Trufflow’s Privacy Policy

Your privacy is important to us, and so is being transparent about how we collect, use, access, process on behalf of another party, transfer, and/or store and/or retain personal information we process through Trufflow’s websites, social media channels, and through your use or access to our products and/or services. 

This Privacy Policy describes Trufflow Ltd’s (“Company” “we” “us” or “our”) policies and procedures on the collection, use and disclosure of your information when you use our Services and/or that you provide to us when you vist any of the Company’s website properties including, but not limited to: the website located at  https://trufflow.com/ (collectively referred to as the “Website(s)”); access features of our software as made available on  Websites; or obtain any professional services from Trufflow (The Website, and professional services are hereinafter collectively referred to as the “Services”).

As used in this Privacy Notice, Personal Information means information and/or data that can identify a natural person. In addition to explaining how Trufflow processes Personal Information, this Privacy Notice further explains how Trufflow collects, uses, accesses, maintains, protects, and/or discloses Personal Information based on its business interest and/or by obtaining your consent. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

If you do not agree with this policy, do not access or use Our Services and/or interact with any other aspect of our business.  

We reserve the right to modify this Policy as described in Section 11.

1. Personal Information We May Collect or Receive

Depending on the context in which you interact with us, we may collect or receive the following types of information, including Personal Information, from and about you:

• When you submit requests or inquiries on our Website (including when registering for content such whitepapers and requesting additional information, services, or support from us), we may collect your name, job title/level, company name, address, phone number, e-mail address, country, and certain company information.
• When you correspond with us via email, we may collect the Personal Information included in your e-mail.
• When you visit our Website we collect certain information automatically. This includes IP address, browser type, browser version, the pages of Our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our Website.
• When you access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, Your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our Website.

We may collect Personal Information from our existing and prospective Customers:

• When Customers register to use Our Services, we require them to provide us with contact information (such as name, company name, phone number, and e-mail address). We will use the email address provided during the registration process to generate a username and temporary password for Customers. Customers will be invited to log-in to change their password.
• With Customers’ consent, we may post Customers’ testimonials, which may include Personal Information such as their name, on the Website about their use of Our Services.
• Customers contact details to send them information about our products or services.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of Our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
• If you do not want us to collect cookies on the Website, you may set your browser to refuse cookies, or to alert you when cookies are being sent. You can opt out of the collection and use of certain information, which we collect about you by automated means, including cookies, when you visit our websites or update your browser settings. Your browser may tell you how to be notified and opt out of receiving certain types of cookies.

2. How we May Use Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give you access to different functionalities of the Service that are available to you as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with Us through the Service.
• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• To our professional advisors such as lawyers and accountants in connection with obtaining guidance.
• For safety and security. We use information about you and your use of the Services to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activity, including violations of Service policies.
• To protect our legitimate business interests and legal rights. Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use information about you in connection with legal claims, compliance, regulatory and audit functions, and disclosures in connection with the acquisition, merger or sale of a business. 
• For research and development: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to contact you.
• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With Your consent: We may disclose your personal information for any other purpose with Your consent.
• Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights. In exceptional circumstances, we may share information about you with a third party if we believe that sharing is necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies, and terms of service, (c) protect the security or integrity of our products and services, (d) protect Company, our customers, or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

3. Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

4. Your Rights and Choices

Subject to applicable law, you may have the rights to request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, and have the information blocked or deleted, as appropriate. These rights may be limited in some circumstances by local law. To exercise these rights, please contact us as set forth below in the how to contact us section.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

You can choose not to provide us with your Personal Information, but if you do not provide us with your Personal Information when we request it, we may not be able to provide you with our full range of products and services, or provide a service appropriately tailored to you.

5. GDBR

This section applies to individuals in the European Economic Area (“EEA”), the United Kingdom, and Switzerland.

Where we process Personal Information as a data controller, we do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., granting you access to and providing the products and services you requested).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
• When we have your consent to do so (e.g., to send you marketing communications). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Please see the “Your Rights and Choices” section above for information about your privacy rights and how to exercise them. In addition, you can object to certain processing or request that we restrict certain processing by contacting us as described in the “How to Contact Us” section below. You can also lodge a complaint with the data protection authority as follows:

• For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
• For individuals in the UK: https://ico.org.uk/global/contact-us/
• For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

We retain Personal Information as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Policy.

6. Your California Privacy Rights

This section provides additional details about the Personal Information we may collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA”.

Additional Disclosures

The categories of information we collect include identifiers, commercial information, internet activity information, professional information, and inferences. The categories of sources from which we collect such information are from you and from third party business partners. For more details about the Personal Information we have collected over the last 12 months, including the categories of sources, please see the Personal Information We May Collect or Receive above.

We collect this information for the following business and commercial purposes (described in more detail in the “How we May Use Your Personal Data” section of this Policy): providing the Services; performing marketing and advertising; conducting analytics and Services improvement; and for security/compliance.

Trufflow does not knowingly sell or share (as those terms are defined in the CCPA) the Personal Information of individuals younger than 16.

Privacy Rights

Subject to certain limitations, the CCPA provides California consumers a number of rights, specifically:

1. the right to request to know more details about the categories Personal Information we collect (including how we use and disclose this information) or access specific pieces of Personal Information we have about them;
2. to delete their Personal Information;
3. to correct inaccurate Personal Information;
4. to opt out of any “sales” or “sharing” that may be occurring through our use of third-party cookies for advertising by disabling targeting and social media cookies; and
5. to not be discriminated against you for exercising these rights.

California consumers may make a request to know, access, correct, or delete pursuant to their rights under the CCPA by contacting us as set out in the How to Contact Us section below. We will verify your request using the information we currently hold about you, including email address. Further information may be required in order to identify you. Consumers can also designate an authorized agent to exercise these rights on their behalf. Authorized agents can submit requests in the same manner as consumers but must include proof of authorization to make the request.

We retain Personal Information as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Policy.

7. Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that 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. Where you receive a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

8. Cross-Border Data Transfers

We may transfer your Personal Information to countries other than the country in which the data was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided that information. When we transfer your Personal Information to other countries, we will protect it as described in this Privacy Policy. To offer our services, we may need to transfer your personal information among several countries where we have employees, facilities or service providers, including the United States and Canada. By using the Services or otherwise providing Personal Information to us, you consent to the transfer of Personal Information to countries outside of your country of residence, including the U.S.

9. Children’s Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require your parent’s consent before We collect and use that information.

10. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time in accordance with applicable privacy and/or data protection law as well to provide additional clarity around Trufflow’s processing of Personal Information.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of the Services is deemed to be acceptance of such changes, to the extent permitted under applicable law.

12. How to Contact Us

If you have any questions about this Privacy Policy, you can contact us:

• By email: [email protected]