Truly Technologies Privacy Policy

We at Truly Technologies Inc., are committed to protecting the privacy of customers and users of our Truly services, users of our website, truly.co and users of our mobile application. We have therefore created this policy statement (the “Policy”) to explain our privacy practices and procedures, including:

Information We Collect

We believe that you should know what information we collect from you, as well as understand how we use, disclose, and protect that information. We believe that you should be able to communicate with us easily to limit the disclosure of any of your personally identifiable information, where practicable, and to address any questions or concerns that you may have. And we will not disclose information to unaffiliated third parties without your consent or as otherwise provided in this Policy.

By purchasing, subscribing to, or using Truly’s services or using Truly’s website, you agree to the terms and conditions set forth in this Policy. For other terms and conditions that govern your use of Truly’s services and its webSite, please review the Truly website.

1. INFORMATION WE COLLECT

We collect a variety of personally identifiable information (also referred to as “personal data”) about users of our services and visitors to our website in order to ensure an enjoyable user experience and seamless communications. When we use the term “personally identifiable information,” we mean information that is directly associated with, or could be used to identify, a specific person. Such information includes a name telephone number, e-mail address, or information about activities directly linked to that person which would permit the physical or online contacting of that person.

Our definition of personally identifiable information does not include “aggregate information”— data we collect about a group or category of services or users or customers and from which individual user or customer identities have been removed. Aggregate information—for example, a report that indicates that a certain number of our customers reside in a particular state or region of the United States, or a report on how many of our customers visited particular pages of our website—aids us in understanding trends and customer needs. For example, aggregate information allows us to consider new services or tailor existing services to customer preferences, and to provide aggregate statistics to customers, potential customers, and business partners.

Our definition of personally identifiable information also does not include your Internet protocol (“IP”) address.  We collect the following types of personally identifiable information through use of our website and telephone calls to Truly customer service:

Truly does not knowingly collect—either actively or passively—any information, including personal information as defined by the Children’s Online Privacy Protection Act, from children under the age of 13.

To see how we use, disclose, and protect the personally identifiable information that we collect, please review the rest of this Policy.

2. OUR USE OF PERSONALLY IDENTIFIABLE INFORMATION

Our Internal Use: In general, we use personally identifiable information to serve our existing and prospective customers and to enhance and extend our customer relationships. By understanding how you use our services and our website, we are able to customize and personalize our interactions with you. More specifically:

While you may choose not to receive marketing information from us, you will continue to receive bills, customer service-related notifications, and other similar information from us electronically or otherwise. You will also continue to receive communications directly related to each service you purchase or subscribe to.

Our Customer Surveys: Periodically, you may be able to participate in our surveys to help us improve our services. Any personally identifiable information that we may collect from you in a survey will ONLY be used internally by Truly. And unless otherwise explained in the instructions for a particular customer survey, any personally identifiable information you provide to us for purposes of that survey will be used in accordance with this Policy.

Third-Party Use: To understand when and how Truly may disclose personally identifiable information to unaffiliated third parties, please read the Disclosure of Your Personally Identifiable Information section below

 

3. DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION

Because information about our existing and prospective customers is one of our most important business assets, we seek to protect it and keep it confidential. We do not share personally identifiable information with unaffiliated third parties, nor do we sell it to third parties, unless permitted to do so in accordance with this Policy.

Your Consent: Truly may disclose your personally identifiable information if you consent to the disclosure in advance. Depending on the service, we may obtain your consent in a number of ways, including:

In general, we may release personally identifiable information without your consent when we believe release is appropriate to do one of the following:

Disclosure to Affiliates: We may share your personal data between our Truly group companies and business affiliates where it is necessary to support the services provided to you.

In order to verify payment methods and prevent fraud, Truly verifies personally identifiable information, including payment information, with payment providers and fraud prevention services. If at any time you apply for a credit line with Truly, Truly may perform a credit inquiry with credit reporting agencies, and such inquiry may be noted on your credit record. We may use automated decision making systems to verify payment methods, assess creditworthiness, or prevent fraud, and we may contact you requesting additional information when needed.

For European Economic Area (“EEA”) customers, this may mean that the personally identifiable information (i.e., personal data) you provide us may be transferred to countries outside the EEA. By way of example, this may happen if any of our group servers or companies are located in a country outside the EEA, such as Truly, Inc., which is located in the United States. These countries may not have similar data protection laws to the EEA. Nonetheless, if we transfer information outside the EEA in this way, we will take steps to ensure your privacy rights continue to be respected.

Disclosure to Unaffiliated Third Parties: We may share personally identifiable information with unaffiliated third parties only as necessary to complete a transaction or perform a service that you have requested, or to support the technical operation and maintenance of our services and of our website. We may also share personally identifiable information with or to our agents, outside vendors or service providers to perform functions on our behalf. For example, we use third party service providers to perform functions such as analyzing data, providing marketing assistance, providing customer service and processing orders. When the unaffiliated third party acts solely on our behalf, Truly requires that party to follow our privacy practices. Truly does not sell its customer lists or any personally identifiable information associated with its customers to third parties.

Business Transfers: Information about our users and customers, including personally identifiable information, may be disclosed as part of any merger, acquisition, or sale of company assets. It may also be disclosed in the unlikely event of an insolvency, bankruptcy, or receivership in which personally identifiable information would be transferred as one of the business assets of Truly.

5. CUSTOMER PRODUCTIVITY SUITE DATA (Google Apps, Outlook)

In order to provide a better user experience, Truly integrates with Google and Office365 productivity suites through Oauth.

Depending on the functionality that the user opts into using,  the following Oauth scopes could be used.  We detail here what those scopes are and how data collected through them may be used.

 

Truly’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

 

5. OUR USE OF “COOKIES”

Truly uses “cookies” to enhance your use of our website. “Cookies” are small text files placed on your computer’s hard drive by a website when you visit that website. These files identify your computer and record your preferences and other data about your visit to a website so that when you return to that site, the site operator knows who you are and can personalize your visit. For example, cookies enable a website shopping cart to function so that you only have to check out once. Consequently, cookies are often tied to the use of personally identifiable information while using our website. If you choose not to accept the use of cookies, your use of our website may be impaired.

Cookies allow us to do the following:

We do not use cookies to store credit card information. Truly does, however, use cookies to store login information (including passwords) for customers who choose the option of storing such information on their computers.

We also use a session-based cookie to maintain continuity of navigation for you when viewing our website during a particular online session. After closing the browser, the session cookie simply terminates; it is not stored on your computer’s hard drive thereafter.

In conjunction with web beacons, Truly may also use cookies, but these cookies are not linked to your personally identifiable information.

Truly does not use technology that recognizes “Do Not Track”’ signals from your browser. You can block cookies from your computer through your web browser’s settings (see below).:

 

6. OUR USE OF WEB BEACONS

Truly uses web beacons on its website. A web beacon (sometimes called a “web bug” or “clear GIF”) is a tiny graphic image (usually a 1-by-1 pixel) displayed in a webpage, web-based document, or e-mail message, but it is usually invisible, as it is usually the same color as the background of the webpage, document, or e-mail message. When the user’s web browser reads the HTML code for the web beacon to retrieve the image, it can pass along the IP address of the user’s computer, the time the web beacon was viewed and for how long, and the type of browser used. Web beacons can also be linked to a user’s cookies and any personally identifiable information that may be stored in them.

Truly uses web beacons to gather aggregate information, as described above in Information We Collect. Truly does not use web beacons that link to cookies or to personally identifiable information on unaffiliated third-party websites. And it does not permit unaffiliated third parties to place such web beacons in advertisements on Truly’s website.

 

7. OUR USE OF BANNER ADS

We may use third-party advertising companies to place advertisements about Truly products and services on other websites. These advertising companies may use cookies, web beacons, or other technologies to measure the effectiveness of our ads. The advertising companies may use anonymous information about your visits to our and other websites in order to measure advertising effectiveness and offer selective ad content. But they use an anonymous identifier, such as a number, to identify you. They do not link to or collect any personally identifying information. The use of such cookies, web beacons, and other technologies is subject to the advertising companies’ privacy policies, not the Policy of Truly. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out of being targeted by contacting the provider serving the advertisement, or by following the instructions to block cookies using your web browser settings, as described above. Please note this does not opt you out of being served advertising; you will continue to receive generic ads.

 

8. CHECKING ACCOUNT AND “Settings” INFORMATION FOR ACCURACY

Truly customers can review or change the information in the “Settings” section of our website, or by telephoning or writing to Customer Service. As noted in the Information We Collect About You section above, we may also use updated address information obtained from other sources to update our records. We will respond to your requests to access your records within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services contact us.

 

9. SOCIAL MEDIA FEATURES

Our website includes Social Media Features, such as the Facebook or Twitter button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the third party company providing them.

11. Forums

Truly offers various services on hosted forums like slack.com which allow customers to ask questions and engage with each other.  Customers should be careful to not share sensitive or confidential information inside this community, as we do not strictly enforce authentication monitoring the way we do with our apps.  Truly is in no way responsible for any material information that you may disclose in these public forums.

 

12. REFERRAL PROGRAMS

If you choose to use our referral programs to refer someone to our site, we will ask you for the intended recipient’s name, email address, and phone number. Truly will store and use this information to send emails inviting him or her to visit the site. Truly stores this information for the sole purpose of sending the emails and tracking the success of our referral program. Your referral may contact us at support@truly.co to request that we remove this information from our database.

 

13. TESTIMONIALS

With your input and your consent, we may post a customer testimonial by you on our website, which may include your name, industry, company, title, or other identifying information. If you want your testimonial removed please contact us at legal@truly.co

14. ENFORCEMENT

Truly regularly reviews its compliance with this Privacy Policy. Please contact us at legal@truly.co with any questions or concerns regarding this Privacy Policy or Truly’s treatment of personal information. When we receive formal written complaints, it is Truly’s policy to contact the complaining customer or user regarding his or her concerns.

 

15. UPDATING OF OUR POLICY

Truly will revise or update this Policy if our practices change or as we change existing services, add new services, or develop better ways to inform you of services we think will interest you. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. You should refer back to this page for the latest information and the effective date of any changes.

 

16. CONTACTING US

If you have any questions, comments or concerns about this Policy, please e-mail us at

legal@truly.co

 

Truly is committed to the policies set forth in this Policy.