Privacy Policy
Our Privacy Policy
December 2023
This Tru-Connect (“TRU-CONNECT”) Privacy Notice describes how we handle information relating to an identified or identifiable person (“personal data”) and what privacy rights you may have in relation to your personal data. Our Privacy Notice applies to our websites that post a link to this Privacy Notice (collectively, the “Website”), when we provide our products and services, and during the general operation of our business. When you use our Website, or interact with us or our service providers, you consent to the collection and handling of your data as described in this Privacy Notice.
Collection of Personal Data
We may collect the following categories of personal data:
- Identifiers (e.g., name, social security number, driver’s license number)
- Contact information (e.g., telephone number, email address, physical address)
- Protected classification information (e.g., age, race, gender, physical or mental disability, sexual orientation, marital status)
- Commercial information (e.g., products or services purchased)
- Biometric information
- Internet and network information (e.g., internet protocol address, information about a consumer’s interaction with our website)
- Geolocation data
- Professional or employment related information
- Education information
- Inferences drawn from the categories of information identified here
- Sensitive personal information
We obtain the above categories of information from the following sources:
- From you when you directly or indirectly provide us the data
- From your activities on our Website and through the use of cookies
- From social networks
- From public records
- From service providers
- From business partners
Cookies
We and our service providers use cookies to collect and store your data. Cookies are small files stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while others remain longer so you can be recognized when you return to our Website.
Cookies allow you to more easily use our Website and help us provide and improve it. Service providers may also use cookies to advertise to you based on your past visit(s) to the Website. Our advertisements may appear on other websites.
Use of Personal Data
We may use your personal data for any of the following purposes:
- To provide, maintain, and improve our products and services
- To communicate with you
- To provide you with information, products, and services that you request from us
- To conduct market and consumer studies
- To personalize, advertise, and market our services
- To conduct background checks
- To evaluate your eligibility for employment or agreements
- To conduct research and development
- To report and investigate adverse events
- To detect, investigate, prevent, and respond to fraud or any other harmful activities
- To comply with our legal and contractual obligations
- To exercise and defend legal claims
- To otherwise operate our business
- As described to you at the point of data collection or handling or otherwise where we are legally permitted or are required to do so
Data that is in an aggregated or deidentified form is not personal data. TRU-CONNECT and its service providers may use, sample, collect, compile, license or sell aggregated or deidentified data.
Sharing of data
We do not rent or sell your personal data. Nor do we share your personal data with third parties for their own direct marketing purposes. We will not disclose or transfer your personal data to any third party except when one of the following is true:
- You consent to the disclosure
- The disclosure is to a party that controls, is controlled by, or is under common control with us
- The disclosure is related to a business purpose
- The disclosure is reasonably necessary for the establishment or maintenance of legal claims
- The disclosure is required by law
- The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets
- The disclosure is not inconsistent with this Privacy Notice or our description at the point of collection or handling, and otherwise not prohibited by applicable law
When we disclose personal data for a business purpose, we enter a contract with the recipient that describes the purpose for handling the data and requires the recipient to keep them secure and confidential and not use them for any purpose except performing the contract. We have disclosed the following categories of data for a business purpose:
- Identifiers
- Contact information
- Protected classification information
- Commercial information
- Biometric information
- Internet and network information
- Geolocation data
- Professional or employment related information
- Education information
- Inferences drawn from the categories of information identified here
- Sensitive personal information
We may disclose data for a business purpose to the following categories of third parties:
- Our affiliates
- Our business partners
- Service providers (e.g., data handling and technology services, customer service administrators, payment processors, advertising networks and marketers)
- Legal and administrative authorities
- To an entity related to a business transfer
- Third parties to whom you authorize us to disclose your information
Data transfers
If you are accessing the Website from outside of the U.S., please be aware that data collected through the Website may be transferred to the U.S. (We are based in the U.S. and our Website is hosted on servers in the U.S.) We transfer data to the U.S. for the purposes described in this Privacy Notice or our description at the point of collection or handling, and otherwise not prohibited by applicable law. Laws in the U.S. may be different from and provide less protection than those in the country you are located. We may also transfer personal data amongst ourselves or with service providers in other countries in order to process consumer privacy requests.
Third-party practices
Our Website may contain links to third-party websites. If you visit a third-party website, you are subject to that website’s privacy notice and not ours.
Data storage and security
We or our service providers may store your personal data in the U.S. or in other countries. Except as otherwise permitted or required by law, we retain your personal data for as long as necessary to fulfill the purposes they were collected for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use of processing by other means, and any applicable legal requirements.
We maintain reasonable administrative, technical, and physical safeguards to protect your data from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Our service providers are also required to adhere to reasonable security practices to further ensure your data. That being said, digital transmission and storage of data is not completely secure and we cannot guarantee the safety of your data.
Children
Our websites are not intended for children under 18 years of age. In the event we learn that we collected personal data from a child under the age of 18 through our website, we will delete the data unless they were collected with the appropriate consent or as otherwise permitted under applicable laws. We may collect personal data from a child with the consent of his or her parent or guardian outside of our website.
Do Not Track
Your browser may allow you to set a Do Not Track (“DNT”) signal indicating that you do not wish your online activity to be tracked. We do not respond to and cannot act on received DNT signal headers.
Opt-out of communications
If you no longer wish to subscribe to our news, alerts, or any similar information sent by us, you can opt-out of receiving such communications by following the unsubscribe instructions included in each communication or by sending us your opt-out request using the “Contact” section below. If you opt-out, you may still receive communications related to your interactions with us, non-promotional communications, or others as required by law. We may also keep data we collected about you to record your decision to opt-out.
Your rights
This section describes data privacy rights you may have and how to exercise them.
- You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past twelve months, such as (i) the categories of personal data we collected about you; (ii) the categories of sources from which we collected such data; (iii) the specific pieces of personal data we collected about you; (iv) the purpose for collecting personal data about you; and (v) the categories of personal data about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such data in the preceding twelve months.
- You have the right to request that we delete your personal data, subject to certain exceptions.
- You have the right to not be discriminated against in pricing and services if you exercise any of your rights. We do not offer financial incentives or price or service differences in exchange for the retention or sale of your personal data.
To exercise your privacy rights, send us your verifiable consumer request using the “Contact” section below.
- The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data, and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- We will respond to your request consistent with applicable law, including, as applicable, the California Consumer Privacy Act and the California Privacy Rights Act.
Privacy Notice updates
We reserve the right to amend this Privacy Notice at our discretion and at any time. Any changes will be posted on this page with an updated revision date. By using the Website, or interacting with us, you agree to be bound by the Privacy Notice as posted.
Contact
If you have any questions, comments, or requests, please contact us by email at privacy@Tru-Connect.net or by telephone at (504) 832-2000.