> For the complete documentation index, see [llms.txt](https://docs.triumpharcade.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.triumpharcade.com/privacy-policy-triumph-partners.md). # Privacy Policy: "Triumph Partners" Effective Date: July 7, 2026 Last Updated: July 8, 2026 ## 1. Introduction Triumph Labs, Inc., and its affiliates (including, without limitation, "Triumph TCG, LLC"), (collectively, "Company") take your privacy seriously. The Company is committed to protecting it through our compliance with this policy. The Company operates the “Triumph Partners Suite”, consisting of the “Triumph Partners” web portal and the “Triumph Partners” mobile application, together with related services for the onboarding, enablement, and management of vendors that sell collectible items and other goods to the Company (each a “Vendor” and together “Vendors”). This policy covers all information collected through the Triumph Partners Suite. In this Privacy Policy, the Triumph Partners web portal and the “Triumph Partners” mobile application are together referred to as the “App”. This policy describes: • The types of information we may collect or that you may provide when you register with, access, use, or transact with the App or the Company website. • Our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect in the App, from our website, and in electronic communications sent through or in connection with any of the foregoing. This policy DOES NOT apply to information that you provide to or is collected by any third party. Third parties have their own privacy policies, which we encourage you to read before providing information on or through them. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use a Company App or the Triumph website. By downloading, registering with, or using the Website or the App, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Company App or Website after we revise this policy means you accept those changes, so please check the policy periodically for updates. ## 2. Age Limits. The App is intended solely for use by individuals who are at least eighteen (18) years old and who use it for business purposes, on their own behalf or on behalf of a company or entity. We do not knowingly collect personal information from children under 13 years of age. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, or if a child under 18 has accessed the App, please contact us at . ## 3. Information We Collect and How We Collect It We collect information from and about users of the App: • Directly from you when you provide it to us. • Automatically when you use the App. • Automatically when you execute transactions on the App. • Automatically when you communicate through the App. • Your responses to surveys that we might ask you to complete for research purposes. • Details of transactions you carry out through the App and details related to the fulfillment of your transaction. • Automatically when you allow various permissions (camera, photos, etc.). • On our websites using cookies, for more information see our [Cookie Policy](https://docs.triumpharcade.com/cookie-policy). ### A. Information You Provide to Us When you download, register with, or use the App, we may ask you provide information: • By which you may be personally identified, such as name, email address, telephone number, and birthdate, and, if you act on behalf of a company or entity, business information such as the entity’s legal name, address, and tax identification number. • Information submitted by you that may allow you to be personally identified, such as a user selected image, a username, and information that you communicate to the Company within the App, for example when you report a problem within the App using the customer support chat function. • That is about you but individually does not identify you, such as the following: App input data, for example the buttons you press when interacting with the App, inventory and submission data, pricing and offer inputs, and vendor performance metrics derived from your transaction history. • When transacting through the App you may be required to provide financial information including credit or debit card information, address, or bank account information, as well as tax documentation such as an IRS Form W-9 or W-8. • In order to receive payments you will be required to provide or we will collect the following additional information by which you may be personally identified including: an image of a government issued identification document or such other identification document as may be accepted by the Company; a short video that includes your face; the location of access; the internet protocol (IP) address from which you access the system; data regarding the browser or software used to access the system; and the time of access (the “Vendor Authentication Data”). ### B. Automatic Information Collection and Tracking When you download, access, and use the App, it may use technology to automatically collect: • Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs of any category of collected data identified in this Privacy Policy, communication data, the resources that you access and use on or through the App, images of the App output during use, results and outputs from App use, account and payment records, transaction and submission history, and vendor performance profiles developed from such data. • Device Information. We may collect information about your mobile device and internet connection including the IP address, the unique device identifier, operating system, browser type, mobile network information, the device's telephone number, and the devices data service providers. • Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device that you provide access to. This includes, for example, photographs which you select for upload, such as images of collectible items or related documentation. • Location Information. The App collects and logs approximate location information derived from your internet protocol (IP) address each time you access the App. The App does not collect precise GPS location information from your device. We use location information only as described in Section 4 (How We Use Your Information). • Cookies. Cookies are small text files placed on your device that allow us to improve our services, analyze traffic, and enhance your overall user experience. You may opt-out of the use of cookies, for more information see our Cookie Policy . If you do not want us to collect this information do not download or use the App or delete your account as well as the applications from your device. ### C. Third-Party Information Collection When you use the App, certain third parties that are contracted with by the Company for the provision of services related to the app (“Integrated Third Parties”), including: (i) payment processors; (ii) in-app communication providers; (iii) device authentication providers; and (iv) customer identity authentication providers, may receive certain information shared by Company. Information provided to Integrated Third Parties should not be used for any other purpose outside of fulfilling their service to the Company. If you believe that your information is or has been used inappropriately by any Integrated Third Parties, please contact . Third parties may use tracking technologies to collect information about you when you use download or use the App. For example: • Platforms from which you download the App. • Your internet service provider. • Your device manufacturer. • Your mobile or data service provider. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. ## 4. How We Use Your Information We use information that we collect about you or that you provide to us, including any personal information, to: • Operate, develop, and improve our vendor ranking engine, which evaluates Vendors based on transaction, submission, pricing, fulfillment, and related performance data in order to rank Vendors and to determine eligibility for programs, rates, and purchasing allocations. • Investigate, trace, and prevent loss and theft, including loss or theft of inventory, shipments, and payments. • Estimate and analyze market conditions and competitive pressure relevant to our purchasing and pricing, including by analyzing aggregate Vendor pricing, volume, and category trends. • Measure and analyze the reach and activity of our vendor network. • Provide you with the App features. • Give you notices about your account. • Contact you regarding any App issues. (Please note that you will never be requested to provide your account credentials to the Company – you should not share your account information with anyone. If you have issues with account access contact .) • Carry out our obligations and enforce our rights arising from the Terms of Use, including related to payments and Vendor transactions. • Notify you when App updates are available and of changes to any products or services we offer or provide though it. • Confirm your identity. • Fulfill any other purpose for which you provide it. • Provide a personalized experience, for example tailoring the App to your business and activity. • Employ anti-fraud algorithms and features. • Track the performance of the App, improve the App and company practices. The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to: • Estimate our audience size and usage patterns. • Store information about your preferences, allowing us to customize our App according to your individual business and preferences. • Recognize you when you use the App. • Maintain compliance, financial, tax, and other legally required records. • Improve App performance. We retain and use Vendor transaction, submission, pricing, fulfillment, and performance data on a long-term basis, including after your account is closed, in order to preserve the historical depth, accuracy, and robustness of our vendor ranking engine and related analytical models, subject to your rights described in Section 6. We may also use such data, in aggregated and/or de-identified form, to develop and publish market indices, benchmarks, or similar analytical products. Any market index, benchmark, or similar product made available outside the Company will consist solely of aggregated or de-identified information that does not identify you or any individual Vendor. We use location information we collect to: (i) ensure that you are in an Eligible Location where use of the App is authorized; (ii) assist in the confirmation of your identity; (iii) measure and analyze the reach and activity of our vendor network; and (iv) investigate, trace, and prevent loss and theft, including loss or theft of inventory and shipments — and for no other purposes. For clarity, location information is not used in our vendor ranking engine or in our analysis of market conditions and competitive pressure. ## 5. Disclosure of Your Information We may disclose: (i) aggregated information about our users in a de-identified form, and (ii) information that does not identify any individual or device, in each case without restriction, including in connection with any market index, benchmark, or similar analytical product described in Section 4. In addition, we may disclose personal information that we collect or you provide: • To contractors, service providers, and other third parties we use to support our business, such as the Integrated Third Parties, who are bound by contractual obligations to keep personal information disclosed to them confidential and use it only for the purposes for which it is disclosed to them. • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our users is among the assets transferred. • To fulfill the purpose for which you provide it. • For any other purpose disclosed by us when you provide the information. • With your consent. • To comply with any court order, law, or legal process, including to respond to any government or regulatory request. • To comply with service provider obligations, including payment processor and compliance requirements. • To enforce our rights arising from any contracts entered into between you and us, including the Terms of Use and any Vendor Agreements. • To execute payments and other Platform transactions. • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, loss and theft prevention, and credit risk reduction. Mobile information will not be shared with third parties or affiliates for third party marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. The Company does not currently sell any information. We do not share personal information collected through the App with third parties for marketing or advertising purposes. ## 6. Your Rights and Choices Relating to Use of Your Information ### 6.1 Your Choices Relating to Use of Your Information • Tracking Technologies. You can choose whether or not to allow the App to collect information through other tracking technologies by not authorizing such collection or terminating the authorization. If you block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly. • Location Information. Because the location information we collect is derived from your IP address, it is collected automatically whenever you access the App and cannot be disabled through your device’s location settings. If you do not want us to collect this information, do not use the App. Please note that use of a VPN or other means to obscure your IP address or location is prohibited by the Terms of Use. • Communication Preferences. If you do not want to be contacted by email or text message you have the right to not consent to such use. If you have already consented you may opt out in accordance with the instructions on such communications. • Sale of Your Data. We do not currently sell any of your data, however, if you do not want your data to be sold in the future, you may opt out of such use. • Sharing Your Data. We do not share your data with third parties for marketing purposes. If you do not want your data to be shared, you may opt out of such use. ### 6.2 Your Rights Relating to Your Information Subject to the limitations and exceptions in applicable law, including but not limited to exceptions related to required retention of data for tax or financial purposes, for anti-fraud and anti-theft purposes, and for system functioning, you have the following rights related to your information: • Right to Withdraw Consent. You have the right to withdraw your consent for marketing communications (by following the opt-out instructions on such communications), and for the sale of your personal information or the sharing of your personal information. You may exercise these rights at any time. • Right to Confirm the Processing of Your Information. You have the right to confirm with the Company whether we are processing your personal information, and the categories of personal information that we collect and use about you. • Right to Access Your Personal Information. You have the right to access the personal information we have collected from you, unless otherwise required by law you may only make this request for access once per year. The delivery of the personal information made under this section will be provided in its native format, for example, CSV, TXT, or a PDF extract. • Right to Correct Your Personal Information. You have the right to correct errors in the personal information we store. • Right to Deletion. You have the right to delete your personal information subject to certain legal exceptions. If you make a request to delete your personal information we will delete or deidentify all information that is not subject to an exception. Following a verified deletion request, information used in our vendor ranking engine, loss- and theft-prevention systems, and market analytics will be deleted or de-identified, and we may retain and continue to use aggregated or de-identified data that does not identify you. • Right to Request a Transfer of Your Information. You have the right to request a transfer of your information, however, please note that the information we collect and store is generally unique to the App, as a result, there is no guaranty and the Company makes no representation that a transferee will be able to make use the information we provide, which will be in the formats described in the above "Right to Access Your Personal Information". • Right to Opt Out of Targeted Advertising. At this time the Company does not engage in targeted advertising and as a result the default is that you are opted out of any future targeted advertising absent a change in this Privacy Policy and your consent to such advertising. • Right to Opt Out of the Sale of Your Personal Information. You have the right to opt out of the sale of your personal information. • Right to Opt Out of the Sharing of Your Personal Information. You have the right to opt out of the sharing of your personal information. To exercise your rights please complete the following [form](https://forms.zohopublic.com/jamin3/form/SellorShareOptOutForm/formperma/9JXdBvZWmc-fbMYrVV2h9jeUNoDk5966QZYSAhHOSoY). If you choose to exercise any of your rights above, you will be required to verify your identity, which may include using Company's then-in-effect identity verification process as outlined in the Company Terms of Use prior to any account information being provided to you or changes made to your personal information handling. The following information will not be deleted for a period of seven years from the last paid transaction or deletion request, whichever is greater, as it is associated with financial transactions, business security practices, or is for internal uses that are compatible with reasonable consumer expectations or the context in which the information was provided: full name, unique device identifier, birthdate, phone number, social security number if required to be collected, transaction / submission history, vendor performance / ranking profiles. The following information will not be deleted upon request for Vendors that have been banned as it is related to business security: full name, unique device identifier, birthdate, phone number, social security number if required to be collected, transaction / submission history, government issued identification documents, internet protocol address. ### 6.3 Third Party Use of Your Information We do not control third parties' collection or use of your information (where we are not providing it to such third parties) to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website . ### 6.4 Additional Rights for Users in Specific Locations Residents in certain states, such as California, or who are located in a European Common Economic Zone country or the United Kingdom may have additional personal information rights and choices. Please see the section Specific Privacy Rights for more information. ## 7. Legally Required Disclosures The Company does not sell personal information collected through the App and does not share such information with third parties for cross-context behavioral advertising. If our practices change, we will update this Privacy Policy and provide any legally required notices and opt-out mechanisms before doing so. ## 8. Specific Privacy Rights for Certain Residents or Locations Country and state consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. If you are a resident of, or otherwise covered by any of the below state or countries applicable laws please review the additional rights and disclosures applicable to you: California Privacy Policy and Notices ## 9. Data Security We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, for example, any payment transactions will be encrypted using SSL technology. The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of the App, this password can allow access to the account you hold with the App and allow the person with such a password to access payments and other sensitive features of your account. You are responsible for choosing a strong password, regularly changing it, and keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our Apps. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. ## 10. SMS/Text Messaging ### 10.1 Collection of Mobile Phone Numbers The Company collects mobile phone numbers when you provide them during account signup. By providing your mobile number and checking the SMS consent box at signup, you consent to receive text messages from the Company at the phone number associated with your account. SMS consent is collected separately from your consent to receive emails and is specific to the Company as the message sender. ### 10.2 Types of Messages You Will Receive After opting in, you may receive two categories of text messages from the Company: Account and transactional messages, such as payment approvals, payment status, order confirmations, shipping and tracking updates, and other notifications related to your account or transactions. Promotional and marketing messages, such as new product announcements, special offers, and similar communications. Message frequency varies. Message and data rates may apply. Consent to receive SMS messages is not a condition of using our services. ### 10.3 Message and Data Costs You are solely responsible for any charges imposed by your mobile carrier or service provider for receiving text messages from the Company, including any data, messaging, or other fees associated with the receipt of SMS messages on your device. Message and data rates may apply, and these charges are determined by your carrier, not by the Company. The Company is not responsible for any costs you incur as a result of receiving messages you have consented to receive. If you are unsure about the charges that may apply, contact your mobile carrier before opting in. ### 10.4 Sender-Specific Consent Your consent to receive SMS messages applies only to the Company as the message sender and only to the messaging program you opted into. We do not use SMS consent collected through one Company product or app to send you text messages from a different Company product or app. If you wish to receive text messages from another Company brand or product, you will be asked to provide separate SMS consent through that product's own opt-in flow. ### 10.5 No Sharing of SMS Opt-In Data with Third Parties Mobile information and SMS opt-in consent will not be shared with third parties or affiliates for marketing or promotional purposes. All categories of personal information described elsewhere in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, including any Company parent, subsidiaries, or affiliated brands, for their own marketing purposes. We may share mobile information only with service providers that help us deliver SMS messages on our behalf — including our SMS platform provider, message aggregators, and mobile carriers responsible for transmitting messages. These parties are contractually limited to using the information solely for delivering messages to you and may not use it for their own marketing purposes. We may also disclose information when required by law, subpoena, or valid legal process. ### 10.6 Opt-Out You may opt out of receiving promotional SMS messages at any time by replying STOP to any message. After you send STOP, we will send a confirmation message and you will no longer receive promotional SMS messages from the program you opted out of. You may continue to receive transactional messages essential to your account (such as payment confirmations or shipping updates) unless you close your account. You may also contact us at to request removal. ### 10.7 Help For help with our SMS program, reply HELP to any message or contact us at . ### 10.8 Eligibility SMS messages from the Company are intended for users 18 years of age or older. By opting in, you represent that you are at least 18 and otherwise meet the eligibility requirements of the product you are using. ### 10.9 Data Retention We retain mobile phone numbers and related messaging records for as long as your account is active and as needed to provide the SMS service. When you opt out or close your account, we retain a record of your opt-out request to ensure we honor it, but we will not send you further promotional messages. ### 10.10 Your Rights You have the right to access, correct, or request deletion of the personal information we hold about you, including your mobile phone number. To exercise these rights, contact us at . Depending on your location, you may have additional rights under laws such as the California Consumer Privacy Act (CCPA). ## 11. Changes to Our Privacy Policy We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes. The Company may log you out of the App in order to require your review and agreement to this Privacy Policy, please review this Privacy Policy and associated documents each time you login for any changes. ## 12. Contact Information To ask questions or comment about this privacy policy and our privacy practices, contact us at . To register a complaint or concern, please provide the full details of your complaint and an email and contact phone number to . ## 13. Governing Law and Dispute Resolution This Privacy Policy arises under the Company's Terms of Use and any dispute between you and the Company related to this Privacy Policy shall be governed by the arbitration provisions contained in the Terms of Use and the law applicable to such disputes as contained therein, except to the extent an alternative choice of law is required under applicable law.