Privacy Policy of Trueli

Full policy

Owner and Data Controller

Trueli Tech Ltd.

Owner contact email: info@trueli.me

Types of Data collected

Among the types of Personal Data that Trueli collects, by itself or through third parties, there are: Usage Data; Contacts permission; Camera permission; Approximate location permission (non-continuous); Microphone permission; Storage permission; Biometric Data access permission; Media Library permission (Music); Photo Library permission; Universally unique identifier (UUID); crash data; device information; Trackers; Data communicated while using the service; country; email address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Trueli.
Unless specified otherwise, all Data requested by Trueli is mandatory and failure to provide this Data may make it impossible for Trueli to provide its services. In cases where Trueli specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Trueli or by the owners of third-party services used by Trueli serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through Trueli.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Trueli (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Device permissions for Personal Data access, Infrastructure monitoring, Social features, Managing contacts and sending messages, Hosting and backend infrastructure, Content performance and features testing (A/B testing), Interaction with support and feedback platforms, Operations, Advertising and Registration and authentication.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Device permissions for Personal Data access

Depending on the User's specific device, Trueli may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of Trueli.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Trueli.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. Trueli may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for Trueli to derive the approximate position of the User on a continuous basis.

Biometric Data access permission

Used for accessing the User's biometrical Data and/or authentication systems, such as for instance, FaceID.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Contacts permission

Used for accessing contacts and profiles on the User's device, including the changing of entries.

Media Library permission (Music)

Allows accessing the User's Media Library audio Data.

Microphone permission

Allows accessing and recording microphone audio from the User's device.

Photo Library permission

Allows access to the User's Photo Library.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Advertising

  This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Trueli, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Trackers for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
  Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

  Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)

  Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta Audience Network with actions performed on Trueli. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics for Firebase (Google LLC)

  Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
  In order to understand Google's use of Data, consult Google's partner policy.

  Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

  Trueli uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

  Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Amplitude Analytics (Amplitude Inc.)

  Amplitude Analytics is an analytics service provided by Amplitude Inc.

  Personal Data processed: Camera permission; device information; Microphone permission; Usage Data.

  Place of processing: United States – Privacy Policy; Netherlands – Privacy Policy; European Union – Privacy Policy; France – Privacy Policy; Japan – Privacy Policy; United Kingdom – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sharing in California

  Meta Events Manager (Meta Platforms Ireland Limited)

  Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited or by Meta Platforms, Inc., depending on how the Owner manages the Data processing. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on Trueli.

  Personal Data processed: country; Data communicated while using the service.

  Place of processing: Ireland – Privacy Policy – Opt out; United States – Privacy Policy – Opt out.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• Content performance and features testing (A/B testing)

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Trueli.

  Firebase Remote Config (Google LLC)

  Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• Device permissions for Personal Data access

  Trueli requests certain permissions from Users that allow it to access the User's device Data as described below.

  Device permissions for Personal Data access (Trueli)

  Trueli requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

  Personal Data processed: Approximate location permission (non-continuous); Biometric Data access permission; Camera permission; Contacts permission; Media Library permission (Music); Microphone permission; Photo Library permission; Storage permission.

  Category of Personal Information collected according to the CCPA: biometric information; internet or other electronic network activity information; geolocation data.

  This processing constitutes:

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable Trueli to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Trueli.

  Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Firebase Cloud Storage (Google LLC)

  Firebase Cloud Storage is a hosting service provided by Google LLC.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  Shotstack

  Shotstack API is an external service that we may use to support video generation features available in Trueli app. We generate these original videos from photos and videos uploaded by Trueli app users to our backend systems and temporarily shared with Shotstack for the purpose of rendering the video only. Subject to Shotstack's data retention policy mentioned in their Privacy Policy, photos and videos shared with Shotstack are securely deleted shortly after rendering. Their full Privacy Policy is available here:
  https://shotstack.io/privacy

  This processing constitutes:

  • a Sale in the United States
  • a Sharing in California

• Infrastructure monitoring

  This type of service allows Trueli to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Trueli.

  Crashlytics (Google LLC)

  Crashlytics is a monitoring service provided by Google LLC.

  Personal Data processed: crash data; device information; Universally unique identifier (UUID).

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  Firebase Performance Monitoring (Google LLC)

  Firebase Performance Monitoring is a monitoring service provided by Google LLC.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  Sentry (Functional Software, Inc. )

  Sentry is a monitoring service provided by Functional Software, Inc. .

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

• Interaction with support and feedback platforms

  This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of Trueli.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  In-app feedback

  When sending in-app feedback, the user full name and email are saved in Trueli's backend DB, if specified.

  This processing constitutes:

  • a Sharing in California

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Firebase Cloud Messaging (Google LLC)

  Firebase Cloud Messaging is a message sending service provided by Google LLC. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Mailjet (SAS Mailjet)

  Mailjet is an email address management and message sending service provided by SAS Mailjet.

  Personal Data processed: email address.

  Place of processing: France – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in the United States
  • a Sharing in California

• Operations

  Email and phone number for account recovery

  If specified in registration or in profile section in the app, email and phone are saved in Trueli's backend DB as one way hash. This data is used for account verification and recovery purposes, as well as for connecting with other users on the platform, as per user's request only.

  This processing constitutes:

  • a Sharing in California

• Registration and authentication

  By registering or authenticating, Users allow Trueli to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, Trueli will be able to access some Data, stored by these third-party services, for registration or identification purposes. Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

  Direct7 Networks

  Direct7 Networks API is an external service that we use to send transactional SMS messages to Trueli app users. For this purpose we share the user's phone number only.

  This processing constitutes:

  • a Sale in the United States
  • a Sharing in California

• Social features

  Firebase Dynamic Links (Google LLC)

  Firebase Dynamic Links is a social feature provided by Google LLC. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within Trueli.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  In-app contacts and groups

  When a user invites a new contact, the invitation creator's full name manually added by the creator is saved in Trueli's backend DB. This data is deleted when the invitation is accepted, rejected or the invitation expires in 30 days.
  When an invitation is accepted, the invitation recipient's full name manually added by the recipient is saved in Trueli's backend DB. This data is deleted when the invitation's creator is notified about the invitation's acceptance.
  When a group is created or updated, the list of members' full names is sent to all group members. This data is encrypted by the sender before saving in Trueli's backend DB and is decryptable only on the group members' devices.

  This processing constitutes:

  • a Sharing in California

  Public sharing

  When user shares their Trueli publically, the user's full name is saved in Trueli's backend DB.

  This processing constitutes:

  • a Sharing in California

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• Credits

  Trueli's "Geo location database" is a derivative of "Geographical database" by GeoNames, used under CC BY. "Geo location database" is licensed under CC BY by Trueli.

• Community Guidelines

  Terms of Use
  
  Trueli is an app for everyone. We value individuals who create and share memories with us, and we take pride in providing a platform that empowers users like you to share your moments and memories with others on the app. We are committed to making and keeping Trueli a safe and secure place for everyone, and we encourage our users to exhibit behaviour that supports this.
  
  Our Community Guidelines are intended to ensure the safe use of our services for all users and must be taken seriously. They are an integral part of our Terms and Conditions.
  
  The Community Guidelines, outlined below, serve as guidelines for respecting other people while using our service and sharing content.
  
  We strongly recommend that you read and adhere to these guidelines when sharing content or interacting with others on our app.
  
  Guidance when sharing content on Trueli
  
  Bullying and Abusive Content: Avoid sharing content that bullies, abuses, or harasses others, whether users or non-users.
  Child Sexual Exploitation: Strictly forbidden; Trueli has zero tolerance for any content promoting or containing child sexual exploitation.
  Hateful Content: Refrain from sharing content that expresses hatred towards individuals or organisations.
  Illegal Activity: Do not share content that promotes or engages in illegal activities.
  Intellectual Property: Respect others' intellectual property; do not share content that violates it.
  Non-Consensual Nudity: Strictly forbidden; Trueli has zero tolerance for any content promoting or containing non-consensual nudity.
  Non-Public Personal Information: Obtain consent before sharing others' nonpublic personal information.
  Suicide and Self-Harm: Avoid sharing content that promotes, encourages, or glorifies suicide or self-harm.
  Violent Content: Do not share content that threatens, incites, glorifies, or expresses a desire for violence or harm.
  
  How to Report Infractions to the Community Guidelines: You can report any violation by emailing us at abuse@trueli.me. The Trueli Support Team will review the report and reply if necessary. We may use your contact information, including your Trueli name, real name, and email address, to get in touch with you. We recommend including screenshots of the content or account in question as part of your email for a thorough evaluation.
  
  What Happens After You Make a Report: Any behavior, activity, or content contrary to the Terms of Use may be sanctioned at our discretion, either temporarily or permanently. We reserve the right to verify compliance with the Terms of Use, and our decision on whether a violation has occurred is final. If you believe a decision has been unfairly made against you, you can contest it by contacting us at info@trueli.me and citing your case.
  
  Thank you for using Trueli while respecting others' sentiments. Enjoy your experience!
  
  

Cookie Policy

Trueli uses Trackers. To learn more, Users may consult the Cookie Policy.

Further information for Users in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running Trueli and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

• your consent to the relevant processing activities;
• compliance with a legal or regulatory obligation that lies with us;
• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
• the exercising of our rights in judicial, administrative or arbitration procedures;
• protection or physical safety of yourself or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
• credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:

• obtain confirmation of the existence of processing activities on your personal information;
• access to your personal information;
• have incomplete, inaccurate or outdated personal information rectified;
• obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• obtain information on the possibility to provide or deny your consent and the consequences thereof;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke your consent at any time;
• lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• when the transfer is necessary to protect your life or physical security or those of a third party;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Trueli and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Trueli.

For example, you directly provide your Personal Information when you submit requests via any forms on Trueli. You also provide Personal Information indirectly when you navigate Trueli, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Trueli and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

• the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
• the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
• the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
• the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
• the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
• the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
• The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have

• The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

• The right to question the results of the profiling;
  
• The right to be informed of the reason that the profiling resulted in the decision; if feasible
  
• The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
  
• The right to review personal data used in the profiling;
  
• If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
  

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:

• The right to opt out of the processing of your Personal Information for Targeted Advertising;
• The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on Trueli.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Trueli or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Trueli may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Trueli and any third-party services may collect files that record interaction with Trueli (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Trueli and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.