Privacy Policy

We collect your Personal Data and other information when you make a purchase, use or register into our Services, take part in campaigns or research or otherwise interact with us. This includes following categories:

Use of Services

When you access our Services online, our web servers automatically create records of your visit. These records typically include IP address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information. Additionally, we may invite you to join voluntary service improvement or research programs where detailed information is collected. See also our Cookie Policy.

Information you provide us with

When you create an account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, feedback and information relating to your language. We also maintain records of your consents, preferences and settings relating to, for example, marketing and sharing of Personal Data.

Your transactions with us

We maintain records of your purchases, the content you have provided us with, your requests, agreements between you and us, the Services provided to you, payment details, your contacts and communications and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.

We may process your Personal Data for the following purposes. One or more purposes may apply simultaneously.

Providing Services

We may use your Personal Data to provide you with our Services, to process your requests or as otherwise may be necessary to perform the contract between you and us, to ensure the functionality and security of our Services, to identify you as well as to prevent and investigate fraud and other misuses.

Developing and managing Services

We may use your Personal Data to develop and manage our Services, customer care, sales and marketing. We may combine Personal Data collected in connection with your use of a particular Truugo service with other Personal Data we may have about you, unless such Personal Data was collected for a different purpose.

Communicating with you

We may use your Personal Data to communicate with you, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our Services and to contact you for customer care related purposes.

Marketing, advertising and making recommendations

We may contact you to inform you of new services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your Personal Data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our Services.

We do not sell, lease, rent or otherwise disclose your Personal Data to third parties unless otherwise stated below.

Your consent and social sharing services

We may share your Personal Data if we have your consent to do so. Some services may allow you to share your Personal Data with other users of the service or with other services and their users. Please consider carefully before disclosing any Personal Data or other information that might be accessible to other users.

Authorized third parties

We may share your Personal Data with other authorized third parties who process Personal Data for us for the purposes described in this Policy. This may include for example payments through our payment processor or otherwise, providing services including customer service, managing and analyzing visitor data, conducting research and managing marketing and other such campaigns.

These authorized third parties are not permitted to use your Personal Data for any other purposes. We require them to act consistently with this Policy and to use appropriate security measures to protect your Personal Data.

Transfers of Personal Data

Our servers and technical infrastructure are located solely in EU. The majority of our activities is performed inside EU. However, some additional sub-processing services (such as Google Analytics) may be provided using resources and servers located in various countries around the world. Therefore your Personal Data may be transferred across international borders outside the country where you use our Services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for Personal Data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that there is a legal basis for such a transfer and that adequate protection for your Personal Data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.

Mandatory disclosures

We may be obligated by mandatory law to disclose your Personal Data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your Personal Data in accordance with applicable law to defend our legitimate interests, for example, in civil or criminal legal proceedings.

Mergers and Acquisitions

If we decide to sell, buy, merge or otherwise reorganize our businesses, this may involve us disclosing Personal Data to prospective or actual purchasers and their advisers, or receiving Personal Data from sellers and their advisers.

We take reasonable steps to keep the Personal Data we possess accurate and to delete incorrect or unnecessary Personal Data.

We encourage you to access your Personal Data through your account from time to time to ensure that it is up to date.

Privacy and security are key considerations in the maintenance and delivery of our Services. Truugo maintains strict administrative, technical, and physical procedures to protect Personal Data stored in our servers. We limit access to our databases containing Personal Data to authorized persons having a justified need to access such information. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected.

You have a right to know what Personal Data we hold about you. You have a right to have incomplete, incorrect, unnecessary or outdated Personal Data deleted or updated. You have a right to unsubscribe from direct marketing messages and to request that we stop processing your Personal Data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out from marketing and other communications, you will continue to receive certain email communications related to your account including information regarding new features, transactions and your relationship with Truugo.

You may exercise your rights by contacting us or by managing your account and choices through your Truugo account. In some cases, especially if you wish us to delete or stop processing your Personal Data, this may also mean that we may not be able to continue to provide the Services to you.

Notice to End Users

Our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and also the data controller and is responsible for the accounts over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.

Administrators are able to:

• restrict, suspend or terminate your access to the Services
• access information in and about your account
• access or retain information stored as part of your account;

In some cases, administrators can also:

• change your information, including profile information
• restrict your ability to edit, restrict, modify or delete information

Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens.

Please contact your organization or refer to your administrator’s organizational policies for more information.

We may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, we will post a notice advising of such change at the beginning of this Policy. In addition, we might notify our registered users by emailing to addresses listed in Truugo accounts. We recommend that you revisit this Policy from time to time to learn of any such changes to this Policy.