⚠️ 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
- Name, email address, and company affiliation
- Billing and payment information (processed by third-party payment processors)
- Password and authentication credentials (stored encrypted)
- Account preferences and settings
API Usage Data
- API requests and query parameters
- Data access patterns and usage frequency
- API key activity and authentication logs
- IP addresses and device information
- Timestamps and duration of API calls
Aggregated Intelligence Data
- Publicly available social media mentions and posts
- News articles and media coverage
- Market data and sentiment scores
- Note: This data is aggregated and anonymized; we do not collect personally identifiable information about individuals
Communication Data
- Support tickets and customer service inquiries
- Feedback, survey responses, and feature requests
- Email communications with our team
Automatic Collection
- Browser type, operating system, and device information
- Referring URL and pages visited
- General geographic location (country/city level, not exact)
- Cookies and similar tracking technologies (see section on cookies below)
2. How We Use Information
We use the information we collect for the following purposes:
Service Delivery
- Authenticating your account and authorizing API access
- Generating API responses and aggregated data
- Processing and fulfilling your requests
- Maintaining uptime and system stability
Billing & Payment
- Processing subscription payments and refunds
- Generating invoices and billing statements
- Enforcing rate limits and usage-based billing
Service Improvement
- Analyzing usage patterns to optimize API performance
- Developing new features based on user feedback
- Conducting research and analytics
- Testing and debugging the Service
Security & Fraud Prevention
- Detecting and preventing unauthorized access
- Investigating suspicious activity and abuse
- Enforcing our Acceptable Use Policy
- Protecting against fraud and security threats
Legal & Compliance
- Responding to legal requests, court orders, and regulatory inquiries
- Complying with applicable laws and regulations
- Maintaining audit logs and record-keeping
Marketing & Communication
- Sending you product updates and announcements (with your consent)
- Notifying you of changes to our Terms or Privacy Policy
- Responding to your inquiries and support requests
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
- Public social media posts, mentions, and engagement metrics
- News articles and media coverage from published sources
- Market intelligence and trading data
- Sentiment scores and trend analysis derived from public content
What We Do NOT Collect
- Personally identifiable information (PII) such as names, phone numbers, or email addresses
- Passwords, payment information, or authentication credentials
- Private messages, direct messages, or non-public communications
- Health, financial, or other sensitive personal information
Data Normalization & Processing
All aggregated data is processed using our proprietary algorithms to:
- Remove or anonymize identifying information
- Normalize data across different platform formats
- Apply AI-powered sentiment scoring and trend detection
- Create abstract metrics and insights (not tied to specific individuals)
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
- All communications are encrypted using TLS 1.2 or higher (HTTPS)
- API calls are authenticated and encrypted end-to-end
Data at Rest
- Sensitive information (passwords, API keys) is hashed and salted
- Database encryption and file-level encryption for sensitive data
- Regular backups stored in secure, geographically redundant locations
Access Controls
- Role-based access control (RBAC) for employee access to systems
- Multi-factor authentication available for account security
- API key rotation and revocation mechanisms
Monitoring & Incident Response
- Continuous monitoring for suspicious activity and unauthorized access
- Security incident response plan and notification procedures
- Regular security audits and penetration testing
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:
- Your name and account email
- A description of your request
- Proof of identity (for security purposes)
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:
- Contract: Necessary to fulfill our Service Agreement with you
- Legitimate Interest: To improve our Service, prevent fraud, and ensure security
- Consent: For marketing communications and optional features (you may withdraw consent)
- Legal Obligation: As required by law (tax, compliance, court orders)
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
- Essential Cookies: Required for login, authentication, and core functionality
- Analytics Cookies: Track usage patterns to improve the Service
- Preference Cookies: Remember your settings and preferences
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: