Welcome to Trickle, the AI-powered personal assistant application (“Application”) developed by Innovation Ventures BV. Your privacy is our number one priority and therefore we have drawn up a transparent and detailed privacy policy (“Privacy Policy”).
This Privacy Policy applies to all personal data collection activities of Trickle (as defined below) as the data controller, in particular to (i) our Website (defined below), (ii) our Application and (iii) all relations between Trickle, its customers, and its users.
Please read this Privacy Policy together with our other supporting & legal documents, such as Cookie Policy and General Terms and Conditions. Trickle may update this Privacy Policy in the future: the latest version can always be found on our Website or Application.
1. INNOVATION VENTURES AS DATA CONTROLLER
We are Innovation Ventures BV, a private limited company, incorporated and existing under the laws of Belgium, with registered office at Kempische Steenweg 293/16, 3500 Hasselt, Belgium, and with enterprise number BE-0788.646.424 (“Trickle” or “we | us”). Trickle is the developer and provider of the Application and the corresponding online services of Trickle (“Services”). In light of Privacy Legislation (defined below), Trickle will act as the data controller of your Personal Data (defined below) for the purposes described in this Privacy Policy. This entails that we are in control of (and therefore responsible for) your Personal Data.
If you read this Privacy Policy as an employee of a company relying on Trickle for business, please note that your employer is to be considered your data controller (as your employer decided to rely on the Application, allow the professional e-mail addresses to be used, your professional calendar, etc.). To set up Trickle for business, your employer might have provided us with some of your personal information (e.g. your name, your function, etc.). If you add your personal e-mail address to your Trickle account, we will act as the data controller.
2. ABOUT THIS PRIVACY POLICY
Trickle may collect, store, and process personal data related to you (“Personal Data”), for example when you visit www.trickle.ai and all related subdomains (“Website”), during interactions with us, or when you have a commercial relationship with Trickle. This Privacy Policy describes (i) how we collect, treat and store your Personal Data; (ii) the rights you can exercise in relation to your Personal Data; and (iii) the measures we take to protect it.
Trickle respects your privacy and we always strive to act in accordance with the applicable privacy legislation, such as (non-exhaustive): (i) the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”); (ii) the ePrivacy Directive 2002/58/EC of 12 July 2002, including future amendments and revisions thereof; and/or (iii) (future) applicable national legislation regarding the implementation of the GDPR (together: “Privacy Legislation”).
3. TRICKLE’S PROCESSING ACTIVITIES
Which Personal Data we collect, store and otherwise process and the purpose for which we process this data may differ depending on your relationship with Trickle. We identify five different scenarios:
You are browsing/using on our Website;
You (request to) receive updates and newsletters related to Trickle Services;
You use our Application;
You are seeking a commercial relationship with Trickle;
You are (or your company) is a partner or supplier of Trickle;
You are applying for a job at Trickle.
3.1 You are browsing on our Website
Contacting Trickle via the Website (live chat, email or messenger)
Purpose: To answer any questions you may have and/or to initiate a conversation
Personal Data:
First name
Last name
Nature of inquiry
Voluntarily provided information
Email address
Legal ground: Consent
Retention period: At least one year or as long as relevant in the context of your inquiry
Registering for waiting list of new Application release
Purpose: To secure your spot on the waiting list for the release of the new version of the Application
Personal Data:
First name
Last name (voluntary)
Work email address
Company and role
Type of calendar you use (Apple, Google, Outlook)
Information as to why Trickle is useful for you
Legal ground: Necessary for entering into a contract
Retention period: Until one (1) year after registration (insofar the information is not needed for other purposes)
Cookies
When browsing on our Website, we may also collect your Personal Data through cookies stored on your device(s) in order to optimize the functioning of the Website. Please read this Privacy Policy in conjunction with Trickle’s Cookie Policy.
3.2 You (wish to) receive newsletters and updates related to Trickle’s Services
Trickle’s newsletter | update
Purpose: Providing more information on (new features of) the Application or our Services
Personal Data:
Email address
Legal ground: Consent, or legitimate interest (if you already use our Services)
Retention period: Until you have withdrawn your consent or until you have objected to the processing of your Personal Data for this purpose (cfr. Section 8 - “Right to object”)
3.3 You use our Application
Using our Application with a personal e-mail address (as a professional user)
Purpose: If you are using the Application as an employee, your employer will act as the data controller of all the personal data related to the professional e-mail address, your professional calendars, etc. Nonetheless, you can opt to add your personal e-mail address to your Trickle account. If so, we will collect the data related to your personal e-mail address as a data controller, and solely use the data to allow you to use the Application as intended.
Personal Data:
First and last name
Personal email address
All data contained in your personal connected mailboxes, calendars, meeting invites, contact lists, etc.
Legal ground: Consent
Retention period: Max. two (2) years after the personal email address is disconnected by the use
Use of data for service enhancement and AI training
Purpose: Personal Data collected during the account creation and provision of the services is used to further optimize the services and train our AI solution
Personal Data:
First and last name
Personal email address
All data contained in your connected personal mailboxes, calendars, meeting invites, contact lists, etc.
Legal ground: Legitimate interest
Retention period: Max. two (2) years after the personal email address is disconnected by the user.
(Technical) support
Purpose: To enable communication with & to provide support to users via support@trickle.ai
Personal Data:
First name (if voluntary provided)
Last name (if voluntary provided)
Email address
Telephone number
Language
Voluntarily provided information
Legal ground: Necessary for the execution of the contract
Retention period: Until one (1) year following the termination of the commercial relationship between the customer and Trickle
3.4 You are seeking a commercial relationship with Trickle
General communication with Trickle
Purpose: If you are interested in Trickle’s services, we can provide more information
Personal Data:
First name
Last Name
Email address
Company/organization
Role/position
Voluntarily provided information
Legal basis: Legitimate interest
Retention period: Until one (1) year following your contact with Trickle
3.5 You are | your company is a partner or supplier of Trickle
General communication and providing of services
Purpose: To communicate with you in the scope of our commercial relationship
Personal Data:
First name
Last name
Email address
Telephone number
Company/organization
Role/position
Voluntarily provided information
Legal ground: Necessary for the performance of the agreement
Retention period: For the duration of your commercial relationship with Trickle and in accordance with any (data processing) agreements concluded with Trickle
Billing
Purpose: To pay your invoices for the services provided (incl. corresponding communication)
Personal Data:
First name
Last name
Email address
Telephone number
Address
Company/organization
Role/position
Bank account number (IBAN)
VAT number
Legal ground: Necessary for the performance of the agreement
Retention period: For the duration of your commercial relationship with Trickle and in any event accordance with any (data processing) agreements concluded with Trickle
3.6 You are applying for a job at Trickle
Selection and recruitment
Purpose: Selecting and assessing the suitability of applicants for a position at Trickle
Personal Data:
First name
Last name
Email address
Telephone number
Address
Company/organization
Role/position
Previous experience
Any other information on your
CV/motivation letter
Legal ground: Legitimate interest
Retention period:
One (1) month after deciding that you are not a suitable candidate, and we have no interest to add you to our recruitment reserve;
One (1) year if we wish to add you to our recruitment reserve if we obtain your consent.
4. LEGAL GROUNDS FOR PROCESSING
You can find more information on the applicable ground for each of the identified processing activities in Section 3 above.
In case the legal ground for processing happens to be legitimate interest, Trickle shall always (i) assess whether this is in proportion with the purpose for which your Personal Data was collected and used; and (ii) take your reasonable expectations into account and ensure a balance with your fundamental rights and freedoms. If we cannot guarantee this, we will stop storing / using your Personal Data or we will determine a new legal ground.
5. RETENTION PERIOD
You can find more information on the retention period of your Personal Data for each of the identified processing activities in Section 3 above.
We do not process your Personal Data any longer than is necessary for the purposes set forth in this Privacy Policy. We do store your Personal Data as long as your account is active or when the processing of your Personal Data is necessary to allow you to make use of our Application. If you want to receive a more detailed description of our different data retention periods, you can always contact support@trickle.ai.
6. SHARING OF PERSONAL DATA WITH THIRD PARTIES
Trickle shall not disclose your Personal Data to other third parties, unless it is necessary to achieve the purposes described in this Privacy Policy. In this respect, (some of) your Personal Data may be disclosed to hosting companies (hosting our online platforms), technology / marketing tool companies (helping us manage our customers and deliver messages) and analytics companies (helping us improve your experience on our website) (“Processors”).
Of course, we have made sure that the necessary agreements or similar legal binding acts are in place to ensure that these third parties treat your Personal Data in accordance with the Privacy Legislation (e.g. Article 28 GDPR).
In addition, Trickle may disclose your Personal Data:
To the competent authorities: for instance (i) if Trickle is obliged to do so under the law or under legal or future legal proceedings, and (ii) to safeguard and defend our rights;
In M&A context: meaning, if Trickle or the majority of its assets, is taken over by a third party, in which case your Personal Data – which Trickle has collected – may be one of the transferred assets.
Trickle shall not transfer, sell, hire out or pass on your Personal Data to third parties for purposes outside the purposes listed in this Privacy Policy, such as, but not limited to marketing purposes, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your Personal Data.
7. TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES
In case any of the above-mentioned Processors or other recipients are located in a country outside the European
Economic Area, Trickle will ensure that one or more of the listed EU-approved safeguards are in place:
European Commission adequacy decision;
Data transfer agreement (cfr. the Standard Contractual Clauses as provided in the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, including the performance of a transfer impact assessment);
Binding corporate rules; or
Certification mechanisms.
Every transfer to a third country, not recognized by an adequacy decision, is subject to an assessment by Trickle to determine if there is anything in the law and/or practices in force of said third country that may infringe on the effectiveness of the appropriate safeguards in place (as identified above).
Where required on the basis of aforementioned assessment, Trickle shall identify and implement appropriate supplementary measures to govern any data transfer to such international organization or a third country without an adequacy decision to ensure the level of data protection as required by EU law.
Furthermore, Trickle shall take all reasonable efforts to implement sufficient guarantees and measures to protect the Personal Data and ensure the effectiveness of the protection of the SCC’s, binding corporate rules and/or certification mechanisms.
8. YOUR PRIVACY RIGHTS
The Privacy Legislation (e.g. GDPR) grants certain rights over your Personal Data in relation to Trickle. You can exercise these rights by contacting us at support@trickle.ai. In light of the processing of your Personal Data, you enjoy the following privacy rights:
Access: you can ask for confirmation of whether or not Personal Data that relates to you is being processed. If so, you can ask us to give you copies of your Personal Data in structured and commonly used, machine-readable format.
Rectification: you can ask us to correct | complete any information you believe is inaccurate | incomplete.
Erasure: you can ask us to erase your Personal Data, under certain conditions. Please be aware that in this context certain services will no longer be accessible and/or can no longer be provided.
Objection: you can object to us processing your Personal Data, without any justification and/or the transmission of your Personal Data to third parties. We are not legally obliged to comply with your request if we can prove that we have compelling legitimate grounds which override your interests, rights and freedoms. When your Personal Data is used for direct marketing purposes, you have an absolute right to object to this processing activity.
Restriction of processing: you can ask us to restrict temporarily halt or “freeze” the processing of your Personal Data, e.g. when it is disputed whether your Persona Data was processed lawfully.
Data portability: you can ask us to transfer your Personal Data to another organization, or directly to you in a commonly used structured format readable by automatic device, under certain conditions.
Updates | Newsletters: if you no longer wish to receive any of our communications, you can object to these direct marketing communications by contacting us via email at support@trickle.ai. Upon receipt of your objection, we will stop processing your Personal Data for Trickle’s communications.
When submitting a request to exercise your rights, Trickle may ask for additional information to identify yourself.
If processing your request requires unreasonable measures (e.g. it is technically or organisationally almost impossible or extremely costly) then Trickle can charge you reasonable compensation in light of the administrative costs involved in fulfilling the request. Trickle can also refuse to process requests that are excessive, particularly due to their repetitive nature.
9. SECURITY OF PERSONAL DATA
The security and safety of your Personal Data is Trickle’s top priority. Trickle implements a variety of technical and organizational security measures designed to protect your Personal Data from (i) unauthorized access or disclosure and (ii) loss, abuse or alteration. However, Trickle is not in a position to guarantee absolute security.
The security of your account will also partly depend on the confidentiality and complexity of your password. You may not disclose to or share with any third parties your account. Trickle therefore strongly advises you, if you observe that someone has accessed your account or if your account has the risks being hacked, to immediately change your password and contact us at support@trickle.ai.
Trickle uses its best efforts to protect the confidentiality and security of your Personal Data. In case Personal Data breaches, Trickle undertakes to notify the Data Protection Authority without delay and, if possible, not later than seventy- two (72) hours after becoming aware of such Personal Data breach (if required by the Privacy Legislation).
Trickle shall in no event be liable for any direct or indirect damages that result from a wrong or illegal handling by third parties.
10. UPDATES
We reserve the right to modify this Privacy Policy at any time. Any changes to the Privacy Policy will be published on the Application and on the Website. In case of significant changes to the Privacy Policy that results in Trickle using your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a notice on the Application and/or send you an email notification.
11. NOTIFICATIONS AND QUESTIONS
Notifications under this Privacy Policy (such as exercising your data subject rights) and/or questions or complaints about the implementation of this Privacy Policy should be directed at support@trickle.ai.
12. COMPLAINTS
You are not satisfied with the manner in which we collect, store or otherwise treat or secure your Personal Data? We are sorry to hear that, and are prepared to take all measures to remedy this situation. Please do contact us as specified above.
You also have the right to lodge a complaint with the authorized supervisory authority (i.e. the Belgian Data Protection Authority or the data protection authority of (i) your residence or (ii) your workplace) should you consider that the processing of your Personal Data infringes the Privacy Legislation. You can send an email to the Belgian Data Protection Authority at contact@apd-gba.be or contact them via regular mail at Drukpersstraat 35, 1000 Brussels, Belgium. You can also call the Belgian Data Protection Authority: +32 (0)2 274 48 00.
If you would like to receive more information on how to contact them, please visit this webpage: https://www.gegevensbeschermingsautoriteit.be/contact.
13. RELEVANT LINKS TO RELATED DOCUMENTS
You can consult our Cookie Policy here.
You can consult our General Terms and Conditions here.