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Privacy Policy

TrueFire Privacy Policy

Effective Date:  May 28, 2018

 

TrueFire takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights. This version was amended May 25, 2018. Earlier versions can be found here.

 

We recommend that you read this privacy policy in full to ensure you are fully informed. If you have any concern about providing information to us or having such information used in any manner permitted in this Privacy Policy, you should not visit our websites, apps or otherwise use our Services.

 

The Basics

TrueFire, Inc ("us," "we," "Company" or "TrueFire") is committed to respecting the privacy rights of its customers, visitors, and other users of the Company Websites ("the Site") and Mobile Applications ("the Apps"), together referred to herein as "Services." We created this Privacy Policy to give you confidence as you visit and use our Services and to demonstrate our commitment to fair information practices and to the protection of privacy. This Privacy Policy is only applicable to the Services, and not to any other websites that you may be able to access from the Services, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy. 

 

This Privacy Policy describes the types of information we may collect from you or that you may provide to us when you visit the TrueFire.com websites, sub domains or servers or use our services located primarily at www.truefire.com  (the "Websites"), or a TrueFire.com mobile or desktop application (an "App") (collectively, the "Services"), and our practices for collecting, using, maintaining, protecting and disclosing such information. This Privacy Policy applies to information we collect: (i) through our Services, and (ii) in text and electronic messages between you and our Services.

 

This Privacy Policy does not apply to any other services or any information collected by us offline or via third-party sites that may be accessed through hyperlinks on our Services such as Facebook, YouTube or others.

 

In keeping with TrueFire's commitment to comply with the various rules and regulations relating to safeguarding and protecting Personal Data it receives from its customers in the United States, in the European Union, and elsewhere, TrueFire has chosen to undertake a good faith effort to comply the European Union's GDPR and the obligations it imposes on controllers and processors of EU Personal Data, and to incorporate the privacy terms required for GDPR compliance herein. 

 

By accessing or using our Services, you agree to this Privacy Policy.

 

Information We Collect About You

We collect several types of information about visitors and/or users of our Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Websites or App.

 

(a) We will collect and process your personal data when you register for a Service, create an account, subscribe to a newsletter, submit feedback, enter a contest, fill out a survey, or send us a communication. When ordering products or services on the Websites or App, you may also be asked to provide a credit card number and other payment-related information. Depending upon the activity, some of the information we ask you to provide is required to use the Services (e.g. registering an account) and some is voluntary. If you do not provide data when needed for a particular activity, you will not be able to engage in that activity.

 

We also collect your Internet Protocol ("IP") address. We use your IP address to diagnose problems with our servers and/or software, to administer our Services, and to gather demographic information.

 

(b) We may collect certain information that does not by itself identify a specific individual. Such information tells us about your equipment, browsing actions, and the resources that you access and use through the Services, such as your operating system and browser type. We use analytics and similar services, as explained in our Cookie Policy, to help us to deliver a better and more personalized service to users by enabling us to estimate usage patterns, customize our Services according to your individual preferences, and speed up your searches.

 

(c) When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best version of the application to provide you. We do not ask you for, access, or track any location-based information from your mobile device at any time while downloading or using our App or Services.

 

(d) When you contact us for customer support we may collect additional information to resolve your issue to improve your customer service experience.

 

(e) We are not a site targeted at children or those under the age of 16. If you are a school and you use a TrueFire service for children under the age of 16, or the equivalent minimum age in the relevant jurisdiction, you are responsible for obtaining consent from the parents/legal guardians of each child you wish to allow to participate in using any of our Services. A child using our Services will be able to participate in certain limited activities (such as taking online educational and informational courses).

 

How We Use Your Information

We use information held about you in the following ways:

       

        To present content from our Services in an effective manner for you and for your computer or mobile device

        To provide you with information, products or services that you request from us or which we feel may interest you

        To allow you to participate in interactive features of our Services, when you choose to do so

        To carry out our obligations arising from any contracts entered into between you and us, including for billing and collection

        If you pay for Services using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company

        To allow our contractors, service providers and other third parties who provide data processing services to us and with whom the sharing of your Personal Information is necessary to undertake the work e.g. to process billing, analyze data, host data, provide customer support, and to deliver online and offline marketing communications that we think will interest you.

        To contact you about our Services

         

        Disclosure of Your Information

We will share your personal data with third parties only in the ways that are described in this Privacy Policy. We do not sell, trade, rent or disclose your information to others, except as provided herein:

 

(a) We provide and support some of our Services through contractual arrangements with service providers and other third parties. We, and our service providers, use your personal data to operate our Websites and to deliver Services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Websites; and provide order information to third parties that help us deliver the Services.

 

(b) We will also disclose personal data in the following circumstances: (i) if it is required by law enforcement or judicial authorities, or to cooperate with a law enforcement investigation; (ii) if we have a good faith belief that we are required or permitted to do so by law or legal process; (iii) to protect our rights, reputation, property or the safety of us or others; (iv) to defend or enforce our rights or your obligations; (v) if the disclosure is required by mandatory professional standards; (vi) to a third party with your prior consent to do so; or (vii) if we are under a duty to disclose or share your personal data in order to enforce or apply any contracts or agreement that may exist between you and us including this Privacy Policy and terms of service. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

Direct Marketing

We currently do not share personal data with third parties for their direct marketing purposes, nor allow for advertising on our Websites. We do however, have third party services to advertise our Websites and Services in other networks to drive traffic to our own network. These partners are: Amazon Associates, Doubleclick, Facebook Custom Audience, Google Adwords, Google Publisher Tags and Linkedin Ads.

 

 

Public Information and Third Parties

Blog.  We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us.

 

Social media platforms and widgets.  Our Websites include social media features, such as the Facebook Social Plugins, Facebook Connect, Google+ Platform, Twitter and Twitter Syndication. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

 

Links to third-party websites.  Our Websites may include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

 

Contests and sweepstakes.  We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively, "Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion's rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.

 

Cookies and Tracking Technologies

We and our service partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send to you. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the IP address, browser, email client type and other similar details.

 

We use this information to measure the performance of our email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.

 

Here are our third-party service partners and function to our Websites and Services:

 

Amazon CDN - Content delivery network of multimedia assets

Intercom - Customer messaging platform

Google Shopping - Reviews

Nextopia - Site search, navigation & merchandising

Onesignal - Mobile and web push notifications delivery

Soundslice - Interactive sheet music platform

Zendesk - Customer service and engagement platform

Sumo - Blog email notifications platform

Symantec - Norton shopping guarantee and web theft protection

Viblast - Cross-platform HTML5 video streaming technology

Vimeo - Video player used for tutorial videos in Channel Manager

GA Audiences, Google Analytics, Linkedin Analytics - Website analytics

Scarab Research - For personalized online shopping experiences and recommendations

 

Updating or Correcting Personal Data

We offer settings to control and manage the personal data we have about you, including the ability to:

 

Amend or Rectify Data: You can edit some of your personal data through your account. You can also ask us to amend your data in certain cases, particularly if it is inaccurate.

 

Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).

Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

       

You may change your personal data associated with your account on your "My Profile" tab. You may also access, request deletion, and correct your personal data by submitting a data request through Customer Support or by writing to us at the addresses at the end of this Privacy Policy.

 

Cancelling your Account and Deleting Personal Data

You may choose to let your subscription lapse, in which case we will retain your information for a reasonable period of time in case you choose to re-subscribe.

 

You may choose to close your account in which case we will delete your information, including your learning history, within 60 days of your request. However, we may retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), comply with contractual obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.

 

If you would like to access the information that we have about your use of and access to TrueFire Services, please request it by writing to us at the addresses at the end of this Privacy Policy. You can also ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., your personal data is inaccurate or unlawfully held) by submitting a data request by writing to us at the addresses at the end of this Privacy Policy.

 

Choices Regarding Control of your Personal Data

You can access some of the information that we collect about you. For example, by logging into your account, you can access information regarding recent orders from the Websites; certain personal data we maintain about you; your communication preferences; and your payment settings.

 

If you have questions on this process, please contact help@truefire.com. You may also contact us by submitting a data request by writing to us at the addresses at the end of this Privacy Policy, and we will assist you in accordance with applicable laws.

 

With respect to your communications preferences, you can unsubscribe from newsletters by following the instructions included in the newsletter you receive, or you can log into your account and update your newsletter and email subscription options. If your email address has changed and you would like to continue to receive newsletters, you will need to access your account, update your email address information in your account, and sign-up again for the newsletter. Administrative emails regarding purchases, downloads and other administrative communications are handled separately and not included in the request to opt-out of marketing or news communications.

 

You also have choices with respect to cookies, as described in our Cookie Policy. By modifying your browser preferences, you may be able to choose to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Websites may not work properly in your case.

 

Lawful Basis for Processing Data

Where we process data based on consent, we will ask for your explicit consent. Where we rely on contract, we will ask that you agree to the processing of personal data that is necessary for entering into or the performance of your contract with us. We may process your personal data for the purposes of our legitimate interests or for the legitimate interests of third parties (e.g., your employer or company), provided that such processing shall not outweigh your rights and freedoms. For example, we may process your personal data to:

Protect you, us or others from threats (such as security threats or fraud);

Comply with laws that apply to us;

Enable or administer our business, such as for quality control, consolidated reporting, and customer service;

Manage corporate transactions, such as mergers or acquisitions;

Understand and improve our business or customer relationships generally.

 

Data Security

Access by you to your account is available through a password and/or unique username selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone, that you change your password often using a combination of letters and numbers, and that you ensure you use a secure web browser. We cannot be held accountable for activity that results from your own neglect to safeguard the secrecy of your password and username. If you share a computer with anyone, you should always log out of your account after you are finished in order to prevent access to your information from subsequent users of that computer.

 

Please notify Customer Support as soon as possible if your username or password is compromised.

 

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.

In the unlikely event that we believe that the security of your personal data in our control may have been compromised, we will try to notify you. To the extent you have provided us with your email address, we may notify you by email and you agree to our use of email as a means of such notification.

 

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the App, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any personal data you submit within the App.

 

Changes to this Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page (with a notice that the Privacy Policy has been updated on the Websites). The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Policy to check for any changes. Your continued use of the Services after such modifications will constitute your agreement to the updated terms of the modified Privacy Policy.

 

Contact Us

If you have questions or complaints regarding this Privacy Policy, please first contact privacy@truefire.com. You can also reach us by physical mail at the addresses below.

 

TrueFire, Inc

2500 Emerson Avenue South

St Petersburg, FL 33712