Triple Crown Privacy Policy

Last Updated: 2/13/2025
Effective Date: 1/1/2025

This Privacy Policy (“Policy”) describes how Triple Crown Consulting, LLC, its brands, affiliates, and subsidiaries (“Triple Crown,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise process personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information.

By using our Services (as defined below), you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms of Use, available at https://www.tripleco.com, including their applicable terms governing limitations on damages and the resolution of disputes.

California residents can view our California Consumer Privacy Act notice at collection by clicking here.

Table of Contents

1. Scope of this Policy
2. Personal Information We Collect
3. How We May Use Personal Information
4. How Personal Information is Disclosed
5. Cookies and Other Tracking Mechanisms
6. Your Privacy Choices
7. Children’s Information
8. External Links and Features
9. Security
10. California Residents
11. Changes to this Policy
12. Contact Us

1. Scope of this Policy

Except as otherwise described below, this Policy applies to the personal information Triple Crown collects and processes related to visitors to our website where this Policy is posted, including https://www.tripleco.com (the “Site”) and individuals who use our services, such as candidates or recruiters (collectively, the “Services”).

Additional Notices. Depending on how you interact with us, we may provide you with other privacy notices with additional details about our privacy practices. For example, this Policy does not apply to job applicants and candidates who apply for employment with us, or to our employees. Our processing of personal information belonging to our business clients is subject to our agreement with the respective client and their data handling practices.

2. Personal Information We Collect

We collect personal information directly from you, automatically through your use of the Services, and from other sources. To the extent permitted by applicable law, we may combine the information we collect from or about you.

Personal Information We Collect Directly From You. While the personal information we collect varies depending upon your use of our Services and our interactions with you, in general, we may collect the following Personal Information directly from you:

• Contact Information. When you contact us, we collect your name, email address, phone number, the nature of your inquiry, and any other personal information you choose to provide.
• Account Information – Businesses. When you register for an On Demand account with us on our Triple Crown On Demand portal as a recruiter/hiring manager representing your business, we collect your name, email address, login ID, password, job title, company name, business email, and business phone number and any other personal information used in connection with accessing your account.
• Account Information – Candidates/Job Seekers. When you register for an On Demand account with us as a candidate or job seeker, we collect your name, email address, login ID, password, job title, company name, email, phone number, location, job preferences, work experience, skills, resume information, credentials or licenses earned or held, and any other personal information used in connection with accessing your account.
• Refer a Friend. If you use our refer-a-friend function we collect the personal information of the person to whom you are referring the job posting.
• Communications and Interactions. When you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications, and our responses.
• Responses and Feedback. If you participate in our surveys or questionnaires, we collect your responses and feedback related to your use of our Services and any other personal information you choose to provide.
• Marketing, Promotions, and Sweepstakes. If you agree to receive marketing communications from us or participate in sweepstakes or other promotions, we collect your email, name, phone number, preferences, and if relevant, information about your account and the Services and features you use. Where required by law, we are obligated to publicly post the sweepstakes winners.
• Events and Other Requests. We also collect personal information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event or webinar that we host or sponsor, we may collect personal information related to your registration for and participation in such event.
• Preferences. We may also collect personal information about your preferences, including communications preferences, preferences related to your use of Sources, and any other preferences or requests you provide when interacting with us.
• Business Development Information. To assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective business partners and others, including name, company information, contact details, and communications records.
• Personal information Collected Automatically. We and third-parties automatically collect personal information related to your use of our Services, including using cookies, pixel tags, and other similar technologies. The personal information collected automatically includes:
  
  
  • Device and Browsing Information. When you visit our Site or use our Services, we may collect IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information.
  
  
  • Activities and Usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us within the Services, and other activity and usage information.

For more information about our use of cookies and other similar technologies, please see the “Cookies and Other Tracking Mechanisms” section below.

Personal Information We Collect from Other Sources. In addition, we may collect and receive certain personal information from our clients, business partners, other personnel management companies, data analytics providers, Internet service providers, operating systems and platforms, government entities, public databases, and vendors and service providers who provide services or perform functions on our behalf.

3. How We May Use Personal Information

We collect, use, disclose and otherwise process the personal information we collect about you for the following purposes:

• Account – Businesses and Candidates. To allow you to create and maintain a user account with us, provide and operate our Services, communicate with you about job opportunities or potential candidates, provide troubleshooting and technical support, respond to your inquiries, and to otherwise run our day-to-day operations.
• Analytics and Improvement. To better understand how users access and use the Services and our product and service offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop our Services and its features, and for internal quality control and training purposes.
• Communicate With You. To communicate with you regarding our Services. We also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
• Refer a Friend. To enable our refer-a-friend functionality.
• Marketing, Promotions, and Sweepstakes. For marketing, promotional, and sweepstakes purposes. For example, to send you information about our Services, such as newsletters and other marketing content, including information about our events and new offerings, as well as any other information that you sign up to receive.
• Advertising. To conduct advertising on other sites and to personalize your experience.
• Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
• Planning and Managing Events. For event and webinar planning, and other management-related purposes, such as registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
• Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.
• Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures.
• General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.
  

4. How Personal Information is Disclosed

Personal information is disclosed in the following ways for the purposes specified:

• Business Clients. If you are a candidate, we may disclose the personal information you provide to us to our clients to facilitate the hiring process.
• Affiliates, Subsidiaries, and Business Partners. We may disclose the personal information we collect to our corporate affiliates and subsidiaries. Triple Crown also partners with other businesses to offer our Services, and we may disclose personal information to those business partners.
• Service Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, marketing providers, customer support, data storage, analysis and processing providers, auditors, consultants, and legal counsel. We may also ask you to set up accounts with certain service providers to allow us to provide our Services.
• Advertising and Analytics Providers. We allow third-parties to collect your personal information, such as device and browsing, and activities and usage information, to marketing and advertising networks, data analytics providers, and other companies who provide marketing or analytics services on our behalf. For more information see the “Cookies and Other Tracking Mechanisms” section below.
• In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transactions such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information
  in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms of Use. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may use, disclose, and otherwise process aggregate and deidentified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes.
• Other Disclosures. We may disclose personal information in other ways not described above, but will notify you and, if necessary, obtain your consent.
  

5. Cookies and Other Tracking Mechanisms

We and our providers use cookies, pixel tags, and other similar tracking mechanisms to automatically collect information about browsing activity, type of device, and similar information within our Services. We use this information to, for example, analyze and understand how you access, use, and interact with us through our Services, to identify and resolve bugs and errors in our Services, to assess, secure, protect, optimize, and improve the performance of our Services, for marketing and advertising purposes, analytics purposes, and to personalize content in our Services. We may also aggregate such information to analyze trends, administer our Services, and gather broad demographic information.

Cookies. “Cookies” are alphanumeric identifiers we transfer to your device’s hard drive through your web browser for tracking purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within the Services.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.

Third Party Analytics. We use third party tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Site and Services. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Services to provide us with reports and metrics that help us evaluate usage of our Services, improve our Site, and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://policies.google.com/technologies/partner-sites. You can also download the Google

Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Tracking. We and our providers may use the information we collect about you within our Services and on other third-party websites and services to help us and these third parties identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Services.

Third-Party Advertising. We work with third-party ad networks, analytics, marketing partners, and others (“third-party ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information within our Services (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other online identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites, and to evaluate the success of such ads and content.

Do Not Track. Currently, our Site and Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed below (e.g., by disabling cookies).

6. Your Privacy Choices

We make available several ways for you to manage choices about your personal information, including preferences regarding cookies, advertising, whether you want to receive marketing and promotional emails from us, and choices regarding your account and profile information.

• Cookie Settings. To prevent cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.
• Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Site, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). Opting out of participating third party ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Site. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
• Marketing Communications. You can opt out of receiving marketing emails from us by using the unsubscribe feature in any such email we send you. You can also log in to your account and change your marketing/communications preferences.
• Account and Profile Information. If you have an On Demand account with us (either as a candidate or a business), you may access, review, and update your account and profile information, such as your name, email address, contact information, notification preferences, and other profile information by logging in navigating to your profile settings page.
  

7. Children’s Information

Our Services are not designed for children, and we do not knowingly collect personal information from children. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information below.

8. External Links and Features

Our Site and Services may contain links to third-party websites or features. Any access to and use of such linked websites or features is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those features.

9. Security

We have implemented safeguards that are intended to protect the personal information that we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no measures can guarantee security.

10. California Residents

This section of the Policy provides additional information for California residents and describes our information practices pursuant to the California Consumer Privacy Act, as amended (the “CCPA”). Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices.

This section applies to “personal information” as defined in the CCPA, whether collected online or offline. This section does not address or apply to our handling of personal information that is exempt under the CCPA. Triple Crown is committed to maintaining and using deidentified information in compliance with the CCPA.

Personal Information We Collect. Depending on how you use the Services, we may collect (and have collected in the prior 12 months) the following categories of personal information:

• Identifiers, such as name, alias, email, phone number, billing and shipping address, unique personal identifier, online identifier, IP address, account name, or other similar identifiers.
• Customer Records, such as your account and profile information, communications preferences, billing and payment information, customer service and support tickets and records, and other information you provide to use our Services.
• Internet or Other Electronic Network Activity Information, such as browsing history, clickstream data, search history, and information regarding interactions with our Site, mobile application, advertisements, or emails, including other usage data related to your use of any of our Services or other online services.
• Geolocation Data, such as location information about a particular individual or device.
• Audio, Electronic, Visual, or Similar Information, such as information collected via call recordings if you are interacting with our customer service or if you call us on a recorded line, recorded meetings and webinars, videos, photographs, user profile images, and security camera footage to secure our offices and premises.
• Professional or employment-related information, such as job history and work experience, titles held, prior employers, and resumes.
• Education information, such as prior educational experience, skills, degrees, certificates earned, and licenses or other credentials held.
• Inferences. Such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.
• Sensitive Personal Information. Such as precise geolocation.

Categories of Sources of Personal Information. We generally collect personal information from the following categories of sources: consumer directly, your references, people who have referred you for a job, business partners, our clients, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers.

Purposes for Collecting and Disclosing Personal Information. As described in the “How We May Use Personal Information” section above, in general, we collect and otherwise process the personal information we collect for the following business or commercial purposes: Account – Businesses and Candidates; Analytics and improvement; Communicating with you; Marketing, promotions, and sweepstakes; Research and surveys; Advertising; Planning and managing events; Security and protection of rights; Compliance and legal process; Auditing, reporting, and other internal operations; and General business and operational support.

Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use, or disclose “sensitive personal information” beyond the purposes authorized by the CCPA.

Retention of Personal Information. We retain your personal information for as long as needed or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than delete your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

Disclosure of Personal Information to Third Parties and Other Recipients. The categories of personal information we have disclosed for a business purpose in the preceding twelve months include: identifiers, customer records, commercial information, Internet or other electronic network activity information, geolocation data, audio, video, and other electronic data, inferences, and sensitive personal information.

The categories of third parties and other recipients to whom we may disclose personal information for a business purpose may include: our business clients, business partners, vendors and service
providers, acquirers of business assets, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks.

Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-contextual behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information: identifiers, and Internet or other electronic network activity information. We disclose these categories to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share personal information about individuals we know are under age 16.

Your CCPA Rights. The CCPA provides California residents with certain rights regarding their personal information.

Note that these rights only apply to personal information we collect and process under this Policy as a business or controller. For personal information we process on behalf of our business clients in our capacity as a service provider or processor, please submit your request directly to the business client with whom you have a relationship, and we will provide reasonable assistance to that business client as necessary to enable them to respond to your requests to exercise your privacy rights.

In general, California residents, including our business clients’ employees who reside in California, have the following rights with respect to their personal information, subject to certain exceptions:

Right to Know/Access. You have the right to request the following regarding the personal information we collect about you:

• The categories or personal information we collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purposes for collecting, selling, or sharing personal information;
• The categories of third parties to whom we have disclosed personal information; and
• A copy of the specific pieces of personal information we have collected about you.

Right to Correct. You have the right to request that we correct incorrect personal information.

Right to Delete. You have the right to request we delete your personal information.

Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA. While we do not “sell” personal information in the traditional sense (i.e., for money), our use of third-party analytics and advertising cookies may be considered “selling” and “sharing” under CCPA. To exercise your right to opt-out of the “sale” or “sharing” of your personal information via third-party cookies, please use our cookie banner or click here.

You also have the right to opt-out of “sales” and “sharing” of your personal information through the use of an opt-out preference signal. If our Site detects that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC— signal, we will opt that browser or device out of cookies on our Site that result in a “sale” or “sharing” of your personal information. If you come to our Site from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.

Right to Limit Use. We do not engage in uses or disclosures of “sensitive personal information” that would trigger the right to limit use of sensitive personal information under the CCPA.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your CCPA Rights. If you are a California resident and would like to exercise your CCPA rights, you may do so via any of the methods described below:

• Calling us collect 512-331-8880
• Email us at info@tripleco.com

Verification. Before responding to your request, we must first verify your identity using the personal information you recently provided to us. You must provide us with your full name and email address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agents. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

11. Changes to this Policy

The Policy is current as of the date set forth above. We may change, update, or modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of the personal information we have previously collected from you, we will endeavor to provide you with notice, such as by posting prominent notice on our Site or within the Services.

12. Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at info@tripleco.com.