This privacy policy (“Privacy Policy”) describes the information collected by TrueBoo, Inc. (“we,” “us,” or “our”), how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. By using our website, located at http://trueboo.app (“Website”), our mobile apps, and/or other services we provide (collectively, “TrueBoo”), you agree to the practices set forth in this Privacy Policy.
Information collected automatically:
When you use TrueBoo, we automatically collect and store certain information about your computer or mobile device and your activities. We may use this and other information described in this Privacy Policy to infer information, such as your interests.
This information includes:
– Mobile Device ID. Your mobile device’s unique ID number (e.g., IMEI, AD ID).
– Geolocation. With your permission, your mobile device’s geographic location (GPS) when you first register for TrueBoo through our mobile app or when you enable location services within the app.
– Device Information/Specifications. Technical information about your computer or mobile device (e.g., type of device, web browser or operating system, IP address) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information.
– Usage Information. How long and in what manner you use TrueBoo, which services and features you use and any content that you generate through and post on TrueBoo. This includes browsing and search history (including profiles you have viewed). We link your subscriber information with your activity on TrueBoo across all your devices using your email, phone number or similar information.
– Cookies: We and our service providers and business partners use “cookies” to keep track of some types of information while you are visiting TrueBoo or using our services. “Cookies” are very small files placed on your computer, and they allow us to count the number of visitors to our Website and distinguish repeat visitors from new visitors. They also allow us and third parties we work with to save user preferences, track user trends, and advertise to you. We use both session and persistent cookies on our Website; session cookies expire at the end of a particular visit to our Website, while persistent cookies (also called stored cookies) remain active until you disable them through your browser settings, or until a pre-set expiration date. We rely on cookies for the proper operation of TrueBoo; therefore if your browser is set to reject all cookies, TrueBoo may not function properly. Without this information, we will not be able to provide you with all of the requested services, and any differences in services are related to your information.
– Web Beacons: “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize TrueBoo for our users, collect a limited set of information about our visitors, and advertise to our users. We may also use web beacons in email communications in order to understand the behavior of our customers, such as whether an email has been opened or acted upon.
Information we obtain from other sources:
Facebook. In order to register with certain TrueBoo apps, you may be asked to sign in using your Facebook login. If you do so, you are authorizing us to access and process certain Facebook account information, including information about you and your Facebook friends who might be common Facebook friends with other TrueBoo users. By allowing us to access your Facebook account, you understand that we may obtain and process certain information from your Facebook account, including your name, email address, birthday, work history, education history, current city, pictures stored on Facebook, and the names, profile pictures, relationship status, and information about your Facebook friends. We only obtain information from your Facebook account that you specifically authorize and grant us permission to obtain.
Third-Party Services : We may receive the information described in this Privacy Policy from third party services, such as analytics providers and advertising partners.
Other users. Users of TrueBoo may provide us with information about you, including through customer support inquiries.
Information you choose to provide:
Information You Provide to Us. When you register with certain TrueBoo apps, you must provide certain information, including your username and password, email address, zip code, birthday, gender, and gender preference. We will also ask you to upload photos for your profile and may collect any information (including location metadata and inferred characterizations or data) contained in these files. You may provide additional information about yourself (such as your school, occupation, current city, etc.) in order to build your TrueBoo profile. You may also provide “special categories of personal data” under applicable law, such as your race, ethnicity, religion, philosophical or political views, and information relating to your sex life or sexual orientation. By affirmatively providing TrueBoo with this information, you explicitly consent to our use of it for the purpose of fine tuning your match criteria. Any information that you provide in the non-personal identifiable section of your profile will be viewable by your match. When using TrueBoo, you may also provide payment information (where required for the purpose of payment). We collect and process your messages with other users as part of the operation of TrueBoo.
Referring Your Friends: We encourage you to refer your friends to TrueBoo by sending us your friends’ email addresses or phone numbers. We will keep this information in our database, and enable you to send these friends a one-time email or text message from your device containing your name and inviting them to visit our site. This email will also include instructions on how to opt out and unsubscribe from our email list. You agree that you will not abuse this feature by entering the email addresses or phone numbers of those individuals who would not be interested in TrueBoo.
Emails: We require an email address from you when you register with certain TrueBoo apps. We use your email for both “administrative” (e.g., confirming your registration, notifying of matches) and “promotional” (e.g., newsletters, new product offerings, special discounts, event notifications, special third-party offers) purposes. Email messages we send you may contain code that enables our database to track your usage of the e-mails, including whether the e-mail was opened and what links (if any) were clicked. You may opt-out of receiving promotional emails and other promotional communications from us at any time via the opt-out links provided in such communications, or by e-mailing privacy@trueboo.app with your specific request. However, we reserve the right to send you certain communications relating to TrueBoo such as service announcements, security alerts, update notices, or other administrative messages) without affording you the opportunity to opt out of receiving such communications.
Text Messages: In certain apps, we may require a mobile telephone number in order to connect you with your match. When both you and your match explicitly express mutual interest by both clicking the “LIKE” button within TrueBoo, we will seek to connect you with him/her by text message. We will also share your first name at this time with your match. We do not share your phone number with your match during this process, as all introductory text messages are sent using third party generated phone numbers. We may also send text messages to your mobile phone for purposes of communicating with you about TrueBoo. By registering with TrueBoo and providing your phone number, you consent to TrueBoo sending you text messages via an automatic telephone dialing system. Your use of TrueBoo is not contingent upon agreeing to receive text messages.
Online Survey Data: We may periodically conduct voluntary member surveys. We encourage our members to participate in such surveys because they provide us with important information regarding the improvement of TrueBoo.
How we use the information
Pursuant to the terms of this Privacy Policy, we may use the information we collect from you for the following business purposes:
1. facilitate matches with other TrueBoo users;
2. respond to your comments and questions and provide customer service;
3. to tailor and provide communications to you about TrueBoo and related offers, promotions, advertising, news, upcoming events, and other information we think will be of interest to you;
4. monitor and analyze trends, usage and activities;
5. investigate and prevent fraud and other illegal activities;
6. provide, maintain, and improve TrueBoo and our overall business;
7. where we otherwise have a legitimate interest in doing so, for example, direct marketing, research (including marketing research), network and information security, fraud prevention, and enforcing our terms, conditions and policies or defending against legal claims; and
8. for any purposes disclosed to you at the time we collect your information or pursuant to your consent.
Use for Research. In addition to the uses outlined above, by using TrueBoo, you agree to allow us to anonymously use the information from you and your experiences to continue our research into successful relationships, including how to create and foster these relationships, so that we may continue to improve the TrueBoo experience. This research may be published in our blogs or interviews. However, all of your responses will be kept anonymous, and we assure you that no personal information will be published.
Sharing Your Information
The information we collect is used to provide and improve the content and the quality of TrueBoo, and without your consent we will not otherwise share your personal information to/with any other parties except: (a) to provide TrueBoo, (b) when we have your permission, or (c) or under the following instances:
Service Providers and Business Partners. We may share your information with our third-party service providers and business partners that help us to accomplish certain business purposes (e.g., marketing and analytics providers, security and technology providers, advertising partners, and payment processors).
Legal Disclosures and Business Transfers. We may disclose any information without notice or consent from you: (a) in response to a legal request, such as a subpoena, court order, or government demand; (b) to investigate or report illegal activity; or (c) to enforce our rights or defend claims. We may also transfer your information to (a) any affiliate of our corporate group or (b) another company in connection with a merger, financing due diligence, corporate restructuring, sale of any or all of our assets, or in the event of bankruptcy.
Aggregate Data. We may aggregate or de-identify the information described in this Privacy Policy. Aggregated or de-identified data is not subject to this Privacy Policy.
If you access third-party services, such as Facebook to login to TrueBoo, these third-party services may be able to collect information about you, including information about your activity on TrueBoo, and they may notify your connections on the third-party services about your use of TrueBoo, in accordance with their privacy policies.
TrueBoo does not sell personal information to third parties. TrueBoo does permit third parties to collect the personal information described above through our service and shares personal information with third parties for business purposes as described in this Privacy Policy, including but not limited to providing advertising outside of our service based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”). The information practices of these third parties are not covered by this Policy.
Updating or Removing Account Information
You may review or edit your profile as you wish, by logging into your TrueBoo account using the information supplied during the registration process. If you would like to have us delete your account information, we may do so by deactivating your account first and then permanently deleting your account. Where you have consented to our use of your personal information, you may withdraw your consent at any time. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for TrueBoo services, or to respond to any inquiry or request made by you, as applicable. To opt out of receiving messages concerning TrueBoo, you must cease requesting and/or utilizing services from TrueBoo, and cease submitting inquiries to TrueBoo, as applicable.
Individual Rights in the European Economic Area
If you are located in the European Economic Area, you may seek confirmation regarding whether TrueBoo is processing personal information about you, request access to your personal information and ask that we correct, amend, delete, or restrict processing of your personal information. In addition, you may object to TrueBoo’s processing of your personal information at any time. However doing so may impact your use of TrueBoo.
If applicable law provides you the right to request access to, (receive) port, object to or restrict processing, seek rectification or request erasure of personal information held about you by TrueBoo, you may do so, as applicable, through the controls in the TrueBoo application or by contacting TrueBoo. To protect your privacy, TrueBoo will endeavor to take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.
Although TrueBoo makes good faith efforts to provide users with access to their personal information, there may be circumstances in which TrueBoo is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question, where the request is manifestly unfounded or excessive, or where the information sought is commercially proprietary.
Third Party Sites
TrueBoo may contain links to other websites and services. If you choose to click on a third party link, you will be directed to that third party’s website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or services. These third parties may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you visit.
Data Retention
TrueBoo retains the personal information we receive as described in this Privacy Policy for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Securing Your Personal Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
By providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of TrueBoo. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
Your Choices
You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionality of TrueBoo may no longer be available to you. Without this information, we are not able to provide you with all the requested services, and any differences in services are related to your information.
You can manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by clicking here and by utilizing the choices available at http://www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices.
Your mobile device may include a feature that allows you to opt out of some types of targeted advertising (“Limit Ad Tracking” on iOS and “Opt out of Interest-Based Ads” on Android).
You can switch off GPS location information functionality on your mobile device if you do not wish to share GPS information.
Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
California Residents
California residents may, in accordance with applicable law, request access to, deletion of, and portability of your information or more information about our information practices. For purposes of this section, “California resident” and “personal information” have the meanings given in the California Consumer Privacy Act of 2018 (the “CCPA”). Personal information does not include de-identified or aggregated information, information publicly available in government records, or certain information excluded from CCPA’s scope.
Right to Access
You can access much of your TrueBoo information by logging into your TrueBoo account. You may also, subject to applicable law and verification procedures, request details from us about the information we have collected from and about you over the past 12 months, including: The categories of personal information we have collected about you, categories of sources from which the personal information was collected, the purpose for our collection or sale of your personal information, the categories of third parties with whom we have shared your personal information, and the specific pieces of personal information we have collected about you. If you wish to request such access to your personal information, please contact us at the email or physical address provided in the How to Contact Us section at the bottom of this policy.
Right to Delete
You may, subject to applicable law and verification procedures, request that we delete any personal information we have collected about you subject to a number of exceptions, including, but not limited to, if the information is necessary to:
If you wish to request deletion of your personal information, please contact us at the email or physical address provided in the How to Contact Us section at the bottom of this policy . You may also delete data on your own, for example, by deactivating and permanently deleting your account.
Verification Procedures
To protect the privacy of your information and account, we are required to verify your request. The verifiable request must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your choices on your behalf, please select an agent registered with the Secretary of State of your state of residence and provide evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
Nondiscrimination
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on TrueBoo may change or no longer be available to you. Any differences are related to your information.
“Shine the Light” requests
You have the right to request and obtain from us once a year at no charge a list of all third parties, if any, to which we have disclosed your personal information during the preceding calendar year for those third parties’ direct marketing purposes. If you would like such a list, please contact us at privacy@trueboo.app . For all such requests, you must put the statement “Shine the Light Request” on your request, as well as your name, street address, city, state, and zip code. Please note that we will not accept these requests by telephone or fax, and are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Using TrueBoo from outside the United States
If you are visiting TrueBoo from outside the United States, please be aware that your information may be transferred to, stored, and processed globally, including in the United States where our servers are located and our central database is operated. By using our services, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it for processing as described in this Privacy Policy. Where required by law, international transfers of personal information will be supported by an adequacy mechanism.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. If there are any material changes to this Privacy Policy, TrueBoo will notify you by email or as otherwise required by applicable law. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy. We recommend that you check our Website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.
How to Contact Us
If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact us by email at privacy@trueboo.app or by mail at TrueBoo, Inc. 2625 Middlefield Road, Palo Alto, CA 94306 .