Trinaro » Privacy Policy

01. INTRODUCTION

This Privacy Policy explains how personal data are collected, used, stored and protected in connection with the website trinaro.com (the “Website”).

We respect the privacy of Website users and process personal data in accordance with applicable European Union and Polish data protection laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – “GDPR”).

This Privacy Policy also provides information concerning the use of cookies and similar technologies and the use of artificial intelligence in the creation of certain content presented on the Website.

02. DATA CONTROLLER

The controller of personal data processed through the Website is:

Legal name: Rafał Budweil Jaxa Networks

Registered office: Gryfity 3, 30-201 Kraków, woj. małopolskie, POLAND

Registration details: NIP: PL6772227675, REGON: 356828625

Operating the Website and the Trinaro brand.

For privacy and data protection enquiries, please contact:

info@trinaro.com

If a Data Protection Officer is appointed in the future, their contact details will be added to this Privacy Policy.

03. PERSONAL DATA WE MAY COLLECT

Depending on how you use the Website, we may process information that you provide directly to us as well as certain technical information generated when you use the Website.

This may include your name, surname, e-mail address, country or region, city, company or organisation name, website address, professional or media affiliation, selected areas of interest, partnership interests, enquiry type and the content of messages submitted through Website forms.

Where you use the Join Trinaro, partnership or media enquiry forms, we process the information that you choose to provide through those forms.

We may also process technical information related to your use of the Website, including IP address, browser type, device type, operating system, approximate location derived from technical information, date and time of access, visited pages, server logs and information collected through cookies or similar technologies.

We do not intentionally request special categories of personal data such as information concerning health, religion, political views, racial or ethnic origin or other sensitive information. Please do not include such information in free-text fields unless it is strictly necessary.

04. PURPOSES AND LEGAL BASES FOR PROCESSING

We may process personal data for the following purposes.

Responding to enquiries and correspondence.We process contact details and the contents of communications in order to respond to questions, media requests, partnership enquiries, expressions of interest and other communications. Depending on the circumstances, the legal basis may be Article 6(1)(b) GDPR where processing is necessary to take steps at your request before entering into a contract, or Article 6(1)(f) GDPR where processing is necessary for our legitimate interest in conducting business communications and responding to enquiries.

Managing potential business, partnership and media relationships.Where you contact Trinaro regarding cooperation, sponsorship, technology partnerships, media activities or other business opportunities, we may retain relevant correspondence to manage the relationship and follow up on the enquiry. The legal basis is Article 6(1)(b) or Article 6(1)(f) GDPR, depending on the context.

Managing expressions of interest in Trinaro.Where you voluntarily register your interest in Trinaro, test drives, events, project updates or ownership opportunities, we may use the information you provide to manage that interest and, where separately permitted, communicate relevant updates to you.

Marketing and project updates.Where you have expressly agreed to receive marketing information or project updates electronically, the legal basis for processing personal data is Article 6(1)(a) GDPR – your consent – together with the applicable provisions of Polish electronic communications law. You may withdraw your consent at any time.

Operating, maintaining and securing the Website.Technical information and server logs may be processed to ensure the proper operation, integrity and security of the Website, prevent abuse and investigate technical incidents. The legal basis is Article 6(1)(f) GDPR – our legitimate interest in providing and securing the Website.

Website analytics.Where analytics technologies require consent, analytics data are processed only after you have given the relevant consent. The legal basis is Article 6(1)(a) GDPR.

Compliance with legal obligations.We may process personal data where required by applicable law. The legal basis is Article 6(1)(c) GDPR.

Establishing, exercising or defending legal claims.Where necessary, information may be retained or otherwise processed for the establishment, exercise or defence of legal claims. The legal basis is Article 6(1)(f) GDPR.

Where processing is based on consent, withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

05. CONTACT FORMS

The Website may include forms intended for prospective users, partners, journalists, media representatives and other persons interested in Trinaro.

Providing data in a form is voluntary. However, information identified as required may be necessary for us to process and respond to your enquiry.

Data submitted through forms will not be used for unrelated marketing purposes unless you have separately consented to such communication or another lawful basis applies.

Please provide only information that is necessary for the purpose of your enquiry.

06. RECIPIENTS OF PERSONAL DATA

Personal data may be disclosed to service providers that support us in operating the Website and our business activities.

These may include providers of website hosting and infrastructure, website development and maintenance services, e-mail and communication services, IT and cybersecurity services, analytics tools, cloud services, professional advisers such as legal or accounting advisers, and public authorities where disclosure is required by law.

Such providers receive access to personal data only to the extent necessary for the services they provide and, where required, process personal data under appropriate data processing agreements.

[[TO BE VERIFIED BEFORE PUBLICATION: insert or confirm key providers, including Website/hosting provider, e-mail provider and analytics provider.]]

If the Website continues to be hosted or operated using WebWave infrastructure, the exact legal entity acting as service provider and the relevant data processing arrangements should be verified and reflected here where appropriate.

07. INTERNATIONAL DATA TRANSFERS

We aim to use service providers located within the European Economic Area (“EEA”) whenever reasonably possible.

Some technology or cloud service providers may, however, process information outside the EEA.

Where personal data are transferred to a country outside the EEA that has not been recognised by the European Commission as providing an adequate level of protection, the transfer will be based on appropriate safeguards recognised by the GDPR, such as Standard Contractual Clauses adopted by the European Commission, together with additional safeguards where required.

[[TO BE COMPLETED AFTER THE FINAL LIST OF WEBSITE, E-MAIL, ANALYTICS AND CLOUD PROVIDERS HAS BEEN CONFIRMED.]]

08. DATA RETENTION

Personal data are retained only for as long as necessary for the purpose for which they were collected.

Correspondence and enquiry data may be stored for the time necessary to handle the enquiry and, where justified, for an additional period required to maintain business records or establish, exercise or defend potential legal claims.

Data processed on the basis of consent for marketing or project updates will generally be processed until the consent is withdrawn or the purpose for which the data were collected no longer exists.

Technical and security logs are retained for the period reasonably necessary to ensure the security and proper operation of the Website.

Cookie retention periods depend on the type and purpose of each cookie and will be indicated in the Website’s cookie settings.

Statutory retention requirements may require certain information to be stored for a longer period.

09. YOUR GDPR RIGHTS

Subject to the conditions set out in the GDPR, you may have the right to access your personal data, obtain a copy of the data, request correction of inaccurate information, request deletion of personal data, request restriction of processing, receive certain data in a portable format, object to processing based on legitimate interests and withdraw consent at any time where processing is based on consent.

You may exercise your rights by contacting:

info@trinaro.com

We may need to verify your identity before fulfilling a request.

You also have the right to lodge a complaint with the competent supervisory authority. In Poland, the supervisory authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych – UODO). The right to complain to the President of UODO is expressly recognised under the GDPR framework.

10. COOKIES AND SIMILAR TECHNOLOGIES

The Website may use cookies and similar technologies.

Cookies are small pieces of information stored on, or accessed from, your device when you visit a website.

We may use the following categories of cookies:

Strictly necessary cookies are required for the Website to operate correctly, provide requested functionality, maintain security or remember privacy choices.

Preference cookies may remember selected Website settings or preferences.

Analytics cookies may help us understand how visitors use the Website, which pages are visited and how the Website can be improved.

Marketing or third-party cookies, if used, may support advertising, campaign measurement or integration with external platforms.

Under Article 399 of the Polish Electronic Communications Law (Prawo komunikacji elektronicznej), storing information on or accessing information already stored on a user’s terminal equipment generally requires prior clear information and the user’s consent.

Cookies that are strictly necessary to provide a service expressly requested by the user or to ensure transmission of communications may be used without a separate consent where permitted by law. Polish public-sector cookie guidance likewise distinguishes necessary cookies from cookies requiring consent.

Non-essential analytics, marketing or similar technologies will not be activated before the required consent has been provided.

Users should be able to accept or reject non-essential cookies and change their choices later through the Website’s cookie settings.

Refusing non-essential cookies should not prevent access to the basic content of the Website.

A detailed and current list of cookies, including provider, purpose and retention period, should be made available through the Website’s cookie management interface.

[[COOKIE SCAN AND COOKIE TABLE TO BE COMPLETED AFTER THE FINAL VERSION OF TRINARO.COM IS PUBLISHED.]]

11. WITHDRAWING OR CHANGING COOKIE CONSENT

You may change or withdraw your cookie choices at any time using the cookie settings available on the Website.

You may also configure your browser to restrict or delete cookies. Browser settings are independent from the consent controls provided on the Website.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

12. AUTOMATED DECISION-MAKING AND PROFILING

At the date of this Privacy Policy, Trinaro does not use personal data collected through the Website to make decisions based solely on automated processing that produce legal effects concerning users or similarly significantly affect them within the meaning of Article 22 GDPR.

We do not use Website enquiry forms to create automated eligibility, credit, risk or behavioural scores.

If this changes, this Privacy Policy will be updated and the required information will be provided to affected users.

13. ARTIFICIAL INTELLIGENCE AND AI-GENERATED CONTENT

Trinaro uses artificial intelligence and AI-assisted creative tools as part of its visual communication and content production process.

Most visual images, visualisations and renderings presented on trinaro.com are AI-generated or AI-assisted.

Such materials may include visualisations of the Trinaro vehicle, conceptual environments, urban scenes, events, demonstrations, people, vehicle finishes, technology concepts or other illustrative scenarios.

Unless expressly identified as documentary material, such images should be understood as conceptual or illustrative visual content and not necessarily as photographs of an actual production vehicle, real event, real location or completed commercial product.

Certain design, technical or product details shown in AI-generated visualisations may differ from current prototypes or future production specifications.

Trinaro seeks to use AI-generated content transparently and in accordance with Regulation (EU) 2024/1689, commonly known as the EU Artificial Intelligence Act (AI Act).

The transparency obligations in Article 50 AI Act apply from 2 August 2026.

Where AI-generated or AI-manipulated image, audio or video content appreciably resembles an existing person, object, place, entity or event and could falsely appear authentic, Trinaro will provide an appropriate, clear and distinguishable disclosure that the content has been artificially generated or manipulated, where required by Article 50 AI Act.

For evidently artistic, creative, fictional or analogous content, disclosure may be provided in a manner that informs users of the artificial origin of the content without unnecessarily interfering with the presentation or enjoyment of the creative work, as permitted by the AI Act.

Where technical provenance information or machine-readable AI-origin markings are provided by the AI system used to create content, Trinaro will not intentionally remove such information where its preservation is technically and operationally feasible.

Some written material may also be prepared with the assistance of AI-based tools. Content published by Trinaro is subject to human review, editorial control and editorial responsibility before publication.

If the Website introduces an AI-powered chatbot or another system that interacts directly with users, users will be informed that they are interacting with an AI system where required by Article 50 AI Act.

14. AI VISUAL CONTENT NOTICE

For additional transparency, Trinaro may mark relevant Website materials with notices such as:

AI-GENERATED VISUAL, AI-ASSISTED VISUAL, CONCEPT VISUALISATION

or another equivalent indication that clearly communicates the artificial or conceptual nature of the content.

A general Website disclosure does not replace an individual disclosure where an individual piece of content is subject to a specific transparency requirement under applicable law.

15. DATA SECURITY

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other unlawful forms of processing.

Security measures are reviewed and adapted where appropriate to the nature of the Website, the processing activities and the risks associated with the processing of personal data.

No method of transmitting or storing information is completely secure. Therefore, absolute security cannot be guaranteed.

16. THIRD-PARTY WEBSITES AND SOCIAL MEDIA

The Website may contain links to external websites, social media platforms, video platforms or other third-party services.

When you follow such a link, the third party may process personal data under its own privacy policy.

Trinaro does not determine and is not responsible for the privacy practices of independent third-party websites.

We recommend reviewing their privacy information before providing personal data.

17. CHILDREN'S PRIVACY

The Website is not specifically directed to children and we do not intentionally seek to collect personal data from children through the Website.

If we become aware that personal data relating to a child have been submitted in circumstances requiring parental or guardian authorisation under applicable law, we will take appropriate steps to address the situation.

18. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, including where Website functionality changes, new services or technologies are introduced, service providers change or legal requirements are updated.

The current version will always be published at:

trinaro.com

The date of the most recent update will be indicated at the beginning of this Privacy Policy.

Material changes may additionally be communicated through the Website where appropriate.

19. CONTACT

For any questions regarding this Privacy Policy, the processing of personal data or the exercise of your privacy rights, please contact:

TRINARO

Rafał Budweil Jaxa Networks

E-mail: info@trinaro.com

Registered address: Gryfity 3, 30-201 Kraków, woj. małopolskie, POLAND

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PRIVACY POLICY.