Copyright © 2020 TruU, Inc. All rights reserved.
Effective Date: Oct 2020
When 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 is comprised of: a cloud service, customer managed software and a mobile app / SDK. These components, along with the website, are referred to as “Services” in this policy.
This Privacy Statement applies to the following activities:
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.
The Personal Data we directly collect, process and/or store from you may include:
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.
We use both session-based and persistent-based 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.
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.
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.
At the core of our Services, sensor data from a registered mobile device, is collected and processed by the TruU platform in order to formulate a unique identity of an end-user. If a user authorizes or opts in, such sensor data may come from the gyroscope and accelerometer of the device, which is processed by the TruU platform consisting of a cloud and a customer managed software component. Other sensor data, including barometric sensor, Bluetooth, Location, Magnetometer and Wi-Fi from a registered device may be collected for the purpose of uniquely identifying a user. TruU will never collect data from a device without the end-user’s permission. End-users can also set the TruU mobile app into ‘Privacy Mode’ on a scheduled or on an ad-hoc basis to disable all data collection by TruU. By default, end-users can also disable any sensor data collection parameter (e.g. location, motion, etc.) within the TruU mobile app; however, Administrators do have the ability to require or disable any of sensor data collection parameter via policy controls, based on the Enterprise’s internal policies.
Customer Administrator can control who uses TruU service from their management console. For a user who is enrolled into using TruU service, TruU only uses less sensitive 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 as part of using the TruU service. TruU staff cannot see who at the customer site is using TruU service. We see only the aggregate user count for billing purposes.
TruU can get your information if you apply for a job at TruU.
TruU has no need of data about very personal traits and does not collect data about:
TruU may have some information about a data subject when requesting employment. TruU does not collect this information from end customers.
We collect, process and store your Personal Data for the purposes and on the legal bases identified below:
We may share collected Personal Data with the following recipients:
You may opt-out of receiving promotional communication and personalized advertisements by managing cookies in your browser. 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.
TruU Services are intended for use by Enterprises. The Administrator of the Enterprise is responsible for user accounts and/or Services over which it has control. TruU is not responsible for the information protection and privacy practices defined and implemented by the Enterprise. Please direct your questions to your Administrator, as your use of TruU Services is subject to Enterprise policies implemented by your Administrator.
TruU Services are not directed at children under the age of 16. We do not knowingly collect personal information from children under the age of 16. 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.
All data retention is managed as per data retention policy. We retain Personal Data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Service. 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.
You have certain rights when it comes to your Personal Data, subject to local data protection laws. These rights include the right to:
To exercise your rights, please refer to the “Contact Us” section of this document. We will try to respond to all legitimate requests within one month of the request and may contact you if we need additional information to honor the request.
TruU employees and contractors are required to go through mandatory recurring training to make sure they understand their role and responsibilities in protect all TruU data.
TruU takes every pre-caution 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.
TruU reserves the right to update our Privacy Statement at any time to reflect changes in our internal practices, technologies and legal requirements. If changes are made to the Privacy Statement, the “Effective Date” at the top of this Privacy Statement will be updated. Your continued use of our Services after we post any modifications to the Privacy Statement described on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Statement.
If you have any questions or concerns about this Privacy Statement or to exercise your rights regarding your Personal Data, please contact us:
Any violation of this policy may result in disciplinary action, up to and including termination of employment. TruU reserves the right to notify the appropriate law enforcement authorities of any unlawful activity and to cooperate in any investigation of such activity. TruU does not consider conduct in violation of this policy to be within an employee’s or partner’s course and scope of employment, or the direct consequence of the discharge of the employee’s or partner’s duties. Accordingly, to the extent permitted by law, TruU reserves the right not to defend or pay any damages awarded against employees or partners that result from violation of this policy.
Any employee or partner who is requested to undertake an activity which he or she believes is in violation of this policy, should provide a written or verbal complaint to his or her manager, any other manager or the Human Resources Department as soon as possible.
ISO/IEC 27001:2013 – Clauses 9.2(g) Internal Audit and others
AT 101 – SOC 2: CC1.0– The Control Environment
AT 101 – SOC 2: CC2.0 – Communication and Information
AT 101 – SOC 2: CC4.0 – Monitoring of Controls
PCI DSS v3.1