Aggregate WEBSITE DATA COLLECTION and use.
True Reply tracks visits to our Websites and uses visitor logs to compile anonymous aggregate statistics. This aggregate information is collected sitewide, and includes anonymous website statistics. In addition, when you browse our Websites, our system automatically collects information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, the date and time of your request and one or more cookies that may uniquely identify your browser. This information is used to analyze trends, administer the Websites, improve the design of our website, and otherwise enhance the services we provide.
Certain pages of the Website and/or html email correspondence may use session cookies, persistent cookies or web beacons to anonymously track unique visitors, save website preferences and to allow us to recognize visits from the same computer and browser. Some cookies are essential for the operation of our Site (“Essential Cookies”). These cookies enable services you have specifically asked for. These cookies remain on your device only until you close your browser after visiting our websites. Some cookies are used to collect anonymous information on the pages visited (“Performance Cookies”). For example, we might use Performance Cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. These cookies remain on your device only until you close your browser after visiting our website. Some cookies remember choices you make to improve your experience (“Functionality Cookies”). These Functionality Cookies remain on your device for an extended period of time. When you revisit our Websites we recognize Functionality Cookies and remember your preferences or can automatically log you on to the website. Personal information on our system may be associated with Functionality Cookies but the cookies themselves do not contain any of your personal information. Finally we may use “Behaviorally Targeting Advertising Cookies” which collect information about your browsing habits to make advertising relevant to you and your interests. You have the option to reject the Websites’ cookies and still use the Websites. However, your access to the Website may be limited. Further general information about cookies and how they work is available at www.allaboutcookies.org.
USAGE AND LOG DATA
Our web servers keep log files that record data each time a device accesses those servers. Log files contain data about the nature of access, including originating IP addresses, internet service providers, the pages accessed or the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type, time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also from time to time allow selected third parties to place cookies through the Websites to provide us with better insights into the use of the Websites or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our Websites. We may also permit third party service providers to place cookies through our Websites to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.
We do not use technology that recognizes a “do-not-track” signal from your web browser.
TYPES OF PERSONALLY IDENTIFIABLE INFORMATION COLLECTED
True Reply may collect, store and use personally identifiable information that you provide or we receive from others, such as:
- Registration information when you create an account with us (such as name, email address, postal address, telephone number and email preferences and account setting preferences). In the registration form, you may have an opportunity to elect to receive certain communications from us.
- Information you submit when contacting us (such as your name, contact information and any other information you choose to submit).
- Information you submit to True Reply via voice-enabled smart devices.
- Payment information if you make a payment through our Websites (such as payment card, billing and shipping information in addition to your contact information).
We may use third party services for processing payments or career applications through the Websites in addition to other potential uses. Information you provide may be linked to other information that we have about you, including data we automatically collect when you visit our Websites and information we have received from third parties.
Use of some of our services will also result in us collecting the following data on your behalf:
- Address book information - We may allow you to import phone numbers or email addresses and other contact information into an Address Book function so you can easily invite people to an engagement or fill in your form via our collectors. We don’t use this data for our own purposes or contact anyone, except at your direction.
- Engagement/form/application data - We store your Engagement/form/application data (questions, audio responses, transcription data and analytics) for you and provide analysis tools for you to use with respect to this data.
- Profile information - When you sign up for our services you are asked to provide us with information about yourself and to give us more detailed insights into who you are.
RIGHT TO ACCESS
In the preceding twelve (12) months, True Reply has not sold personal information.
Your Rights and Choices
True Reply believes in complying with the highest standards of consumer data privacy. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. We have applied these rights to our entire customer base, regardless of location within the United States.
Access to Specific Information and Data Portability Rights
You have the right to request that True Reply disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that True Reply delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 888-310-0592, extension 704.
- Emailing us at firstname.lastname@example.org
Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We may use third-party Service Providers such as but not limited to Google Analytics to monitor and analyze the use of our Service. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/analytics/terms/us.html
USE OF PERSONAL INFORMATION
We may use your personal information for our general commercial purposes such as to improve our Websites and to offer you information which True Reply believes may be of interest to you including, but not limited to the following:
- to contact you,
- to improve this site and expand our business,
- to provide you with information that you have requested,
- to respond to your inquiries,
- to provide you with technical support,
- to enforce our Terms of Service and other policies governing use of our website and services,
- to alert you to new features or enhancements to our services,
- to communicate with you about your transactions or potential transactions with us,
- to administer your account including processing of payments,
- to ensure that our Website and our Services function in an effective manner for you,
- to keep our Websites safe and secure, and
- to measure or understand the effectiveness of advertising and outreach.
True Reply will not sell or rent your personally identifiable information to any other company or organization without your consent. We may reveal information about you to trusted third parties:
- if you request or authorize it;
- if the information is provided to help complete a transaction for you;
- if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets);
- if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); or
We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.
Agents, vendors, and service providers who may have access to protected health information are contractually obligated to protect the privacy and security of such information. We may disclose aggregate statistical information to third parties for any purpose.
USE AND DISCLOSURE OF DE-IDENTIFIED INFORMATION
“De-identified” means that we have removed all your personally-identifiable information (or anonymized the data), such as your name, address, phone number, or birthdate. We may use de-identified information that we have obtained from our Services for various purposes, including for example (but not limited to):
- In accordance with regulatory requirements, we may de-identify, store and use patients’ samples and information for internal quality control, validation, and research and development.
- Academic research that requires anonymity in collection in response to an IRB.
The security of your data is extremely important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We use reasonable technical, administrative, and physical measures to protect information contained in our system against misuse, loss or alteration. Information that you provide to True Reply through these Websites is encrypted using industry standard Secure Sockets Layer (SSL) technology, with the exception of information you send via email. Your information is processed and stored on controlled servers with restricted access. Unfortunately no method of electronic transmission is 100% secure, so we cannot ensure or warrant the security of any information you transmit to our Websites, and you do so at your own risk. Please keep your user name, password, ID numbers, or other special access credentials secure; if we receive instructions using your log-in information we will consider that you have authorized the instructions.
We will never request your personal login, credit card, bank, or Paypal information via any method unless communications is initiated by you. Access to your account is only provided through verification of your identity.
INFORMATION ACCESS, UPDATES, AND CHOICE
You can update, amend or delete your account information and preferences at any time by visiting the My Account page after logging in.
True Reply email correspondence will include instructions on how to update certain personal information and how to unsubscribe from our emails and postal mail correspondence. Please follow the instructions in the emails to notify True Reply of changes to your name, email address and preference information. True Reply will take reasonable steps, such as confirmation emails, to verify your identity before granting access to your personal information.
If you choose to unsubscribe from our email and/or postal mail services, you will no longer receive this type of promotional correspondence. We will still be able to communicate with you about your account and your transactions with us. True Reply may retain your information for a period of time to resolve disputes, troubleshoot problems, or for other valid business or legal reasons.
You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Site may be impaired and certain features may not function at all.
You agree that you have provided notice to, and obtained consent from, any third party individuals whose personal information you supply to us, including with regard to: (a) the purposes for which such third party’s personal information has been collected; (b) the intended recipients or categories of recipients of the third party’s personal information; (c) which of the third party’s information is obligatory and which information, if any, is voluntary; and (d) how the third party can access and, if necessary, rectify the information held about them.
The True Reply Websites are directed toward adults. If you are under the age of 18, you must obtain the authorization of a parent, guardian or legal custodian before using or accessing our Websites. We will not knowingly collect or use any personal information from any children under the age of 18. If we become aware that we have collected any personal information from children under 18, we will promptly remove such information from our databases. If you have reason to believe that this has occurred, please contact customer support.
The True Reply Websites may contain links to external websites. True Reply does not maintain these sites and is not responsible for the privacy practices of sites that it does not operate. Please refer to the specific privacy policies posted on these sites.
These websites are owned and operated by True Reply Inc. You can contact us using the Contact Us page, via Twitter at http://twitter.com/truereply, or by telephone at 888-310-0592, extension 704.
EFFECTIVE DATE: November 2017
Updated: January 2020