[vc_row][vc_column][vcex_heading source=”post_title” tag=”h1″ css=”.vc_custom_1618692579082{margin-bottom: 30px !important;}”][vc_column_text]February 2020

The privacy and protection of your information is important to us.

Please read this notice before using our websites, content, mobile applications, email notifications, and products and/or services to understand our Privacy Policy.

This notice advises you about what data we collect, how it is used or shared, and your choices regarding its use. By accessing our public websites, content and/or our products or services, you acknowledge that you have read, understood and agree to Truefort data collection, storage, use and disclosure of your personal information as described herein, and that you are aware of the privacy choices offered to you.

In addition, the TrueFort Privacy Policy may vary from country to country in the markets in which we do business and in accordance with applicable local practices and legal requirements.

If you have opted-in for communications with us and would like to change your preferences, you may click “Manage preferences” at the bottom of an email you have received from us to make changes, or elect to stop receiving all communications.  If you have concerns or require assistance, please send email to legal@truefort.com.

OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION

Through your use of our Website, Communications, Content and our Products and Services, we may collect personal information (“Personal Data”) that you provide us with, including without limitation:

• Your contact information. Name, username, company, email address, postal address, telephone number;
• Your payment information (if applicable). Credit card number, billing address, security code and other payment transaction or banking information;
• Your job title;
• Analytical information. Such as emails from us that you open, content that you access or download from our communications via social media, email or the web, your Internet Protocol (IP) address, or device information such as browser type, operating system, Internet service provider;
• Publicly available information collected from third-party sources;
• Information or usage data collected from third parties. Such as a third-party website, application or feature;
• Additional personal information forwarded by third parties. Used to understand how visitors use our website, to obtain feedback, and to enhance our ability to engage with and serve you.

Your collected information may be used as follows, to:

• Provide you customer service and address your questions;
• Provide you with a personalized experience through your creation of an account;
• Remember your preferences;
• Gather analytics such as the frequency of your visits, pages visited, links clicked, geographical location;
• Provide targeted marketing communications;
• Understand the number, traffic, usage and demographics of our users;
• Plan for and enhance our Products and Services;
• Use in other ways consistent with the foregoing.

Please note: The terms of this Privacy Policy will be applied by TrueFort to any Personal Data received from a third-party, unless otherwise disclosed to you. However, TrueFort is not responsible for the dissemination of this information by these third-parties.

OUR USE OF COOKIES AND OTHER TRACKING TECHNOLOGY

Cookies, Flash objects, web beacons, file information and similar tracking technologies may be used to collect certain types of information for several purposes, including those enumerated in the section above.

Most internet browsers will allow you to manage, disable or reject cookies through the options/settings feature. Please note that disabling or rejecting cookies may adversely impact the use of our website and your experience with it.

OUR SHARING OF YOUR INFORMATION WITH THIRD-PARTIES

Your Personal Data may be shared outside of TrueFort in the following instances:

• With Affiliates and Third Parties. This includes any affiliates or other companies worldwide so that these companies may contact you regarding products, services or other items that might interest you. Using the TrueFort website, registering for an account or service, or providing TrueFort with your Personal Data constitutes your consent to the transfer of this Personal data worldwide as provided in this notice. Please email legal@truefort.com to choose to opt-out of this provision and prevent this disclosure.
• With Service Providers. This includes affiliated or third-party providers who help to deliver or improve our Product and Services or Providers who perform services on our behalf, such as measuring site traffic, sending marketing information or processing payments. The Personal Data is shared as necessary for the third-party providers to perform their services.
• As is Required or Appropriate. (1) if it is determined, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, to comply with these or to respond to requests from public or government authorities; (2) to enforce our terms and conditions; (3) in connection with detecting or preventing fraud, security or technical issues; and (4) if we reasonably believe disclosure is necessary to protect the rights, privacy, safety or property of TrueFort and/or its affiliates or others, and to prevent or limit our harm and financial loss.
• Business Transfers. In the event TrueFort may buy businesses or sell, transfer or otherwise dispose of all or a portion of its business or assets (through any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or any similar transaction or proceeding), Personal Data may be shared or transferred as one of the business assets. TrueFort shall use reasonable efforts to ensure that the shared/transferred information remains subject to and/or is treated in a manner consistent with this Privacy policy.
• Based on Your Consent. Personal Data may be shared or disclosed with your permission. Data in an aggregated or otherwise anonymized (stripped of personally identifying characteristics) format may be shared with third-parties such as advertisers or other websites, and may be made publicly available to demonstrate use of our Products and Services.

OUR USE AND/OR TRANSFER OF PERSONAL DATA INTERNATIONALLY

TrueFort is headquartered in the United States and conducts business internationally. We may transfer, process or store your information on servers inside the United States or other countries. By accessing the TrueFort website, content, communications or using its Products or Services, you consent to the collection, use, disclosure and transfer of your information as described in this Privacy notice by and to TrueFort in the United States and other countries where TrueFort operates.

You may choose not to consent at any time by contacting TrueFort at legal@truefort.com. Prior uses and disclosures shall not be affected, and your Personal data shall continue to be processed in accordance with the TrueFort internal policies and statutory obligations.

TRUEFORT & GDPR

The European Union’s General Data Protection Regulation (GDPR), which went into effect on May 25, 2018, is a regulation designed to standardize data protection laws throughout Europe, establish fundamental privacy rights for individuals and set guidelines for information security and compliance.

PLEASE NOTE: This document does not provide legal advice nor is it a substitute for legal advice. Please consult your legal department or an attorney for advice concerning GDPR. This document does provide information about TrueFort and its privacy policy for use of its website in accordance with the EU Regulation.

When TrueFort provides Content, Products and Services, we are acting as a data processor for any personal data we receive and store on behalf of our customers, as part of providing the services. TrueFort is committed to complying with the GDPR and to keeping user information secure. If you are located in the EU, please find also our general TrueFort privacy commitments within this global Truefort Privacy Policy on this page.

The TrueFort GDPR terms reflect the commitments required of processors. The GDPR Terms apply to the processing of Personal Data, within the scope of the GDPR, by TrueFort on behalf of the Customer. For the purposes of the GDPR, it is agreed by and between TrueFort and the Customer or Visitor that the Customer/Visitor is the controller, except when the Customer/Visitor acts as a processor of the Personal data, in which case TrueFort is the subprocessor. The basic terms to which TrueFort commits are as follows, to:

Process Personal Data only upon the direction of the Customer/Visitor, except if require to do so by Union or member State law, in which case TrueFort shall advise Customer in advance of processing, unless that law prohibits that disclosure for reasons of public interest;

Ensure that persons processing the Personal Data are committed to confidentiality or are subject to a statutory confidentiality obligation;

(iii) Obtain Customer/Visitor written consent prior to engaging another processor to carry out specific processing activities on behalf of Customer/Visitor, with the same data protection obligations as set forth herein;

(iv) Implement technical and organizational measures, as is practicable, to ensure a level of Personal Data security appropriate to the risk;

(v) Assist Customer/Visitor in its obligations to respond to data subjects’ exercise of their GDPR rights;

(vi) Delete or return all Personal Data to Customer/Visitor upon the conclusion of providing services, and to delete all copies unless Union or member State requires the storage of Personal Data;

(vii) Meet the GDPR’s breach notification and assistance measures;

(viii) Assist Customer/Visitor with data protection impact assessments, audits and governmental inquiries; and

(ix) Support the Customer/Visitor by making available all necessary information to evidence compliance with the GDPR, as needed.

TrueFort shall notify Customer/Visitor without undue delay after becoming aware of a personal data breach. The notification shall include the information specified by the GDPR that a processor must provide to a controller to the extent such information is reasonably available to TrueFort.

If you are an EU-based individual or entity, please be advised that your personal data may be transferred to entities located outside the European Economic Area. If so, TrueFort will take appropriate steps to verify that the third-parties are certified under the Privacy Shield or that there are binding rules in place with the relevant supervisory authority.

To exercise your rights, or should you believe that TrueFort or a company we have communicated your Persona Data to has violated your rights, a complaint may be filed with the Data Protection Authority in your country or other supervisory authorities.

To contact TrueFort in its capacity as Controller of Personal Data, please email legal@truefort.com.

YOUR RIGHTS AND CHOICES RELATING TO PERSONAL DATA

Specific rights exist with respect to your Personal Data, subject to applicable data protection laws, to:

• Access to view and make changes or corrections to your information;
• Erase or delete to the extent permissible by other legal obligations;
• Restrict its processing;
• Transfer to the extent possible to another controller;
• Object to the processing of any of your information;
• Object to its use for direct marketing purposes by TrueFort or shared with a third party for marketing purposes;
• Withdraw your consent at any time without affecting the permission to processing based on consent before the withdrawal, to the extend the collection, processing and sharing is predicated on your consent.

THE RETENTION OF YOUR DATA

TrueFort may retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and for record keeping and audit purposes, or a longer period if required or allowed by law.

OUR PROTECTION OF MINORS & CHILDREN’S PRIVACY

As per the US Children’s Online Privacy Protection Act, 15 U.S.C. Section 6501-06 and 16C.F.R. 312.1-312.12, the TrueFort website is not intended for use by children under 13 years of age, and TrueFort does not knowingly solicit or collect personal information from children. By using the TrueFort website, you are representing that you are 13 years of age or older.

Should TrueFort learn or be notified that any personal data has been inadvertently collected from a minor/child under age 13, the information will be deleted.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may be changed or updated from time to time. Please check the “Effective Date” at the top of this page for the most recent version. Changes or updates are in effect as soon as they are posted. Your continued use of the website or services after any change or updated to this Privacy Notice is posted will constitute your acceptance of the revised Privacy Policy.

CONTACT US

Should you have any questions about this Privacy Policy, please email us at legal@truefort.com or write us by mail at TrueFort Inc., Attention: CFO, 3 West 18th Street, Weehawken, NJ 07086 USA.[/vc_column_text][/vc_column][/vc_row]