Privacy Policy

WEBSITE, DIGITAL, AND STORE PRIVACY POLICY (U.S. AND CANADA)

Last Updated – May 2024

 

BR Intimates LLC, itself and/or through its service provider PVH Corp. (collectively, “BRI”, “we”, “us”), operates the website located at www.trueandco.com (which, together with our social media pages, online platforms and mobile applications operated under the TRUE & CO brand, is referred to herein as the “Website”). This Privacy Policy describes the information that is collected via our Website and emails and how that information is used. If you have any questions about our Privacy Policy, please contact us at support@trueandco.com.

What You Will Find in This Privacy Policy

  1. Who We Are
  2. What Information And Personal Information We Might Collect About You
  3. How We Use Your Information
  4. How Is Your Information Shared
  5. What Choices Can You Make About Your Data
  6. Notice of Financial Incentive
  7. How Do We Protect Your Data
  8. How Do You Contact Us
  9. Special Notice For Canadian Users
  10. International Users
  11. Your State Privacy Rights

 

  1. Who We Are 

BRI together with its parents, subsidiaries and affiliates (“Affiliates”) are the makers of high-quality intimate apparel under various world-renowned brands.  BRI’s portfolio of licensed marks includes True & Co., Warner’s, and Olga. In some cases, BRI’s shared services and technology infrastructure may result in your personal data being accessed by BRI’s Affiliates for analytics and other operational purposes in support of BRI.

 

  1. What Information And Personal Information We Might Collect About You

 

Information about you may be collected via direct interactions, automated technologies or interactions, or third parties or publicly available sources.

 

Information that you provide

 

In order to handle your purchases, provide customer service, improve our products and services, provide in-person experiences or events, engage with you on social media and online, and send you information about our products, trends and promotions, we may ask you to provide your:

 

  • Identifiers: such as your name, postal address, email address, social media handle, telephone number, or identification materials used to verify eligibility for discounts and other offers;
  • Demographic information: such as your age, date of birth, marital status, profession, interests, preferences, or gender;
  • Transaction information: such as information regarding payments, purchases, purchase history, returns or exchanges; product reviews you provide; login and password information;
    clothing size/fit information; and communications between us;
  • Payment and financial information, including credit card information and gift card information; and
  • User generated content (UGC): such as photos, videos, blog posts, or social media posts, or direct or personal messages sent to us on social media platforms.

 

If you choose not to provide certain information to us, you may not be able to complete a purchase, participate in an experience, or receive other services or information.

 

Information that we automatically collect from you

 

When you visit our Website, engage with our emails, visit our stores, or access our in-store Wi-Fi, we may automatically collect:

 

  • Identifiers: such as device ID, IP address, and online identifiers, such as cookie data;
  • Internet activity information: such as device type; browser types and version; operating systems and platforms; browsing history; search history; interactions with our websites, applications, communications, and advertisements; referring sites; network activities when using our Wi-Fi; and content and pages viewed;
  • Location information: such as time zone and geo-location of your devices and in-store location;
  • Audiovisual information: such as call recordings and CCTV;
  • Inferences: such as your preferences and interests based on your online and in-store activities;
  • Browsing behavior on our websites: such as when and how you visit our website, the amount of time spent viewing our website, the buttons and links you click, videos you watch, and where you scroll on our website, the search terms that you enter in our website, and the form submissions, purchases, and transactions you make through the website;
  • Behavior related to emails such as the buttons and links you click, the date and time an email was opened, whether an email was forwarded, and whether an email led to a sale; and
  • Text or other messages sent or shared through chat or chatbot services.

 

Other information we collect

We may collect information about you from activities related to other  BRI or Affiliate businesses or third parties like web hosting providers, service providers, shipping providers, retail partners, analytics companies, social media platforms, data companies, data brokers, advertising networks, business partners, and marketing and advertising services such as:

 

  • Identifiers: such as updated contact information, social media handles, device identifiers, cookie data or similar online identifiers;
  • Demographic information: such as your age, date of birth, or gender;
  • Internet activity information: such as content or reviews you post on social media or other third-party platforms;
  • Inferences: such as information about your shopping preferences and interests and inferences drawn from all other data collected in order to create a consumer profile;
  • Marketing and communications data, including your preferences in receiving marketing communications from us and third parties and your communication preferences; and
  • Other types of data identified in the lists above.

 

The information that we obtain from social media platforms depends on your account and privacy settings within the platforms and the platforms’ privacy policies.

Some of the information above is collected on our Website through web browser cookies and other technologies (web beacons/gifs, pixels, page tags, script) that receive and store certain types of information whenever you interact with us or third parties that may direct you to our Website. We may use similar technologies to collect information when you use our applications. We use these tools for a variety of reasons, including to analyze and improve our websites and applications, or to remember your preferences and provide more personalized advertising.

 

Sensitive Personal Information

 

Sensitive Personal Information is a subtype of Personal Information consisting of specific information categories.  We may collect or use information that falls within the Sensitive Personal Information categories listed below to infer characteristics about a person:

 

  • Government identifiers, such as your Social Security number, driver’s license, state identification card, or passport;
  • Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password;
  • Precise geolocation, such as your physical location within a small area;
  • Racial or ethnic origin;
  • Religious or philosophical beliefs;
  • Union membership;
  • Mail, email, or text messages contents not directed at us;
  • Genetic data;
  • Unique biometric information used for identification;
  • Health information;
  • Sex life or sexual orientation information.

 

Third party automated information collection and Interest-Based Advertising

 

BRI uses third party advertising companies to display ads tailored to you based on how you browse and shop online, a practice commonly referred to as “interest-based” or “behavioral” advertising. We allow these third parties to collect certain information when you visit our Website or use our applications, including non-personally identifiable information (browser type, subject of advertisements clicked on, session IDs) and personal information (such as IP address).These third parties typically use cookies or tracking technologies to collect this information on websites and applications owned by us or third parties. BRI endeavors to provide you with choices regarding the personal information you provide us. We do not control third parties’ collection or use of your information to serve interest-based advertising; however, these parties may provide you with ways to choose not to have your information collected or used in this way.  You can opt out of receiving targeted ads from members of the Networking Advertising Initiative.  To learn more about interest-based/behavioral advertising visit the Network Advertising Initiative Website or the Digital Advertising Alliance Website.

 

  1. How We Use Your Information


We use the information we collect for a variety of purposes, including:

 

  • To process your transactions and provide you with the products and services you request
  • To provide, maintain, protect, develop, and improve our websites, applications and services
  • To improve your experience on our websites and applications, and in our stores
  • For customer service, including to respond to your inquiries and requests
  • To communicate with you about our and third-party products and services, in accordance with applicable laws and with your consent where required
  • To analyze and learn about consumer trends and interests
  • To learn about the devices you use to access our websites, applications and other online services
  • To personalize the content you see on our websites and applications
  • To administer contests, sweepstakes, surveys and other promotions
  • To maintain your reward or loyalty program memberships
  • To provide you with communications, recommendations, ads, and other information of interest to you, including via text message and email and interest-based advertising based on your online activities on our websites, applications and other online services
  • To tailor your experience on our Website by showing you content that we think you might be interested in
  • To maintain our community programs and focus groups
  • To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent)
  • To verify eligibility for discounts and other offers
  • To prevent and detect fraud, criminal activity and violations of our terms of use
  • To protect our rights, as well as yours and others and
  • To comply with our legal obligations
  • To serve our own internal business purposes, such as maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, and performing analytics
  • To conduct research and development and product improvement

 

We may also use information for purposes disclosed to you at the point of collection, as authorized by you, or as otherwise permitted or required by law.

 

  1. How Your Information Is Shared 

BRI utilizes shared services and technology infrastructure of its Affiliates that may result in your data being shared with other branded-businesses. This data may be used for data analytics, customer service and other operational purposes.   We may also disclose your personal information to affiliate partners with whom we may jointly provide services or sell product lines.

 

We may share your information with our third party service providers that work on our behalf, including by providing or fulfilling the products and services you request, authorizing and processing your payments, performing fraud protection and credit risk reduction, product customization, marketing and promotional material distribution, website and application evaluation, operation, hosting or maintenance, data analysis and analytics, website improvements, and, where applicable, data cleansing, marketing, promotions and other services performed on our behalf or on behalf of our parent or affiliates.  Third party service providers have their own privacy policies in respect to the information we are required to provide them for your purchase-related transactions.  For these providers, we recommend that you read their privacy policies so you can understand the manner in which your information will be handled by these providers.

 

We may also disclose your personal information to other parties where you have provided your consent.

 

In addition, we may share or transfer information about you to unrelated third parties:

 

  • When you engage in activities that are sponsored by third parties (e.g., cobranded offerings);
  • As required by law or a legal process, including investigating a potential crime;
  • When we believe it is necessary to protect the rights, property, or safety of BRI, its Affiliates or other persons.

 

We disclose the following categories of information for our business purposes:

  • Identifiers: disclosed to service providers and contractors; payment processors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
  • Demographic information: disclosed to service providers and contractors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
  • Transaction information: disclosed to service providers and contractors; payment processors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
  • Payment information: disclosed to service providers and contractors; payment processors; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; and retail partners.
  • Internet activity information: disclosed to service providers and contractors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
  • User generated content (UGC): disclosed to service providers and contractors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
  • Location information: disclosed to service providers and contractors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing
  • Audiovisual information: disclosed to service providers and contractors;
    affiliates and subsidiaries; law enforcement, public and
    government authorities, and others; and advisors and
  • Inferences: disclosed to service providers and contractors; advertising and
    marketing partners; affiliates and subsidiaries; law
    enforcement, public and government authorities, and others;
    advisors and consultants; retail partners; and joint marketing

 

We do not share your personal information with third parties in exchange for money. We do share certain information with advertising and marketing partners in exchange for insights, digital advertising, and other valuable services. Such sharing may be considered a “Sale,” “Sharing,” or “Targeted Advertising” under certain laws. We disclose the following information in such circumstances:

 

  • Identifiers;
  • Demographic information
  • Internet activity information;
  • Location information;
  • Inferences; and
  • Transaction information.

 

We may also share your data in the event of an actual or potential sale, merger, acquisition or transfer of our business or assets or in the event of a reorganization, spin-off, dissolution or liquidation.

 

We may use or share information that does not reasonably identify you with any third party and for any purpose.  We may disclose aggregated information about our users without restriction.

 

We retain the information we collect for as long as we have a legitimate business purpose to retain the data, as long as permitted by law, or until you request we delete the data if such a right exists in your jurisdiction.

 

  1. What Choices Can You Make About Your Data

 

Unsubscribe/Opt-Out

 

If you no longer wish to receive promotional emails or direct mail from BRI, you can contact email support@trueandco.com or call 1-888-698-8783. A request to opt-out may take at least three to five business days to take effect. If you have a Rewards Account with us, you may still receive communications related to your account, loyalty points or special offers (such as birthday discounts). You may also opt out of promotional emails by clicking the unsubscribe link in such emails.  An opt-out request will not stop transactional emails related to your purchases.

 

If you no longer wish to receive the text messages that you had consented to previously, you can text “STOP” after receiving a message or otherwise follow the directions stated therein to opt-out.

 

“Do Not Track” Signals

 

“Do Not Track” is a privacy preference that Internet users can set in their web browsers. When a user turns on the Do Not Track option, the browser sends a message to websites requesting them not to track the user. Like many websites, our Website does not at this time react to such requests sent via a Do Not Track signal.

 

Accessing, Correcting or Deleting your Data

 

If you would like to receive a copy of the personal information that BRI has collected from or about you, you can email support@trueandco.com or call 1-888-698-8783. You will be asked to verify your identity via the process outlined on the form, including providing your name and email address.

 

If you would like BRI to correct or delete your data, you can email support@trueandco.com or call 1-888-698-8783. You will be asked to verify your identity via the process outlined on the form, including providing your name and email address.

 

You may continue to receive advertisements for BRI regarding our products. Those advertisements may be delivered to you based on your future interactions with us or based on the determination of our business or advertising partners that you are a member of the desired audience for a campaign.

If you wish to exercise one of the above rights on behalf of someone else, you may use the channels listed above.

 

Please note that if you create an account separately with a third party found on our site, such as to redeem a first responder discount, you will need to submit an access, deletion, or correction request directly with that third party.

 

BRI will respond to all such requests in the manner required by applicable law.

 

State consumer privacy laws may provide residents of certain states with additional rights regarding our use of personal information.  Please refer to the section titled “Your State Privacy Rights” below for further information.

 

  1. Notice of Financial Incentive 

From time to time, we may offer free shipping, order discounts, or other benefits to consumers who provide us their email address, phone number, and/or zip codes when they sign up to receive our marketing communications. Consumers may opt in by entering their information where prompted on our website. Consumers may opt out at any time by following the unsubscribe instructions in our marketing communications. The value of the consumer information that we collect is reasonably related to the expenses of providing the discounts and other benefits (which may vary depending upon the specific benefits offered or the value of the consumer relationship in terms of purchases.

 

  1. How Do We Protect Your Data 

Security Methods

 

We use commercially reasonable technical, administrative and physical security measures to protect the information that we collect or receive, in addition to contractual safeguards.   To the extent that we collect your credit card information, we do not reveal the entirety of your credit card numbers when confirming an order (but do of course transmit the entire credit card number to the appropriate credit card company during order processing).  It is important for you to protect against unauthorized access to your password and to your computer.  Be sure to sign off when finished using a shared computer.

 

Children’s Personal Information


BRI  is concerned about the safety of children when they use the Internet. Our websites and applications are not directed to children under the age of 18. To the extent that we sell any children’s products, they are intended for purchase by adults.  You must be age 18 or older to use the Website.  By submitting personal information to us, placing an order on the site, and/or participating in one of our online promotions, you are representing to us that you are 18 years of age or older.  If a parent or guardian discovers that a child has provided us with information, we ask that you contact us at support@trueandco.com.

 

  1. How Do You Contact Us


If you have any questions about this Privacy Policy or our data practices, please contact support@trueandco.com.

 

  1. Special Notice For Canadian Users


We may store or process your personal information on servers in jurisdictions outside of Canada, including in the United States of America. While your personal information is in a jurisdiction it may be accessed by the courts, law enforcement and national security authorities of that jurisdiction, or otherwise, in accordance with the laws applicable in that jurisdiction.

 

  1. International Users

 

The Website is intended for users in the United States. If you choose to provide us with your information, you consent to the transfer, storage, and processing of that information on our servers located in the United States and around the world. The information collected may be subject to international and U.S. state and federal law. If you are accessing the Website from outside the U.S., please be advised that you may be transferring your personal information to us in the United States where data protection and privacy laws may be different than the laws of your country. By using the Website, you consent to the transfer and use of your personal information in accordance with this privacy policy.

 

  1. Your State Privacy Rights

 

State consumer privacy laws may provide residents of certain states with additional rights regarding use of their personal information.

 

The additional rights and requirements below may not apply when they restrict our ability to (i) comply with a court order or regulator with competent authority, (ii) comply with federal, state or local laws, (iii) cooperate with law enforcement, (iv) exercise of our legal claims, or (v) collect or use of de-identified information.

 

  1. California Residents

 

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), and other applicable California state privacy laws. The CCPA and CPRA give you certain rights with respect to the processing of your Personal Information.  These rights include:

 

Right to Know Request:

 

Under the CCPA, California residents have a right to request information about our collection, use, and disclosure of your Personal Information over the prior 12 months, and ask that we provide you with the following information:

 

  • Categories of and specific pieces of Personal Information we have collected about you.
  • Categories of sources from which we collect Personal Information.
  • Purposes for collecting, using, or selling (if applicable) Personal Information.
  • Categories of third parties with which we share Personal Information.
  • Categories of Personal Information disclosed about you for a business purpose.
  • If applicable, categories of Personal Information sold about you and the categories of third parties to which the Personal Information was sold, by category or categories of Personal Information for each third party to which the Personal Information was sold.

 

To make a verifiable request for information about the Personal Information we have collected about you, please email us at support@trueandco.com.

 

Right to Delete Request:

 

Under the CCPA, California residents also have a right to request that we delete Personal Information, subject to certain exceptions. You may exercise your right to delete by emailing us at  support@trueandco.com. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your Personal Information accordingly. Your request to delete your Personal Information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

 

Right to Opt-Out:

 

Under the CCPA and CPRA, California residents have the right to opt-out of the sharing or disclosing of your Personal Information to a third party in any way, which include the right to opt-out of targeted advertising.  To make a verifiable request to opt-out of the sharing or disclosing of Personal Information we have collected from you, please email us at  support@trueandco.com.

 

Right to Limit the Use of Sensitive Personal Information:

 

California residents have the right under certain circumstances to limit the use and disclosure of Sensitive Personal Information used for the purpose of inferring characteristics about a person.  To make a verifiable request to exercise this right, please email us at  support@trueandco.com.

 

Right to Correct:

 

Under the CPRA, California residents have the right under certain circumstances to limit the use and disclosure of Sensitive Personal Information used for the purpose of inferring characteristics about a person.  To make a verifiable request to exercise this right, please email us at support@trueandco.com or call us toll-free at  1-866-513-0513.

 

California Privacy Rights under the “Shine the Light” Law:

 

Pursuant to Section 1798.83 of the California Civil Code (a separate law from the CCPA and CPRA), residents of California have the right to ask us for a notice describing the categories of Personal Information we have shared with third parties or among our affiliated companies, for their direct marketing purposes, during the preceding calendar year. If you are a California resident and would like a copy of this notice, please send an email message to support@trueandco.com with “Request for California Privacy Information” in the subject line and body of your message. Please allow 30 days for a response.

 

Supplemental CCPA Disclosures:


We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and describe, for each category of personal information collected, the business or commercial purposes for which the information was collected. Each of the categories of personal information listed in the table are collected directly from consumers. Each of the categories of personal information in the table may also be shared with the following categories of third parties: (i) our Service providers, contractors, and business partners (ii) Government entities as required by applicable law (iii) other recipients at your discretion or with your consent (iv) Third parties in the event of a proposed or actual business transaction involving all or any portion of our business. We disclose that information for the purposes described in this Privacy Policy.

Additional information about sales of information can be found below the table.

 

Category of personal information: We collected such personal information for the following purposes:
Identifiers: such as your name, postal address, email address, social media handle, telephone number, or Identification materials

●     To process your transactions and provide you with the products and services you request;

●     To provide, maintain, protect, develop, and improve our websites, applications and services;

●     To improve your experience on our websites and applications, and in our stores;

●     For customer service, including to respond to your inquiries and requests;

●     To communicate with you about our and third-party products and services, in accordance with applicable laws and with your consent where required;

●     To analyze and learn about consumer trends and interests;

●     To learn about the devices you use to access our websites, applications and other online services

●     To personalize the content you see on our websites and applications;

●     To administer contests, sweepstakes, surveys and other promotions;

●     To maintain your reward or loyalty program memberships;

●     To provide you with communications, recommendations, ads, and other information of interest to you, including via text message and email and interest-based advertising based on your online activities on our websites, applications and other online services;

●     To maintain our community programs and focus groups;

●     To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent);

●     To verify eligibility for discounts and other offers;

●     To prevent and detect fraud, criminal activity and violations of our terms of use;

●     To protect our rights, as well as yours and others; and

●     To comply with our legal obligations.

We may use this information for any of the purposes described in this privacy policy.

Categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code, including name, signature, address, telephone number, passport number, and credit card number, debit card number, or any other financial information. We use this information to process payment, fulfill your order, or process a return.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We use this information to fulfill your order, manage consumers’ online account with us, personalize and optimize consumers’ shopping experience with us (for example, letting you know when a favorite product is back in stock, recording certain information from past purchases which can be used in future purchases such as preferred address and favorite store locations), provide consumers with customer care, and customize a product per a consumer’s specific request.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

●     To process your transactions and provide you with the products and services you request;

●     To provide, maintain, protect, develop, and improve our websites, applications and services;

●     To improve your experience on our websites and applications, and in our stores;

●     For customer service, including to respond to your inquiries and requests;

●     To communicate with you about our and third-party products and services, in accordance with applicable laws and with your consent where required;

●     To analyze and learn about consumer trends and interests;

●     To learn about the devices you use to access our websites, applications and other online services

●     To personalize the content you see on our websites and applications;

●     To administer contests, sweepstakes, surveys and other promotions;

●     To maintain your reward or loyalty program memberships;

●     To provide you with communications, recommendations, ads, and other information of interest to you, including via text message and email and interest-based advertising based on your online activities on our websites, applications and other online services;

●     To maintain our community programs and focus groups;

●     To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent);

●     To verify eligibility for discounts and other offers;

●     To prevent and detect fraud, criminal activity and violations of our terms of use;

●     To protect our rights, as well as yours and others; and

●     To comply with our legal obligations.

We may use this information for any of the purposes described in this privacy policy.

User Generated Content (UGC).

●     To process your transactions and provide you with the products and services you request;

●     To provide, maintain, protect, develop, and improve our websites, applications and services;

●     To improve your experience on our websites and applications, and in our stores;

●     For customer service, including to respond to your inquiries and requests;

●     To communicate with you about our and third-party products and services, in accordance with applicable laws and with your consent where required;

●     To analyze and learn about consumer trends and interests;

●     To learn about the devices you use to access our websites, applications and other online services

●     To personalize the content you see on our websites and applications;

●     To administer contests, sweepstakes, surveys and other promotions;

●     To maintain your reward or loyalty program memberships;

●     To provide you with communications, recommendations, ads, and other information of interest to you, including via text message and email and interest-based advertising based on your online activities on our websites, applications and other online services;

●     To maintain our community programs and focus groups;

●     To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent);

●     To verify eligibility for discounts and other offers;

●     To prevent and detect fraud, criminal activity and violations of our terms of use;

●     To protect our rights, as well as yours and others; and

●     To comply with our legal obligations.

We may use this information for any of the purposes described in this privacy policy.

Geolocation data. We may use this information to enable consumers to view nearby stores.
Audio, electronic, visual, or similar information. We use audio, visual or similar information that you may voluntarily provide in connection with customer care inquiries or when you engage with our social media initiatives for purposes of providing and improving customer service, training, resolving complaints or inquiries, legal compliance, and exercising or defending legal claims.
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics and attitudes. We use such information to personalize and optimize consumers’ shopping experience with us, enable consumers to use our “wish list” or “add to closet” features online, tailor our marketing efforts, and develop and improve our products and services.
Sensitive personal information, including account credentials and precise geolocation. We use account credentials for the security purposes and to process your transactions and provide you with the products and services you request.

 

We retain personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we retain your personal information for a period of time that enables us to:

 

  • Maintain business records for analysis and/or audit purposes.
  • Comply with record retention requirements under the law or other relevant legal or regulatory requirements.
  • Defend or bring any existing or potential legal claims.
  • Deal with any complaints regarding the services.
  • Preserve historical records of transactions.

 

During the past 12 months, we have shared Identifiers; Demographic information; Internet activity information; Location information; Inferences; and Transaction information. certain categories of personal information about California residents with third parties and business partners in a manner that may constitute a “Sale” or “Sharing” under the CCPA, as described below:

 

  • Online Promotions and Advertising: We work with one or more third parties to: (i) administer and analyze effectiveness of advertising or promotional campaigns. These third parties may place cookies on individuals’ computers to receive information about traffic to our site, browsing and purchasing activity on our online services, and (ii) From time to time third parties may help us to provide a more tailored user experience. These third parties may collect information about individuals’ internet or other similar network activity and browsing patterns, IP address, page interaction (such as scrolling, clicks and mouseovers), and information obtained via cookies with these third parties (such as the site visited before or after). To opt out of these disclosures, please click: Do Not Sell or Share My Personal Information. We also recognize the “Global Privacy Control” (GPC) to allow you to opt out of the sale of your personal information and the sharing of your personal information for targeted advertising on our websites. The GPC is a proposed specification designed to allow Internet users to notify businesses of their privacy preferences, such as whether or not they want their personal information to be sold or shared. To learn more about the GPC and how you can use it to opt out of the sale or sharing of your personal information you can visit their website here. If you visit our website with a browser transmitting GPC, we will not share for targeted advertising or sell your personal information associated with your visit.
  • We do not use or disclose information deemed sensitive under applicable law for purposes other than permitted under such law. We do not knowingly sell or share the personal information of individuals under 16.

 

  1. Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia Residents

 

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

 

  • Confirm whether we process their Personal Information.
  • Access and delete certain Personal Information.
  • Correct inaccuracies in their Personal Information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
  • Data portability.
  • Opt-out of personal data processing for: targeted advertising (excluding Iowa); sales; or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
  • Either limit (opt-out of) or require consent to process Sensitive Personal Information.

 

The exact scope of these rights may vary by state. To exercise any of these applicable rights, please email support@trueandco.com.

 

  1. Household Requests

 

We do not knowingly collect household data. If all the members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

 

  1. Requests, Generally

 

You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA or other applicable state law.

 

  1. Requests made through Agents

 

You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

 

  1. Disclosures of Personal Information for a Business Purpose

 

In the last 12 months, we may have disclosed certain personal information (e.g., username; display name; email address; billing information and history; business information, if applicable) to third party recipients for one or more business purposes.

 

  1. Appeals

 

Please contact us at support@trueandco.com for information on how to appeal a decision regarding a consumer rights request.

 

* * * * * *