Privacy Statement

Effective Date: March 2024

When you (“customer,” or “you”) visit and interact with our website, contact and communicate with us or use any of our products and services, TruU may collect, use, and process information related to you (“Personal Data”). “TruU”, “We”, “Us”, “Our” or the “Company, refer to TruU, Inc. TruU offers a solution that may be comprised of: a cloud service, customer managed software, and software on customer devices. These components, along with the website, are referred to as “Services” in this policy. Authorized end users of TruU products and services may have additional or different policies, rights and obligations specifically applicable to those authorized end users and will receive those policies, rights and obligations set forth in separate policies available upon and during enrollment as an authorized end user.

This Privacy Statement Applies to the Following Activities:

• Visiting our website;
• Visiting our offices;
• Communicating with us, including emails, text, information forms, phone calls or in writing;
• Applying for a position whether full time, part time or as a contractor;
• Registering for our events; or,
• Using our Services.

Website

Our website (https://truu.ai) and other websites under the truu.ai domain, include links to other websites, applications and services maintained by third parties. The information protection and privacy practices of these external websites, applications and services are governed by the privacy statements of the respective third-party. We encourage you to review these privacy statements to better understand the privacy practices of each third party.

Personal Data Collected

The Personal Data we directly collect, process and/or store from you may include the categories listed below. By visiting our website, or inquiring about or using our Services, TruU or its partners, subcontractors, and service providers may collect Personal Data from you and your registered device(s) and you hereby consent to allow collection and use of this information in accordance with this policy.

• Information Request: If you request for information about our Services, or use the “Contact Us” feature on our website, we generally require contact information such as your name, email address, company name, title and telephone number.
• Website Interaction: If you use and interact with our website, we may collect your usage information through cookies, web beacons and similar tracking technologies that may qualify as Personal Data.
• Office Visit: If you visit our offices, you may be required to sign-in with your name, email address, telephone number, company, title, purpose of visit and date/time of arrival.
• Customer Personal Identification Information (PII): Customer first / last name, GUID, email address (if available), UPN, mobile device info (HW version, OS version, etc.), and public key trust associations during an interaction with the TruU cloud when a user is registered to use TruU authentication service. TruU does not have direct visibility into this category of data and it is within the customer to grant TruU access to such data, provided that you acknowledge and agree that TruU may not be able to provide certain support services without such access and TruU shall have no liability to the extent TruU is unable to perform such services without access to this data.
• Device Information: Such information, collected with customer consent, includes the hardware MAC address, and network information, which are used to assess presence, risk, and identity.

Cookies, Log Files & Web-Beacons

We use common information-gathering tools, such as cookies, log files and web-beacons that may collect Personal Data about you, to make interactions with our website more meaningful.

Cookies

We use cookies and similar web tracking technologies such as tags and scripts to collect your usage information and interactions with us on our website. When you visit our website, our servers send a cookie to your computer. Cookies allow us to track overall usage and make your interactions with us more customized and meaningful.

We use both session and persistent cookies. Session cookies only exist during a session and disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Most browsers automatically accept cookies however, if you choose to disable cookies, it may limit your use of certain features and functions on our website or service.

Log Files

As with most websites, we automatically gather certain information in log files as you navigate our website. This information may include your Internet Protocol (IP) address, your Internet Service Provider (ISP), your device identification numbers, your location, your browser, your mobile carrier, your searches on our website, your pages and files viewed, your operating system and date/time stamps of your usage. We analyze this information to help us improve our website and to guarantee proper functionality and security.

Web-Beacons

We may also use web-beacon technologies such as clear gifs that help us better manage content on our website and emails. Clear gifs are tiny graphics with a unique identifier that help track the online movement of users on the website. We do not tie information gathered from clear gifs to Personal Data.

Data Collected Through TruU Services

Authorized end users of TruU products and services may have additional or different policies, rights and obligations specifically applicable to those authorized end users and will receive those policies, rights and obligations set forth in separate policies available upon and during enrollment as an authorized end user. This disclosure is in addition to those in the separate policies. At the core of our Services, data from a registered device(s) is collected and processed by the TruU platform in order to formulate a unique identity of a customer. If a customer authorizes or opts in, such data may come from the, network or the device, which is processed by the TruU platform consisting of a cloud, customer managed software component, and device applications. 

Customer’s administrator can control who uses TruU service from their management console. For a user who is enrolled into using TruU service, TruU uses data such as first / last name, GUID, email address (if available), UPN, mobile device info (HW version, OS version, etc.). This data is obtained from the corporation or users as part of using the TruU service. By default, TruU staff cannot see who at the customer site is using TruU service. We see only the aggregate user count for billing purposes.

Employment Application:

TruU can get your information if you apply for a job at TruU.

Data NOT Collected by TruU:

TruU has no need of data about very personal traits and does not collect data about:

• Children
• Mentally Ill People
• Asylum seekers
• The Elderly
• Patients
• Race or ethnic origin
• Religious or philosophical beliefs
• Political opinions
• Trade union memberships
• Genetic data
• Health data
• Health data, data related to sexual preferences, sex life or sexual orientation

Employment Information Exception:

TruU may have some information about a subject when requesting employment. TruU does not collect this information from end customers.

• Criminal convictions or offences (unless volunteered during employment screening)
• Government issued identification numbers required for employment verification as protected by the law
• Bank, credit card or other financial details required for sending or receiving payments

How We Use Your Data

We collect, process and store your Personal Data for the purposes and on the legal bases identified below:

• Improving Website: We collect and process Personal Data to analyze trends and track your usage of our website for our legitimate interest in further improving and developing our website and to provide you with more relevant and meaningful content.
• General Inquiries: We collect and process Personal Data to respond to inquiries and information requests, and to send materials such as whitepapers, datasheets and pricing through email, postal mail or telephone.
• Marketing Communications: We collect and process your Personal Data to send advertisements, newsletters, product updates, events and promotions necessary for our legitimate interest in providing Services on a commercial basis.
• Sharing of Personal Information: We do not sell or rent your personal information to third parties. However, we may share your information with our trusted partners and service providers who assist us in delivering our services. We may also disclose your information if required by law or to protect our legal rights.
• Employment Opportunities: We collect and process your Personal Data for current and future potential employment.
• Delivering Core Services: We collect and process Personal Data such as first / last name, User ID, GUID, email address (if available), UPN, mobile device info (HW version, OS version).,
• Customer Support: We collect and process Personal Data to respond to your request for assistance, to resolve technical issues you encounter, to analyze crash information and to repair and improve our Service.
• Office Visitors: We collect and process Personal Data of all personnel who visit our offices, for security purposes.
• Legal: We collect and process your Personal Data to cooperate and comply with public and government authorities, courts, and lawful requests in accordance with our legal obligations under applicable laws that require processing or disclosure of Personal Data to protect our rights.

Marketing Opt-Out

You may opt-out of receiving promotional communication and personalized advertisements by managing cookies in your browser and referring to the “Contact Us” section below. Please note, however, that by disabling cookies and similar technologies, you may not be able to take full advantage of features and functionality on our website. You can also withdraw your opt-in consent at any time by referring to the “Contact Us” section below.

End-User Notice

TruU Services are not intended for personal use. The administrator of a customer’s business is responsible for all user accounts and/or Services purchased from TruU. TruU is not responsible for the information protection and privacy practices defined and implemented by the customer. Please direct all questions to your customer administrator, as your use of TruU Services is subject to customer policies implemented by your administrator.

Administrators are able to:

• Access information in and about your account;
• Access or retain information stored as part of your account;
• Restrict, suspect or terminate your access to the Services;
• Enable policies that require certain PII to use the Services;
• Install or uninstall third-party apps or other integrations;
• Change your information, including profile information;
• Restrict your ability to edit, modify or delete information.

Children

TruU Services are not directed at children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If you are a parent or guardian and believe your child has provided TruU with Personal Data without your consent, please contact by referring to the “Contact Us” section below. TruU will take steps to delete such Personal Data from our systems.

Personal Data Retention Period

All data retention is managed as per data retention policy. We retain Personal Data for as long as permitted to use the Services and in accordance with customer standards. TruU also retains certain Personal Data required to comply with legal obligations, resolve disputes and to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where TruU retains information for Service improvements, TruU takes every step to eliminate information that directly identifies you, and only use the information to uncover collective insights about the use of our Service, not to specifically analyze personal characteristics about you.

Your Rights

You have certain rights when it comes to your Personal Data, subject to any additional data protection laws available in your jurisdiction. These rights include the rights to:

• be informed about how we use your personal information.
• access your personal information and to receive a copy of it.
• have your personal information corrected or updated.
• have your personal information deleted or removed.
• restrict our use of your personal information.
• object to our use of your personal information.
• withdraw your consent at any time.

To exercise any of these rights, please contact us using the details provided at the end of this privacy policy

Personal Data Protection

TruU takes every precaution to protect against unlawful or accidental loss, theft, alteration, disclosure or unauthorized access to any Personal Data. While TruU follows generally accepted standards to protect Personal Data, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

If you have any questions or concerns about our privacy practices or would prefer we delete all personal information or data we have about you, please contact us at legalandcompliance@truu.ai or by mail at TruU, Inc., attn: Legal and Compliance 2350 Mission College Blvd. Suite 780 Santa Clara, CA 95054. Please include all email addresses, company name and/or user names you may have used in connection with providing us your personal information.

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