Website and Cookie Policy

Cookie Policy

Last update: 1/02/2021

This document informs Users about the technologies that help Trooli Ltd. to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with Trooli Ltd.

For simplicity, all such technologies are defined as “Trackers” within this document – unless there is a reason to differentiate.

For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

Some of the purposes for which Trackers are used may also require the User’s consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

Trooli Ltd. uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.

The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.

In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers – in the linked privacy policies of the respective third-party providers or by contacting the Owner.

Activities strictly necessary for the operation of Trooli Ltd. and delivery of the Service

Trooli Ltd. uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

Other activities involving the use of Trackers

Basic interactions & functionalities

Trooli Ltd. uses Trackers to enable basic interactions and functionalities, allowing Users to access selected features of the Service and facilitating the User’s communication with the Owner.

Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages of Trooli Ltd., in order to contact and be contacted by Trooli Ltd.‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

LiveChat Widget (LiveChat, Inc.)

The LiveChat Widget is a service for interacting with the LiveChat live chat platform provided by LiveChat, Inc.

Personal Data processed: Data communicated while using the service, Tracker and Usage Data.

Place of processing: United States – Privacy Policy.

Measurement

Trooli Ltd. uses Trackers to measure traffic and analyse User behaviour with the goal of improving the Service.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on Trooli Ltd. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

Personal Data processed: Tracker and Usage Data.

Place of processing: Ireland – Privacy Policy.

Cookie lifetime:

  • _fbp: up to 3 months

Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Trooli Ltd., to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Tracker and Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Cookie lifetime:

  • _ga: up to 7 days
  • _gid: up to 7 days

Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Tracker and Usage Data.

Place of processing: Malta – Privacy Policy – Opt Out.

Microsoft Advertising Universal Event Tracking (Microsoft Corporation)

Microsoft Advertising Universal Event Tracking is an analytics service provided by Microsoft Corporation that connects data from the Microsoft Advertising network with actions performed on Trooli Ltd.

Personal Data processed: Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), Universally unique identifier (UUID) and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Twitter Ads conversion tracking (Twitter, Inc.)

Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on Trooli Ltd.

Personal Data processed: Tracker and Usage Data.

Place of processing: United States – Privacy Policy.

Cookie lifetime: up to 12 months

AdInsight

AdInsight is a phone call analytics tool, used by companies to understand the customer interaction between the website and calling the company. Three cookies are used by AdInsight to help demonstrate this journey so the business can improve their customer experience.

The adiV cookie contains an identifier which is used by AdInsight to track a visitor over time. This allows AdInsight to show multiple visits made by a customer over time from the same browser.

The adiVi cookie contains an identifier which is used by AdInsight to help track a visitor’s path while they are on the website.

The adiLP cookie is used to help track visitors who have multiple tabs open in the same browser to prevent errors in tracking.

Cookie lifetime:

  • adiV: up to 12 months
  • adiVi: up to 1 hour
  • adiLP: up to 12 hours

WordPress Stats (Aut O’Mattic A8C Ireland Ltd.)

WordPress Stats is an analytics service provided by Aut O’Mattic A8C Ireland Ltd.

Personal Data processed: Tracker and Usage Data.

Place of processing: Ireland – Privacy Policy.

Cookie lifetime: up to 3 months

Content performance and features testing (A/B testing)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Trooli Ltd.

Google Optimize 360 (Google Ireland Limited)

Google Optimize 360 is an A/B testing service provided by Google Ireland Limited (“Google”).

This service allows the Owner to target groups of Users on the base of their past use of Trooli Ltd. Users that opt-out of tracking by Google Analytics will not be included in experiments created in Google Optimize 360.

Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Tracker and Usage Data.

Place of processing: Ireland – Privacy Policy.

Cookie lifetime: up to 3 months

Google Optimize (Google Ireland Limited)

Google Optimize is an A/B testing service provided by Google Ireland Limited (“Google”).

Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Tracker and Usage Data.

Place of processing: Ireland – Privacy Policy.

Cookie lifetime: up to 3 months

Heat mapping and session recording

Heat mapping services are used to display the areas of Trooli Ltd. that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of User behaviour. Some of these services may record sessions and make them available for later visual playback.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User’s data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Tracker, Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: Malta – Privacy Policy – Opt Out.

Targeting & Advertising

Trooli Ltd. uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Trooli Ltd., possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Trooli Ltd. For more information, please check the privacy policies of the relevant services.

In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google Campaign Manager 360 (Google Ireland Limited)

Google Campaign Manager 360 is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. Google Campaign Manager 360 also allows the Owner to measure the campaign’s performance, to set up placements, ads, and creatives, and to verify tag implementations (such as errors in the ad’s formatting). Trooli Ltd. is collecting and transmitting Data from the User through Google Campaign Manager 360 to media buyers bidding to purchase its inventory. These buyers may collect and store such Data and use such Data for retargeting or other advertising purposes.

Users may decide to disable all the ad personalization Cookies by going to: Google Ad Settings.

Personal Data processed: geographic position, Tracker and Usage Data.

Place of processing: Ireland – Privacy Policy.

Cookie lifetime: up to 12 months

Google Ad Manager (Google Ireland Limited)

Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google’s use of data, consult Google’s partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of Trooli Ltd. and User behavior concerning ads, products and services offered.

Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

Personal Data processed: Tracker and Usage Data.

Place of processing: Ireland – Privacy Policy.

Cookie lifetime: up to 12 months

How to manage preferences and provide or withdraw consent

There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:

Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.

Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.

It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.

Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.

With regard to any third-party Trackers, Users can manage their preferences and withdraw their consent via the related opt-out link (where provided), by using the means indicated in the third party’s privacy policy, or by contacting the third party.

Locating Tracker Settings

Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings, such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings, view and look for the relevant setting).

Advertising industry specific opt-outs

Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Owner and Data Controller

Trooli Ltd. – 1 Abbey Wood Road, Kings Hill, West Malling, ME18 4YT

Owner contact email: support@trooli.com

Since the use of third-party Trackers through Trooli Ltd. cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.

Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by Trooli Ltd.

Definitions and references

For the purposes of avoidance of doubt, all terms used are defined as below:

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Trooli Ltd. (or third-party services employed in Trooli Ltd.), which can include: the IP addresses or domain names of the computers utilized by the Users who use Trooli Ltd., the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using Trooli Ltd. who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Trooli Ltd. The Data Controller, unless otherwise specified, is the Owner of Trooli Ltd.

Trooli Ltd. (or this Website)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Trooli Ltd. as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker

Tracker indicates any technology – e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal Information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This cookie policy relates solely to Trooli Ltd., if not stated otherwise within this document.