PRIVACY POLICY

Last updated May 25, 2023

We at True Digital Group, LLC and our affiliates and subsidiaries (“True Digital,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of True Digital in connection with our website located at www.truedigitalgroup.com (the “Website”), our True Digital Platform (“Platform”) that is made available to you through our Website, and when you otherwise interact with us in any way.

Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to the Website who view only publicly-available content (“Visitors”), customers who have signed up to access and use the Platform and services offered through the Platform (the “Customers”), and Customer’s employees and independent contractors authorized by Customer to access and use the Platform (“Authorized Users”).

By visiting our Website, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Website Terms of Use.

By accessing and/or using the Platform, each Customer and Authorized User is agreeing to the terms of this Privacy Policy and the accompanying Platform Terms of Use.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Website Terms of Use or the Platform Terms of Use, as the context requires.

The Information We Collect and/or Receive

In the course of operating the Website and the Platform, and/or interacting with you, we will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1. Contact Information.

When you contact us through the Website, email or by mail, when you call us, when you subscribe to receive more information about our products and services, when you schedule a demo of our Platform, or when you sign up to use the Platform, you will be asked to provide certain information, including but not limited to, your name, email address, phone number, company name, job title, and any other information you are contacting us about (collectively, the “Contact Information”). The Contact Information is used to provide the requested service or information and to contact you for purposes of direct marketing of our current and future services.

2. Account Information.

In order to access and use our Platform, you will have to create an account on our Platform. In connection with creating an account on our Platform, you will be asked to provide your email address and create a password (collectively, “Account Information”). We use the Account Information to process the creation of your account, including to verify your identity, and to manage your account.

3. Customer-Provided Information

In using the Platform, you will provide us Customer-Provided Information. We will use Customer-Provided Information (other than any personal information contained therein) in accordance with our Platform Terms of Use. Any personal information contained in the Customer-Provided Information will be used in accordance with this Privacy Policy.

4. Other Information.

In addition to the Contact Information, Account Information, and Customer-Provided Information, we may collect additional information (“Other Information”). Such Other Information may include:

a)

From Your Activity. Information that we automatically collect when you visit the Website and the Platform, such as your IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website and the Platform you visit, and similar information concerning your use of the Website and the Platform.

b)

From Cookies. We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We use session cookies, which expire once you close your web browser, to help us collect Other Information and to enhance your experience using the Website and the Platform. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website and the Platform may not function properly.

c)

Third-Party Analytics. We may use one or more third–party analytics services (such as Google Analytics) to evaluate your use of the Website and the Platform, compile reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Website you visit, number of links clicked while on the Website and the Platform, search terms and other similar usage data), and analyze performance metrics. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing the Website and/or the Platform, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website and the Platform.

For Google Analytics, please visit: https://www.google.com/analytics 
For DataDog, please visit: https://www.datadoghq.com/legal/privacy/
For HubSpot, please visit: https://legal.hubspot.com/privacy-policy

How We Use and Share the Information   

You authorize us to use your Contact Information, Account Information, Other Information, and personal information contained in the Customer-Provided Information (collectively, the “Information”) to provide and improve our Website and Platform; to solicit your feedback; and to inform you about our company, products, and services.

You also authorize us to use and/or share your Information as described below.

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Agents, Providers and Related Third Parties. We may engage other companies and individuals to perform certain business-related functions on our behalf. Examples may include providing technical assistance, order fulfillment, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law. We may also share your Information with any of our parent companies, subsidiaries, or other companies under common control with us.

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Aggregated Information. In an ongoing effort to better understand our users and our Website and Platform, we might analyze your Information in aggregate form in order to operate, maintain, manage, and improve the Website and Platform. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our Website and Platform to current and prospective business partners and to other third parties for other lawful purposes.

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Business Transfers. As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, your Information may be part of the transferred assets.

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Legal Requirements. To the extent permitted by law, we may also disclose your Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of True Digital or others.

We will take reasonable measures to require that any party receiving any of your personal information from us undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information.

Accessing and Modifying Information and Communication Preferences

If you have provided us any personal information, you may access, remove, review, and/or make changes to the same by contacting us at info@truedigitalgroup.com. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “Unsubscribe” link located on the bottom of any True Digital marketing email. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

How We Protect the Information

We take commercially reasonable steps to protect your Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We shall (i) provide technical and organizational safeguards against accidental, unlawful or unauthorized access to or use, destruction, loss, alteration, disclosure, transfer, commingling or processing of confidential information, consistent with the industry practice and standards, (ii) use commercially reasonable measures designed to secure and defend locations, equipment, systems and other materials and facilities employed in connection with the Platform against “hackers” and others who may seek, without authorization, to disrupt, damage, modify, access or otherwise use our systems or the information found therein and (iii) implement controls intended to prevent your confidential information from being commingled with or contaminated by the data of other customers by using logically separated unique identifiers, separate database instances, or other technical safeguards.

Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email.

In the event of any unauthorized use, loss, or disclosure of your nonpublic personal information (“Security Breach”) we will report such Security Breach to you notify you as promptly as possible and in no event more than 72 hours of our discovery, or earlier, if required by law or regulation. We will investigate any such Security Breach and will take commercially reasonable actions to mitigate the problem and, unless prevented by applicable law, disclose details obtained through such investigation to you. 

External Sites

The Website and Platform may contain links to external third-party websites (“External Sites”). True Digital has no control over the privacy practices or the content of these External Sites. As such, we are not responsible for the content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any External Sites.

Children

We do not knowingly collect personal information from children under the age of 18 through the Website and the Platform. If you are under 18, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through the Website and the Platform without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Important Notice to Non-U.S. Residents

The Website, the Platform and their servers are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use any of our Website and/or Platform, you consent to any transfer and processing of your personal information in accordance with this Privacy Policy and you do so at your own risk.

DO NOT TRACK

We currently do not change our tracking practices in response to “do not track” settings in your browser. We may have our third-party partners, including web analytics companies, collect information about your online activities over time and across the Website and the Platform. These third parties may not change their tracking practices in response to DNT settings in your browser.

Notice to California Residents

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via email at info@truedigitalgroup.com.

Notice to Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by contacting us at info@truedigitalgroup.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and any such changes will be posted on the Website and the Platform. In the event of any material change to this Privacy Policy, will notify you in advance electronically via e-mail or through the True Digital Platform. You may terminate your account on the Platform if you do not agree to the material change. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your information is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

Contact Us

If you have any questions about this Privacy Policy or to report a privacy issue, please contact us at: legal@truedigitalgroup.com