Triplo.AI Privacy Terms 2023.02.13

Last updated 2023.02.13

Overview

This privacy notice (“Privacy Notice”) describes how ELBRUZ TEKNOLOJİ LİMİTED ŞİRKETİ ("Triplo.AI") will process your personal data, where Triplo.AI acts as a controller of your personal data; namely, in connection with your use of the Triplo.AI owned and operated websites including without limitation www.triplo.ai and any of its related or subdomains (the “Website(s)“), including the Triplo.AI portals (such as Technical Community, Partners Community, Training and Certification Portal and the Marketplace) (the “Portals“); in connection with certain instances of your use of Triplo.AI's products, services, and other technical applications and tools (the “Services“), where Triplo.AI acts as the controller of your personal data; in connection with Triplo.AI's relationship with our business-to-business contacts, such as with the representatives of our service providers, processors, or suppliers; and in connection with other occasions where Triplo.AI collects and processes your personal data, as further detailed in this Privacy Notice.

References to “we”, “us” or "Triplo.AI" in this Privacy Notice mean ELBRUZ TEKNOLOJİ LİMİTED ŞİRKETİ, and any of its affiliated entities, as far as they are related to the operation of the Websites, the Portals or the Services or as otherwise relevant under this Privacy Notice. Our contact details for these entities and their respective office locations can be found here. The Triplo.AI entity that will be responsible for processing your personal data will depend on how you use Triplo.AI Services and your geographical location.

References to “we”, “us” or "Triplo.AI" in this Privacy Notice mean ELBRUZ TEKNOLOJİ LİMİTED ŞİRKETİ, and any of its affiliated entities, as far as they are related to the operation of the Websites, the Portals or the Services or as otherwise relevant under this Privacy Notice. Our contact details for these entities and their respective office locations can be found here. The Triplo.AI entity that will be responsible for processing your personal data will depend on how you use Triplo.AI Services and your geographical location.

References to “you” or “your” mean the individual who has or may in the future enter into a relationship with Triplo.AI as a user of Triplo.AI mobile applications (excluding: (i) when you are using Triplo.AI Mobile on behalf of your employer or customer; or (ii) Triplo.AI's Identity mobile application, in which case Triplo.AI will be processing the data on behalf of our customer), a representative of a prospective or existing customer or authorized channel partner, a user of our Website or Portals, an investor, or otherwise use the Triplo.AI Websites or Services. When you are browsing our Websites or using our Services for your own benefit, Triplo.AI is the “controller/responsible” (as such term is used in the Turkey Personal Data Protection Regulations (“KVKK“).

References to “personal data” mean information that identifies you or is reasonably capable of identifying you. It also includes similar terms under data privacy laws, such as “personal information” and “personally identifiable information.”
If you are an end user of Triplo.AI Services, this Privacy Notice does not apply to our processing of your personal data. The controller and/or the business of your personal data is your employer or the organization to which Triplo.AI is providing services and which is a Triplo.AI customer. Triplo.AI is the “processor” or “service provider” of such personal data under the KVKK, respectively. In such case, the processing of the personal data by us is subject to a data processing agreement between the applicable Triplo.AI entity and such customer, and this Privacy Notice does not apply to you.

General

At Triplo.AI, we pride ourselves on being an organization that has a privacy-minded culture consistent with legal requirements.

When you use the Triplo.AI client in your computer or mobile, we take all necessary measures to ensure your privacy and safety, including, but not limited to, the encryption of the data transmited from and to our servers (TLS) and the anonymization of all data that may uniquely identify the you (e.g. user names, personally identifiable information, IP addresses); further, we do not read, proccess, or store your clipboard. We are just collecting statistics of which words are used mostly with "ooo" command to improve our service we may collect information about your use of the services, such as the types of smart prompts that you use, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, computer connection, IP address, and the like.

You can contact Triplo.AI at any time to request more information about the way we process personal data by using this form or sending an email to privacyrequest@triplo.ai. We will respond to your request in the timescales prescribed by applicable laws.

You should read this Privacy Notice in conjunction with the terms and conditions of the Website, or in conjunction with the terms and conditions applicable to you in the specific context.

The use of Triplo.ai to begins with the user providing a prompt. This prompt is then sent to OpenAI, which uses its artificial intelligence service to generate content based on the user prompt. After the API call is made, Triplo.ai receives the content generated by OpenAI and then delivers it to the user.

Triplo.ai is not capable of generating content itself. Instead, it acts as a bridge between users and OpenAI, allowing users to benefit from OpenAI's advanced AI capabilities. Triplo.ai's services include managing and monitoring OpenAI API calls done by it's users.

Since we are using OpenAI as a third party, your personal data might be processed, read or stored by OpenAI. With using our application, user/customer accept that user/customer’s data could be read, processed or stored by OpenAI. Also user/customer accept that Triplo.AI doesn’t have any responsibility for the personal data that read,processed or stored by Open AI.

What personal data does Triplo.AI process and for what purposes?

The following describes the types of personal data that Triplo.AI processes about you, in which instances this personal data is collected and processed, the purposes of the processing, and the lawful bases for processing (where the KVKK applies). We collect the personal data described below from you or the company you represent during your interactions with us.

When you use one of our Websites, Portals, Software or join a physical or virtual event hosted by Triplo.AI

Instance of data collectionPersonal Data ProcessedPurposes of ProcessingLawful Bases for processing where the GDPR applies
When you browse our Websites• Names, usernames or similar identifiers used on our Websites
• information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, internet service provider (“ISP”), operating system, date/time stamp, clickstream data and analytics data regarding the actions you take on the Websites (such as the web pages viewed and the links clicked on)
• Administer our Websites
• provide you with relevant website content
• measure the effectiveness of the content served to you and of our marketing efforts
• analyze and improve the use of the Websites
• provide more relevant and personalized information, promote our business in various platforms and assess the success of our promotional activities
• fraud prevention and security of our Websites
Our legitimate interests in monitoring and improving our Websites and/or your consent where necessary under applicable law.
When you submit a contact form or request a demo form through the Websites, download any whitepapers or other downloadable materials from the Websites, and/or when you subscribe for a free trial• First and last name, email address, telephone number, company name, role, job title, department, and country• To reply to your request or query
• to set up a demo at your request
• to send the requested materials to you, if requested
• to send you communications related to our products, services, and/or events through different channels
Our legitimate business interests and/or your consent where necessary under applicable law (e.g. where you have provided your consent for CyberArk or our Partners to send you marketing communications).
When you set up an account in our Portals• First and last name, telephone number, mobile phone number, country, language, email address, job function, organization, and address• To set you up as an authorized user of the Portal and create a user profile for you
• to manage and administer your use of the Portals
• to send you communications (including marketing) related to our products, services or events via different channels
• to operate our business, for example, transmitting your personal data within the CyberArk group for internal administrative purposes, such as auditing and accounting
Our and/or our customers’ legitimate business interests and/or your consent where necessary under applicable law (e.g. where you have provided your consent to be included in our marketing mailing lists)
When you log into and use our Portals• Credentials used to log into our Portals
• Browser type and browser language, referring URL, your IP address, ISP, operating system, date/time stamp, and clickstream data and the actions you take on the Portals (such as the web pages viewed, the links clicked on and searches performed)
• To provide you with support and training related to the Portals
• to understand how our partners/customers use the Portals and analysis thereof for the purpose of monitoring and improvement of Portals
• measure the effectiveness of the content served to you
• to send you communications (including marketing) related to our products, services or events via different channels
Our and/or our customers’ legitimate business interests and/or your consent where necessary under applicable law (e.g. where you have provided your consent to be included in our marketing mailing lists)
When you set up an account for use of any of our Services• First name, last name, phone number, phone model and operating system, and, if you choose to provide this, a profile picture• To allow you access to the services, in accordance with the specific functionality for which you have access rights and authorizations
• provide technical support
• measure our marketing efforts and performance
• to operate our business, for example, transmitting your personal data within the CyberArk group for internal administrative purposes, such as auditing
• to notify you about transactional issues, or other issues relating to CyberArk services (such as new features, version releases) or invitations to our customers related events
Fulfilment of our contractual obligation
Our legitimate business interest
When you register to the event• First and last name, email address, telephone number, company name, role, job title, department, and country• To set you up as a registered participant in the event
• to manage and administer your participation in the event including sending your communications related to your attendance
• to send you communications (including marketing) related to our products, services or events via different channels
• to operate our business, for example, transmitting your personal data within the CyberArk group for internal administrative purposes, such as auditing and accounting
Fulfilment of our contractual obligation, our legitimate business interest and/or your consent where necessary under applicable law
When you log into the event and during the event in which you participate (online events)• Log in and out time, time spent, any information that you choose to provide for networking purposes, and chat stream• To manage and enable your access to the event
• to provide you with technical support related to the event
• to keep records regarding our events and analysis thereof for the purpose of planning of future events
• to improve our understanding of your needs and interests
• understand how you and other participants benefit from the events, including to assess which content is the most useful
• to send you communications (including marketing) related to our products, services or events via different channels
Fulfilment of our contractual obligation, our legitimate business interest and/or your consent where necessary under applicable law
During the event in which you participate (in person)Business card information• To send you communications (including marketing) related to our products, services or events via different channelsFulfilment of our contractual obligation, our legitimate business interest and/or your consent where necessary under applicable law
When we request and you submit feedback to a survey, for example, following closing of a support ticket, delivery of our services or following training;• Your responses to the survey• To consider your feedback and assess the level of service we have provided, and to improve our processes and services
• follow-up with you depending on the nature of your feedback
Our legitimate business interests including as necessary for the performance of the contract with the relevant customer/partner/investor
When delivering communications to you (including marketing communications and advertising)• Your email address, display name of your email account, information about your interactions with our communications (e.g. links clicked on) =, actions that you take on our and our partners’ websites such as your visits or interactions with such websites• To monitor and analyze electronic communications sent or received by our users, including to tailor our communications accordingly and measure our marketing efforts
• security and fraud prevention
• to cater to your requests, for example, to reply to your inquiry, arrange a meeting for you, arrange a demo for you, etc.
• measure the effectiveness of our (online) advertising, improve our marketing practices, and helps us deliver more relevant communications and advertising to you and people like you (including on social media)
Our legitimate business interests and/or your consent where necessary under applicable law
When you conduct business dealings with us as a representative of a service provider, contractor, processor or supplier• Your contact information, such as name, title, company name, email address, address, and phone number• To enter into and perform under a contract providing us certain services
• to communicate with you about potential business dealings
Fulfilment of our contractual obligation, our legitimate business interest, and/or your consent where necessary under applicable law

 

When delivering communications to you (including marketing communications and advertising)

Your email address, display name of your email account, information about your interactions with our communications (e.g. links clicked on), actions that you take on our and our partners’ websites such as your visits or interactions with such websites
• To monitor and analyze electronic communications sent or received by our users, including to tailor our communications accordingly and measure our marketing efforts
• security and fraud prevention
• to cater to your requests, for example, to reply to your inquiry, arrange a meeting for you, arrange a demo for you, etc.

Our legitimate business interests and/or your consent where necessary under applicable law.


When you conduct business dealings with us as a representative of a service provider, contractor, processor or supplier

• Your contact information, such as name, title, company name, email address, address, and phone number
• To enter into and perform under a contract providing us certain services to communicate with you about potential business dealings

Fulfilment of our contractual obligation, our legitimate business interest, and/or your consent where necessary under applicable law.


When delivering communications to you (including marketing communications and advertising)

• Your email address, display name of your email account, information about your interactions with our communications (e.g. links clicked on) , actions that you take on our and our partners’ websites such as your visits or interactions with such websites
• To monitor and analyze electronic communications sent or received by our users, including to tailor our communications accordingly and measure our marketing efforts
• security and fraud prevention
• to cater to your requests, for example, to reply to your inquiry, arrange a meeting for you, arrange a demo for you, etc.
• measure the effectiveness of our (online) advertising, improve our marketing practices, and helps us deliver more relevant communications and advertising to you and people like you (including on social media)


Our legitimate business interests and/or your consent where necessary under applicable law.
In addition to the above, under some circumstances we may collect and process other types of personal data; in these cases, we will provide an in-time notification with respect to the additional personal data collected and processed.
In addition to the above uses of your personal data, we will also process your personal data for the following purposes:


   1. To prevent, detect and fight fraud or other illegal or unauthorized activities
   2. To ensure legal compliance – from our side (to legal requirements that apply to us (such as various records keeping) and to our obligations under the Terms of Use) and from your side (compliance with laws applicable to you and with the Terms of Use)
 

For some of the above processing, we may rely on multiple legal grounds. For example, we process some information both for our legitimate interests as a business regarding user compliance with applicable terms of use and to comply with legal obligations applying to us (GDPR Article 6(1)(f) and 6(1)(c)).

How will Triplo.AI disclose your personal data with other parties?

We may disclose your personal data with other parties when outsourcing certain tasks or processes to service providers or subcontractors, whether in relation to our services, website operation or internal requirements. We use the following categories of service providers or contractors who are only authorized to process your personal data as necessary to provide these services to us:

  • Relationship management software
  • Marketing automation platform
  • Webinar software
  • E-mail platforms
  • Hosting provider, including website hosting
  • Customer success software
  • Online community platforms
  • Human Resources Information Systems
  • Background check service providers
  • Analytics providers
  • Customer reference management software
  • Survey tool service providers
  • Learning management system software

We may also disclose your personal data with our partners when we run or sponsor events with them and with social media and/or advertising companies to personalize our communications and your experience on our and other websites. These third parties may also disclose your personal data with us where you have provided your information to them, and they have the right to disclose this information to us under applicable law. This includes contact details and other identifiers.

Where you are a member of staff at a Triplo.AI Customer or Partner and you register for a Triplo.AI event, this information may be shared with that Customer or Partner.

We may use or disclose personal data if required by applicable law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud and/or to comply with a judicial proceeding, court order, legal process or other governmental authority; provided, however, that unless prohibited by law, we will use reasonable efforts to give you notice to enable you to seek a protective order or take other appropriate action.

We may also disclose your information to third parties in and outside your country only to the extent allowed by applicable law. We may also transfer your information if we sell, buy, merge or partner with other companies or businesses, undergo a reorganization, bankruptcy, or liquidation; or otherwise undertake a business transaction or sell some or all of our assets. In such transactions, your information may be among the transferred assets.

 

Processing Data Outside of European Economic Area (“EEA”)

Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the European Commission data is adequately protected by KVKK.

 

How long will Triplo.AI store your personal data?

We will retain your personal data for such periods of times required or permitted by law or subject to our retention policies as may be in place from time to time. Triplo.AI takes the following considerations into account in order to determine the retention period:

  • The time required to retain personal data to fulfill business purposes, including providing products and services
  • Maintaining corresponding transaction and business records
  • Controlling and improving the performance and quality of the Websites
  • Handling possible user queries or complaints and locating problems
  • Whether the user agrees to a longer retention period
  • Whether we reasonably believe that this data will be needed for the handling of any litigation
  • Whether the laws, contracts, and other equivalencies pose any requirements for data retention.

 

Security of processing

We will maintain administrative, physical and technical safeguards designed to protect the security, confidentiality and integrity of your personal data processed by us as part of your use of our products/services, our Websites and any other aspects of our business as described in this Privacy Notice; and will not materially decrease the overall security of such items. However, no method of data security is 100% effective. Therefore, we cannot guarantee or warrant its absolute security.

 

Children

Our Websites, Portals and Services are not intended for or directed at children under the age of 13. In addition, we do not knowingly collect personal data from children under the age of 13.

If you have reason to believe that a child under the age of 13 has provided Personal Information to Triplo.AI through the application/product please email us at support@triplo.ai and we will endeavor to delete that information from our databases.

 

Community Forums

Triplo.AI provides community forums on some of the Company’s Websites, Portals or Services. Any personal data you choose to submit in such a forum may be viewed by others who visit these forums. Triplo.AI is not responsible for any misconduct by any person or entity of any personal data you choose to submit in these forums.

 

Additional terms which apply where you are a partner using Triplo.AI's Portals

If you submit a Deal Registration Form via the Portal, we will also collect the following information: corporate name of end customer and contact details for your point of contact within the end customer (including name, job title and address).

Any marketing consents opt-ins/opt-outs or other preference details provided to us in connection with another website or service operated by us (such as the Triplo.AI community or our transactional websites) will be recorded and administered separately from any preferences or consents provided in connection with the Portal. You have the option to change your preferences registered in connection with any of our Websites or Services at any time.

If you are an authorized channel partner and no longer want us to contact you related to marketing events or information, please contact us at channel@triplo.ai.

 

Your choices, rights and instructions

You have the right to request the following information by applying to Triplo.AI at any time;

§ To learn whether personal data is processed or not,
§ To request information if personal data is processed,
§ To learn the purpose of processing personal data and whether they are used in accordance with its purpose,
§ To know the third parties to whom personal data is transferred in the country or abroad,
§ To request correction of personal data in case of incomplete or incorrect processing and requesting notification of the operations made within this scope to third parties to whom the personal data is transferred,
§ To the deletion or destruction of personal data in the event that the reasons requiring it to be processed disappear despite the fact that it has been processed in accordance with the provisions of the Law No. 6698 and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
§ To object to the emergence of a result against the person themself by analyzing the processed data exclusively through automated systems,
§ To request the compensation of the damage in case of loss due to unlawful processing of personal data,

In your application regarding your rights mentioned above;

1. Name, Surname and, if the application is written, your handwritten (wet) signature,
2. In case it is done through a proxy; the original or certified copy of the power of attorney, which includes the name, surname and signature of the attorney, together with the special authorization to carry out this action,
3. For citizens of the Republic of Turkey, your TR identity number, if you are a foreigner, your nationality, passport number or foreign identity number, if any,
4. Your place of residence or workplace address for notification,
5. Your e-mail address, telephone or fax number, if any, 
6. Your request subject (in plain, clear and understandable terms), are obligatory to submit, and information and documents related to the subject should also be attached to the application, if any.

You can make your application by choosing any of the following methods:

You can send your applications to;
1. After completing the form attached to this disclosure statement, a wet-signed copy can be sent to ELBRUZ TEKNOLOJİ LİMİTED ŞİRKETİ residing at the address of “Abdurrahman Nafiz Gürman Mah. G. Ali Rıza Gürcan Cad. Platform Suit B Blok No:27/148 Güngören / İSTANBUL " 
2. Or again, after completing the form, you can forward your applications via the message you send to support@triplo.ai

If your application for these purposes requires an additional cost, you will have to pay the fee determined by the Communiqué on Application Procedures and Principles to the Data Controller issued by the Personal Data Protection Board. In case of a written response via e-mail to your application, no fee shall be charged.

Your requests in your application will be finalized as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request.

In order to take advantage of your rights under the law, you can submit your applications in writing, in Turkish or English, to Triplo.AI, and visit the website of the Personal Data Protection Authority for detailed information.

In your application, which includes your explanations regarding the right you have as a personal data owner and which you will make and request to exercise your rights mentioned above, the subject you request is clear and understandable, the subject you request is related to you or if you are acting on behalf of someone else, you must submit your special power of attorney certified by a notary public.

In your applications, it is obligatory to include name-surname, signature, TR identity number, residence or workplace address, telephone and fax number, and the elements of the request in accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller". Applications that do not contain the aforementioned elements will be rejected by Triplo.AI.

You use the application/product at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the application/product or e-mail. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the application/product, or third party websites. 
 

How can you opt-out of receiving marketing communications from Triplo.AI?

To opt-out of receiving communications relating to marketing, events or promotions from Triplo.AI, you can contact us at any time by completing this form or sending an email to privacyrequest@triplo.ai. Please note that if you are an existing customer then we may need to retain business contact information in order to provide you with Triplo.AI services, however, this will not be used for marketing purposes.

 

How will you know if Triplo.AI updates this statement?

We will make periodic updates to our Privacy Notice via this statement and will note the date the then-existing version takes effect. If you have any queries concerning such changes then please contact us via privacyrequest@triplo.ai.

 

How does Triplo.AI use Cookies in relation to your use of the Websites and Portals?

What are cookies?

A cookie is a very small text document, which often includes a unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website’s server. Find out more about the use of cookies at https://terms.triplo.ai/cookies2023.02.13.

We also use other forms of technology which serve a similar purpose to cookies, and which allow us to monitor and improve our Websites. When we talk about cookies, this term includes these similar technologies.

 

What cookies do we use and what information do they collect?

Provenance:
- First-party cookies are issued by a website that a user views directly
- Third-party cookies are not created by the website being visited, but by a third party like Google Analytics, DoubleClick, Facebook, Twitter, LinkedIn, Youtube, Vimеo, etc.

Duration:
- Session cookies which is erased when the user closes the browser
- Persistent cookies which remains on the user device for a some period of time

Purpose:
- Strictly necessary cookies are required for website to work properly
- Preferences cookies allow a website to remember choices you have made in the past
- Statistics cookies help website owner to collect statistic data and understand how visitors interact with website
- Marketing cookies track user's online activity to help advertisers deliver more relevant ad. These are almost always third-party persistent cookies
 

Third parties

Your use of our Websites may result in some cookies being stored that are not controlled by us. This may occur when the part of the Websites you are visiting makes use of a third party analytics or marketing automation/management tool or includes content displayed from a third party website.

 

How do you manage these technologies?

If you want to delete any cookies that are already on your device, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

To manage your cookie consent preferences, please click here.

 

International Users

By using our Service, you understand and acknowledge that any collected information on our Google Cloud servers could be accessed or transferred from your location to our facilities in Turkey.
Notice for California Residents
This section is only applicable to California residents for purposes of compliance with the CPRA and other California privacy laws. The CPRA requires businesses like Triplo.AI to provide certain disclosures and offer certain rights in their privacy policies.

You can learn more about these rights and how to exercise them in the Your choices and rights and instructions section above.

Prior 12-month personal information handling practices

You can find a list of the categories of personal information we collect as well as the purposes for which we use it under the section entitled What personal data does Triplo.AI process and for what purposes? This also covers the instances and sources from which we obtain your personal information.

For additional details regarding how we disclose personal information to third parties please see the above section entitled How will Triplo.AI disclose your personal data with other parties?

Selling or Sharing of Personal Information

Our use of tracking technologies may be considered a “sale”/ “sharing” under California law. You can opt-out of being tracked by these third parties by clicking the “Cookie Choices” link at the bottom of our website and selecting your preferences.

You can also contact us at privacyrequest@triplo.ai or by completing this form.

Additional Disclosure for California Residents

California law permits residents of California to request certain details about how their information is disclosed to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please email us at privacyrequest@triplo.ai.

 

California and Delaware “do not track” Disclosures

Triplo.AI does not monitor or respond to Do Not Track browser requests. Hence please ensure to change any settings of your browser and/or our Services, whenever you wish cookies to cease.

Contacts
You may contact Triplo.AI's Data Protection Office and make the relevant requests permitted pursuant to applicable law by completing this form or sending an email to privacyrequest@triplo.ai

 

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