1. Scope
This policy explains how we handle personal information in connection with IDEN, the platform operated by Trocola Inc, our website, and related support. In IDEN, each company has its own partitioned workspace (its ‘universe’). Consultants are the platform’s paying customers; a company’s workspace is included so the company can receive proposals, work with its consultants, and keep its records. Access to a company’s workspace is granted, is visible to the company, and can be revoked by the company, as described in Section 4. This policy does not replace a customer’s own privacy notice or the agreement governing a consultant’s services to a client.
When an organization directs us to process information in its workspace, we process that information on its behalf as described in the applicable agreement. For our own account administration, security, billing and business communications, we determine the relevant purposes. The exact controller, processor, business or service-provider role depends on the activity and applicable law.
2. Information we process
Depending on the features you use, we may process:
- Account and contact information: names, business email addresses, company details, roles and account status.
- Workspace content: proposals, services, scope, terms, project details, uploaded documents, notes, assignments, and information about people included in those records.
- Assessment content: tool names, intended uses, submitted evidence and assessment outputs, including GAR readings where used.
- Activity and security records: access events, actions, timestamps, attribution and diagnostic information needed to operate and protect the service.
- Communications: demo requests, support messages and correspondence.
- Transaction information: plan, invoice and transaction references where payment features are enabled.
Information comes from users, their organizations, authorized collaborators, service operation and, for relevant assessment features, public vendor materials.
3. Purposes
We use information to provide accounts; prepare, deliver and manage proposals; operate authorized project workspaces; process requested assessments; support collaboration; maintain security and records of activity; respond to requests; administer agreed charges; and meet legal obligations.
We also create aggregated, de-identified statistics as described in Section 5A of our Terms, and, only for customers who opt in, use de-identified information as described in our Data Contribution Program.
4. Access and disclosures
Access to a company’s workspace exists only as a recorded grant (a ‘handshake’). A grant is scoped to view only, or to view and edit. A company can see every grant held by a person outside its organization, and can revoke any grant at any time; revocation takes effect immediately. A grant ends when its stated end condition is reached: a consultant’s grant ends when the engagement ends, and an auditor’s grant ends when the audit ends, unless the person who gave the grant set it to continue indefinitely.
Trocola staff access (‘house’ access) is as follows. Authorized Trocola staff may view a company’s workspace for support, security, and operation of the Service. House viewing is announced to the customer and is recorded. Whether Trocola staff may write in a company’s workspace is governed by the house-access clause in the Terms and Conditions (Section 3).
Force Entry is a separate capability reserved to named Trocola Super Admins. It allows a Super Admin to enter a workspace and edit records without a customer grant. It exists for lockout recovery and for compliance with legal process. Every use of Force Entry is logged.
Auditors engaged by a customer receive access only through the platform’s auditor mechanics: a grant to the customer’s workspace that ends when the audit ends. Trocola does not provide direct or backend system access to third-party auditors.
We disclose information to the contracted providers listed below, and only for the functions listed. This list is exhaustive: if a provider is not listed here, we do not disclose workspace information to it. We will announce any addition to, or change in, this list before it takes effect.
- Hosting and storage: Netlify.
- Database: Neon.
- Payment processing: Square.
- Email delivery: Resend.
- AI-assisted features, only when a user requests one: Anthropic.
We may also disclose information to comply with applicable law; to protect lawful rights and service security; and in a business transaction subject to applicable safeguards and law.
5. AI features and GAR
Some features in IDEN are AI-assisted. When you request an AI-assisted feature, only the content needed to produce the requested result may be sent to an external model provider. Workspace content is not sent to an external model provider for any other purpose.
No AI system makes determinations in IDEN. Assessment outputs, including GAR readings, are analysis and recommendations. A determination about a tool, including whether it is approved for use, is made by the customer company and is recorded as that company’s decision.
We do not use private workspace content to train AI models, and we do not authorize providers to do so, except for customers who join our Data Contribution Program through a separate, express agreement, and then only for the categories that agreement covers and after identifiers are removed. Processing an authorized assessment to produce its requested result is not model training.
An assessment output is not a guarantee of accuracy, legal compliance, safety or approval. Public vendor documents remain subject to their owners’ rights.
6. Data sale, licensing and advertising
We do not sell private workspace content or license it to data brokers. We do not use private workspace content for cross-context behavioral advertising. No permission for these activities is inferred from free workspace access.
Whether particular disclosures are a “sale,” “sharing” or targeted advertising under applicable law depends on the actual arrangements, including advertising and analytics providers.
6A. Aggregate information and the Data Contribution Program
We may combine information from across the Service into aggregated statistics that do not identify any organization or person and do not include the text of anyone’s workspace content. We use these statistics to run and improve IDEN and to publish industry insights, and we never attempt to re-identify them.
Separately, organizations may choose to join our Data Contribution Program. Participation is optional, requires a separate agreement accepted by an authorized administrator, can be withdrawn at any time for future use, and never involves contributing any individual person’s assessment or survey results on their own. Details are in Sections 5A and 5B of our Terms.
7. Retention, correction and deletion
We retain information for the purposes described above, subject to applicable agreements and legal requirements.
Where lawful and appropriate, a corrected record may preserve an attributed correction history. An append-only audit design does not cancel statutory deletion, restriction or other privacy rights. Information retained for legal, security or evidentiary reasons must have a lawful basis, appropriate limits and restricted access. Backup deletion may occur on a defined cycle; do not promise immediate deletion from every copy unless that is actually provided.
8. Rights and requests
Depending on location and applicable law, individuals may have rights to access, correct, delete, obtain a copy of, restrict or object to processing of their personal information; withdraw consent; opt out of specified uses; or appeal a denied request. These rights are subject to legal conditions and exceptions.
Contact privacy@trocolainc.com. We may reasonably verify identity and authority. When we process workspace information for an organization, we may direct or assist the request through that organization as appropriate. We will not require waiver of statutory rights to exercise them.
9. Cookies and choices
IDEN uses cookies and similar storage only to operate the service. Essential cookies keep you signed in, protect the session, and remember settings the interface needs in order to work. We do not use cookies for cross-context behavioral advertising, and we do not place third-party advertising or social-media trackers in the workspace.
If optional analytics are introduced in the future, this section will describe them first, together with any consent or opt-out controls they require. You can block cookies in your browser: the public pages will still load, but signing in and using the workspace require the essential session cookie to function.
10. Security
We maintain safeguards appropriate to the information and risks involved. No system is completely secure.
Trocola does not hold SOC 2, ISO 27001, or NIST certifications for IDEN, and is not currently seeking them. Customers evaluating the Service should rely on the safeguards described in this policy and in their agreement with us, rather than on third-party certifications.
Each company’s workspace is isolated in its own partition; one company’s records are not reachable from another company’s workspace. Access permissions are enforced inside the product at the point of access. Access to workspace content, including grants to people outside the company and house access by Trocola staff, is recorded. Data is encrypted in transit, and at rest.
11. Children and sensitive information
IDEN is intended for business use, not services directed to children. Do not upload health, payment-card, biometric or other specially regulated information unless the relevant feature and contractual safeguards have been expressly approved. A generic policy does not establish HIPAA compliance or a business associate agreement.
12. Changes and contact
We will identify changes through an updated effective date and provide material notices or obtain consent where required. A policy update does not automatically authorize materially different use of previously collected information.
Questions and requests: privacy@trocolainc.com — Trocola Inc, c/o Universal Registered Agents, Inc., 300 Creek View Road, Suite 209, Newark, DE 19711.