Privacy Policy
TRUESELF PRIVACY POLICY
TrueSelf Systems, Inc. (“TrueSelf”, “we” or “us”) created and maintains the TrueSelf website currently located at http://trueself.io (the “Website,” and together with any successor URLs, mobile applications and other online services TrueSelf may offer, the “Service”). Your use of the Services is governed by the terms and conditions set forth below (the “Privacy Policy”) and the TrueSelf Terms of Use (collectively, the “Terms”).
PLEASE READ THIS PRIVACY POLICY. BY USING THE SERVICE, YOU ACCEPT ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND THE TERMS OF USE AND REPRESENT TO US THAT YOU ARE 18 YEARS OF AGE OR OLDER AND ARE LEGALLY COMPETENT TO ENTER INTO AND AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TERMS OF USE. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY TERMS OF USE, THEN YOU ARE NOT AUTHORIZED TO ACCESS OR USE ANY OF THE SERVICES. CERTAIN TERMS USED HEREIN ARE DEFINED AT THE END OF THIS DOCUMENT.
We operate from the United States of America, while you may reside in a country with stricter data collection and usage laws. However, by accessing our website, you consent to forego these restrictive laws and agree to abide by the laws of the United States.
1. Types of Information We Collect
We may collect the following categories of information:
·Registration information you provide when you create an account, which may include your name, email address, telephone number, birthdate, username and password.
· Information you provide to us when you access or use the Services and each time you interact with the Services, for example, when you update your account information, communicate with us by telephone or email, and order or download new products or services.
· Information you provide in public forums through the Services, including using our review, comment, post or similar functionality and any social media functionality.
· Usage, viewing and technical data, including your IP address or device identifier when you use the Services. If you access your account from a mobile device, that mobile device may also provide us with details of your location. Most mobile devices allow you to disable this functionality.
· Information we receive from third parties. For example, if you access the Services through a third party platform or log-in, we may also collect your email address associated with that third party, and any information you have made public in connection with that service or which the third party shares with partner services.
2. How We Collect Your Information
· We collect information you provide to us when you register with us; create user generated content; request products, services or information from us; participate in public forums, social media or other activities through the Services; respond to customer surveys; or otherwise interact with us. Please keep in mind that when you post information on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you make on the third-party site or platform will not apply to our use of the information we collect directly through our Services.
· We collect information through unique identifiers (such as IP address or your mobile device advertising identifier).
· We may use "cookies" and other technologies to collect data that enable us to better understand and improve the usability, performance and effectiveness of our website. Cookies are files sent to your browser and stored on your computer. We may use cookies to gather general information about your visits to our website, the files you have designated for backup, the configuration of your computer and your computer’s interaction with the Services, and stores this information in log files. We may use this information to understand traffic and downloads on our website, enabling us to improve the website, provide the best online experience possible, and improve our customer service. We may use the following types of cookies on our site:
· Strictly necessary cookies - These cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of the website and remembering which files you have marked for backup. Without these cookies, services you have asked for, like security or e-billing, cannot be provided.
· Performance cookies - These cookies collect information about how you use the website. These cookies don’t collect information that identifies you and are only used to improve how the website works.
· Functionality cookies - These cookies allow the website to remember choices you make, such as the configuration of your computer, to provide enhanced, more personal features.
· Other Technologies - We may also use other Internet technologies, such as web beacons or pixel tags and other similar technologies, to deliver or communicate with cookies and analyze your use of the Services. We also may include web beacons in e-mail messages so that we know when you have opened an email message received from TrueSelf.
You may disable cookies by changing the settings on your browser. Check the help menu in your browser for further information. Remember that if you disable cookies it is likely to affect how the Services work and you may not be able to access or use certain areas of our website or functionality. Unless you have adjusted your browser setting so that it will refuse cookies, our system will place cookies when you log on to the Services.
· We use third parties’ analytic and tracking tools to better understand who is using the Service, how people are using the Service and how to improve the effectiveness of the Service and its content, and to help those parties serve more targeted advertising to you across the Internet or help us serve more targeted advertising to you. Those third party companies may use cookies, pixel tags or other technologies to collect and store anonymous information such as time of visit, pages visited, time spent on each page of the Service, device identifiers, type of operating system used and other website(s) you may have visited. They might combine information they collect from your interaction with Service with personal information they collect from other sources. We do not have access to, nor control over, third parties' use of cookies or other tracking technologies.
· Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. TrueSelf and the Services do not recognize DNT.
3. Use of Your Information by TrueSelf
TrueSelf may use your data for the following purposes:
· To provide you with the Services and the products and services you request.
· To administer your TrueSelf account.
· To communicate with you about your account or transactions with us and send you information about features of the Services or changes to our policies.
· To process payments.
· To ensure consistency with local law and choices and controls that may be available to you.
· To personalize content and experiences and advertising.
· To detect, investigate and prevent activities that may violate our policies or be illegal.
· To optimize or improve the content, products, services, and features of the Services.
· To personalize and improve the Services and user experiences, to increase the functionality and user friendliness of the Services, to deliver content or features that match user profiles or interests.
· To monitor and analyze the Services usage and trends and otherwise measure the effectiveness of the services.
• TrueSelf may also send you offers and promotions for relevant products and services.
We use the information we collect from you while you are using the Site in various ways, including using the information to customize features; advertising that appears on the Site; and, making other offers available to you via email, direct mail or otherwise. We also may provide your information to third parties, such as service providers, contractors and third-party publishers and advertisers for a variety of purposes. Unless you inform us in accordance with the process described below, we reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using the Site in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services that we believe you will find valuable and life-enhancing based on what we know about your TrueSelf. If you do not wish your information to be used for these purposes, you must send a letter to the Online Privacy Coordinator whose address is listed at the end of this Privacy Policy requesting to be taken off any lists of information that may be used for these purposes or that may be given or sold to third-parties.
4. Sharing Your Information
We will not share your personal information outside TrueSelf except in limited circumstances, including:
· When you allow us to share your personal information, such as directing us to share your personal information with third-party sites or platforms, such as social networking sites, or disclosing your test results to third parties you designate.
· When we contract or partner with a third party to provide services on our behalf, including Services development and maintenance. We require all third parties to process your data in a manner consistent with this Privacy Policy and as permitted by applicable data protection laws.
· When we share personal information with third parties in connection with the sale of a business (including merger, acquisition, or sale of all or a material portion of its assets, change in corporate control, or insolvency or bankruptcy proceedings), to enforce our Terms of Use or rules, to ensure the safety and security of our users and third parties, to protect our rights and property and the rights and property of our users and third parties, to comply with legal process, including judicial warrant, rule, order or subpoena or in other cases if we believe in good faith that disclosure is required by law or regulation.
In addition, we may use and share any aggregate information with third parties for any reason, however you will not be personally identifiable from such information.
Joint Venture Partners. We may participate with another company or individual for purposes of jointly promoting our products, services, promotions or contests or their products, services, promotions, or contests. We may disclose relevant and necessary Personal Information and Usage Data to them for purposes of (i) compensation, transaction processing, fulfillment, and support, and (ii) for purposes of offering you other products, services, promotions, and contests. These joint venture marketing partners may also contact you regarding other products, services, promotions, or contests.
Marketing Partners. We may share necessary and relevant Personal Information and Usage Data with our marketing partners including third party service providers, advertisers, advertising networks and platforms, advertising agencies, and data brokers and aggregators to serve and offer personalized ads.
AdWords (Google) - We may participate in AdWords program which is a personalized ad service provided by Google Inc. that connects the activity of this site with the Adwords advertising network and the Doubleclick cookie. Information collected: cookie and Usage Data. For the opt-out, visit --> https://support.google.com/ads/answer/2662922?hl=en
Google Analytics for Display Advertising (Google) - We may participate in any and all of the following Google Analytics Advertising Features provided by Google: Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. These features use first party cookies (such as the Google Analytics cookie) for connecting the tracking activity performed by Google Analytics and its cookies with the Adwords advertising network and the DoubleClick cookie (a third-party cookie). Information collected: cookie and Usage Data, including audience data such as age, gender, and interests.
For the opt-out, visit --> https://support.google.com/ads/answer/2662922?hl=en You may opt-out of the Google Analytics service with the Google's Browser Add-on that's available at --> https://tools.google.com/dlpage/gaoptout
For another Google resource for opting out of Google's use of cookies, visit --> http://www.google.com/settings/ads
For information regarding how Google uses data when you use Google's partners' sites or apps, visit --> http://www.google.com/policies/privacy/partners/
For an additional resource recommended by Google for opting out of a third party vendor's use of cookies, visit --> http://www.networkadvertising.org/managing/opt_out.asp
Custom Audience (Facebook). We may participate in Facebook.com's Custom Audience program which enables us to display personalized ads to persons on our email lists when they visit Facebook.com. We provide Personal Information such as your email address and phone number to Facebook to enable Facebook to determine if you are a registered account holder with Facebook. You may opt-out of participation in our Facebook Custom Audience by sending an email, from the email address you are opting out of, to the facebookCA@trueself.io. For your opt-out to be effective, you must: (i) place the following text in the subject line of the email - "Opting Out of Facebook.com Website Custom Audience Ads", and (ii) in the body of the email, include your name and email address. We will forward your name and email address to Facebook.com with a request to delete you from all of our Facebook Custom Audience Ads.
Tailored Audiences/Conversion Tracking Programs (Twitter). We may participate in Twitter.com's Tailored Audiences/Conversion Tracking Programs which enable us to display personalized ads. You may opt-out of participation in these programs by visiting https://support.twitter.com/articles/20170405 .
Other Personalized And Behavioral Advertising Services. We may participate in additional retargeting and behavioral advertising services that will be similar to the services described above.
Managing Personalized Ads. You can control the placement of cookies and other data collection methodologies for purposes of opting out.
Managing Cookies Via Your Browser. You should note that although most browsers are initially set up to accept cookies, you may be able to change your browser settings to cause your browser to refuse first party or third-party cookies or to indicate when a third-party cookie is being sent. However, disabling or limiting cookies may cause certain features of this website to not function properly or optimally. Check your browser's "Help" files or other similar resources to learn more about handling cookies on your browser. In addition, visit --> http://www.allaboutcookies.org/manage-cookies/
Managing Flash Cookies. Flash cookies, also called local shared objects (LSOs), function similarly to standard cookies except that they are often larger and are downloaded to a computer or mobile device by the Adobe Flash Player. In some cases, these Flash cookies can be managed through browser settings. Adobe also provides a means of controlling Flash cookies on its Flash Player: Setting Manager page.
Opting Out With Ad Choices For Mobile Devices. When using mobile applications you may receive personalized in-application advertisements. Depending on your device, you may be able to reset your mobile device's advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system (iOS for Apple phones, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of personalized in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of these advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.
You may request a notice disclosing the categories of personal information we have shared with third parties, and the names of those third parties. To request such notice, please contact us at info@trueself.io
5. Public Venues and Social Media
If you use a message board, comment function, or other public or social media function of the Services you will be identified on those venues by the username you submit and by any other personal information you disclose in such manner.
Information you provide on public or semi-public venues, including information you share on third party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services, users of those third party platforms, and other third parties. We are not responsible for any personal information you choose to post on public or semi-public venues and we recommend careful consideration before you post such information.
6. Your Controls and Choices
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with local law, your controls and choices may include:
· You may correct, and update your registration account.
· You may change your choices for newsletters and alerts.
· You may choose whether to receive from us offers and promotions for our products and services.
· You may request access to the personal information we hold about you and that we amend it.
You may exercise your controls and choices, or request access to your personal information, by modifying your profile or by contacting us at info@trueself.io or following instructions provided in communications sent to you. Please be aware that, if you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific personal information about you that we process or retain, please contact us at info@trueself.io
7. Third Party Websites and Links
Our Services may contain links to other sites operated by third parties. TrueSelf does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal information. TrueSelf's inclusion of such links does not, by itself, imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. TrueSelf expressly disclaims any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.
8. Children’s Privacy
The Services are not intended for use by individuals who cannot enter a legally binding contract. Accordingly, TrueSelf does not intentionally gather any personal information about individuals who are under the age of eighteen (18). If you are under eighteen (18) years of age or otherwise lack the capacity to enter into a binding contract do not use our Services. If TrueSelf becomes aware that it has collected personal information from someone under the age of majority, such information will be deleted immediately.
If you are a user of this service and a California resident under the age of eighteen (18) you may request to have your posted content or information removed from the publicly-viewable portion of this web site by contacting us directly using the contact information provided below. Some content may not be removed from internal systems or databases and in certain situations public content cannot be removed.
We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.
If you are the parent or guardian of a minor child who has provided us with personal information, you may contact us at privacy@trueself.io to request it be deleted.
We require any underage users who want to use our site to have the consent of their legal guardians. Sometimes parents fill out the TrueSelf personality test on behalf of their children because they want to learn more about them for the sake of bettering themselves as parents to these children. The service and its content are not directed at children under the age of 13. In the event we learn that we have collected personal information from a child under age 13 without parental consent we will delete that information. If you believe that we might have any information from or about a child under 13 please email us at privacy@trueself.io. If a child under 13 has provided us with personal information without parental or guardian consent, the parent or guardian may contact us by emailing us at privacy@trueself.io. We will remove the information and unsubscribe the child from any of our electronic communication.
9. Data Security, Integrity and Retention
General. We have implemented reasonable technical, administrative, and physical security measures that are designed to protect user information from unauthorized access, disclosure, use and, modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.
10. Your EU Data Protection Rights
Location of Personal Information and Transfers. TrueSelf processes personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live. By using the Services, you freely and specifically give TrueSelf your consent to export your personal information outside of the EEA, including to the US and understand that data stored outside of the EEA may be subject to lawful requests by the courts or law enforcement authorities in the countries in which it is stored.
Access Requests. You have the right to request a copy of the your personal information we hold about you. TrueSelf will take commercially reasonable steps to provide you with such access and to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
11. Changes to this Privacy Policy
From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We will provide notice to you if these changes are material.
12. Your California Privacy Rights
This Privacy Policy describes how we may use and share your personal information for marketing and other purposes. It applies to all users of the Services, including California residents.
As a California resident, you may contact us with any questions or request a list of third parties to whom we may disclose information for their own marketing purposes and the categories of information we may disclose.
Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to the email address provided in our contact information below and include the phrase "California Privacy Request" in the subject line, along with your name, address and email address.
13. Dispute Resolution
Any questions or concerns regarding the use or disclosure of personal information should be directed to TrueSelf at info@trueself.io. TrueSelf will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.
If TrueSelf is unable to resolve your complaint, you can escalate the issue in accordance with the dispute resolution procedure set out in the “Governing Law and Arbitration; No Class Actions” provision in the Terms of Use.
14. Definitions
Aggregate Information. Aggregate information means information about groups or categories of users, which does not identify and cannot reasonably be used to identify an individual user. Aggregate Information is not personal information.
Anonymous Information. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual user.
Children. Children means individuals who we have identified are not of legal age to consent to the collection and processing of their personal information. For the purposes of this agreement, “children” are people under 13 in the United States, and anyone under 18 in any other jurisdiction.
Notice. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on the Services, or by other means, consistent with applicable law.
Parents. Parents means a parent or legal guardian.
Personal information. Personal information means information that identifies a particular individual, such as the individual’s name, postal address, email address and telephone number.
15. Contact Information
TrueSelf
10900 Research Blvd, Ste 160C PMB 1258
Austin, TX 78759
This Privacy Policy was updated on 8/2/23