⚠️ DRAFT — FOR REVIEW BY LEGAL COUNSEL BEFORE USE

Privacy Policy

Trinity Data Feed
Effective Date: [INSERT DATE]
Version: 1.0 (Draft)
Last Updated: April 2026

1. Information We Collect

Trinity Data Feed collects the following categories of information to provide, maintain, and improve our Service:

Account Information

API Usage Data

Aggregated Intelligence Data

Communication Data

Automatic Collection

2. How We Use Information

We use the information we collect for the following purposes:

Service Delivery

Billing & Payment

Service Improvement

Security & Fraud Prevention

Legal & Compliance

Marketing & Communication

3. Data We Aggregate

A core function of Trinity Data Feed is aggregating publicly available data from 55+ web platforms. It is important to understand what data we collect and how we treat it:

What We Aggregate

What We Do NOT Collect

Data Normalization & Processing

All aggregated data is processed using our proprietary algorithms to:

The output of our Service is business intelligence, not personal information about specific people.

4. Data Retention

We retain different categories of data for different periods:

Account Data

Account information (name, email, billing details) is retained throughout your subscription and for 90 days after termination. This allows you to recover your account within a grace period if requested.

Aggregated Intelligence Data

Aggregated data is maintained on a rolling 12-month window. Data older than 12 months is automatically purged unless you request longer retention for archival purposes.

API Usage Logs

Request logs and usage analytics are retained for 30 days for billing, performance monitoring, and security purposes.

Backups

Backup copies may exist for up to 30 days after deletion for disaster recovery purposes. After 30 days, all copies are securely destroyed.

Deletion Requests

You may request deletion of your account and associated data at any time. We will delete your data within 30 days, except where required to retain it for legal, tax, or security purposes.

5. Third-Party Services

Trinity Data Feed uses third-party service providers for specific functions. These providers are contractually obligated to protect your data:

Payment Processing

We use PayPal to process all subscription and one-time payments. Payment information is not stored on our servers. See PayPal's Privacy Policy for details on how they handle your data.

Cloud Hosting & Infrastructure

We host our infrastructure on cloud providers including [INSERT PROVIDER]. These providers have data processing agreements in place to protect your information.

Email & Communication

We use third-party email and support tools for customer communications. These services are configured to comply with our privacy standards.

Analytics

We may use analytics tools to understand how users interact with our Service. These tools are configured to respect user privacy and comply with regulations.

No data sharing for marketing: We do not sell, trade, or share your personal information with third parties for marketing purposes.

6. Security Measures

Trinity Data Feed implements industry-standard security controls to protect your information:

Data in Transit

Data at Rest

Access Controls

Monitoring & Incident Response

Security Notice: While we implement robust security measures, no system is completely secure. We encourage you to use strong passwords, enable two-factor authentication, and protect your API keys. Report any suspected security incidents immediately to security@trinitydatafeed.com.

7. Your Data Rights

Depending on your location, you may have certain rights regarding your personal data:

Right of Access

You may request a copy of the personal data we hold about you.

Right to Correction

You may request correction of inaccurate or incomplete information.

Right to Deletion

You may request deletion of your data (subject to legal retention requirements).

Right to Portability

You may request your data in a portable, machine-readable format.

Right to Withdraw Consent

You may withdraw consent for marketing communications at any time.

Right to Opt-Out

You may opt out of certain data collection (where permitted by law).

How to Exercise Your Rights

To exercise any of these rights, submit a request to privacy@trinitydatafeed.com with:

We will respond to your request within 30 days. If your request is complex or requires investigation, we may extend this period by an additional 30 days with notification.

8. GDPR Compliance

For users located in the European Union or processing data subject to the GDPR, Trinity Data Feed complies with all applicable GDPR requirements:

Legal Basis for Processing

We process your personal data on the following legal bases:

Data Processing Agreement

If you are a business customer in the EU, we offer a Data Processing Agreement (DPA) as required by GDPR Article 28. Contact legal@trinitydatafeed.com to execute a DPA.

International Data Transfers

If you are located in the EU and your data is transferred outside the EU, we use Standard Contractual Clauses (SCCs) or other mechanisms approved by the European Commission to ensure adequate protection.

Data Protection Officer

For GDPR-related inquiries, contact our Data Protection Officer at dpo@trinitydatafeed.com.

9. Cookies & Tracking Technologies

Trinity Data Feed uses cookies and similar technologies to improve your experience:

Types of Cookies We Use

Cookie Management

You may control cookies through your browser settings. However, disabling essential cookies may limit your ability to use the Service. For more information, visit aboutcookies.org.

10. Changes to This Privacy Policy

Trinity Holdings may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors.

Material changes (changes that affect your rights or significantly alter our practices) will be announced with at least 30 days' notice via email or our website. Your continued use of the Service after changes take effect constitutes acceptance of the updated policy.

We encourage you to review this policy regularly to stay informed about how we protect your information.

11. Contact & Data Privacy Inquiries

If you have questions about this Privacy Policy, our data practices, or wish to exercise your data rights, please contact:

Trinity Holdings — Privacy Team

General Privacy: privacy@trinitydatafeed.com

Data Protection Officer (GDPR): dpo@trinitydatafeed.com

Security Issues: security@trinitydatafeed.com

Postal Address: [INSERT MAILING ADDRESS]

Response Time: We aim to respond to all inquiries within 30 days.