Effective Date: April 18, 2019
- How and why we collect your Personal Information;
- How your Personal Information is used and protected;
- When and with whom we share your Personal Information; and
- What choices you can make about how we collect, use, and share your Personal Information.
- How we store, use, transfer, and retain your Personal Information.
We collect your Personal Information for various purposes, such as, but not limited to, corresponding with you, informing you about your account, security updates and product information, processing your application, providing you with Services, processing your order, providing you with a subscription, and other purposes.
We may combine the information we collect from you with information obtained from other sources to help us improve its overall accuracy and completeness, and to help us improve our business and better tailor our interactions with you.
We may also collect information relating to your use of our Site through the use of various technologies, including cookies.
Overview of Uses of Your Data
- To create a user account.
- To fulfill your requests by us or by others involved in fulfillment.
- To contact you for customer satisfaction surveys, market research or in connection with certain transactions.
- To support products or services you have obtained from us.
- To share with our service providers who provide services to us in support of our business.
- To personalize your experience while you are on our Site, make navigation easier, and for Site usage statistics.
- By us and selected organizations for marketing purposes if you have permitted such use.
When we collect information from you, you may tell us that you do not want it used for further marketing contact.
You may also turn off cookies in your browser.
You can view and edit your Personal Information online at our Preference Center website page or delete it by contacting us.
Visitors may withdraw their consent to us using their Personal Information at any time.
You may also opt out from receiving certain communications from us by visiting your Preferences Center page.
Acknowledgement and Consent
We gather various types of Personal Information, and we use this Personal Information internally in connection with our Services, including to personalize and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and Services, to provide and improve the Services, and to analyze how you use the Services, all as explained in more detail below. In certain cases, we may also share some Personal Information with third parties, but only as described below.
Individuals under the Age of 18
As noted in the Terms, we do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. No one under age 18 should provide any Personal Information to or on the Services. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
Information We Collect About You and How We Collect It
We collect several types of information from and about you.
Information You Provide to Us. The information we collect on or through our Site may include:
- Information that you provide by filling in forms on our Site. This includes information provided if you request a demo, by purchasing our products or Services, or by subscribing to our e-newsletters, blog, or other communications. We may also ask you for information when you report a problem with our Site.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Your search queries on the Site.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Site, including, but not limited to, traffic data, geolocation data, logs and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Site, the amount of time you spent on our Site, and the pages you viewed while on our Site.
- We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For more information on how to opt-out of third-party advertiser tracking mechanisms, please click here.
The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Site; (c) speed up your searches; and/or, (d) recognize you when you return to our Site.
The technologies we use for this automatic data collection may include cookies, flash cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.
Cookies (or browser cookies)
A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Firefox, Safari or Google Chrome).
Different types of cookies which have different purposes are used on our Site.
These cookies are essential to allow you to browse our Site and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
These cookies collect information on the use of our Site, such as which pages are consulted most often. This information enables us to optimize our Site and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Sites from their site and whether your visit has led to the use or purchase of a product or Service from our Site, including the references for the product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
These cookies enable our Site to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Site corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Site. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pixel Tracking. In addition to using Cookies, the Site may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our goods, services, and other offers with your interests and needs. For example, if you visit our Site from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Site. If you visit our Site, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing and research.
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages of the Service you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Services. These log files are generally deleted periodically.
Information We Collect from Third Parties
We may collect information that others provide about you when they use the Site, or obtain information from other sources and combine that with information we collect through the Site.
- Third Party Services. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, WeChat), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive information about you and your activities on and off the Site through partnerships, or about your experiences and interactions from our partner ad networks.
Some content or applications, including advertisements, on the Site are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc. from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies 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 and other online services (i.e., tracking such activities). 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.
We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Site.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
- To present our Site and its contents to you.
- To provide you with information on products or services that you request from us.
- To provide you with services that you have requested.
- To process transaction payments or have such payments processed by a third-party payment processor
- To provide you with notices about your account, including expiration and renewal notices.
- To send you emails, blog posts, and newsletters with product, service, company, and other information.
- To communicate with you regarding information, features or offers that we believe will be of interest to you.
- To respond to your questions or other requests.
- To process any applications, changes to your account information.
- To process other information or Personal Information that you submit through this Site.
- To notify you about changes to our Site, our policies, terms or any products or Services we offer or provide though it.
- To allow you to participate in interactive features on our Site.
- To ask for ratings and reviews of our Site, Services, and/or products.
- To provide access to restricted parts of our Site.
- To request your participation in surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.
- To provide verification of event attendance.
- To serve relevant information to you when you visit our Site or other third-party sites (including social media platforms).
- To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends and measuring demographics and interests.
- For internal purposes, such as Site and system administration or internal audits and reviews.
- To comply with applicable law(s) (for example, to comply with a search warrant, subpoena or court order) or to carry out professional ethics/conduct investigations.
- For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
- To operate, maintain, and provide to you the features and functionality of the Services.
- To provide statistics about the usage levels of the Site and other related information to reputable third parties, but these statistics will not include information which will allow you to be identified.
- To fulfill any other purpose for which you provide it.
- In any other way we may describe when you provide the information.
De-Identified Personal Information or non-Personal Information is aggregated for system administration and to monitor usage of the Site. It is utilized to measure the number of visits to our Site, average time spent, number of pages viewed and to monitor various other Site statistics. This monitoring helps us evaluate how visitors use and navigate our Site so we can improve the content.
We may use your Personal Information you provide to us and which we obtain from other sources to better understand your interests so we can try to predict what other products, services and information you might be most interested in. This practice is called “profiling”, which involves making automated decisions about you based on this information in order to better enable us to tailor our interactions with you to make them more relevant and interesting. If you object to such profiling, you may change your preferences on your Preferences Center page.
How We Share Your Information
Broadly stated, we may disclose, rent, or sell your Personal Information, in whole or in part, with third parties for the purpose of providing or improving the Services to you, who perform services on our behalf, or for marketing purposes. We disclose Personal Information to the following types of third parties, and for one or more the following purposes:
- Hosting providers for the secure storage and transmission of your data
- Learning technology and online event providers for the delivery and improvement of web events and learning programs and the tracking of your progress
- Marketing providers who send communications on our behalf regarding our products and Services
- Payment solution providers for the secure processing of payments you provide to us
- Fulfillment and shipping vendors for the fulfillment of our products and Services
- Survey and research providers who perform studies on our behalf
- Advertising partners, including social media providers, for the delivery of targeted advertisements
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Site, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
De-Identified Personal Information: We may share De-Identified Personal Information (such as anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services.
Your Consent to Disclosure/Transfer of Your Personal Information
You consent to our disclosure of your Personal Information and other information to a potential or actual buyer or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent.
Data Transfer/Access Outside of the United States
We have our headquarters in the United States. The Personal Information we collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area (“EEA”) or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the EEA or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.
If you are a resident of country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.
- Your Personal Information is contained behind secured networks and a firewall and is only accessible by a limited number of persons and service providers who have special access rights to such systems, and are required to keep the information confidential.
- Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information.
- Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information.
- Our Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Site safer.
- We may store, retrieve, access, and transmit your Personal Information in the US or in other countries.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to certain parts of the Site or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We’ll never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or used with our Services.
We will keep your Personal Information only for as long as necessary depending on the purpose for which it was provided. When determining the relevant retention periods, we take into account factors, including, but not limited to, the following:
- our contractual and business relationships with you;
- legal obligations under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- (potential) disputes; and
- guidelines issued by relevant supervisory authorities.
We may retain De-Identified Personal Information for as long as we choose.
What Information You Can Access, Change, or Delete
Through your account settings, you may access and, in some cases, edit or delete certain information you’ve provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.
Your California Privacy Rights
Online Privacy Protection Act (“CalOPPA”)
Under California Civil Code Sections 1798.83-1798.84 (known as the “Shine the Light” law), California residents are entitled to ask us annually for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom the business has shared such information during the immediately preceding calendar year. To make such a request, please contact us with “Request for California Privacy Information” on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. To obtain information under CalOPPA from us, please contact us, or, see more at the CalOPPA website.
Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to our Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity on the Service to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
**Provisions That Apply Only to Citizens and Residents of the European Economic Area and Switzerland:
The following provisions apply to you only if you are a European or Swiss citizen or resident. If you are a European or Swiss citizen or resident of the European Economic Area (“EEA”), or other regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. We may do so to process your information by staff operating outside the EEA who works for us or for one of our service providers.
What is our legal basis for processing Personal Data (EEA and Swiss visitors only)?
If you are a visitor from the EEA or Switzerland, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we need the Personal Data to perform Services for you for which you have contracted with us, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
Your Data Rights Under GDPR
Your rights under GDPR include the following:
- The right to access – Upon request, we will confirm any processing of your Personal Information and, and provide you with a copy of that Personal Information in an acceptable machine-readable format.
- The right to rectification – You have the right to have us correct any inaccurate Personal Information or to have us complete any incomplete Personal Information.
- The right to erasure – You may ask us to delete or remove your Personal Information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion).
- The right to restrict processing – You have the right to ask us to suppress the processing of your Personal Information but we may still store your Personal Information. See below for more information.
- The right to object to processing – You have the right to object to your Personal Information used in the following manners: (a) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (b) direct marketing (including profiling); and, (c) processing for purposes of scientific/historical research and statistics. See below for more information.
- The right to data portability – You have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform fulfillment of member benefits with you. We will give you your Personal Information in a structured, commonly used and machine-readable format.
- The right to complaint to a supervisory authority – You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of Personal Information relating to you infringes upon your rights.
- The right to withdraw consent – We rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
Privacy Shield Policy
TRUCE has adopted this Privacy Shield Policy (“PS Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This PS Policy applies to the processing of Personal Data that TRUCE obtains from Customers located in the European Union and Switzerland. “Customer” means a visitor to our website or a customer of TRUCE.
- Compliance. TRUCE complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from visitors and customers in the European Union member countries and Switzerland. TRUCE has certified that it adheres to the Privacy Shield Privacy Principles (“Principles”) of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this PS Policy and the Principles, the Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please click here. The list of organizations which are on the Privacy Shield List is here. The U.S. Federal Trade Commission (FTC) has jurisdiction over TRUCE’s compliance with the Privacy Shield.
- How to Contact TRUCE With Inquiries or Complaints. In compliance with the EU-US and Swiss-US Privacy Shield Principles, TRUCE commits to resolve complaints about your privacy and our collection or use of your personal information. EU or Swiss individuals with questions or concerns about the use of their Personal Data should contact TRUCE at [email protected].
- Data Access and Use Limitation Rights. Your rights to access, and the choices and means TRUCE offers you for limiting the use and disclosure of your Personal Data are described above in the subsection entitled “Your Data Rights Under GDPR.”
- Enforcement and Dispute Resolution
a. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by TRUCE, EU and Swiss individuals may bring a complaint before the BBB EU and Swiss Privacy Shield program, information for which can be found here.
b. Finally, as a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism. Information may be found here. TRUCE commits to cooperate with EU and Swiss data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
c. If a Customer’s question or concern cannot be satisfied through this process, TRUCE has further committed to refer unresolved privacy complaints under EU-US Privacy Shield and Swiss-US Privacy Shield to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus.
8. Responsibility for Transfers of Personal Data. To the extent provided by the Principles, TRUCE shall remain liable if a third party TRUCE engages to process Personal Data on its behalf does so in a manner inconsistent with the Principles, unless TRUCE proves that it is not responsible for the event giving rise to the damage.