data is carried out in respect of AWS Security Standards at all times. If personal data is transferred outside of the EEA, we always require that appropriate safeguards are in place to protect the information when it is processed.

3.2. Additionally, the Data may be accessible to certain types of persons in charge, involved with the operation of the service (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). The updated list of these parties may be requested from the Data Controller at any time.

 

4. Personal Data You Give Us

4.1. Trilo collects the information you provide when you: correspond with us; fill in any forms;  register to use the Trilo service; take part in online promotions; open an account or use any of our services; enter a competition; speak with a member of our customer support team; or contact us for other reasons.

4.2. Trilo will, by itself or through third parties, collect the following information: your name, address, and date of birth; your username, password and other registration information; your email address, phone number and details of the device you use (for example, your phone, computer or tablet); details of your bank account, including the account number, sort code and IBAN; records of our discussions, if you contact us or we contact you; and identification documents should they be needed (such as your passport or driving licence number), copies of any documents you have provided for identification purposes if required, and any other information you provide to prove you are eligible to use our services.

4.3 Other types of Personal Data collected may be described in other sections of this Privacy Policy.

4.4 Failure to provide Personal Data may make it impossible for Trilo to provide its Service.

 

5. Information We Collect From Other Sources

5.1. If you have location services in the Trilo service switched on, we track your location using GPS technology and your IP address. This information may be used to improve and personalise our service.

5.2. Whenever you use our website or the Trilo service, we collect the following information: information about your visit, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page; technical information, including the internet protocol (IP) address used to connect your computer to the internet, your log-in information, the browser type and version, the time-zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device identifier, number, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use and so on. The Trilo service will regularly collect this information in order to stay up to date. 

5.3. We may collect information from third parties, such as credit reference agencies, fraud-prevention agencies and partners who help us to provide our services. This includes your credit record, information to help us check your identity, and information relating to your transactions.

5.4. In cases where, in order to provide our service, personal data is to be collected from third parties who can be considered as autonomous data controllers, such as, for instance, likes on Facebook, Instagram or Twitter put by the Users, we guarantee to process this data exclusively for the fulfilment of contractual obligations related to our service.

6. Bank Account and Financial Details

6.1. The Service requires the processing in read only mode of your bank account details and financial data such as your transaction history and balance. To ensure the maximum level of protection of your Data, Trilo collaborates with the following service providers that store and process User’s Data:

Truelayer is a service provider which helps securely access data, initiate, and authenticate open banking payments in real time.  Trilo has signed up for the Payments API and Account Information API offered by Truelayer so you may link your ASPSP account to the service by using Truelayer’s platform service. Truelayer will allow you to Initiate payments, and consolidate your account information with Trilo.

Collected Data: None

Privacy Policy

7. Fraud Monitoring, Account Monitoring, and Transaction Monitoring

7.1. Depending on your use of the service, we may also use your data to make certain automated decisions; this is called automated decision-making. We may use your personal data, including financial transaction data, to make automated decisions on the likelihood of you committing fraud on our platform. As a result of this automated decision making we may suspend your use of the services, either temporarily or permanently. You agree and acknowledge that you have understood this, and by accepting this Privacy Policy you agree and confirm that you give your explicit consent  for this automated decision making to happen. 

7.2. If you have been affected by the automated decision making, you may request human intervention or challenge the decision of the algorithm which results in the automated decision making by sending an email to privacy@trilo.io  with the words ‘automated decision making’ in the subject. 

7.3. In addition to this we will use your personal information to help prevent fraud in a more general manner, by: trying to stop you from becoming a victim of fraud; confirming you are eligible to use our services; and complying with financial crime laws. The data we will use for these purposes comes from the information you have provided us, the information from your device, and/or the information from third parties. Our legal basis for this activity is in complying with our legal obligations, complying with agreements between you and us, and/or legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities). 

8. Other Uses of The Data Collected 

8.1 The Data we collect from Users are also used for the following purposes:

 

Analytics. The services described in this section allow the Data Controller to control and analyse traffic data. The services also allow the tracking of the User’s behavior.

Amplitude is an analytics service provided by Amplitude, Inc.

Data collected: different types of Personal Data, such as Usage Data, as specified in the Privacy Policy of Google.

Privacy Policy

 

Advertising. This type of services allows User Data to be utilised for advertising communication purposes displayed in the form of banners and other advertisements on this service, possibly based on User interests.

AdWords is a remarketing and behavioral targeting tool to advertise across websites provided by Google, Inc. 

Collected Data: Usage Data and various types of Data, as specified in AdWords’ Privacy Policy

 

Facebook Conversion is a tracking tool for ads on the social network Facebook provided by Facebook, Inc. 

Collected Data: Usage Data and various types of Data as specified in Facebook’s Privacy Policy

9. Mode and Place Of Processing Data

9.1. Security Measures

9.1.1 Trilo processes Users’ Personal Data in a proper manner and shall adopt appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. Even where all precautions are adopted we cannot guarantee complete security in all events.

9.1.2. The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated.

9.2. Place of processing

9.2.1. The Data is processed at the Data Controller's operating offices and where the Data Processor’s operating offices or other parties involved with the processing are located. If we or our service providers transfer personal data outside of the EEA, we always require that appropriate safeguards are in place to protect the information when it is processed. 

9.3. Retention time

9.3.1. The Data is kept strictly for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this Privacy Policy.

9.3.2 The User may always request that the Data Controller suspend or remove the Data.

10. Data Transfer

10.1. The User consents to the transfer of the collected Data through the Service in the event of rearrangement, merger, sale, joint venture, transfer or any other arrangement method of the whole or part of the Company, of its goods and shares, according to the purpose and the limits of this document.

11. Legal Action

11.1. Your Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this service or related services.

11.2. You acknowledge to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

12. Rights of Users

You have the right, at any time, to:

12.1. Know whether your Personal Data has been stored and may consult the Data Controller to learn about their contents and origin (right of access);

12.2. Verify your Personal Data accuracy or ask for them to be supplemented, updated or corrected (right to rectification);

12.3. Request the erasure of your Personal Data or their transformation into anonymous format (right to erasure);

12.4. Request the restriction of processing of your Personal Data for any and all legitimate reasons (right to restriction of processing);

12.5. Receive your Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another controller (right to data portability);

12.6. Withdraw the consent to the processing of your Personal Data at any time, without prejudice to the lawfulness of the processing based on consent before its withdrawal;

12.7. Object to the direct marketing activities carried out by Trilo, including any segmentation for marketing purposes.

Requests should be sent to the Data Controller at: privacy@trilo.io

13. Changes To The Privacy Policy 

13.1 The Data Controller reserves the right to change this Privacy Policy at any time by giving notice to its Users through this page. It is recommended, therefore, to check this page often and refer to the latest update date at the bottom of the page. If a User objects to all or any of the changes to the Policy, you must cease using the service and may request that the Data Controller remove your Personal Data. Unless stated otherwise, the then-current Privacy Policy applies to all your Personal Data processed by the Data Controller at the time.

DEFINITIONS

PERSONAL DATA (OR DATA)

Any information regarding a natural person, which is, or may be, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.

USAGE DATA

Information collected automatically from this service (or Third Party services employed in this service), which may include: IP addresses or domain names of the computers used by the Users, URI addresses (Uniform Resource Identifier), time of the request, method of request submission to the server, size of the file received in response, numerical code indicating the status of the server's answer (successful outcome, error, etc.), Country of origin, features of the browser and the operating system utilised by the User, various time details per visit (e.g., time spent on each page within the service) and details about the process followed within the service, specifically the visited pages sequence and other parameters about the device operating system and/or the User's IT environment.

DATA CONTROLLER (OR OWNER)

The natural person, legal person, public administration or any other body, association or organisation, also jointly with another Data Controller, having the right to make decisions regarding the purposes and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this service. The Data Controller, unless otherwise specified, is the Owner of this service.

USER

The individual using this service, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.

DATA PROCESSOR

The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this Privacy Policy.




For anything else, contact us at: legal@trilo.io