Privacy Policy

1. Introduction and Who We Are

TerryTrilla LLC ("TerryTrilla," "we," "us," or "our") is an educational SaaS company organized under the laws of the State of Wyoming, United States (Filing No. 2026-001900930). We operate the online learning platform accessible at https://terrytrilla.com (the "Platform").

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Platform, whether as an individual learner, a student, or a representative of a company or organization.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller Information

For users in the European Union and European Economic Area (EEA), TerryTrilla LLC acts as the Data Controller under the General Data Protection Regulation (GDPR).

• Company: TerryTrilla LLC
• Registered Address: 30 N Gould St, Ste R, Sheridan, WY 82801, United States
• Website: https://terrytrilla.com
• Contact: [email protected]

For EU/EEA residents who cannot resolve a concern directly with us, you have the right to contact your local Data Protection Authority (DPA).

3. EU Representative (Art. 27 GDPR)

In accordance with Article 27 of the GDPR, TerryTrilla LLC is in the process of appointing an EU Representative. Once appointed, their contact details will be published here.

Until an EU Representative is formally appointed, EU/EEA residents may direct all data protection inquiries directly to:

• Email: [email protected]
• Mail: TerryTrilla LLC, 30 N Gould St, Ste R, Sheridan, WY 82801, USA

This section will be updated upon appointment of an EU Representative. Appointment is anticipated prior to active marketing to EU/EEA residents.

4. Information We Collect

4.1 Information You Provide Directly

• Account registration: full name, email address, and password
• Payment information: billing name, address, and payment card details (processed securely by our payment processor; we do not store full card numbers)
• Profile information: profile photo, bio, or other optional details you choose to add
• Communications: messages you send us via support, email, or contact forms

4.2 Information Collected Automatically

• Learning progress and course completion data
• Usage analytics: pages visited, features used, session duration
• Device information: browser type, operating system, IP address
• Cookies and similar tracking technologies (see Section 9)

4.3 Information from Third Parties

• Single sign-on providers (e.g., Google, Apple) if you use social login
• Payment processors who confirm transaction status

5. How We Use Your Information

5.1 Contract Performance (GDPR Art. 6(1)(b))

• To create and manage your account
• To provide access to courses and educational content
• To process payments and issue receipts
• To manage subscriptions, upgrades, and cancellations

5.2 Legitimate Interests (GDPR Art. 6(1)(f))

• To improve Platform performance and user experience
• To analyze usage trends and detect technical issues
• To prevent fraud, abuse, and unauthorized access
• To send service-related notifications (downtime alerts, feature updates)

5.3 Consent (GDPR Art. 6(1)(a))

• To send marketing emails and promotional offers (you may unsubscribe at any time)
• To use non-essential cookies and analytics tools

5.4 Legal Obligation (GDPR Art. 6(1)(c))

• To comply with applicable laws, regulations, or valid legal requests
• To maintain financial records as required by tax law

6. Legal Bases for Processing (EU/EEA Users)

If you are located in the EU or EEA, we process your personal data only when we have a valid legal basis as required by the GDPR. The applicable legal bases are described in Section 4 above alongside each purpose. Where we rely on legitimate interests, we have conducted a balancing test to ensure our interests do not override your rights.

7. Data Sharing and Disclosure

We do not sell your personal information. We may share it with:

7.1 Service Providers (Processors)

Third-party vendors who help us operate the Platform, including:

• Payment processors (e.g., Stripe)
• Cloud hosting providers (e.g., AWS, Google Cloud)
• Email service providers
• Analytics providers

All processors are bound by data processing agreements and are prohibited from using your data for their own purposes.

7.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity. We will notify you via email or a prominent notice on the Platform.

7.3 Legal Requirements

We may disclose your data when required by law, court order, or to protect the rights, property, or safety of TerryTrilla, our users, or the public.

8. International Data Transfers

TerryTrilla LLC is based in the United States. If you access the Platform from the EU/EEA or other regions with data protection laws, your information may be transferred to and processed in the United States.

For transfers from the EU/EEA, we rely on the following safeguards:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data processing agreements with all sub-processors

You may request a copy of the applicable transfer safeguards by contacting us at [email protected].

9. Your Rights

9.1 Rights for EU/EEA Residents (GDPR)

• Right of Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure (Right to be Forgotten): Request deletion of your data in certain circumstances
• Right to Restriction of Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time
• Right to Lodge a Complaint: Contact your national Data Protection Authority

9.2 Rights for California Residents (CCPA/CPRA)

• Right to Know: Request disclosure of the categories and specific pieces of personal information collected
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out of Sale: We do not sell personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights
• Right to Correct Inaccurate Information

9.3 Additional US State Privacy Rights

Residents of certain US states may have additional privacy rights under applicable state privacy laws, including:

• Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with enacted privacy legislation

These rights may include the right to access, correct, delete, or opt out of certain uses of your personal data. To submit a state privacy rights request, contact: [email protected]. We will respond in accordance with the applicable state law timeframe.

9.4 How to Exercise Your Rights

Submit requests to: [email protected]. We will respond within 30 days (GDPR) or 45 days (CCPA). We may need to verify your identity before processing your request.

10. Cookies and Tracking Technologies

We use cookies and similar technologies. Please refer to our separate Cookie Policy available at https://terrytrilla.com/cookie-policy for full details.

In summary, we use:

• Essential cookies: required for the Platform to function
• Analytics cookies: to understand how users interact with the Platform
• Marketing cookies: only with your explicit consent

You can manage your cookie preferences through your browser settings or our cookie consent tool.

11. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

• Account data: retained for the duration of your account plus 3 years after closure
• Payment records: retained for 7 years as required by US tax law
• Learning progress data: retained for the duration of your account
• Marketing data: until you unsubscribe or withdraw consent

When retention periods expire, we securely delete or anonymize your data.

12. Children's Privacy

The Platform is intended for users aged 13 and older. We do not knowingly collect personal information from children under 13 (or under 16 in the EU/EEA without verifiable parental consent).

If you believe we have inadvertently collected data from a child, please contact us immediately at [email protected] and we will delete such information promptly.

13. Automated Decision-Making and Profiling

We do not use automated decision-making processes or profiling that produce legal or similarly significant effects on you, as described in Article 22 of the GDPR. Our use of analytics data is for aggregate platform improvement only and does not result in decisions that materially affect your rights or access to the Platform.

14. Security

We implement industry-standard technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Access controls and authentication requirements
• Regular security assessments
• Employee training on data protection

Despite our safeguards, no system is completely secure, and we cannot guarantee absolute security of your personal data. Users are responsible for maintaining the security of their own account credentials. If you suspect unauthorized access to your account, contact us immediately at [email protected].

15. Third-Party Links

The Platform may contain links to third-party websites. We are not responsible for the privacy practices of those sites. We encourage you to review their privacy policies.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on this page with a revised effective date
• Sending an email notification to registered users

Continued use of the Platform after changes take effect constitutes acceptance of the revised policy.

17. Contact Us

• Email: [email protected]
• Mail: TerryTrilla LLC, 30 N Gould St, Ste R, Sheridan, WY 82801, USA

We aim to respond to all inquiries within 5 business days.