Our Commitment to Privacy
Troika IO, Inc ("Troika IO") and Troika Media Group, Inc ("TMG") companies are committed to maintaining the confidentiality, integrity, and security of personal information about our current and prospective customers.
How and why we obtain personal information
Troika IO takes great care to protect personal information about you and when we use it and we do so with respect for your privacy. Troika IO may collect public and non-public personal information about you from any of the following sources:
- Your applications (for example, name, address, Social Security number/ Government issued identification, birth date, occupation, employer, anticipated transaction volume, and sources of wealth)
- Transactional activity in your account (for example, account history and balances)
- Other interactions with Troika IO (for example, discussions with our customer service staff or information you enter into our websites)
- Information from other third-party data services (for example, to verify your identity and bank account ownership)
- Other sources with your consent (for example, from other institutions, such as when cash is transferred to Troika IO from your bank)
- References or from a background check report in connection with your application, as permitted by applicable law
How we use your personal information
Troika IO may use personal information about you to maintain and protect your account; process transactions in your account; respond to inquiries from you; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Troika IO may use personal information about you in the following circumstances:
- To contact you by mail, phone, text message, email, social media, fax, using our online website or other means, but not in a way contrary to your instructions to us or contrary to law.
- To monitor and record our conversations when we speak on the telephone (for example, to check your instructions to us, to analyze, to assess and improve customer service; for training and quality purposes; and for verification, fraud analysis and prevention purposes).
- To manage and respond to a complaint or inquiry.
- When you or others give us information verbally or in writing. This information may be on application forms, in records of your transactions with us or if you make an inquiry.
- To obtain information from credit reference agencies such as the Central Credit Register, credit reporting agencies, fraud prevention agencies, fraud detection service providers or public agencies such as property registration authorities, the Companies Registration Office or judgement registries.
- In connection with your status as a beneficiary, guarantor, director, representative of one of our customers, or in connection with your application for a Troika IO product or service.
How we protect information about you
Troika IO considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic, and procedural controls, and we regularly adapt these controls to respond to changing requirements and advances in technology.
At Troika IO, we restrict access to personal information to those employees who require it to develop, support, offer and deliver products and services to you or to those who require it in order to comply with a legal or regulatory obligation.
How long we hold your information
The length of time we hold your data depends on a number of factors, such as regulatory rules and the type of financial product we have provided to you.
Troika IO will retain your personal information in accordance with Troika IO Assets data retention obligations, policies, and any applicable legal or regulatory obligations or for the period of time permitted by local laws.
How we share information about you
We may share personal information about you with various Troika IO corporate affiliates, including internal service providers that perform, for example, data processing services, fraud detection and prevention services, printing and mailing, and marketing support.
Troika IO does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services.
We may, however, share information that we collect or generate about current and former customers with unaffiliated third parties, in the following circumstances:
- Unaffiliated service providers that perform services on our behalf, including printing and mailing services
- Third-party identity verification services for comparison or addition to their databases in order to verify the accuracy of your information and to confirm your identity to comply with applicable anti-money laundering requirements
- In response to Government agencies, other regulatory bodies, law enforcement officials (for example, for tax purposes or for reporting suspicious transactions), and legal processes (for example a warrant or subpoena, where we believe such disclosure is warranted or required)
- Other organizations as permitted or required by law (for example for fraud prevention)
- Other organizations with your consent.
Our service providers are obligated to keep the personal information that we share with them confidential and use it only to provide those services specified by Troika IO. Troika IO may transfer any and all information that we collect about you to third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Troika IO's assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
For residents of the European Economic Area
Disclosing your personal information may include transferring personal information to other countries than where you reside, and those countries may have different data protection regimes. If you are located in the European Economic Area (the "EEA") this may include countries outside of the EEA. As we transfer your personal information outside of the European Economic Area (EEA) to help us provide you products and services, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your information.
If you are an EEA resident you have the right to complain to the Data Protection Commission or another supervisory authority of your country or region about the way in which we process your personal information.
For California Residents
The California Consumer Privacy Act of 2018 ("CCPA") gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents have under the CCPA generally. Please note that the CCPA contains a number of exemptions and exclusions that apply to Troika IO, so some or all of these rights may not apply to you with regard to personal information collected by us. As used below, a "consumer" means a resident of the State of California and a "covered business" means a business that is subject to the CCPA.
- A consumer has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the categories and specific pieces of information the business has collected in the past year including sources of information, purpose for collecting information and the third parties of which the information is shared.
- A consumer has the right to request that a covered business delete any personal information about the consumer which the business has collected from the consumer. However, the covered business is not required to comply with such a request if the covered business needs to maintain the consumer's personal information for certain purposes set forth in the CCPA.
If you have a privacy request, please contact Troika IO customer support by email at email@example.com.
Privacy, security, and service in Troika IO's online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and double authentication (2fa) procedures, dispute judges, among other controls, to maintain the security of your online session and to protect Troika IO accounts and systems from unauthorized access.
When you interact with us through the Troika IO website, Troika IO manages personal information in accordance with all of the practices and safeguards described previously.
When you visit the Troika IO website, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on the Troika IO website. We use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving Troika IO website design and functionality, and personalizing your experience on the Troika IO website. Additionally, the following policies and practices apply when you are online:
Cookies and similar technologies
Connecting with Troika IO on social media
Protecting children's privacy online
Troika IO websites are not directed to people under the age of thirteen (13). Troika IO does not intentionally collect information on Troika IO websites from those we actually know are under 13, and we request that these individuals do not provide personal information through the sites.
Review or Update your Personal Information
Current Troika IO customers may review or update their personal information by calling Troika IO.
Where provided by applicable local law, you may access, modify or object to the use of personal information, or request that your personal information be transferred to you or another organization in a structured, commonly used and machine-readable format. For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. Please note that certain personal information may be exempt from such access, correction, or objection rights pursuant to local data protection laws. Please see the Contact Us section for Additional information regarding such requests.