3. LEGAL BASIS FOR PROCESSING
The legal basis by which Truvalue Labs may process Personal Information includes the following:
Individuals, directly or through their employers, have given their consent for one or more specific purposes, including without limitation, provision of Personal Information is necessary for the performance of an agreement with the individuals’ employer and/or for any pre-contractual obligations thereof;
Processing is necessary for compliance with a legal obligation to which Truvalue Labs is subject;
Processing is necessary for the purposes of the legitimate interests pursued by Truvalue Labs or by a third party.
4. TYPES of Personal Information We Collect and How We Use It
Among the types of Personal Information that our Service and/or Site collects, by itself or through third parties, there are: web browser cookies, usage data, email address, phone number, first name, last name, company name, profession, address, ZIP/Postal code, various types of machine data, field of activity, number of employees and data communicated while using the service.
Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
Truvalue Labs collects Personal Information regarding its current, prospective, and former customers, users, visitors, and guests (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Communications with Us. We may collect Personal Information from you such as name, address, phone number, email address, or mailing address when you choose to request information about our Services, create an account, register for our newsletter or blog, request to receive customer or technical support, or otherwise communicate with us.
- Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein.
- Interactive Features. Our social media sites and Services may contain interactive functionality that allow you to engage with other users on our Facebook page, to participate in surveys, and otherwise to interact with the Services and with other users. If you use any interactive functionality that requests or permits you to provide Personal Information (including, for example, any Services that allow you to post User Materials on any of our Services), we and/or Third-Party Services collect the Personal Information that you provide in the course of using these interactive features. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
- Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, unique Service ID, mobile carrier, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
3.2 Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. How TRUVALUE LABS Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Products, Services, or Information Requested. Truvalue Labs may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of our Services;
- Contact you to answer requests for customer support or technical support; and
- Allow you to register for events.
- Information We Process on Behalf of Our Customers
- If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Service to Process this data. Our customers control the Personal Information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our customers to address any concerns you may have, in accordance with the terms of our contract with them.
- Administrative Purposes. We may use Personal Information about you for its administrative purposes, including to:
- Measure interest in our Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate about Individual accounts and activities on our Services and systems, and, in our discretion, changes to any Truvalue Labs policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Process payment for products or Services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities; or
- Enforce our Terms.
- Marketing Our Products and Services. Truvalue Labs may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and Services that may be of interest to you;
- To provide Services to you and our sponsors; or
- For other purposes disclosed at the time that Individuals provide Personal Information.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below.
- Research and Development. Truvalue Labs may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Truvalue Labs may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
- Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Truvalue Labs’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions below.
- Anonymous and Aggregated Information Use. Truvalue Labs may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site and the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Truvalue Labs and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Other Uses. Truvalue Labs may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, LOCAL STORAGE, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site and Services may not work properly.
- Local Storage and Local Shared Objects:We use local shared objects such as cookies and local storage to enhance your experience by storing your user preferences and settings on the Site and Services. Local storage is similar to browser cookies but can store data more complex than simple text. Like cookies, local storage can only access personal data that you have provided on the Site or Services. Various browsers may offer their own management tools.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site and in our Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or Third-Party cookies and web beacons to deliver content, including ads relevant to your interests on Third-Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Site, Services, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites, Social Media Platforms, and APIS
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Site and our other Services may also contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such Third-Party services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
We may use Third-Party code or APIs as part of the functionality of our Services.
4. Onward Transfer—TRUVALUE LABS May Disclose Your Information
4.1 Information We Share
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site and Services. Truvalue Labs has entered into appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners. We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners whose products or services we believe may be of interest to you.
- Marketing – Interest-Based Advertising and Third Party Marketing. On our Site, Truvalue Labs may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Truvalue Labs related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions below.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) enforce our policies or contracts; (v) collect amounts owed to us; (vi) prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) disclose your Personal Information in good faith where it is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
4.2 INTERNATIONAL Data Transfers
You agree that all Personal Information collected via or by Truvalue Labs may be transferred, Processed, and stored anywhere in the world, including but not limited to the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Truvalue Labs, you explicitly consent to the storage of your Personal Information in these locations.
5. Opt-Out (RIGHT TO OBJECT TO PROCESSING)
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Truvalue Labs’s Processing of your Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting us as the address below.
5.2 Email and Telephone Communications
5.3 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.4 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. See http://www.networkadvertising.org/mobile-choice.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our Third-Party advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/, http://youradchoices.ca/choices/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
6. Rights of Access, Rectification, Erasure, and Restriction
Although we makes a good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your Information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
10. Children’s Privacy
The Services are not directed to children under 13 years of age (16 in some jurisdictions), and Truvalue Labs does not knowingly collect Personal Information from children under 13 years of age (16 in some jurisdictions). If you learn that your child has provided us with Personal Information without your consent, you may alert us as described below. If we learn that we have collected any Personal Information from children under 13 years old (16 in some jurisdictions), we will promptly take steps to delete such information.
11. Redress/Compliance and Accountability
12. Other Rights and Important Information
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, we will endeavor to comply with the law or contract.
12.2 California Privacy Rights
12.3 Contact Us
If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request to the data controller of your Personal Information or to Truvalue Labs at email@example.com or Privacy Office, 111 Sutter St., Floor 22, San Francisco, CA 94104.