This privacy notice for Minimal Complexity Inc. ("Company", "we", "us", "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our Trim Chat services ("Services"), such as when you:
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.
In Short: Our services have been designed to avoid collection of personal information. Minor exceptions are necessary for the operation of our Services and use of our third party subprocessors. These exceptions include only anonymous data, such as IP addresses, application instance identifiers, and randomly generated user ids. All user submitted content (text, media), with the exception of customer feedback and support requests, is encrypted and inaccessible by the Trim Chat Service or our third party subprocessors.
Our subprocessors are:
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Minimal Complexity Inc. and the Services, the choices you make, and the products and features you use. We avoid direct processing of personal information, however, our third party subprocessors may process your personal information as required to provide their services and according to their privacy policies.
We do not process sensitive personal information.
We do not receive information from public databases, marketing partners, social media platforms, or other outside sources.
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
We may share information in specific situations and with specific categories of third parties.
We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
Contact us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.
In Short: We collect personal information that you provide to us or that is required by our third party subprocessors. This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. Our third party subprocessors require certain anonymous information to provide their services.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
We do not process sensitive information.
We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is processed and/or stored by the operators of the third party application store used to make the purchase, i.e. Apple Inc. or Google. You may find their privacy notice links here:
We may collect data necessary to monitor and implement your purchases, such as anonymous user identifiers, subscription type, and date of purchase. Purchase data is stored by our third party subprocessor, RevenueCat. You may find their privacy notice links here:
If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
Application data is stored by our third party subprocessors, Google and Cloudflare Inc. You may find their privacy notice links here:
In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, geographical region, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Cookie Notice: We do not use cookies.
The information we collect includes:
Automatic collection data is stored by our third party subprocessors, Google and Cloudflare Inc. You may find their privacy notice links here:
We do not receive information from public databases, marketing partners, social media platforms, or other outside sources.
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
Our Services may link to third party websites, (mobile) applications, or online services from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third party websites, services, or applications. The inclusion of a link towards a third party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
In Short: We may transfer, store, and process your information in countries other than your own.
Our Services are implemented using third party cloud providers with servers located globally, including in the United States. Please be aware that your information may be transferred to, stored, and processed by us and by those third parties with whom we may share your personal information (see WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? above), in the United States and other countries.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 6 months past the termination of the user's account. Termination of a user's account may occur automatically after an extended period of inactivity.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor at least 13 years of age and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/info/law/law-topic/data-protection_en
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by contacting us using the details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below. You will then be removed from the marketing lists — however, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: We do not use cookies or similar technologies.
If you have questions or comments about your privacy rights, you may email us at [email protected].
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
The California Code of Regulations defines a "resident" as:
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES - IP addresses in subprocessors' log files; anonymous mobile application identifiers for the purpose of push notification services |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | NO |
| C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES - purchase history if Services subscription is purchased |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | NO |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO - all media uploaded by the user is encrypted and inaccessible by the Services |
| I. Professional or employment related information | Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics | NO |
We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:
Minimal Complexity Inc. collects and shares your personal information with third party subprocessors as required to use their services. We do not sell your data.
More information about our data collection and sharing practices can be found in this privacy notice.
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
Minimal Complexity Inc. has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Minimal Complexity Inc. has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
To exercise these rights, you can contact us by email at [email protected]. If you have a complaint about how we handle your data, we would like to hear from you.
"Financial incentive" means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information.
The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer's data. A business must be able to explain how the financial incentive or price or service difference is reasonably related to the value of the consumer's data. The explanation must include:
We may decide to offer a financial incentive (e.g., price or service difference) in exchange for the retention or sale of a consumer's personal information.
If we decide to offer a financial incentive, we will notify you of such financial incentive and explain the price difference, as well as material terms of the financial incentive or price of service difference, including the categories of personal information that are implicated by the financial incentive or price or service difference.
If you choose to participate in the financial incentive you can withdraw from the financial incentive at any time by emailing us at [email protected].
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may contact us by email at [email protected].
If you are a resident in the United Kingdom or European Economic Area, the "data controller" of your personal information is Minimal Complexity Inc.
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email us at [email protected].