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Plain-English Privacy Policy

Welcome to Trustle! We wanted to provide you an easy to understand version of our privacy policy as well as the legal version to the right. This applies to all our services including our website and mobile app.

We at Trustle Inc. respect the privacy of your personal information and, as such, make every effort to ensure your information is protected and remains private. As the owner and operator of our Service, the website www.trustle.com (the “Website”) and the mobile application Trustle (the “App”), hereafter collectively referred to in this Privacy Policy as “Trustle”, “us”, “our” or “we”, we have provided this Privacy Policy to explain how we collect, use, share and protect information about the users of our Service.
For the purposes of this Agreement and our Terms of Service, any use of the terms “Trustle”, “us”, “our” or “we” includes Trustle Inc., without limitation.

We will not use or share your personal information with anyone except as described in this Privacy Policy.

This Privacy Policy, which is incorporated into the Trustle Terms of Services Agreement accessible here (insert link to the Terms of Services page here), will inform you about the types of personal data we collect, the purposes for which we use the data, the ways in which the data is handled and your rights with regard to your personal data.

For the purpose of this Privacy Policy the Data Controller of personal data is Trustle Inc. and our contact details are set out in the Contact section at the end of this Privacy Policy. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which, and the manner in which, any personal information are, or are to be, processed.

For purposes of this Privacy Policy, “Your Information” or “Personal Data” means information about you, which may be of a confidential or sensitive nature and may include personally identifiable information (“PII”) and/or financial information. PII means individually identifiable information that would allow us to determine the actual identity of a specific living person, while sensitive data may include information, comments, content and other information that you voluntarily provide.

Trustle collects information about you when you use our Website or App to access our services, and other online services (collectively, the “Services”) and through other interactions and communications you have with us or our Coaches and Clinicians.

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by sending you a notice to your registered email address and by posting the revised Privacy Policy on the Site and in the App. If the changes to the Privacy Policy are significant, the email notice we send you will require you to accept the revised Privacy Policy terms. Those changes will go into effect on the “Last updated” date shown at the end of this Privacy Policy. By continuing to use the Site or Services, you consent to the revised Privacy Policy. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.

BY CHECKING THE BOX ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THIS PRIVACY POLICY AND PROVIDING EXPLICIT CONSENT AT THE TIME OF YOUR REGISTRATION FOR YOUR ACCOUNT, AND BY ACCESSING OR USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, MANIPULATION, STORAGE, DISCLOSURE AND OTHER USES OF YOUR INFORMATION (COLLECTIVELY, “USE OF YOUR INFORMATION”) AS DESCRIBED IN THIS PRIVACY POLICY AND OUR TERMS OF SERVICE WHICH MAY BE ACCESSED HERE TRUSTLE.COM/TERMS . IF YOU DO NOT, OR NO LONGER, AGREE WITH OR CONSENT TO THIS PRIVACY POLICY AND OUR TERMS OF SERVICE YOU MAY NOT ACCESS OR USE OUR SERVICES. FURTHERMORE, FOR USERS OF OUR SERVICES PROVIDING INFORMATION FROM THE EUROPEAN UNION, WE RELY UPON THE LEGAL GROUNDS FOUND IN THE SECTION ENTITLED “THE LEGAL BASIS AND REASONS FOR COLLECTION AND PROCESSING YOUR PERSONAL INFORMATION” FOUND HEREINAFTER IN THIS PRIVACY POLICY

HIPAA

HIPAA is a set of laws that applies to healthcare information.  We’re not a healthcare provider so those laws don’t apply to us.

HIPAA DISCLAIMER: TRUSTLE IS NOT A HEALTHCARE PROVIDER AND DOES NOT PROVIDE MEDICAL CARE, ADVICE, DIAGNOSIS, TREATMENT OR SERVICES AND YOUR USE OF OUR SERVICES DOES NOT CREATE A PATIENT/PHYSICIAN RELATIONSHIP. AS SUCH, WE SPECIFICALLY DISCLAIM ANY REPRESENTATION OR WARRANTY THAT TRUSTLE’S SERVICES, AS OFFERED, COMPLY WITH THE FEDERAL HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA”). TRUSTLE ONLY MAINTAINS THE MINIMUM DATA NECESSARY TO PROVIDE OUR SERVICES AND DOES NOT STORE OR MAINTAIN YOUR PROTECTED HEALTH INFORMATION (PHI) AND IS NOT COMPLIANT

What we collect

We collect and store the data that we need to run the service including the information you provide to sign up, and information you send to your team, and information about how you use the service. Children (under 13 years old) are not allowed to sign up and so we don’t collect information from them.

1. Children’s Privacy

Our Services are intended for users who have attained the age of majority where they reside (18 years of age or older in most jurisdictions). Furthermore, we do not knowingly collect personally identifiable information (PII) from persons under the age of 13 in the United States (“U.S.”), or under the age of 16 in the European Union (“EU”), the “Protected Age”. If you are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.

2. Information Provided Directly By You

We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, order a subscription to our Services, message your Coach or Clinician, complete a Trustle form, survey, questionnaire or application, contact customer support, make a purchase, join or enroll for an event or otherwise communicate with us in any manner. This information may include, without limitation: name, date of birth, e-mail address, physical address,  business address, phone number, profile photograph, credit card or other method of payment information, or any other personal information you choose to provide.

3. Information Collected Through Your Use of Our Services

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) and how you interact with other users, Coaches, Clinicians and us. The following are situations in which you may provide Your Information to us:

  1. When you fill out forms or fields through our Services;
  2. When you register for an account with our Service;
  3. When you create a subscription for our Services;
  4. When you order products or services from, or through our Service;
  5. When you provide responses to a survey;
  6. When you answer questions on a questionnaire;
  7. When you join or enroll in an event through our Services;
  8. When you sign up for any newsletters or other materials through our Services;
  9. When you provide information to us through a third-party application, service or Website;
  10. When you communicate with us or request information about us or our products or Services, whether via email or other means;
  11. When you participate in any of our marketing initiatives, including, contests, events, or promotions; and
  12. When you participate in forums, communities, reviews or provide or post user generated content or other submissions.

We also automatically collect information via the Website or App through the use of various technologies, including, but not limited to Cookies and Web Beacons. We may collect your IP address, browsing behavior and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.

4. Information Collected From Other Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your Trustle account with a social media service, e.g. LinkedIn, Facebook or Twitter, or if you engage with a separate App or Website that uses our API, or whose API we use, we may receive information about you or your connections from that Site or App. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, your contact names, e-mail addresses, phone numbers, and other identifiers and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your personal privacy settings with the social network.

5. Aggregated Data

We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Data as this data does not directly or indirectly reveal your identity. If we ever combine Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as PII which will only be used in accordance with this Privacy Policy.

Cookies and technical use

We use cookies on our website as part of our marketing efforts. We may also look at the hardware and software you use when using our service.

6. Cookies, Log Files and Anonymous Identifiers

  1. When you visit our Services, we may send one or more Cookies – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website browsing equipment for record keeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience.
  2. Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Site.
  3. Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).
  4. Certain Cookies may be used on the Sites regardless of whether you are logged in to your account or not.
  5. We may also employ Cookies so that we remember your computer when it is used to return to the Site to help customize your Trustle web experience.
  6. We may associate personal information with a Cookie file.
  7. We use Cookies to help us know that you are logged on, provide you with features based on your preferences, understand when you are interacting with our Services, and compile other information regarding use of our Services.
  8. Third parties with whom we partner to provide certain features on our Site or to display advertising based upon your Web browsing activity use Cookies to collect and store information.
  9. Our Website may use remarketing services, to serve ads on our behalf across the internet on third party websites to previous visitors to our Sites.
  10. Trustle may use third-party services such as Google Analytics to help understand use of the Services.
  11. You can control the use of Cookies at the individual browser level. Use the options in your web browser if you do not wish to receive a Cookie or if you wish to set your browser to notify you when you receive a Cookie.
  12. Trustle cannot control the use of Cookies by third parties.
  13. We automatically collect information about how you interact with our Services, preferences expressed, and settings chosen and store it in Log Files.

7. Device Information

When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time.

8. Do Not Track Settings

Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting Cookies.

Protecting your information

We do our best to look after your information.

10. Protective Measures We Use

We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

Payment processing

We use Chargebee and Stripe to manage your subscription and payment processing. We don’t store any of your financial information.

What we do with your information

We will never sell your information to a third party (for example for advertising.)

12. How We Use Information We Collect

Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not sell, rent, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared.

Additionally, we may use the information we collect about you to: 01. Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Trustle and other companies. 02. Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity.

13. How We Share Information We Collect

  1. We may share the information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:
  2. With third party Service Providers to enable them to provide the Services you request;
  3. With companies that perform services for us, such as processing payments and managing our data;
  4. With Trustle subsidiaries and affiliated entities that provide services or conduct data processing on our behalf.

Your rights to change, delete and edit your info

You can ask us at any time to:

- Delete your info
- Edit your info
- See what info we’re holding on you
- Stop sending you promotional content

18. Account Information
You may correct your account information at any time by logging into your online account.

19. Promotional Information Opt Out
You may opt out of receiving promotional messages from us at any time by following the instructions in those messages sent to you or by contacting us at any time using the Contact Us information at the end of this Privacy Policy.