Privacy Policy
Troomi Privacy Notice Introduction
At Troomi®, we are committed to protecting personal information. In this Privacy Notice (“Notice”), Troomi Wireless, Inc. and its affiliated entities (“Troomi,” “we,” or “us”) set out how we, as data controller, may collect, create, share and use personal information relating to identifiable individuals (“Personal Data”) and provide you with information regarding your Personal Data rights and choices.
This Privacy Notice is integrated into, and made part of the Troomi Terms and Conditions found here (https://troomi.com/terms-and-conditions/) and by continuing to use our Sites, or the Services, you agree to both this Privacy Notice and the Troomi Terms and Conditions.
1. Scope of this Notice
This Notice describes Troomi’s privacy practices for Personal Data collected by Troomi websites (“Sites”), the Troomi Wireless Service (including Troomi devices) (the “Service(s)”) as well as other activities, such as if you visit our offices, attend a Troomi event or otherwise interact with Troomi and provide Personal Data, such as corresponding by email, unless such activities are covered by our other notices outlined below. Please read this Notice in full. By using our Sites, using the Services, or participating in other activities with Troomi described below, you consent to the collection, creation, sharing and use of information as described in this Notice, where consent is required by relevant law.
Unless specifically identified, references to Services will include both the operation of Sites as well as the Services.
Troomi also operates a public forum on certain Troomi social media pages and on our websites (“Forums”). The purpose of Forums is to discuss our products and Services. Please note that any Personal Data you choose to post in a Forum may be read or used by other visitors (for example, to send to you unsolicited messages). Troomi Forum users should not upload sensitive or confidential content on this public forum.
As a convenience to visitors to our Sites, we may also provide links to other websites that are not governed by this Notice. These linked websites are not under the control of Troomi and we are not responsible for the content on such websites or the protection/privacy of any information which you provide while visiting such websites.
For information about Personal Data and other data we collect with Troomi products or the Services, see Section 10.
2. Personal Data Collected
The Personal Data Troomi may collect about you will depend on your interaction/relationship with us. It may include:
- account information you give us about yourself, such as contact and billing information. We also keep service-related history and details, including Customer Proprietary Network Information (https://www.att.com/consent/cpni/)
- equipment information: we collect about equipment on our network like the type of device you use, device ID, and phone number if you browse our Sites, information systems data relating to your interaction with our Sites, such as location (e.g., IP address), cookie related information (see section 6 below), usage (e.g., mouse clicks, page visits, feature usage, view time, downloads) and other information, such as language preference;
- network performance acquired as we monitor and test the health and performance of our network. This includes your use of Products and Services to show how our network and your device are working;
- location information we collect which is automatically generated when devices, products and services interact with cell towers and Wi- Fi routers. Location can also be generated by Bluetooth services, network devices and other tech, including GPS satellites;
- biometric information such as Fingerprints, voice prints and face scans are examples of biological characteristics that may be used to identify individuals;
- if you complete a webform on our Sites (e.g., to make a purchase or create a Troomi Account), attend a Troomi event (online or in-person) or office, or otherwise send this data to Troomi (e.g., by email, telephone, exchange of business cards), identifying/contact information such as your name, job title, work email, organization/employer name, work telephone, and location information such as work address;
- if you purchase Troomi products or Services, financial or billing data, such as name, address, credit card number or bank account information; if you attend a Troomi event (in-person or online) or our offices, your attendance details (e.g., entry time);
- if you avail yourself of Troomi Services, such submit a technical support case, your activity with Troomi to interact with and take part in these services; your image and/or voice, such as for phone/video call recordings (for training, quality assurance and administration purposes), if you attend a Troomi event (event recording) or office (e.g., CCTV), post an image/recording to a Troomi Site (e.g., add a profile photo to a Forum) or you otherwise send a recording/image to Troomi;
- information from otherwise engaging/interacting with you, such as your feedback to us through our Services and responses to any promotional or survey communications; and/or information considered sensitive under local law, namely health information voice recordings, text messages (including emojis), and/or images transmitted to or from your device in order to provide analytics you enable on your device.
We may also collect Personal Data about you from third parties, such as vendors (e.g., web analytics tools, data enrichment providers) and Troomi partners (e.g., where your contact details are provided to enable delivery of Troomi software, for customer success purposes and/or in relation to maintenance/support, including renewal and/or cancellation of same). We also maintain social media pages and may collect Personal Data from you when you interact with these or communicate with us through our social media pages.
3. Use of Personal Data
Depending on your relationship with Troomi, we may use your Personal Data for different purposes. Where required by applicable law in relation to the particular use, we will obtain your consent to collect and use your Personal Data. Otherwise, we will rely on another legal basis, such as in connection with a contract or for our legitimate interests, as set out below.
- Perform a Contract: We may process your Personal Data in connection with a contract with you or your organization, such as to process relevant payments, deliver (customer) or receive (vendor) products/services.
- Operate our Services: We may use your Personal Data to provide our Services, content and offerings (e.g., downloads, registrations for accounts or profiles, such as a Troomi Account), including necessary functionality, content customization (e.g., based on what we think will interest you), and functionality to enhance ease of use (e.g., make the Services easier for you to use by not making you enter information more than once, etc.). Unless such processing is in connection with a contract or our legitimate interests, it will be on the basis of your consent.
- Improve our Services: We process your interactions with our Services, content and offerings (e.g., Troomi support) to assess and improve these and the user experience, such as by use of cookies (see section 6 below). This data is typically aggregated unless Personal Data is required for the particular processing operation. We process your Personal Data for this purpose for our legitimate interests of maintaining and improving our Services and providing tailored content, or where required by law, on the basis of your consent.
- Manage Contact Requests: We may use your Personal Data to reply to contact initiated by you, such as through a webform, chatbot, survey responses or Troomi support. We process your Personal Data for these purpose for our legitimate interest in replying to/fulfilling your request, collecting survey responses and to carry out our contractual obligations under the applicable terms (e.g., providing Troomi support).
- Other Communications: We may use your Personal Data to otherwise communicate with you to manage our relationship with you/your organization, such as to manage our offerings, for customer success purposes, to contact you regarding updates to our offerings you may be interested in, and to run surveys and contests. Such processing will be to fulfill our contractual obligations, where necessary for our legitimate interests or, where legally required, with your consent. Billing: We may use your personal data for billing, collection, and protection of our property and legal rights.
- Call Recording: We may record phone or video calls (e.g., Zoom) for training, quality assurance, the functionality of programs, functionality, or features you have selected, and/or administration purposes. We process this Personal Data on the basis of our legitimate interests however, if required under applicable law, we will obtain your consent or give you the option to object to the call being recorded.
- Marketing: We may use your Personal Data to contact you for marketing purposes, such as to alert you to product upgrades, special offers, updated information/services from Troomi, and to contact you (e.g., by phone or email) regarding your interest in our offerings and/or invite you to Troomi events. Such contact will be on the basis of legitimate interest or, where legally required, on the basis of your consent. To opt-out of marketing contact, please unsubscribe here [email protected].
- Events: We may process your Personal Data to operate Troomi events, including training/education related activities, in-person and online, that you have selected to attend. Such processing will be on the basis of our legitimate interests or to perform a contract with you under the applicable terms of service.
- Manage Premises: Where you attend our offices, we may process your Personal Data to administer our premises and fulfill our legal obligations regarding health and safety, and to manage the security of our premises to ensure there is no unauthorized access. Such processing will be on the basis of our legitimate interests and/or to carry out our legal obligations.
- Compliance and Security: We process your Personal Data to comply with our legal obligations and to ensure compliant use/security, such as to ensure the use of our Services, content and offerings in compliance with our terms and/or to ensure their security, to cooperate with courts, regulators or other government authorities to the extent processing/disclosure of Personal Data is required under applicable law, where it is necessary to protect our legal rights or those of others, or for other compliance purposes such as auditing, investigations and responding to legal processes or lawful requests. Where we process health related data for Covid-19 related reasons or to accommodate a reasonable adjustment for a disability, we will only do so to carry out our legal obligations relating to health and safety, under applicable law.
- Professional Advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
- Third Parties Involved in a Corporate Transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
We may also combine Personal Data we hold about you. For example, we may combine your contact information with your usage data relating to our offerings and our Services for the purposes above, such as to improve our Services and our offerings, as well as to create more tailored experiences by providing content that may be of interest to you. We may also use your Personal Data to fulfill any other purposes disclosed to you at the time of collection or as otherwise required/permitted by applicable law.
4. Sharing Personal Data
Troomi may share Personal Data for various purposes, such as:
- within the international group of Troomi companies to operate our business and provide our Sites, products and Services;
with authorized Troomi vendors, advisors and contractors providing services on our behalf (such as a technology or professional service providers) to operate our business, Sites, products and Services;
- if you register for or attend a Troomi event, Troomi may share participant information (e.g., your name, organization, work email) with other participants, organizers or hosts of the same event in order to facilitate the event and the subsequent exchange of ideas. Troomi may also share your contact details with event sponsors where you have consented, e.g., through registration, to these sponsors contacting you regarding their own offerings. Your contact details may also be used by other hosts of the same event, such as to send marketing material, according to their privacy notices provided to you;
- sharing with non-Troomi companies or entities where authorized or required by law. This can happen when we: (i) Comply with court orders, subpoenas, and lawful discovery requests, and as otherwise authorized or required by law. Like all companies, we must comply with legal requirements; (ii) Detect and prevent fraud; (iii) Provide or obtain information related to payment for your service, (iv) Route your calls or other communications, like connecting calls or text messages with other carrier networks, (v) Ensure network operations and security, defend against legal claims and enforce our legal rights, (vi) Notify, respond, or provide information (including location) to an appropriate governmental entity in emergency circumstances such as immediate danger of death or serious physical injury, (vii) Alert the National Center for Missing and Exploited Children to information concerning child pornography if we become aware through the provision of our services, (viii) Share the names, addresses and telephone numbers of non-mobile phone customers with phone directory publishers and directory assistance services as required by law. We honor your request for non- published or non-listed numbers; (ix) Provide name and phone number for wireline and wireless Caller ID and related services like Call Trace.
- voice recordings, text messages (including emojis), and/or images transmitted to or from your device in order to provide analytics your enable on your device.
Troomi will only share Personal Data to the extent needed to perform the relevant use and will take such steps as are necessary to safeguard Personal Data. For example, our vendors, advisors and contractors are required to keep such Personal Data confidential and not to use it other than for the purposes intended. Troomi partners are obliged to comply with the privacy rules set out in their agreement with Troomi. Troomi does not sell or rent Personal Data to third parties.
Troomi may also disclose Personal Data to comply with legal requirements, such as in relation to legal proceedings or investigations by governmental or law enforcement agencies, or to meet tax or other reporting requirements, including to (a) protect and defend the rights or property of Troomi, including the defense and management of legal claims and investigations, (b) act in urgent circumstances to protect the personal safety of users our Services, our Troomi team members, or the public, (c) as part of a merger or change in corporate ownership or control, and/or (d) as otherwise permitted or required by applicable law.
5. Transfer of Personal Data
To operate our business your Personal Data may be transferred to a destination country outside the U.S. In such instances, in addition to the other measures outlined in this Notice, Troomi will put in place appropriate safeguards for such transfers.
6. Cookies and Similar Technologies
As is true of most websites, when you visit our Sites, cookies will be placed on your device (computer, mobile or tablet). A “cookie” is a small text file that is placed on your device by websites you visit. Some of the cookies we use are strictly necessary to operate our Sites. Others relate to the Site’s performance, functionality and/or to advertising. Information relating to a cookie or similar technology may include identifiers such as IP address, and information like general location, browser type and language, and internet activity such as timestamps. Troomi uses the following types of cookies and similar technologies on our Sites:
Strictly Necessary: These cookies enable the Sites to function correctly and deliver the Services and products you have requested. These cookies do not gather information about you that could be used for marketing or remembering other websites you have visited on the internet.
Functional: These cookies do things like remember your preferred language, understand your preferences and associate users to forms submitted to enable pre-completion of subsequent forms as well as improve and customize your experience on our Sites.
Performance: We use third-party analytics tools to help us analyze how our Sites and other electronic mediums are used, such as allowing us to compile reports on website activity, providing us other services relating to website activity and internet usage and whether email communications are opened or left unread.
Advertising: These cookies may be set on our Sites by our advertising partners. They may be used to build a profile of your interests and/or show you relevant adverts on other sites. If you wish to not have your online information used for this purpose you can also visit resources such as https://optout.networkadvertising.org and/or https://www.youronlinechoices.eu (please note these and similar resources do not prevent you from being served ads as you will continue to receive generic ads).
Cookies can be session-based (which disappear once you close your device or browser) or persistent (which remain on your device afterwards). Troomi may also rely on cookies or similar technology operating on other websites, for example to display our adverts to you. You can generally disable the use of cookies by changing your browser settings. You may also adjust your browser settings, however if you choose to not have your browser accept cookies from the Troomi Sites, you will not be able to experience a personalized visit and it may limit your ability to use some features on our Sites. For more information about cookies, visit https://www.aboutcookies.org. We may also use pixels, web beacons and similar technologies on our Sites and in emails, for example in a marketing email that notifies us if you click on a link in the email.
7. Protection of Personal Data
Troomi takes appropriate precautions to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Such measures may include (i) using security controls such as, passwords, firewalls and/or encryption, (ii) restricting Personal Data to those with a legitimate purpose in receiving/accessing it, (iii) de-identifying Personal Data, or assigning codes or pseudonyms when the personal identifiers are not required for the purpose at hand, (iv) providing training and internal policies to team members to embed privacy and security across our organization, and (v) putting in place relevant procedures (such privacy and security vetting) and contracts relating to the use and protection of Personal Data with third parties.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
8. Retaining Personal Data
Troomi will retain and process Personal Data for a period of time consistent with the purpose of collection (see section 3 above) and/or as long as necessary to fulfil our legal obligations. We determine the applicable retention period by taking into account the (i) amount, nature and sensitivity of the Personal Data, (i) relevant use, including whether we can achieve the use through other means (e.g., by instead using deidentified data); (iii) potential risk of harm from unauthorized use or disclosure of the Personal Data, and (iv) applicable legal requirements (e.g., statutes of limitation).
9. Children’s Privacy
We don’t knowingly collect personal information from anyone under 13 without parental notice, and we get parental consent where appropriate. We also won’t contact a child under 13 for marketing purposes without parental consent. However, if we are not aware that a child is using a service or device purchased by an adult, we may collect the information and treat it as the adult’s.
Troomi Services are intended for adult use and for use by minors who are authorized by Troomi account holders. You may only provide access to a Troomi Device or to Troomi Services to a minor if you are authorized to do so, and you acknowledge and agree if you provide such access you consent to Troomi providing the device or Services to such minor.
In certain circumstances, where you have enable applicable technology, Troomi may store and analyze text, image, and voice communications from you or the minor to whom you provide access to Troomi Services. You hereby consent to recordings of your voice, and the capture of text and/or images if you enable applicable technology.
10. Troomi Parent Portal Privacy Terms
Troomi’s products are accessed by utilizing a cloud hosted solution provided and managed by Troomi (the “Troomi Parent Portal”).
Troomi Parent Portal
What user Personal Data is processed by Troomi when a user uses Troomi Parent Portal?
Personal Data: Troomi is the Data Controller of user Personal Data collected and processed by us to administer, maintain and improve our products and Services. When using Troomi Parent Portal, user data processed may include (i) tenant activation and consumption data, (ii) authentication data such as usernames and passwords, (iii) technical data from interacting with Troomi Parent Portal, such as IP address, (iv) usage data such as frequency of log-in, feature usage, usage per day, etc. and (v) contact data, such as email. Such data may be Personal Data where it is associated with or contains your name or other identifiers. You may also provide contact details (e.g., name, email), for example when completing a feedback form or otherwise contact us in-product.
Uses of Personal Data: Troomi processes Personal Data described above for the uses set out below.
(a) Operate Troomi Parent Portal: We may process your Personal Data to ensure the availability and quality of Troomi Parent Portal (e.g., authentication) and to monitor consumption (e.g., access) for customer consumption management purposes. We do this to carry out our contract with you/your organization under the applicable terms.
(b) Troomi Services: We may process your Personal Data to provide you with Troomi Services, such as support services. We do this to carry out our contract with you under the applicable terms.
(c) Customer success & adoption: We may process your Personal Data for customer success purposes to assist customers and users in improving their use of Troomi Parent Portal, for example by making tailored suggestions and delivering insights to customers/users based on their interaction with our offerings. We may also use this data to enhance conversations with existing customers by providing Troomi with greater context and background regarding how customers deploy and use our offerings. We do this to carry out our contract with you under the applicable terms and for our legitimate business interests in ensuring customers improve/maximize their use of our offerings.
(d) Communication: We may process your Personal Data to contact you, such as in relation to errors, or if you complete a feedback form in the product and ask to be contacted by us. We process Personal Data for this purpose for our legitimate interest in reviewing your submission and to fulfill/respond to your request.
(e) Improve our offerings: We may process your Personal Data to analyze use of our products and Services (e.g., reviewing trends and which features are popular) to improve these. We do this for our legitimate interest in improving our offerings.
(f) Security & compliance: We may process user Personal Data for our legitimate interests in ensuring the security of our offerings, for example to monitor for suspicious activity, and for compliance purposes, such as to review compliance with the applicable usage terms (e.g., validate licensed user numbers) and to comply with our legal obligations (e.g., regarding restricted/denied party lists).
While certain uses of Personal Data may require it to be individualized (e.g., for authentication), Personal Data identifiers are typically removed by Troomi where the data is used for other purposes (e.g., when using statistical data to analyze usage trends to improve our offerings).
Sharing of your product usage data
Troomi may share data relating to your use of Troomi offerings in the following ways:
- to assist your organization in managing its Troomi offerings.
- with our affiliates to perform our Services and/or operate our products, as well as with third party service providers who may use this information to in order to operate our business.
- with our partners who may use such information to market products to you, modify product offerings to you, or use such information for operating their own business.
- where your organization has purchased our offerings through a Troomi partner, we may share such data with that relevant partner to manage our relationships with your organization, the relevant partner, and to aid the direct relationship between your organization and the relevant partner.
11. Your Rights and Controlling Your Personal Information
Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.
12. Contact Info
For privacy inquiries or complaints, or to otherwise contact Troomi, please email [email protected].
Changes to this Notice
Troomi reserves the right to modify or update this Notice from time to time to reflect changes in technology, our practices, law and other factors impacting the collection/use of Personal Data. You are encouraged to regularly check this Notice for any updates. We may also collect, use and disclose Personal Data for other purposes otherwise disclosed to you at the time of collection/processing in a supplementary notice.
Frequently asked questions
Everything you need to know
Troomi is the safe phone that grows with your child. We provide safety today and prepare kids for the future. Other solutions are so locked down that they quickly become impractical as children’s needs evolve.
Troomi also prevents problems before they happen! With Troomi, prevent problems by keeping kids away from pornography, predators and the dangers of social media to begin with.
Simplify your child’s safe phone with one service that does everything you need. Pay for your safe phone and phone service in one place, with no extra subscriptions required.
You won't be locked into anything, and can cancel at any point. If you cancel, you will not be required to continue payment once the current month is over. No contracts, here! Our service is a simple month-to-month system.
You won't be locked into anything, and can cancel at any point. If you cancel, you will not be required to continue payment once the current month is over. No contracts, here! Our service is a simple month-to-month system.
No monthly contracts! We don’t lock you in because we know you’ll want to stay.
Have confidence with our 30-day, money-back guarantee! Return your device within 30 days of purchase for a refund minus shipping and any applicable repair fees.
You can bring the number with you! We make porting a number into Troomi as painless as possible. We’ll welcome you—and your phone number—with open arms.
During the checkout process, you’ll see an option to port your existing phone number. All you need to do is input your phone number and PIN from your current carrier when prompted—we’ll do the rest!
