Please read this privacy policy carefully.

 

Last Updated and effective as of:  March, 2022

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At TrigoFi, we take seriously our responsibility to protect the privacy and confidentiality of your information. TrigoFi is committed to earning and maintaining your trust by safeguarding your personal information and making its protection a priority. This Privacy Policy describes how TrigoFi LLC. (“TrigoFi”, “we”, “us”, or “our”) collects, uses, discloses, shares, and protects information of users or visitors to our website, our secure website, our mobile application (together the “Platform”) and users of any services that are provided, offered, or made available by us (the “Services”).

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1. Your Acceptance of this Privacy Policy

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By accessing or using the Platform or Services, you consent to our collection, storage, use, and disclosure of your information as described by this Privacy Policy. The provisions contained in this Privacy Policy supersede all prior notices and statements regarding our privacy practices with respect to the Services. If you do not agree to every provision of this Privacy Policy, you may not access or use the Platform or Services.

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2. How We Collect Information

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When you access or use the Platform or Services, we may collect information that identifies you (“Personal Information”), and we may also collect information that does not identify you (“Anonymous Information”). We obtain information about you in a number of ways.

 

Information you provide to us

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In general, you may visit the Website or download the TrigoFi Mobile app without telling us who you are or sharing any Personal Information with us. When you register for an account for the Services (an “Account”), use other aspects of the Services, or communicate with us for customer service or technical support for the Services, we may ask you to provide certain Personal Information, such as your name, email address, postal address, mobile number, demographic information (such as your age, occupation, gender, race or nationality), Taxpayer Identification Number and financial account information. Additionally, if we are required enable the provision of Services or by law, we may ask you to provide us or our service providers certain Personal Information. You may decline to provide certain Personal Information to us, but, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

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Information you provide us may also include user created content such as messages, comments, photos, audio, or video that you post, upload, submit, share or otherwise provide on or through the Platform (“User Content”). You grant us permission to utilize the User Content in a commercially reasonable manner on the Platform, and any in marketing materials now and in the future, and you waive any and all rights to compensation of such use. The posting of User Content is subject to our Terms of Use.

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Information Collected from Devices

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When you use or access TrigoFi’s Platform or Services via a computer or mobile device, including, without limitation, a desktop, laptop, mobile phone, tablet or other electronic device (each, a “Device”), TrigoFi may collect information from your Device, such as your Device type and manufacturer, your Device operating system and version, your mobile carrier, your Device identifiers, your mobile phone number, your IP address, your location, your browser type, your network connection type, information about the webpage that referred you to the Website or that you visited prior to the Website and your behavior and activity on the Website and the TrigoFi Mobile App.

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In addition, if you download the TrigoFi mobile app to your mobile Device, we, or our third-party service provider, Moxtra, may collect information from your mobile Device about your location while you are accessing or using the TrigoFi Mobile App and while you are not accessing or using the TrigoFi Mobile App. We may opt out of the collection of location data at any time by changing the settings on you mobile Device, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

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TrigoFi may generate analytics based on your preferences, characteristics, use and interactions with the Platform and Services. Our Services may then analyze such data and generate derivative data or aggregated data as well as reports and other output.

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Information Collected by Cookies and Tracking Technologies

TrigoFi uses automated collection tools such as Cookies and similar technologies. Like many online services, we use the following technologies tom improve our Platform and Service:

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• “Cookies” are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or store information or setting in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patters, and facilitating analytics and online advertising. Session Cookies are deleted when you log off from Services and close your browser while other Cookies are persistent. Most browsers automatically accept Cookies. You can change your browser settings to prompt you before accepting Cookies. Note that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party service providers that we engage may also use Cookies.

• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications

• “Web Beacons” also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened or that content was viewed or clicked.

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See “Choices” to understand your choices regarding Cookies and other Technologies.

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Information from Others

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In addition to the information that you provide to us directly, we may also obtain information about you from other sources. For example, we may obtain information from a third-party service provided whose application you authorized or used to sign into our Platform. We may purchase information about you from third parties or gather publicly available information about you from online and offline sources, such as your public profile on social media. While we obtain information from third parties that we believe to be reliable, TrigoFi cannot guarantee the accuracy, timeliness, completeness, or the fitness of such information for any particular purpose. If we combine such information with the Personal Information that we collect from you, we will treat the combined information as Personal Information under this Privacy Policy.

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Data about others

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Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

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3. How Your Information is Used

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In general, TrigoFi collects, uses, stores, and processes your information to, enhance, improve our Platform and Services we provide, to develop new services and to market our company and the services we offer.

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Here are some examples of how we use the information submitted, collected, received, or generated about you:

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• To operate, improve, maintain, administer and further develop the Platform and Services, and to operate and support our related business activities;

• To provide services that you request;

• To respond to comments and questions and provide customer service and user support;

• To send information including invoices, technical notices, updates, and support and administrative messages;

• To provide personalized experiences and recommendations, location customization, personalized help and instructions, or tother targeted improvements of the Platform and Services;

• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity as well as to address safety, security, or technical issues;

• To better understand how users access and use the Platform and Services;

• To conduct quality control and to fix technical and other errors or problems;

• To conduct market research

• To response to user desires and preferences;

• To comply with applicable laws, rules and regulations and any regulatory mandate or court order;

• To protect the rights and property of TrigoFi, our service providers, customers and others including enforcing our agreements, policies and Terms of Use;

• To use in any other manner or for any other purpose for which you have given express permission or consent to us. To the extent that you share your User Content through the Platform with other users or public forums on the Platform that User content may also be shared by us with other users, larger groups of users and/or the public in general.

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We may combine the information we collect (“Aggregate”) or remove pieces of information (“De-Identify”) to limit or prevent identification of any particular user or device to help with goals like research and marketing. We may perform analytics on your preferences, characteristics, use and interactions with the Platform to generate Aggregated information. Our Services may then analyze such Aggregated information to generate derivative data as well as reports and other output. Aggregated or De-Identified, Anonymous Information is not Personal Information, and this Privacy Policy does not apply to our sue of such Aggregated or De-Identified information.

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4. Information We Share or Disclose to Others or the Public

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TrigoFi does not sell your Personal Information. We may share Anonymous Information with third parties as described elsewhere in this Privacy Policy and for our commercial purposes. We do not share Personal Information with third-party service providers, except as described elsewhere in this Privacy Policy and as follows:

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• if you request or authorize it;

• to provide a service requested or contracted by you;

• to our third-party services providers that provide services to support the Services, such as payment processing, data analysis, email delivery, hosting, order fulfillment, infrastructure, network storage, customer support, Platform infrastructure, financial planning tools, data aggregation, technical support, and promotional services;

• to comply with applicable law, rules, and regulations, including, but not limited to tax laws;

• to comply with governmental and regulatory requests, court orders, and subpoenas;

• to protect our rights, property, and safety and their rights, property, and safety of our users and others or to prevent fraud;

• to enforce our rights arising from any contracts entered into between you and us, including the Terms of Use;

• with merchants that you transact with that already have Personal Information about you for the purpose of verifying information; and

• if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets) or in the event of bankruptcy.

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In order to provide the Platform and Services and in connection with our everyday business purposes and activities, we may share your Personal Information with third parties who perform services on our behalf. Examples of these third parties and services included public accounting firms, other professional firms, and certain other vendors and service providers who perform marketing, advertising, research, and analytic services on our behalf.

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We may also share your Personal Information with our third-party service providers to deliver our Services. TrigoFi may give you opportunities to interact with third party service providers through our Services, such as when we provide the opportunity to provide your Personal Information to a partner in orders to pre-populate your information on our third-party provider’s site, or when we automatically send you to a third-party service providers’ site for you to provide your Personal Information.

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We may permit third parties to provide analytics services that allow us to optimize the functionality of our Platform and inform our marketing activities. These third parties may use Cookies, and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and third parties to analyze and track data, determine the popularity of certain content and other websites, and better understand your online activity. Our Privacy Policy does not apply to, and we are not responsible for, third party cookies, web beacons, or other tracking technologies; and we encourage you to check the privacy policies of these third parties to learn more about their privacy practices. We use Google Analytics to help collect and analyze certain information for the purposes discussed above. You can learn more about Google Analytics’ data practices by clicking here and opt out of the use of cookies in web browsers by Google Analytics by clicking here. Your use of our Platform and Services constitutes your consent to these analytics services that are critical to our business operations, including the following:

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• Google Tag Manager manages the JavaScript and HTML tags that may be placed on the Platform. To learn more, click here.

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To find out more about online advertising and your choices related to such advertising, including retargeted ads, please visit the Network Advertising Initiative ("NAI") website and the Digital Advertising Alliance (“DAA”) website. You can opt out of such online based advertising by following the instructions below. Please note that the opt-out will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies or mobile Advertising IDs or Advertising Identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work, and you will need to opt out again.

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Web Browser Opt-Out

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To opt out in web browsers, please visit the opt-out pages of the Network Advertising Alliance and the Digital Advertising Alliance. To help preserve the choices that you make in the DAA’s WebChoices page, you can install the DAA’s “Protect My Choices” extension that is available here.

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Mobile Application Opt-Out

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To opt out in mobile apps, you can adjust the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, or in Android, visit Settings > Google > Ads > Opt out of interest-based ads). You can also opt out for companies that participate in the DAA’s AppChoices tool by downloading AppChoices here and following the instructions in the app. For more information about opting out on mobile devices, please see here.

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The Platform may also offer you the ability to interact with plugins from social media sites such as Facebook, Twitter, Pinterest, and others that may collect, use, and share information about you from our Platform as part of the operation of the plugins. These plugins are subject to the privacy practices of the respective third-party social media companies, which may differ from this Privacy Policy.

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Finally, we may disclose Personal Information in specific other cases with your consent or per your instructions.

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5. Protection of Your Information

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TrigoFi’s goal is to protect your information. TrigoFi employs physical, technical, and administrative safeguards to keep your information secure. TrigoFi uses third-party service providers with robust, industry-standard browser encryption, have secure facilities and implement systematic processes and procedures for data storage. TrigoFi limits access to your Personal Information to only those employees with authorized access who need to know the information in order to perform their jobs. If you choose to end your Services with TrigoFi we will continue to adhere to the privacy policies outlined in this Privacy Policy. While TrigoFi follows generally accepted standards to protect Personal Information submitted to us, both during transmission and once we receive it, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security.

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Changing or Accessing Your Information

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If the Personal Information on file for you changes, or if you no longer desire access to our Platform or Services, you may update your information by contacting us at contact@trigofi.com

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TrigoFi will retain copies of your Personal Information in a form that permits identification for as long as we deem necessary in connection with the purposes set out in this Privacy Policy unless applicable law or regulation requires us to preserve this information for a longer or shorter period of time. We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

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6. California Privacy Rights

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This Supplemental California Privacy Notice applies only to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of Personal Information TrigoFi has collected about them and whether TrigoFi has disclosed that Personal Information for business purposes (e.g., to a third-party service provider) in the preceding 12 months, subject to certain limitations and exemptions.  California residents may find this information as follows:

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Category of Personal Information Collected by TrigoFi

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Identifiers:

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• Name

• Postal Address

• Internet Protocol address

• Email address

• Social security number

• Driver’s license number, passport number or other similar identifiers

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Unique personal identifier (i.e. – persistent identifier such as device identifier, cookies, pixel tags, mobile ad identifiers or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers). Category of Third Parties Information is Disclosed to for a Business Purpose;

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• Service providers

• Advertising networks

• Data analytics providers

• Government entities

• Social networks

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Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

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• Other financial information

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Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some Personal Information included in this category may overlap with other categories. 

Category of Third Parties Information is Disclosed to for a Business Purpose;

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• Service providers

• Data analytics providers

• Government entities

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Protected classification characteristics under California or federal law

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• Age (40 years or older)

• Gender

• Marital status

• National origin

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Category of Third Parties Information is Disclosed to for a Business Purpose;

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• Service providers

• Data analytics providers

• Government entities

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​Commercial information

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• Products or services purchased, obtained, or considered

• Other purchasing or consuming histories or tendencies

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Category of Third Parties Information is Disclosed to for a Business Purpose;

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• Service providers

• Advertising networks

• Data analytics providers

• Government entities

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Internet or other electronic network activity

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Interaction with internet websites, mobile applications, or advertisements. Category of Third Parties Information is Disclosed to for a Business Purpose;

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• Service providers

• Advertising networks

• Data analytics providers

• Government entities

• Social networks

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Geolocation data

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Physical location of person or mobile device. Category of Third Parties Information is Disclosed to for a Business Purpose;

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• Service providers

• Advertising networks

• Data analytics providers

• Government entities

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Professional or employment-related information

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Current or past job history. Category of Third Parties Information is Disclosed to for a Business Purpose;

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• Service providers

• Data analytics providers

• Government entities

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Inferences drawn from other Personal Information to create a profile about a consumer

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• Preferences

• Characteristics

• Predispositions

• Behavior

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Category of Third Parties Information is Disclosed to for a Business Purpose;

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• Service providers

• Business partners and affiliates

• Advertising networks

• Data analytics providers

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Above in the sections “Information Collected or Received from You” and “How We Use Personal Information” cover the categories of sources from which we collect Personal information for our business and commercial use.

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“Sale” of Personal Information under the CCPA

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For purposes of CCPA, TrigoFi does not “sell” Personal Information. TrigoFi does not have actual knowledge of any “sale” of Personal Information of minors under the age of 16 years.

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Non-Discrimination

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California residents have the right not to receive discriminatory treatment by TrigoFi for the exercise of their rights conferred by the CCPA.

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Authorized Agent

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Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable request on behalf of your minor child. To designate an authorized agent, please contact us as described in “Contact Us” section.

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Verification

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To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Platform and Services.

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If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” section. We will process such requests in accordance with applicable laws.

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Right for minors to remove posted content

Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly viewable portions of the Platform or Services by contacting us as set forth in Contact Us section.

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7. Nevada Privacy Rights

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If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you would like to request that we do not sell your Personal Information going forward, or for any questions, please contact us as set forth in How to Contact Us section with the subject line “Nevada Do Not Sell Request” and provide us with your name and the email address associated with your account.

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8. Links to Other Applications and Services

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TrigoFi’s Platform and Services may contain links to interoperate with, and allow you to share content to and from third party services, websites, and applications. The fact that we link to a website, service, or application or allow you to share content with or through these third parties is not an endorsement, authorization, or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. Other websites, services, and applications follow different rules regarding the collection, use, storage, or disclosure of personal and other information. We encourage you to read the privacy policies or statements of the other websites, services, and applications you use.

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9. International Visitors

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TrigoFi’s Platform and Services are hosted in the United States and are only intended for residents of the United States. If you use TrigoFi’s Platform or Services from outside the United States with laws or regulations governing personal data collection, use, and disclosure that differ from the laws and regulations of the United States, please be advised that through the use of the Platform and Services, you are permitting the transfer off your personal information to the United States; and permitting the use of your Personal Information in accordance with this Privacy Policy.

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10. Other Information for You

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Children

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In order to use the Platform and Services you must represent that you are over the age of 18. Children under the age of 18 are not eligible to use the Platform and Services and must not attempt to sign -up with the Services and/or submit any Personal Information to use. TrigoFi’s does do not knowingly collect Personal Information from a person under 18. If we learn that we have collected Personal Information of a child under 18 we will take steps to delete such information from our files as soon as possible.

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Former Customers

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If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current and prospective customers.

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Changes to TrigoFi’s Privacy Policy

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We reserve the right to modify this privacy policy at any time, so please review it frequently. Any information that is collected via our Platform or Services is covered by the Privacy Policy in effect at the time such information is collected. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Platform or through our Services or by sending you an email or other notification and we’ll update the “Last Updated” date above to indicate when those changes will become effective.

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Limitation of Liability

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Even though we have taken reasonable commercial steps and efforts to prevent your Personal Information and other information covered by this Privacy Policy from being accessed, used, intercepted, or disclosed by unauthorized individuals, you should know and acknowledge that we cannot fully eliminate risks associated with your information. By providing to or allowing access by us to your information as a result of your us of the Platform and/or Services, you acknowledge and agree that we are not liable for (i) any special, indirect, consequential, incidental or punitive damages, costs or liabilities whatsoever arising out of or resulting from your use of the Platform or Services, including from uploading, posting, providing, storing, using, analyzing, transmitting, sharing and/or allowing access to Personal Information or other information and content; or (iii) and loss, disclosure, or use of Personal Information or other information and content.

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If you have questions

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If you have any comments, questions, or concerns about any of the information in our Privacy Policy, or any other issues relating to the processing of your Personal Information by TrigoFi under this Privacy Policy, please contact us at contact@trigofi.com