Triline Software

Privacy Policy

Last Updated: October 31, 2025

1. Introduction

Triline Software LLC (hereinafter referred to as "the Company," "we," "us," or "our") values the protection of your personal information and is committed to handling it appropriately in compliance with Japan's Act on the Protection of Personal Information. This Privacy Policy explains what personal information we collect through our website, products, and services (collectively, "Services"), and how we use, manage, and protect it.

2. Data Controller

The data controller responsible for your personal information under this Privacy Policy is:

Company Name: Triline Software LLC

Address: 6F Nishishinjuku Mizuma Bldg., 3-3-13 Nishishinjuku, Shinjuku-ku, Tokyo 160-0023, Japan

Contact: support@trilinesoftware.com

Representative: Kazushige Hosokawa

3. Personal Information We Collect

We may collect the following categories of personal information when you use our Services:

(1) Information You Provide Directly

  • Your name
  • Email address
  • Inquiry or message content
  • Other information you voluntarily provide

(2) Information Collected During Purchase

  • Your name
  • Email address
  • FX broker name
  • Broker account ID (trading account number)
  • Purchase date and time, product information
  • PayPal transaction ID (payment information processed by PayPal Inc.)

Note: We do not store or manage credit card numbers or other payment credentials. These are processed directly by PayPal Inc.

(3) Automatically Collected Information

  • IP address
  • Browser type and version
  • Operating system
  • Access date and time
  • URLs of visited pages
  • Cookie information (see Section 10 for details)

(4) Information Collected During Software Use

  • License activation information (account ID, device identifiers)
  • Software version information
  • Error logs and diagnostic information (for troubleshooting purposes)

Note: We do not collect or store your trading data, account balances, trading history, or other financial information.

4. Legal Basis for Processing

We process your personal information based on the following legal grounds:

  • Contract performance: To provide software licenses, deliver products, and provide support
  • Legal obligations: To comply with applicable laws including Japan's Act on Specified Commercial Transactions and Personal Information Protection Act
  • Legitimate interests: To improve services, prevent fraud, and ensure security
  • Consent: When you have expressly consented (e.g., for inquiry responses)

5. Purpose of Use

We use the collected personal information for the following purposes:

  • (1) Providing and managing software licenses
  • (2) Delivering products (sending download links)
  • (3) License activation and account management
  • (4) Responding to inquiries and providing customer support
  • (5) Providing important information about services and products (such as update notifications)
  • (6) Detecting and preventing fraud and unauthorized use
  • (7) Improving Services, enhancing quality, and developing new features
  • (8) Creating statistical data in a non-personally identifiable format
  • (9) Fulfilling legal obligations (such as record retention under commercial transaction laws)
  • (10) Other purposes for which we have obtained your consent

6. Sharing with Third Parties

We do not share your personal information with third parties except in the following circumstances:

(1) Service Providers (Data Processors)

To provide our Services, we engage the following service providers to process personal information on our behalf. These providers process data under our instructions and maintain appropriate security measures.

  • PayPal Inc. (United States) - Payment processing
  • Cloudflare, Inc. (United States) - Website hosting and CDN services

For information about data transfers to these providers, please see Section 8.

(2) Legal Requirements

We may disclose personal information without your consent in the following cases:

  • When required by law
  • When necessary to protect life, body, or property and obtaining consent is difficult
  • When especially necessary for improving public health or promoting children's healthy development and obtaining consent is difficult
  • When cooperating with government agencies or local authorities in performing legally mandated duties

(3) Business Transfer

If we transfer all or part of our business to a third party, we may transfer your personal information to the transferee, provided that the transferee implements protection measures equivalent to or better than this Privacy Policy.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy or as required by law.

  • Purchase records: 5 years after transaction completion (as required by commercial transaction laws)
  • Inquiry records: 2 years after resolution
  • License information: During license validity and 3 years after termination
  • Access logs: 6 months

After the retention period expires or when the purpose is fulfilled and retention is no longer necessary, we securely delete or anonymize personal information.

8. International Data Transfers

To provide our Services, we may store your personal information on servers located outside Japan or engage overseas service providers to process it.

Specifically, data may be transferred to the following countries/regions:

  • United States: PayPal Inc. (payment processing), Cloudflare, Inc. (hosting)

For these international transfers, we implement appropriate safeguards as required by Japan's Personal Information Protection Act (Article 28), such as standard contractual clauses, to ensure that your data receives protection equivalent to that provided under Japanese law.

9. Security Measures

We implement the following security measures to prevent unauthorized access, loss, destruction, falsification, and leakage of personal information:

  • Organizational measures: Establishment of personal information handling regulations, designation of responsible personnel
  • Personnel measures: Regular training and education for employees, execution of confidentiality agreements
  • Physical measures: Access control to areas handling personal information, theft prevention measures
  • Technical measures: Access controls, encrypted communications (SSL/TLS), firewalls, anti-malware protection

However, no method of transmission over the Internet or electronic storage is completely secure, so we cannot guarantee absolute security.

10. Cookies and Similar Technologies

Our website uses cookies and similar technologies to improve user experience and optimize our Services.

(1) What Are Cookies

Cookies are small text files that a website stores on your device through your browser. Cookies allow the website to remember your preferences and visit history.

(2) Types of Cookies We Use

  • Essential cookies: Required for basic website functionality (shopping cart, session management, etc.)
  • Functional cookies: Used to remember your settings and preferences
  • Analytics cookies: Used to understand website usage and improve our services (if used)

(3) Managing Cookies

You can disable, delete, or receive notifications about cookies through your browser settings. However, disabling cookies may prevent some features of our Services from functioning properly.

11. Your Rights

Under Japan's Personal Information Protection Act, you have the following rights:

  • (1) Right to access: Request disclosure of your personal information
  • (2) Right to rectification: Request correction, addition, or deletion if your information is inaccurate
  • (3) Right to erasure: Request suspension or deletion if your information is being used beyond the stated purposes or was obtained unlawfully
  • (4) Right to object: Request suspension of provision to third parties if provided unlawfully

How to Exercise Your Rights

To exercise these rights, please contact us using the information in Section 14 below. We may request information to verify your identity. We will respond to your request within two weeks in principle. Please note that we may decline requests in certain cases as permitted by law.

12. Children's Privacy

Our Services are intended for individuals aged 18 and over. If you are under 18, please obtain consent from your parent or legal guardian before using our Services. We do not knowingly collect personal information from individuals under 18.

13. Changes to This Privacy Policy

We may update this Privacy Policy due to changes in laws, business operations, or other reasons. The revised Privacy Policy will take effect when posted on our website. For material changes, we will notify you through our website or via email.

14. Contact Information

For questions about this Privacy Policy, concerns about how we handle your personal information, or to exercise your rights, please contact us:

Triline Software LLC - Privacy Officer

Email: support@trilinesoftware.com

Business hours: Weekdays 10:00-18:00 JST (excluding weekends, national holidays, and year-end/new year period)

Please note that it may take several days to respond to your inquiry.

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