Privacy Policy

Introduction

Welcome to Triton Digital's Privacy Policy ("Policy").  In this Policy, the use of the terms "Triton Digital", "our", "us" and "we" refers to Ando Media, LLC dba Triton Digital and/or, as applicable, Triton Digital Canada Inc., both of which are subsidiaries of iHeartMedia. When we process your personal information in the context of managing our customer relationship with you, operating our Website, and performing our marketing activities, the controller of your personal information is Ando Media, LLC (if you are located in the United States) or Triton Digital Canada Inc. (if you are located anywhere else in the world). If you are an employee, contractor, or job applicant, your personal information collected in those contexts will be subject to a separate privacy notice that we provide to you where and when appropriate.

We take data protection and privacy responsibilities very seriously. As such, we are committed to protecting the privacy of individuals ("you" or "your"), when you subscribe to our streaming, measurement, advertising and hosting services (collectively, the "Services") and visit our website at https://www.tritondigital.com/ (the "Website") or otherwise engage with us. As such, when you use our Services, visit our Website, or otherwise engage with us, you do so with the knowledge that your data will be collected and processed in accordance with the terms set out in this Policy. If you do not agree with our policies and practices as to how your data will be collected and processed, please do not use our Services, visit our Website, or listen to the audio content of our clients. This Policy does not apply to personal information that we collect on behalf of our clients in our role as a processor or service provider, such as information we collect on a client's behalf when you listen to our clients' digital audio streamers, podcasts, and mobile applications. In those cases, please refer to the privacy policy of the website or app where you accessed the audio content. 

In case you're in a hurry, we've compiled a quick overview of our Policy in the below table for easy reading.  From there, you can click through the specific sections of our Table of Contents that may be of interest for you.

Briefly Put:

Table of Contents

1. Important Information
2. How we collect your information
3. What types of information we collect
4. How and why we use your information
5. Sharing your personal information with third parties
6. Cookies
7. Your Choices and Marketing Preferences
8. Jurisdiction-Specific Privacy Rights
9. Data Security
10. Data Storage and Retention

1. Important information

About Us

Triton Digital provides technology and services that enable broadcasters, podcasters, and online streaming music services to build their audience, maximize their revenue, and streamline their operations.

We typically do not directly interact with the individual owners of information, unless the owner of the information is our client.  Rather, we typically process information (including personal information, if any) on behalf of our clients when they are using our Services.  

When we process personal information in the context of managing our customer relationship with you, operating our Website, performing our marketing activities, and combatting fraudulent and criminal activity in connection with the Services, including but not limited to, conducting invalid traffic analyses ("IVT Analyses"), the controller of your personal information is Ando Media, LLC (if you are located in the United States) or Triton Digital Canada Inc. (if you are located anywhere else in the world). When we process your personal information on behalf of our clients as part of the Services we perform on their behalf, the controller of your personal information is our client, not us.  This Policy is not intended to describe the privacy practices of our clients.  To learn about their privacy practices, please refer to the privacy policy of the website or app where you accessed the audio content.

How to contact us

If you have any questions about this Policy, including any request to exercise your legal rights, please contact us as follows:

• By email to [email protected]
• By post to Triton Digital, Attn: Privacy Officer, 1440 Ste.-Catherine St, West, Suite 1200, Montreal, Qc. H3G 1R8, Canada
• By phone at 1 (800) 860-8318

You have the right to lodge any complaints you have regarding our processing of your personal information with the relevant regulatory authority.  We care about your privacy, and we appreciate the chance to address your concern before you do so.

This Policy

This Policy sets out how Triton Digital collects, uses, and shares the information, including personal information or the equivalent terminology in your jurisdiction, that we may obtain from (i) our clients using our Services and (ii) individuals who interact with us, such as visitors to our Website.

You should read this Policy carefully so that you are fully aware of how and why we are using your information.

Links, other websites and other third parties

Our clients and/or our clients' contractors may use and operate the Services using their tags, pixels, cookies or other similar technologies for their business activities.  We are not responsible for our clients' and/or our clients' contractors' use of your personal information or any sort of tracking technologies, and this Policy is not intended to describe the privacy practices of our clients or our clients' contractors.  To learn about their privacy practices, please refer to the privacy policy of the website or app where you accessed the audio content.  Furthermore, our Website may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by Triton Digital.  This Policy does not apply to such third-party content.  We encourage you to review the privacy policies of these third-party websites or services.

Changes to this Policy

We may update this Policy from time to time to keep it up to date with legal requirements and the way we operate our business.  Please make sure to regularly check our Privacy Policy page to ensure that you understand any applicable changes.

Children

The Website and the Services are not directed to persons under 16. If you become aware that your child has provided us with personal information without your consent, please contact us at [email protected]. We do not knowingly collect personal information from children under 16 (or under 14 in Quebec). If we become aware that a child under 16 (or under 14 in Quebec) has provided us with personal information, we take steps to remove such information and terminate the child's account.

2. How we collect your information

From the first moment you interact with Triton Digital, we and our vendors are collecting information.  Sometimes you provide us with information, and sometimes information about you is collected automatically through cookies, pixels, and other tracking tools  (see Section 6 below for more information about these tools).

We collect information directly from you and your devices when:

• You use our Services
• You chat with us for customer support
• You communicate with us by telephone, email, or social media
• You sign up for newsletters, research, insights, webinars, or other information that we disseminate
• You fill out forms within our Website
• You browse any page of our Website
• You listen to our clients’ audio content, including digital radio stations, podcasts and mobile applications (as mentioned under Section 1 above, to combat fraudulent and criminal activity in connection with the Services, including by conducting IVT Analyses)
• If you are a business contact, we also collect personal information directly from you when we communicate with you, onboard you, or provide/receive products or services to/from you

We also receive personal information from vendors we hire to work on our behalf. For example, vendors that host or maintain our websites and apps for us may give us personal information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with information about you.

We may receive information about you from other third parties who we have business relationships with. These third parties might include our clients, marketing partners, and social media platforms that give us information they have collected either directly or indirectly from you. If you are a business contact, we also collect information from other individuals within your organization or from referring parties at different organizations.

We may get personal information from our affiliates, subsidiaries, and other companies under common control and ownership with Triton Digital, including the iHeartMedia family of companies. 

We combine information. We may combine information that we have collected offline with information we collect online. Or we may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time.

3. What types of information we collect

The information we collect and process about you varies depending on how you interact with Triton Digital (i.e., whether you are a content owner, a visitor of our Website or a listener of the audio content of one of our clients).

From users of our Services:

• Identifiers: Name, e-mail address, postal address, telephone number, and IP address.
• Customer record information: Any correspondence or information that you send us, and records of products or services purchased, obtained or considered.
• Purchase and Preference Information: Information about the products and content you browse or purchase, and records of your transactions and subscription purchases.
• Geolocation data: General location derived from an IP address (but not your precise geolocation within the ranges defined by applicable laws unless we obtain a separate consent from you).
• Device, Internet, or other electronic network activity information: Internet Service Provider, operating system, internet browser type, device type, settings, language, browsing activity (such as URLs, titles and content of the web pages and other information you search for or access through the Services), which ads and digital content you click on or engage with, whether you open and click through our emails, and information related to the manner in which you access the Services.
• Professional Information: If you interact with us on behalf of business customers, vendors, or other companies, in addition to other information described in this notice, we may also collect information like your job title, office location, compensation or payments, and engagement history with us. Please note that certain business contact information may be considered non-personal or subject to exceptions in some jurisdictions.
• Inferences: We may analyze the information that we collect in order to draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.
• Sensitive personal information: We will collect your payment information (such as bank information, payment card number, and expiration date), and account username and password for your Triton Digital account. In addition to the above, if you interact with us on behalf of business customers, vendors, or other companies, we may also collect your driver’s license number, background check information, and social security number if relevant to our relationship with you.

From visitors of our Website:

• Identifiers: IP address, unique identifiers, including mobile device identification
• Customer record information: any information you provide by submitting a form (such as name, e-mail address, postal address, telephone number, and any comments or questions you submit)
• Geolocation data: general location derived from an IP address (but not your precise geolocation within the ranges defined by applicable laws unless we obtain a separate consent from you)
• Device, Internet, or other electronic network activity information: Internet Service Provider, operating system, internet browser type, device type, settings, language, and browsing activity (such as URLs, titles and content of the web pages and other information you search for or access through the Services), which ads and digital content you click on or engage with, whether you open and click through our emails, and information related to the manner in which you access the Services
• Inferences: we may analyze the information that we collect in order to draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes

Personal information, once "anonymized" so that it cannot be linked back to you, is not subject to this Policy, and we may treat such information as non-personal information and use it without obligation to you, except where prohibited by applicable law.  We may also combine personal information with information that does not directly identify you; if we do so, we will consider the combined information to be personal information.

4. How and why we use your information

Operating in accordance with data protection law means that we can only use your information for certain reasons and where we have a legal basis to do so.

Purposes of Processing

We process personal information (including sensitive personal information) to (i) provide our Services in accordance with the agreement with you; (ii) for our legitimate business interests such as securing and protecting the integrity of our Website and improving our Services; (iii) to conduct business prospect and marketing activities, (iv) to provide you market data (e.g., rankers, reports, research, and other insights), if you have requested such data, and (v) as permitted to meet applicable legal requirements.

Use of Information

We use the personal information we collect about you (including sensitive personal information to the extent applicable) to:

• Provide, operate, maintain, improve, and promote the Services;
• Enable you to access and use the Services, including to view, stream, download, upload, collaborate on, and share content;
• Process and complete transactions, and send you related information, including invoices;
• Communicate with you, including to respond to your comments, questions, and requests, and to provide customer service and support;
• Provide you with information about services, features, surveys, newsletters, offers, promotions, contests, and events; 
• Provide you with news or information about us and our selected partners;
• Send you technical notices, updates, security alerts, and support and administrative messages;
• Verify your identity;
• Deliver and measure advertising on behalf of our clients and advertisers;
• Monitor and analyse trends, usage, and activities in connection with the Services and for marketing or advertising purpose;
• Monitor and analyse trends, usage, and activities in connections with accessing audio content for reporting and analytics purposes for our clients;
• Investigate and prevent fraudulent transactions, unauthorised access to the Services, and other illegal activities;
• Personalise the Services, including by providing content, features, or advertisements that match your interests and preferences;
• Enable you to communicate, collaborate, and share content with users you designate; 
• Conduct business prospect activities, when you have opted-in to such activities
• Provide you market data (e.g., rankers, reports, research, and other insights), if you have requested such data;
• Provide you a demonstration of our Services; 
• In the case of business contacts, to administer and manage our relationship with you and your employer (such as record-keeping, payments, communicating with you, tracking outcomes, and verifying your eligibility and suitability); and 
• For other purposes about which we may notify you from time to time.

We also may use the information we collect about you in an aggregate form to conduct analysis or research, such as research about customer demographics, internet use, and interests and behaviour. Aggregate data is not personal information.  Aggregate data may also be used for website administration, advertising, and promotional purposes. 

5. Sharing your personal information with third parties

We may share your personal information (including, in some cases, sensitive personal information) with third parties as described below:

• Corporate Parents, Affiliates and Subsidiaries: We may share the information we collect about you with our corporate parents, affiliates and subsidiaries for a variety of purposes, including business, operational and marketing purposes.
• Service Providers: We may share the information we collect about you with service providers (including vendors and technology partners) that perform certain functions or services to help us run our business, such as installation, maintenance and repair services, operations, billing and debt-recovery services, information technology, network services, market research, and marketing services.  We use the following categories of service providers:

1. Billing and collection providers, such as payment processors and organizations that assist us in assessing your credit and payment status;
2. Professional services consultants, such as auditing and accounting firms, law firms or other firms providing project-based resources and assistance;
3. Advertising and marketing services; 
4. IT vendors, such as entities that assist with website design, hosting and maintenance, data and software storage, and network operations; and
5. Vendors whose components or technologies are integrated into the Triton Digital products, services, and/or platforms, including those here: https://userguides.tritondigital.com/spc/sub/.

• Clients: We may share your information with our clients, if we have collected the information on a client’s behalf (as mentioned under Section 1 above, to combat fraudulent and criminal activity in connection with the Services, including by conducting IVT Analyses).
• Advertisers and marketing companies:  We may share your information with select advertising, marketing and analytics partners so that they can personalize the advertisements inserted into our clients’ audio content on behalf of our clients.
• Other third parties when required by law or in order to protect the safety of our Website and/or the Services: We may share your information with regulators, law enforcement, judicial bodies, or other third parties as necessary to comply with applicable laws or to protect the security of Triton Digital, its corporate parents, affiliates and subsidiaries, our users and customer, our Website, and/or the Services.
• In connection with a transfer of assets: If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of a bankruptcy, we may transfer your information to a third party as a result of, or in connection with, that transaction.
• Other third parties with your consent: We may share your information with other third parties if you consent to such sharing.

6. Cookies

We use "cookies", "pixel tags" and other technologies from time to time for the following purposes:

• Website Operations/Essential Cookies: To enable features that are necessary for providing you the Services on our site, such as identifying you as being signed in, tracking content views, and remembering your preferences.
• Analytics: To allow us to understand how our Services are being used, track site performance and make improvements.
• Personalized Advertising: To deliver personalized advertising based on your preferences or interests and to measure the effectiveness of ads.

Cookies are small bits of information that are stored by your computer’s web browser. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain features of our Website and/or Services.

We may allow third parties to place and read their own cookies, pixel tags, and other technologies to collect information through our Website and/or Services.  Our third-party service providers may use these technologies to collect information (i) that helps us with traffic measurement, research, and analytics, and (ii) that is used to serve personalized advertisements to you across the Internet tailored to your apparent interests.  To the extent we combine information from third party services with personal information we collect directly from you, we will treat the combined information as personal information under this Policy. Otherwise, the information collected and stored by third parties remains subject to their policies and practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on third party services.

7. Your Choices and Marketing Preferences

You have certain choices about how we use your personal information, including for marketing purposes:

• Direct Marketing: We take steps to limit direct marketing to a reasonable and proportionate level and only send communications which we believe may be of interest or relevance. If you want to stop receiving our marketing emails, you can click the "unsubscribe" or similar link that you find on any online newsletters you receive from us. Please note that if you opt out of receiving promotional communications, we will still send you non-promotional communications, such as those about your account or our ongoing business relations.
• Cookies: You can exercise certain choices with regard to the cookies that we or third parties place on our Websites and Services. You can block cookies by activating a setting on your browser allowing you to refuse the setting of cookies. You can also delete cookies through your browser settings.  If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our Website and/or our Services will not function fully.  In some cases, our Website may not be accessible at all.  You may exercise choices regarding the use of cookies from any of our third-party analytics providers as allowed by such third parties.
• Our Do Not Track Policy: Some browsers have "do not track" features that allow you to tell a website not to track you. These features are not all uniform; because there is as of yet no common understanding of how to interpret Web browser-based Do Not Track ("DNT") signals, we do not currently respond to undefined DNT signals.
• Interest-Based Advertising: We use cookies and other tracking tools to collect information about your use of the Websites and Services over time and across devices for purposes of serving you with interest-based advertising. To learn more and to opt out of certain uses of cookies for purposes of interest-based advertising, visit www.aboutads.info/choices  and https://optout.networkadvertising.org or by disabling advertising cookies by clicking the "Do Not Sell or Share my Personal Information" link in the footer of this webpage. You can also visit www.aboutads.info/appchoices for information on the DAA's opt-out program for mobile apps. Choices you make are device-specific and browser-specific. If you use different browsers on your device, or multiple devices, you will need to opt out of from each browser and on each device that you use. Please be aware that, even if you opt out of being tracked for certain kinds of interest-based advertising, you may continue to receive non-personalized ads and contextual ads.

8. Jurisdiction-Specific Privacy Rights

Below, we describe additional privacy rights you may have based on the laws of where you live.  

Except as otherwise provided by applicable law, note that for purposes of these requests, personal information does not include information we have collected as a service provider to our clients. 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights described below). However, we may charge a reasonable fee if your request for access is unfounded or excessive if permitted by law.  Alternatively, we may refuse to comply with the request in such circumstances.  In addition, there may be requests that we are unable to process because of other legal requirements.  If a request is denied, we will notify you of the reason.

You may submit a request on your own behalf, or you may have a request submitted on your behalf by an authorized agent or, if you are a minor, by your parent or legal guardian.  When an authorized agent submits the request on your behalf, please ensure the authorized agent identifies himself/herself/itself as an authorized agent. Your request must provide sufficient information that allows us to reasonably verify that you are the person about whom the requested personal information relates (or an authorized agent for such person). Therefore, please provide us with the following information:

• a clear description of your matter; and
• your contact information

Depending on the nature and sensitivity of your request, we may request additional verification information (which we will describe to you at the time). We will use the information you provide only for the purpose of verification. This is a security measure to ensure that personal information is not disclosed to a requesting person who has no right to receive it.  

Your EU and UK Privacy Rights

For purposes of EU and UK data protection law, we process personal information on the following legal bases:

• Contract: It is necessary for our performance of the contract you have agreed to enter with us.  If you do not provide your personal information to us, we will not be able to carry out our obligations under the terms of the contract.
• Legitimate Interests: We process your personal information if it is based on our legitimate interests.  For example, we may process personal information in reliance on a legitimate interest in the effective and lawful operation of our business, the effective delivery and improvement of our products, services, and platforms, information security operations, compliance with laws and regulations, compliance with requests for disclosure to law enforcement, courts, and regulatory bodies, and to prevent and detect fraud or suspected fraud.  In relation to general inquiry and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support.  You can object to the processing that we carry out on the grounds of legitimate interests.  See below to find out how.
• Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you.  You have the right to withdraw your consent. Please see below to find out how.
• Legal Claims: We need to process your personal information to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).

If you are in the EU or UK, you may have legal rights in relation to the personal information about you that Triton Digital holds: 

• Right to be informed - You have the right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights.  This is why we are providing you with the information in this Policy;
• Right of Access – You have the right to be informed of and request access to the personal information we process about you;
• Right to Rectification – You have the right to request that we amend or update your personal information where it is inaccurate or incomplete;
• Right to Erasure – You have the right to request that we delete your personal information.  This is not a general right to deletion, and there are exceptions to this right;
• Right to Restrict – You have the right to request that we temporarily or permanently stop processing all or some of your personal information;
• Right to Object – You have the right, at any time, to object to us processing your personal information on grounds relating to your particular situation and the right to object to your personal information being processed for direct marketing purposes;
• Right to Data Portability – You have the right to request a copy of your personal information in electronic format and the right to transmit that personal information for use in another party’s service;
• Right not to be subject to Automated Decision-making – You have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

Eligible EU and UK data subjects may make a privacy request through the following methods:

• By using our online form here
• By email to [email protected]

If you are located in the EU or UK, you have the right to lodge a complaint with your EU or UK Supervisory Authority. However, if you have a complaint regarding the processing of your personal information, we request that you first contact us, and we will reply in a timely manner.

Your United States Privacy Rights

Where provided for by applicable privacy laws, you may be entitled to exercise some or all of the rights described below with respect to your personal information:

• Right to Access / Right to Know – You have the right to confirm whether we process personal information about you and to request that we disclose to you the following: (i) the categories of personal information that we have collected about you (including sensitive personal information); (ii) the categories of sources from which we have collected personal information about you; (iii) the business or commercial purpose for collecting or selling your personal information; (iv) the categories of personal information that we have sold about you and the categories of outside parties to whom the personal information was sold; (v) the categories of personal information that we have disclosed about you for our business purposes and the categories of suppliers to whom the personal information was disclosed; (vi) a portable copy of the specific pieces of personal information that we have collected about you; and (vii) information about the logic involved in any automated decision-making processes used by us (if applicable), as well as a description of the likely outcome of the process with respect to you.
• Right to Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
• Right to Opt-Out of Sale or Sharing of your Personal Information – You can request that we not “sell” or “share” your personal information to or with third parties for monetary or other consideration, as defined under applicable privacy laws, by clicking the “Do Not Sell or Share My Personal Information” link in the footer of this webpage. If you would like to opt out of cookie-based tracking for advertising purposes, you should visit www.aboutads.info/choices and https://optout.privacyrights.info to opt out of certain uses of cookies for advertising purposes.  Your selections are specific to the device, website and internet browser you are using.  Your selections are deleted whenever you clear your cookies or internet browser’s cache.
• Right to Correct or Update – You have the right to request that we correct, update or modify the personal information we maintain about you. If you have an account, you can also update your profile information any time by visiting the account settings page within your account.
• Opt-out of Automated Decision-Making - You have the right to request to opt-out of any profiling or automated decision-making, to the extent we engage in those processing activities.
• Limit the Use of your Sensitive Personal Information - In relation to any sensitive personal information identified in Section 3 above, you can request that we limit our use and sharing of such information only to those uses which are set forth under applicable privacy laws.  Please note that we only use your sensitive personal information as necessary to carry out our relationship with you (such as providing our goods and services that you’ve requested, maintaining the quality of our services, or protecting our services against illegal activity), or as otherwise allowed by relevant privacy laws. 

Eligible U.S. residents can request to exercise these rights through the following methods:

• Online using one of our webforms:
• Complete this form to exercise your rights to correct your information, delete your information, understand the categories/use of your information, or request a portable copy of your information
• Complete this form to exercise your right to not sell or share your personal information. 
• By email to [email protected]

Triton Digital will not discriminate against you because you made any of these requests.  We will take reasonable steps to verify your identity prior to responding to your requests.  The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. As noted earlier, if you are an employee, contractor, or job applicant, your rights with respect to your personal information collected in those contexts will be described in a separate privacy notice that we provide to you where and when appropriate.

Additional California Privacy Disclosures 

For purposes of California privacy laws, please note the following: 

We collect and use the following categories of personal information for the business and commercial purposes described in this Privacy Policy: identifiers; customer record information; commercial information; geolocation data; device, Internet, or other electronic network activity information; professional or employment-related information; inferences; sensitive personal information; and inferences. See Section 3 above for further details.

We use the above categories of personal information for the business and commercial purposes described in Section 4 above.

We collect these categories of personal information from the following categories of sources, as more fully described in Section 2 above: directly from you; from vendors we hire to work on our behalf; from other third parties who we have business relationships with, which might include our clients, marketing partners, and social media platforms; and from our corporate affiliates, subsidiaries, and/or parents. 

We disclose each of the foregoing categories of personal information to our corporate parents, affiliates and subsidiaries; service providers; advertisers and marketing companies; clients; other third parties when required by law in order to protect the safety of our Website and/or the Services; in connection with a transfer of assets; and other third parties with your consent. See Section 5 above for more details.

We may “sell” or “share” the following categories of your personal information: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; Internet or other electronic network activity; geolocation data; and inferences.  We sell and share this personal information to and with advertisers and advertising networks. We do not knowingly sell or share the personal information of consumers under 16 years of age.

We do not use or disclose sensitive personal information for purposes other than those specified under applicable California privacy regulations.

Your Canada Privacy Rights

If you are a resident of Canada, you have the rights detailed below:

• Right to access or rectification of your personal data: you may request to access, review, and request correction of your personal information held by Triton Digital.  You can submit a request regarding your personal information by using the contact information provided above.  We reserve the right not to change personal information if we disagree that it is incorrect, but we will append your requested alternative information.  We may not provide access to personal information where permitted or required to deny access by the applicable law, for example, where the information requested would disclose the personal information, including opinions, of another individual or if it is subject to solicitor-client or litigation privilege.
• Right to erasure of your personal data: you may request the deletion or removal your personal data held by Triton Digital if there is no valid reason for us to continue to process it. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable.
• Right to portability of your personal data: You may request the transfer your personal data held by Triton Digital to you or a third party, in which case we will provide you, or the third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated or computerized personal data information. 
• Right to withdraw consent: You have the right to refuse to provide or to withdraw your consent to processing of your personal information at any time with effect for future processing.  This would not affect processing where the applicable law allows us to process personal information without consent. Please note that if you withdraw your consent, we may not be able to provide you with certain products or services, and this may prevent us from responding to inquiries, providing technical support or otherwise assist you in connection with the use of our products and services.

Eligible residents of Canada may make a privacy request through the following methods:

• By using our online form here
• By email to [email protected]
• By post to Triton Digital, Attn: Privacy Officer, 1440 Ste.-Catherine St, West, Suite 1200, Montreal, Qc. H3G 1R8, Canada

9. Data Security

We have implemented and maintain technical and organisational security measures, policies, and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to personal information appropriate to the nature of the information concerned. 

Nevertheless, no transmission or storage of information on the Internet is 100% safe.  As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

10. Data Storage and Retention

Triton Digital hosts data with hosting service providers in numerous locations including the United States, Canada, Latin America, Europe and Australia. We may disclose your information to our hosting service providers or any other service providers in those countries or any other country in which we may conduct our business from time to time. As a result, this information may be subject to access by and disclosure to government and law enforcement agencies in those countries according to their laws. If you're located in the European Union and/or the UK, your personal information may be transferred and stored in countries outside the European Union and/or the UK, including to the United States, that are subject to different standards of data protection. The standard of data protection in the United States and in certain other countries where we may process your information may not be considered by the European Commission and the UK government to be adequate when compared to the data protection standards of the EU, EEA and the United Kingdom. By using our Websites or Services, or by submitting your personal information, you consent to such transfer, storing and processing. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable laws.

We will only store your personal information (including your sensitive personal information) for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Policy. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances, where we are legally permitted to, we may store your personal information for longer periods of time. The criteria used to determine the appropriate retention period includes:

• regulatory requirements that we are subject to, including laws and regulations related to tax, employment, accounting and securities; 
• whether a legal claim might be brought against us, for which the information would be relevant; 
• the necessity of the information to provide our Services to our customers; and/or
• the types and sensitivity of personal information being processed