Information Collection and Use
We will use commercially reasonable efforts to ensure that all Personally Identifiable Information disclosed by you and that is held by us will be: (i) processed lawfully, fairly, and in a transparent manner; (ii) collected for specified, explicit, and legitimate business purposes and not further processed in a manner that is incompatible with those legitimate business purposes; (iii) adequate, relevant and limited to what is necessary; (iv) kept in a form which permits identification of data subjects for no longer than is necessary; and (v) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
Any time you use the App, we may use third party protect to collect log data, including but not limited to your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing the App, the time and date of your use of the App, and other statistics as may be reasonably necessary or helpful in troubleshooting errors or bugs in the App.
Cookies, Pixels, and Other System Technologies
“Cookies” are small files placed on your computer, mobile phone, or other device that are commonly used as anonymous unique identifiers. “Pixels” (also called clear GIFs, web beacons, or pixel tags) are small blocks of code on webpages that are often used in combination with cookies.
You can configure your browser to handle cookies according to your preferences, including rejecting all cookies. When using the App or visiting or using the Website, you are free to decline cookies. However, please note that doing so may impact your interaction with the Website and/or the App.
We may employ third-party companies and individuals to process payment, host and maintain the Website, facilitate the App, perform services related to the App, analyze how the Website and the App are used, and troubleshoot issues or errors with the Website or App. These third parties may have access to your Personally Identifiable Information as needed to perform their functions. You agree that Trulight Holdings, LLC and those with whom it shares information may disclose and transfer your information worldwide, including in and outside the United States, the European Economic Area, Canada, and any other jurisdiction, for any purpose relating to the App or the Website.
If at any time you decide that you no longer want us to have some or all of your Personally Identifiable Information, you may indicate this preference by emailing us at email@example.com or contacting us as detailed below in the “Contact Us” section.
Social Networking Sites
Links to Other Sites
We are a United States based company. By providing your information, visiting or using the Website, and/or using the App, you explicitly consent to the transfer, processing, and storage of your information within the United States. If you at any time you no longer wish for us to transfer your Personally Identifiable Information within the United States, please contact us using the information in the “Contact Us” section below.
We maintain administrative, technical, and physical safeguards, which vary depending on the sensitivity of the Personally Identifiable Information, that are commercially reasonable for a company of our size and sophistication. However, due to the widespread occurrence of data breaches, database down time, and inadvertent data loss, we cannot ensure or warrant the security of any information you provide to us. We explicitly disclaim all liability for the unintentional disclosure, access to, or loss of your information.
We will retain your Personally Identifiable Information only for as long as necessary to fulfill the legitimate business purposes for which it was collected and to comply with applicable laws. By providing the information to us, you consent to such collection and storage of your Personally Identifiable Information, and such consent remains valid after termination of our relationship with you.
EU/ EEA Citizens
The EU General Data Protection Regulation (GDPR) grants individuals who are in the European Union and European Economic Area (EU/EEA) certain rights, with some limitations. If applicable, we will establish a system to enable and facilitate the exercise of data subject rights related to: 1) information access; 2) objection to processing; 3) objection to automated decision-making and profiling; 4) restriction of processing; 5) data portability; 6) data rectification; and 7) data erasure.
The California Consumer Privacy Act (CCPA) provides California consumers with the right to request access to their personal data, additional details about our information practices, and deletion of their personal information (subject to certain exceptions). California consumers also have the right to opt out of sales of personal information, if applicable. We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney. Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information. We will not discriminate against you if you choose to exercise your rights under the CCPA.
You may request, no more than twice in a twelve (12) month period, access to the specific pieces and transportable copies of personal data we have collected about you in the last twelve (12) months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the sources of such collection, the categories of personal information we share for a legitimate business or commercial purposes, and the categories of third parties with whom we share your personal information. You may make these requests by contacting using the contact information provided below in the “Contact Us” Section below. After submitting your request, please monitor your email for a verification email. We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.
You may request that we delete the personal information we have collected about you. Please note that we may nonetheless retain certain information as required or permitted by applicable law. You may make these requests by contacting us using the contact information provided below in the “Contact Us” Section below. After submitting your request, please monitor your email for a verification email. We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.
California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties.
Exercising of Individual Rights
If you would like to exercise above EU General Data Protection Regulation (GDPR) rights about your personal information we hold about you, or exercise any other data subject right available to you under the California Consumer Privacy Act (CCPA) or other law applicable to you, please submit a written request to: firstname.lastname@example.org or contact us using the information provided in the “Contact Us” section below. Our privacy team will examine your request and respond to you as quickly as possible.
Aggregate and De-Identified Data
Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
The Website and the App are not intended to be used by anyone under the age of 13 without parental consent. Consistent with the Children’s Online Privacy Protection Act of 1998, we do not knowingly collect Personally Identifiable Information from anyone under the age of 13 without prior, verifiable parental consent. In the case we discover that a child under 13 has provided us with Personally Identifiable Information, we will use commercially reasonable efforts to remove such information anywhere it may appear. If you are a parent or guardian and you become aware that your child has provided us with Personally Identifiable Information without your consent, please contact us according to the “Contact Us” section below so that we can rectify the situation.
Email, Text, and Telephone Communications