Introduction and Overview
We collect the following types of information from users of the Services.
1. Information You Provide to TrueVault
We collect certain information you provide directly via the Services:
Your contact information when you contact us by email, chat, telephone, or via a contact form.
Professional information about you, including your employer.
Payment information when you subscribe to the Services.
The content of your communications with us as necessary to provide you with the Services.
2. Information Collected Automatically
As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Details of your use of the Services, including traffic data, logs, and other communication data and the resources that you access and use on the Services.
Information about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data may include IP address, MAC address, device advertising ID (e.g., IDFA or AAID), and other device identifiers.
The information we collect automatically helps us to improve the Services, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize the Services according to your individual interests.
Recognize you when you return to the Services.
The technologies we use for this automatic data collection may include:
3. Third-Party Sources of Information
We may receive your personal information from third-party resellers of consumer data for our sales and marketing purposes.
Use of Information
We use information that we collect about you or that you provide to us, including any personal information:
To present the Services and its contents to you, including to provide customer support.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
If you have an account with TrueVault, to provide you with notices about your account.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to the Services or any products or services we offer or provide through it.
To allow you to participate in interactive features of the Services.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please let us know at firstname.lastname@example.org.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law.
For information on your rights and choices regarding how we use your information, see Your Rights and Choices below.
Sharing of Information
We share information about you as follows:
Service Providers. We may share your information with our agents, vendors and other service providers (collectively "Service Providers") in connection with their work on our behalf. Service Providers assist us with services such as payment processing, data analytics, marketing and promotional services, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of TrueVault, the Services or any third party.
Consent. We may share your information for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may share aggregated information that does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see Your Rights and Choices below.
Your Rights and Choices
1. Review and Update of Account Information
You may access, update, or remove certain account information that you have voluntarily submitted to us through the Services by sending an email to us at email@example.com. We may require additional information from you to allow us to confirm your identity.
Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents have additional rights as set forth in Your California Privacy Rights below.
2. Tracking Technology Choices
Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. When we detect a Do Not Track signal, we place a U.S. Privacy String setting in your browser so that any third party who respects that signal will not track your activity on our website.
Please be aware that if you disable or remove tracking technologies, some parts of the Services may not function correctly.
You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at firstname.lastname@example.org with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of certain non-promotional emails, such as those about your account, transactions, servicing, or TrueVault’s ongoing business relations with you.
The Services are intended for a general audience and are not directed to children under 13 years of age. TrueVault does not knowingly collect personal information as defined by the Children’s Online Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe TrueVault has collected such information in a manner not permitted by COPPA, please contact us at email@example.com and we will remove such information to the extent required by COPPA.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
Information for California Residents
This section provides additional information for residents of California under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered "personal information," such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.
Personal Information Collected in the Last 12 Months
We collect the following categories of personal information about website visitors:
- Personal Identifiers, including name, email address, and telephone number
- Online Identifiers, including unique personal identifier and IP address
- Internet Activity, including interactions with websites, apps or ads and search history
We collect the following categories of personal information about Prospective Polaris customers:
- Personal Identifiers, including name, email address, and telephone number
- Online Identifiers, including IP address
- Internet Activity, including email open and click-through rates
Sources of Personal Information
We collect personal information from the following sources:
- You (the consumer)
- Data Brokers
Business or Commercial Purposes for Collecting Information
We collect personal information for the following business purposes:
- Advertising and Marketing
Information Disclosed for Business or Commercial Purposes in the Last 12 Months, and Categories of Parties Disclosed To
|Personal Information Disclosed||Category of Party|
|Personal Identifiers, including name, email address, and telephone number||Service Providers|
|Online Identifiers, including unique personal identifier and IP address||Service Providers|
|Internet Activity, including interactions with websites, apps or ads and search history||Service Providers|
Prospective Polaris customers
|Personal Information Disclosed||Category of Party|
|Personal Identifiers, including name, email address, and telephone number||Prospecting Contractors, Service Providers|
|Online Identifiers, including IP address||Service Providers|
|Internet Activity, including email open and click-through rates||Service Providers|
Your CCPA rights are described below. You can make a Request to Know or a Request to Delete under the CCPA by submitting a Privacy Request at the top of this page, or by clicking here.
Right to Know
You have the right to request to know the following about the personal information we have collected about you in the past 12 months:
- the categories and specific pieces of personal information we have collected about you
- the categories of sources from which we collect personal information about you
- the business and commercial purposes for which we collect personal information
- the categories of third parties with whom we share the information
- the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose
If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal information about you that you have provided to us. We will permanently delete from our records any personal information that is not necessary for our business operations and direct our service providers to do the same.
We consider information to be necessary for our business operations if it is used to:
- Complete an obligation to you that you have requested
- Detect and resolve issues related to security or functionality
- Comply with legal obligations
Right to Non-Discrimination
If you exercise your CCPA consumer rights:
- We will not deny goods or services to you
- We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
- We will not provide a different level or quality of goods or services to you
Right to Opt-Out
You have the right to opt-out of any selling and sharing of your personal information.
We do not sell any personal information to any third parties.
Before we can respond to any CCPA requests, we will need to verify that you are the consumer who is the subject of the CCPA request. Verification is important for preventing fraudulent requests and identity theft.
The verification process depends on which type of request you make and how you make it. Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request.
For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required by the CCPA.
In some cases, we may have no reasonable method by which we can verify a consumer's identity. For example:
- If a consumer submits a request but we have not collected any personal information about that consumer, we cannot verify the request.
- If the only data we have collected about a consumer is gathered through website cookies (i.e., the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.
A California resident's authorized agent may submit a Request to Know or a Request to Delete under the CCPA by emailing us at firstname.lastname@example.org. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.
If you have trouble accessing this notice, please contact us at email@example.com.
If you have any privacy-related questions, please send them to firstname.lastname@example.org.