Privacy Policy for www.engagett.com

Last Updated: June 27, 2025

1. Introduction and Scope

Welcome to www.engagett.com (the “Platform”), a civil engagement ecosystem operated by ThaVibes Inc, a company registered under the laws of Florida, United States, with its principal office at 111 NE St, 8th Floor, 8832, Miami, FL 33132. This Privacy Policy (the “Policy”) governs the collection, processing, use, storage, disclosure and protection of personal and non-personal information from users (“you” or “your”) during your interaction with the Platform, including its website, mobile applications, APIs and integrated services (collectively, the “Services”), primarily used in Trinidad and Tobago.

ThaVibes Inc is committed to protecting your privacy in compliance with the Data Protection Act of 2011 of Trinidad and Tobago, as well as applicable U.S. federal and state laws (e.g. Florida Information Protection Act), the General Data Protection Regulation (GDPR) for EU users where relevant and other international data protection standards. By using the Platform, you consent to the data practices described in this Policy. If you disagree with any provision, please discontinue use of the Platform and its Services immediately.

The Platform facilitates civil engagement in Trinidad and Tobago through polls, surveys, leaderboards and a hotspot map feature for reporting community issues. We collaborate with government agencies, non-governmental organizations (NGOs) and other third-party entities (“Partners”) to enhance services, conduct research and inform public policy, with data sharing conducted under strict legal and privacy safeguards.

2. Definitions

For clarity, the following terms are defined as:

Personal Information: Data that can identify an individual, such as demographic details, contact information or user-generated content.
Non-Personal Information: Data that cannot directly identify an individual, such as anonymized usage statistics or device metadata.
Processing: Any operation on information, including collection, storage, analysis, disclosure or deletion.
Third Parties: Entities other than ThaVibes Inc and its users, including service providers, Partners and regulatory authorities.

3. Information We Collect

To provide an effective user experience, we collect:

3.1 Personal Information

Demographic and Identity Data: Age range, gender, address and other identifiers provided during registration or submissions.
Account Credentials: Username, encrypted password, email address, phone number and linked social media account details if integrated.
User-Generated Content: Polls, survey responses, hotspot map entries (including geolocation, photos, videos), comments and feedback.
Communication Data: Correspondence via emails, support tickets or voice hotline interactions.

3.2 Non-Personal Information

Usage and Behavioral Data: Pages visited, features used (e.g. leaderboards, polls), session duration and interaction patterns.
Device and Technical Data: IP address, browser type/version, operating system, device identifiers and network details.
Aggregated Data: Anonymized datasets for analytical purposes.

3.3 Information from Third Parties

Social Media Platforms: Profile data if you authenticate via third-party accounts (e.g. Google, Facebook).
Partners: Data from Trinidad and Tobago government agencies, NGOs or community kiosks integrated with the Platform.
Service Providers: Analytics or user insights from vendors supporting Platform operations.

4. Mechanisms of Information Collection

We collect information through:

4.1 Direct Collection

User Inputs: Data entered via registration forms, surveys, hotspot map submissions or communications.
Voluntary Disclosures: Details shared during account creation or feature participation.

4.2 Automatic Collection

Cookies: Persistent and session cookies for tracking preferences and usage.
Web Beacons/Pixels: Technologies to monitor page views and engagement.
Log Files: Server logs capturing IP addresses, timestamps and errors.
Analytics Tools: Third-party tools (e.g. Google Analytics) for aggregated insights.

4.3 Third-Party Collection

Integrated Services: Data from kiosks, voice hotlines or Partner systems in Trinidad and Tobago.
APIs and SDKs: Information via application programming interfaces or software development kits.

5. Purposes of Information Use

We process your information for:

5.1 Core Service Delivery

Operate the Platform, including account management and hotspot map functionality.
Enable participation in polls, surveys and community reporting in Trinidad and Tobago.

5.2 Enhancement and Optimization

Analyze usage trends to improve algorithms and user interfaces.
Develop and test new features, such as leaderboard enhancements.

5.3 Communication and Engagement

Send personalized notifications, updates and responses via email, SMS or in-app messaging.
Solicit feedback to enhance service quality.

5.4 Legal and Regulatory Compliance

Comply with Trinidad and Tobago’s Data Protection Act of 2011, Florida laws and other applicable regulations, including lawful requests from authorities.
Maintain records for audits or dispute resolution.

5.5 Research and Public Policy

Analyze aggregated data for research, public safety and policy development with Partners in Trinidad and Tobago.
Use hotspot map data to address community needs, such as infrastructure or disaster relief.

6. Data Sharing and Disclosure

Your information may be shared as follows:

6.1 Service Providers

Scope: Vendors for hosting, analytics, customer support and payment processing.
Safeguards: Providers are bound by contracts ensuring confidentiality and compliance with Trinidad and Tobago and U.S. laws.

6.2 Government and NGO Partners

Purpose: Enhance services, support public safety and inform policy in Trinidad and Tobago (e.g. with Trinidad and Tobago Police Service or NGOs).
Data Treatment: Data is anonymized where possible; identifiable data is shared only with legal justification.

6.3 Legal Obligations

Compelled Disclosure: Information may be released for subpoenas, court orders or investigations under Trinidad and Tobago or U.S. law.
Protective Measures: Disclosures are limited to the minimum required.

6.4 Business Transactions

Context: Data may be transferred during mergers, acquisitions or restructuring.
Notification: Users will be informed as required by law.

6.5 Consent-Based Sharing

Data may be shared for additional purposes (e.g. promotions) with your explicit consent.

7. Data Retention and Deletion

Retention Periods: Personal Information is retained only as necessary for the purposes in Section 5 or as required by Trinidad and Tobago law (e.g. 7 years for tax records) or U.S. law.
Deletion Protocols: Data is securely deleted upon request or retention expiration, using cryptographic erasure or overwriting, subject to legal exceptions.

8. International Data Transfers

Primary Jurisdiction: Data is stored and processed primarily in the United States, compliant with Florida law, with operations tailored for Trinidad and Tobago.
Cross-Border Transfers: Data may be transferred to jurisdictions like the EU or elsewhere for service provider or Partner operations.
Safeguards: We use Standard Contractual Clauses (SCCs) or other mechanisms approved under Trinidad and Tobago’s Data Protection Act and GDPR (where applicable).

9. Security Measures

We implement:

Encryption: TLS 1.3 for data in transit; AES-256 for data at rest.
Authentication: Two-factor authentication (2FA) is available.
Monitoring: Intrusion detection, penetration testing and security audits.
Access Controls: Role-based restrictions and employee training.
Incident Response: Plans to address breaches, with prompt user notification as required by Trinidad and Tobago or U.S. law.
Limitations: No system is fully secure; we disclaim absolute guarantees.

10. User Rights and Control Mechanisms

Under Trinidad and Tobago’s Data Protection Act of 2011 and where applicable, GDPR or U.S. laws, you have:

10.1 Access and Transparency

Request a report of your Personal Information, including sources and uses.

10.2 Correction and Accuracy

Request correction of inaccurate or incomplete data within 30 days.

10.3 Deletion and Erasure

Request deletion (“right to be forgotten”), subject to legal obligations.

10.4 Restriction and Objection

Restrict or object to specific processing (e.g. analytics or Partner sharing).

10.5 Data Portability

Obtain your data in a structured, machine-readable format.

10.6 Opt-Out Preferences

Opt out of marketing or adjust cookie settings via the Platform’s dashboard.

10.7 Exercising Rights

Submit requests to connect@engagett.com. Responses will be provided within 30 days, with extensions communicated if needed.

11. Cookies, Tracking Technologies and Behavioral Analytics

Cookies: First- and third-party cookies for authentication and tracking.
Other Tools: Web beacons, pixel tags and local storage for analytics.
Management: Adjust settings via browser or Platform’s consent portal; disabling cookies may impair functionality.
Do Not Track: We honor “Do Not Track” signals where feasible.

12. Children’s Privacy Protections

Age Restriction: The Platform is not for individuals under 13.
Policy: We do not knowingly collect data from children under 13. Such data will be deleted upon verification.
Parental Oversight: Users aged 13-17 require verifiable parental consent.

13. Third-Party Links and Integrations

The Platform may link to external sites or services. We are not responsible for their privacy practices, which are not covered by this Policy.

14. Amendments to This Policy

Updates: We may modify this Policy to reflect legal or operational changes.
Notification: Material changes will be communicated via email, in-app alerts or Platform notices at least 14 days prior, unless legally mandated otherwise.
Review: Check the “Last Updated” date regularly.

15. Contact Information and Grievance Redressal

Inquiries: Contact us at connect@engagett.com.

16. Miscellaneous Provisions

Severability: If any provision is unenforceable, the remainder remains effective.
Language: This Policy is in English, which prevails over translations.

This Policy reflects our commitment to privacy, balancing innovation with accountability in fostering civil engagement in Trinidad and Tobago.