Privacy Policy

This Privacy Policy applies to information collected by TruWill, Inc. (“TruWill,” “we,” “our,” or “us) in connection with the products and services that TruWill offers. This includes information collected online through our website, branded pages on third party and partner platforms, mobile applications, and through other channels of communications including through mobile messaging services (collectively, the “Services”). We encourage you to read this Privacy Policy carefully when using our Services, or otherwise transacting business with us. By using our Services on any platform, you are accepting the practices described in this Privacy Policy.

This Privacy Policy explains what information may be collected through the Services, how such information may be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and business activities. By using the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, do not use the Services.

This Privacy Policy is hereby incorporated into and forms part of our Terms of Service.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

1. INFORMATION WE COLLECT

As used in this Privacy Policy, “Personal Information” means the following:

• your name;
• where you live (your full address);
• your email address;
• financial information, such as credit card and bank information;
• geolocation data; and
• other data and details you provide as part of your use of the products and services provided by us.

As used in this Privacy Policy, “Non-personal Information” means all other data, including but not limited to:

• your IP address;
• your phone or mobile-device ID number; and
• any searches and details regarding the properties you are listing or interested in.

When we use the word “information” in this Privacy Policy, we mean all types of information, including Personal Information and Non-personal Information. 

Information You Provide

We may collect and store Personal Information and Non-personal Information that you provide in order to use our Services. For example, we may ask for information when you:

• register to create an account, update your information, or sign up for a membership or subscription;
• use certain features;
• access, upload or download content;
• purchase partner products or services; or
• fill out a survey, request customer support, or otherwise communicate with us.

We (or our service providers or business partners) may collect and store this information.

Information We Receive from Others 

In addition to the information you provide us directly, we may receive information about you from others.

• Information from email providers. You may be able to use your email account login (such as Gmail) to create and log into your TruWill account. This allows you to share some information from your email account with us.
• Information from other partners. We may receive information about you from our partners, for instance when TruWill accounts can be created through a partner’s websites (in which case they pass along registration information to us) or where TruWill ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

Information Collected During Your Use of Our Services 

When you use our Services, we collect information about which features you use, how you use them and the devices you use to access our Services.

• Usage information. We collect information about your activity on our Services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on); what properties you look at or otherwise show interest in; and how you interact with other users (e.g., buyers or sellers of contracts that you connect and interact with, time and date of your exchanges, number of messages you send and receive).
• Device information. We collect information from and about the device(s) you use to access our Services, including:
  • hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
  • information on your wireless and mobile network connection, like your service provider and signal strength; and
  • information on device sensors such as accelerometers, gyroscopes and compasses.
• Other information. When we are legally permitted to do so, we may collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the Services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.

Similarly, we may collect your photos and videos from you (for instance, if you want to publish a photo, video or streaming on the Services). We may obtain information directly from you or when you give us permission to obtain information from a third party like Facebook. For more information on how we may use content you provide to us, see our Terms of Service.

4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). We may use these technologies for many purposes, such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, etc.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked.  If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many businesses do not currently respond to DNT signals. We do not respond to DNT signals.

5. HOW WE USE INFORMATION

We may use your information to operate our business to the extent allowed by law, including for the following purposes.

• To administer your account and provide our Services. For example, to:
  • create and manage your account;
  • provide you with customer support and respond to your requests;
  • complete your transactions and fulfill your orders; and
  • communicate with you about our Services, including order management and billing.
• To help you connect with others. For example:
  • to analyze your profile and that of other users to recommend connections between you and service providers or users we believe you may be interested in connecting with; and
  • show users’ profiles and contact information to one another.
• To ensure a consistent experience across your devices. We may link the various devices you use so that you can enjoy a consistent experience of our Services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.
• To serve you relevant offers and ads. For example, to:
  • administer sweepstakes, contests, discounts or other offers;
  • develop, display and track content and advertising tailored to your interests on our Services and other sites; and
  • communicate with you by email, phone, social media or mobile device about products or Services that we think may interest you.
• To improve our Services and develop new ones. For example, to:
  • administer focus groups and surveys;
  • conduct research and analysis of users’ behavior to improve our Services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior); and
  • develop new features and Services.
• To prevent, detect and fight fraud or other illegal or unauthorized activities. For example, to:
  • address ongoing or alleged misbehavior on and off-platform;
  • perform data analysis to better understand and design countermeasures against these activities; and
  • retain data related to fraudulent activities to prevent against recurrences.
• To ensure legal compliance. For example, to:
  • comply with legal requirements;
  • assist law enforcement; and
  • enforce or exercise our rights, for example our Terms.

6. HOW WE SHARE INFORMATION

We may share your information with others, as follows.

• With other users. You share information with other users when you voluntarily disclose information on the Services. Please be careful with your information and make sure that the content you share is content that you are comfortable with being publicly viewable since neither you nor we can control what others do with your information once you share it. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

• With our service providers and partners. We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We may also share information with partners who distribute and assist us in advertising our Services. In all cases, we will not share Personal Information unless the third party has committed to keep it confidential and only use it for the purposes for which we have retained the service provider or partner. We may also share Personal Information in hashed, non-human readable form to advertising partners.

• For corporate transactions. We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

• When required by law. We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

• To enforce legal rights. We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

• With your consent or at your request. We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

In addition to any of the circumstances mentioned above, we may also share Non-personal Information, as well as Personal Information in hashed, non-human readable form, with third parties to the extent allowed by law. We may also monetize and share this information with other TruWill companies, affiliates, and other third parties (notably advertisers) to develop and deliver targeted advertising on our Services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional Non-personal Information or Personal Information in hashed, non-human readable form collected from other sources.

8. YOUR RIGHTS

We do not participate in the Digital Advertising Alliance, and we are not a member of NAI. However, to opt-out of such collection and use for online behavioral advertising by the Digital Advertising Alliance (DAA) participating companies in the United States, please visit: http://www.aboutads.info/choices and http://www.aboutads.info/appchoices. To opt-out from the use of information about your online activities for online behavioral advertising by NAI member companies, visit: http://www.networkadvertising.org/choices. Please note that even if you opt-out, you may still receive advertisements from us that are not customized based on your usage Information. To learn how to manage privacy and storage settings for Flash cookies, please visit:

https://www.adobe.com/support/documentation/en/flashplayer/help/settings_manager.html

Opt-out Information and Procedures

The following tools and information are provided to assist you in understanding how to manage your information.

• Access / Update tools in the Services. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the Services.
• Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location Services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain Services may lose full functionality.

• Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your Personal Information by submitting a request to inforequest@truwill.co.

• Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer any of the requests listed above. We may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide the Services to you anymore.

9. RESIDENTS OF CALIFORNIA

If you are a California resident, you can request a notice disclosing the categories of Personal Information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to inforequest@truwill.co. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

10. HOW WE PROTECT YOUR INFORMATION

Although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately at infosecurity@truwill.co.

11. HOW LONG WE RETAIN YOUR INFORMATION

We keep your information to the extent permitted by applicable law, even after you terminate your account with us.

12. CHILDREN’S PRIVACY

We do not attempt to, nor do we knowingly collect any personal information from, children under the age of thirteen. If we learn that a child under the age of thirteen has provided personally identifiable information through the Services, we will use reasonable efforts to remove such information from our files.

13. PRIVACY POLICY CHANGES

This policy may change over time. It is your responsibility to visit this page regularly and stay informed of any changes.

14. HOW TO CONTACT US

If you have questions about this Privacy Policy, here’s how you can reach us:

Online: www.TruWill.co/contact-us

By mail:

Privacy Officer
TruWill, Inc.
62 E 800 N STE 207
Spanish Fork, UT 84660