PRIVACY POLICY

Last update: 09/18/2021

 

True Voice and its affiliates (“Company,” “us,” "we," or “our”) is committed to protecting and respecting your privacy in connection with your use of our website, truevoiceapp.com (the “Website(s)”), applications (“Apps”) and other products, services and features thereof (the Website, the Apps and such other products, services and features are collectively referred to herein as the “Product” or “Products”, which may be updated from time-to-time at the sole discretion of Company). This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Products will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data.

Any collection, use, and management of personal information by the social networks, including Facebook, Instagram, Twitter, and LinkedIn (collectively, the “Social Networks”) are governed by their respective privacy policies and terms. When using Social Networks, you are required to comply with their privacy policies and terms. We recommend you carefully review their privacy policies and terms, as Hootsuite is not responsible for the Social Networks.

1. DATA WE MAY COLLECT

We may collect and process the following data about you:

• Personal data including, for example, your name, gender, telephone number, e-mail address, password, and in certain instances, data about your usage of the Products, data you provide in connection with your usage of the Products, and data collected by tracking technologies as further described in section 4 below that may identify you as an individual or allow online contact with you as an individual.
• Company does not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data with respect to in-app purchases made through the Apps, and our payment processor collects Payment Card data with respect to purchases made through the Websites. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored, and your card’s type, expiration date, billing address, and the last four digits of your card number.
• Device information such as operating system version, device type, and system performance data.
• Data collected via tracking technologies, as fully described in section 5.
• Your social profile information for Social Networks you choose to connect to the Products. For example, your Facebook profile information may include your Facebook username and profile image.
• A specific location such as an address, a city, or a place (for example, a restaurant) if you choose to share this information.
• Your messages, posts, comments, images, advertising, and other material you curate on and upload to the Products; and information that is collected from the Social Networks that you choose to connect to and which is displayed on our Products.
• Content that you may send and receive through Social Networks may contain personal information of third parties. This may include information such as: names, photos, age, gender, geographic location, opinions, preferences, and phone numbers that are provided or posted by social media users.
• Log data, which may include your IP address, the address of the web page you visited before using the Services, your browser type and settings, your device information (such as make, model, and OS), the date and time when you used the Products, information about your browser configuration, language preferences, unique identifiers, and cookies.
• Usage data and analytics, which may include the frequency of login, and the different types of activity undertaken by users such as frequently accessed areas of the Products.
• General location information, such as IP address and the region in which you are located when you are logging in and using the Products, in accordance with the settings on your device.
• Customer support questions, issues, and general feedback that you choose to provide.

2. USES MADE OF THE DATA

We use information held about you in the following ways:

• To provide you with the Products.
• To answer your questions or requests for information or handle your complaints.
• To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other device.
• To provide you with promotional communications, such as email, to the extent that you have provided consent and/or consistent with notice and any opt-out rights to receive such communications under applicable law.
• To carry out our obligations arising from any agreements entered into between you and us.
• To allow you to participate in interactive features of the Products, when you choose to do so.
• To notify you about updates or changes to Product features and content.
• To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state or country).
• To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Website.
• To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent and/or consistent with notice and any opt-out rights for such uses under applicable law.
• To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• To manage your payments and orders.
• 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.
• To attend and manage your requests to us.
• 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 Product users is among the assets transferred.
• For other purposes: 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 Product, products, services, marketing and your experience.

3. CONFIDENTIALITY AND SECURITY

The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at [email protected]. Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law. Company maintains technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, misuse or disclosure. Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.

4. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS

If you sign up to receive promotional materials from us via email and/or push notifications we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at [email protected], we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level. If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply. We will endeavor to comply with these requests as soon as reasonably practicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional email messages from us that are required to provide you with our Products.

5. TRACKING TECHNOLOGIES

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, device identifiers, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by True Voice and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and online services, and better understand your online activity. You can disable cookies used for advertising purposes through our cookie preferences manager. Or, for more information about interest-based ads, including to use ad industry tools to opt out of having your web browsing information used for behavioral advertising purposes, please visit  www.aboutads.info/choices  (if you are in the EU, please visit  www.youronlinechoices.eu/). Your mobile device should also include a feature that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

6. WHERE WE STORE YOUR PERSONAL DATA

All data you provide to us through the Products is stored on our secure servers located in the US. Any payment transactions will be encrypted using SSL technology; all payment data is stored with our payment processor and is never stored on Company’s servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.

Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

7. SINGLE SIGN-ON

You may be able to log-in to our Products using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form. Services like Facebook Connect give you to the option to post data about your activities on our Products or to your profile page to share with others within your network.

8. YOUR DATA RIGHTS

As you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. 

As required under applicable law, the rights afforded to you are: 

• A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof.
• A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Company will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Company may have legal or legitimate grounds for keeping such data.
• A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
• A right to data portability: you have the right to receive the personal data concerning you which you have provided to Company, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Company. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
• A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Company. Company may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received.
• A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Company’s personal data protection practices.
• A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Company instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email [email protected]. You may access your personal data to modify or update at any time via an online account, or by emailing [email protected]. We will respond to your request in a reasonable timeframe in accordance with applicable law.

9. LEGAL BASES OF PERSONAL DATA PROCESSING

In accordance with GDPR, Company provides the following information regarding its Article 6 legal bases for personal data processing: The performance of the contract (the Terms & Conditions) between you and Company for the data processing relating to your use of Company’s Products (including your orders and payments);

Company’s legitimate interest, more specifically:

• Our business interest in providing you with emails and push notifications for timely introductory materials and information about your Company account, our Product features and updates, and offers to upgrade your free account to a subscription account.
• Our financial interest in providing you with promotional offers and/or discounts with respect to paid subscriptions and special offerings, such as the Company Family Plan.
• Our business interest in offering you particularized or adapted content based on your usage of the Products.
• Our business interest in collecting data regarding your general usage activities for the purpose of improving our Company user experience.
• Our business interest in requesting that you partake in Product surveys in order to better understand your needs and expectations.
• Our business interest in providing you with customer service communications regarding your account, questions about our content offerings, or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to all your requests.
• Our business interest in collecting data related to unplanned downtime or errors in the Products.
• Our business interest in complying with our legal obligations, such as maintaining accurate financial records.

10. DISCLOSURE OF YOUR DATA

We may disclose your personal data with and among our subsidiaries and any affiliates.

We may also disclose your personal data to third parties as follows:

• In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfill a request for data from such party. An example of this is the SMS Service.
• In some circumstances, we may disclose the personal data that you have provided to Company to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options.
• In some limited circumstances, our email service provider may receive certain information you share in-app to provide you with personalized email communications.
• If Company’s service providers (like hosting, IT maintenance, market analytics, and payment service providers) require this data to provide services to Company. Company requires each of its service providers to agree to maintain the confidentiality and security of your personal data.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Company or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• With third parties, such as Facebook, in order to serve Company advertisements on such third party platforms, to the extent that you have consented to or have been provided with notice of, and an opportunity to opt-out of, such practices under applicable law.

11. DATA RETENTION

The retention periods applied by Company comply with applicable legislation in effect on the date hereof, namely:

• For data relating to your account: such data will be permanently and irrevocably anonymized in the event that your account is inactive for a period of two (2) years.  Moreover, we will permanently and irrevocably anonymize your account data within thirty (30) days of your written request to do so via email to [email protected].
• For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not Company.
• For data collected based on your consent to receive our marketing communications: we will use such data until you opt out, withdraw consent or applicable law requires that such data is no longer used.
• When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.
• When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.

12. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES

To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing [email protected].

13. LINKS TO THIRD PARTY SITES

The Products may, from time to time, contain links to and from the products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.

14. SOCIAL MEDIA WIDGETS

Our Products include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.

15. USE BY MINORS

You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement of a parent or legal guardian under such person's account.

16. DATA POSTED ON FORUMS

Company users may have the ability to post content to one or more Company forums. All such users may request and obtain removal of such posted content by contacting Company [email protected] and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the Company forum(s).

17. CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by in-Product message, email (sent to the e-mail address specified in your account) or by means of a notice in the Products prior to the change becoming effective. We encourage you to periodically review this page for the latest data on our privacy practices.

20. CONTACT 

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]. In the alternative, you may reach Company customer support at ‭(424) 331-9260‬.

Company’s principal office address is 312 S. Alameda st. Los Angeles, California 90013.

CCPA ADDENDUM

Effective Date: January 1, 2020 

Last Reviewed On: June 30, 2021

This California Consumer Privacy Act (“CCPA”) Addendum for California residents supplements the information contained in the above Privacy Policy and applies solely to all visitors, users and others who reside in the State of California. We adopt this CCPA Addendum to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Addendum.

1. INFORMATION WE MAY COLLECT FROM YOU

Our Products collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, whether collected online or offline (“personal information”). In particular, the Products have collected the following categories of personal information from consumers within the last twelve (12) months:

The specific types of personal information we collect are described more fully in section 1 of the Privacy Policy. Personal information does not include: (1) deidentified or aggregated consumer information; (2) publicly available information from government records; or (3) information excluded from the CCPA’s scope.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete when registering for the Products. Indirectly from you. For example, from observing your actions on our Products.

2. USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for the purposes described in section 9 of the Privacy Policy.

3. SHARING PERSONAL INFORMATION

We may disclose your personal information to third parties for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category 1: Identifiers
• Category 2: Personal Information
• Category 3: Internet activity

Specific examples of such sharing activities can be found in sections 6 and 11 of the Privacy Policy.

We may sell your personal information to third parties.  We do share a limited set of data that is gathered when you visit our Websites, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements, as further detailed in Section 4 of our Privacy Policy. To the extent this online advertising activity is interpreted as included in California’s broad definition of “data sale”, you may use the opt-out tools described below in Section 5 of this CCPA Notice.

In the last twelve (12) months, we’ve disclosed the following categories of personal information to advertising partners as described above:

• Category 1: Identifiers
• Category 2: Personal Information
• Category 3: Internet activity

4. YOUR RIGHTS AND CHOICES

Access to Specific Information and Data Portability Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The categories of personal information we share with third parties.
• The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will permanently and irrevocably anonymize your personal information, unless an exception applies.

We may deny your deletion request if certain CCPA exemptions apply, including but not limited to, if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise your right to access, data portability, or deletion, please follow these steps:

Steps to Request Account Deletion

1. From Within the App:

• Open the TrueVoice app.
• Navigate to the Account Settings section.
• Select the option for Delete Account and follow the prompts to confirm the deletion.

2. By Email:

• Send an email to [email protected] with the subject line "Account Deletion Request."
• In your email, include your full name and the email address associated with your TrueVoice account to help us verify your request.

Once we receive and verify your deletion request, we will process it and notify you when the account has been successfully deleted. Please note that some data may be retained in accordance with legal or security obligations, as outlined above.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 

The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Response Timing and Format

Upon receiving a request for access, portability, or deletion, we will confirm receipt of the request within 10 business days and provide information about our verification process and how we will process the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address associated with the account for account holders, and to the email address provided with the request submission for non-account holders.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily readable and useable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

5. Notice of Right To Opt-Out

Like most companies, we partner with third parties, such as Facebook and Google, to manage our marketing of Company on other platforms, where such advertising is based on your past visits to our Products. These third party partners may use technologies, such as cookies, to gather information about your activities on the Products to deliver such advertising to you when you visit their platforms. 

Accordingly, if you wish to opt-out of our sharing of the limited data that is gathered when you visit our Websites for purposes of targeted digital advertising, as described in this CCPA Notice and our Privacy Policy, you can opt-out by visiting the Company Cookie Policy and clicking “opt-out of marketing / analytics cookies” at the bottom of the page. Doing so will erase all current marketing cookies and disable the placement of future marketing cookies.

We do use cookies so that third parties can serve ads to you about their own products or services.

We may sell or rent your personal information to any third parties for their own advertising or marketing purposes.

6. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. 

Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

7. Changes to our CCPA Addendum

We reserve the right to amend this CCPA Addendum at our discretion and at any time. When we make changes to this CCPA Addendum, we will post the updated notice on the Website and update the effective date. Your continued use of our Products following the posting of changes constitutes your acceptance of such changes.

8. Contact Information

If you have any questions or comments about this CCPA Addendum, the ways in which we collect and use your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Email:  [email protected]
• Phone: ‭(424) 331-9260‬
• Postal Address: 312 S. Alameda st Los Angeles, California 90013