TrueSpace

Privacy Policy

Last Updated: April 13, 2020

TrueSpace, LLC (“TrueSpace,” “we,” “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Privacy Policy”).

Capitalized terms not defined in this Privacy Policy have the meaning set forth in the Terms of Use or any additional TrueSpace policies, addendums, and agreements made available to you.

We at TrueSpace constantly aim to provide the best user experience possible to our Users. We value the long-term relationship that allows us to provide a personalized, valuable experience that delivers information, resources and services that are helpful to you. This Privacy Policy discusses, among other things, how information and data obtained during your visit or use of the TrueSpace Platform and Services may be collected and used.By using the TrueSpace Platform or Services, you agree to be bound by the terms of this Privacy Policy.

If you do not agree or consent to any of the terms of this Policy, your recourse is to discontinue accessing or otherwise using the website or any materials obtained from it, and relying on the choices we have provided herein in Section 6. By using or continuing to use or access the TrueSpace PLATFORM or Services, you agree to this Privacy Policy.

1. Personal Data and Aggregate Information

“Personal Data” refers to information that tells us specifically who you are, such as your name, phone number, email, approximate geographic location of your computer or device, or postal address, household, and other information that personally identifies you.

While some experiences will not prompt a collection of Personal Data, you generally need to provide us with Personal Data to use most of the features of the TrueSpace Platform and Services, including to allow us to provide you with certain personalized or enhanced Services. How we collect and store information depends on the Services in which you elect to participate.

From time to time, we may collect general, non-personal, statistical information about the use of the TrueSpace Platform or Services.

We collect this information using technologies such as “cookies”, which are discussed in greater detail below. We also collect this information through your use of the Services, such as when you take one of our assessments. We collect this information to (i) determine, for example, which areas of the TrueSpace Platform are most popular and to enhance the TrueSpace Platform; (ii) share with our existing or potential business partners or other third parties, or in response to a government request; (iii) optimize third-party offers of products and/or services; (iv) enable the provision of targeted information; and (v) enhance our Services and business through research and data analysis.

We use commercially reasonable efforts to ensure that this aggregate data will in no way personally identify you or any other Users.

2. Information TrueSpace May Collect From You

TrueSpace receives and stores any information you enter on the TrueSpace Platform or give to us in any other way. Types of information you may provide include:

• Contact Information. When you sign up for a User Account or use one of our Services, such as an assessment, questionnaire, or networking event, you may be required to give us your name, email address, street address, billing address, and phone number, and additional information that enables you to sign up for and use the TrueSpace Platform and Services.
• Payment Information. We may collect Personal Data such as your credit card number or expiration date when you sign up for Services. We use a third party payment processor to process your payment, and do not store your credit card information. You will be notified of the payment processor we use. We encourage you to check such third party payment processor’s privacy policy and terms of use. We cannot speak to such third party payment processor’s collection and use of your data.
• Information You Submit. We may collect information you submit to us using our Services, such as when you take an assessment, use any of our feedback tools, or take any other type of questionnaires we offer. For example, when you take an assessment we will receive your name, email address, phone number, the answers to our questions (which may contain confidential information), any attachments that you may send to us, and other information you choose to provide. If you take an assessment via the TrueSpace Platform, you may be asked to enter into an Assessment Agreement which shall govern and control our use of the information you provide through such assessment. In the event of a conflict between such Assessment Agreement and this Privacy Policy, the terms of the Assessment Agreement shall control.
• Phone Information. If you use the TrueSpace Platform on your mobile device or tablet, it may require special permission such as access to the camera, microphone, pictures, location, read and write external storage, network access, etc. Those permissions allow the TrueSpace Platform to work properly on your device. If you do not allow all required permission to the TrueSpace Platform, it may not work properly.
• Testimonials. TrueSpace may also collect information and data provided by you from our responses to surveys that we might ask for research purposes to improve our Services. TrueSpace may post testimonials on the TrueSpace Platform. We may also post or share news, events, results, accomplishments, marketing materials from individuals or companies. Requests to remove posted materials should be submitted to support@truespace.com. Reasonable efforts will be made to remove posts upon receiving written notice.

3. Automatically Collected Information

When you visit or access certain areas of the TrueSpace Platform, TrueSpace may collect certain information from you automatically, such as information provided by your website browser or mobile device, including but not limited to:

• Device Identifiable Information. We may collect information that is linked to your computer or device (“Device Identifiable Information”). This information may include your IP address, browser type and language, access times, pages visited, and operating system.
• Mobile Device Information. We may collect information from any mobile device you use to access the TrueSpace Platform and Services, including device type and model, network provider, and unique device identifier.
• Cookies and Similar Technologies. We may collect technologies such as “cookies,” “pixels,” and “widgets.”
  • Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device and to provide features, such as personalized advertisements on other websites. If you do not wish for TrueSpace to place and use cookies on your computer, you may modify and control how cookies are handled in your browser settings. If you choose to disable cookies, certain functions of the TrueSpace Platform and Services may not function correctly.
  • Pixels/Web Beacons (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the User’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
  • Social Media Widgets such as a share button to Facebook or Twitter may be on our TrueSpace Platform. These features may collect your IP address and what page you are visiting on the TrueSpace Platform.
• Google Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Data. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to tools.google.com/dlpage/gaoptout.

The TrueSpace Platform does not currently support Do Not Track, which is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites.

4. How We Use Your Information

We use, store, and process information, including Personal Data about you, to provide, understand, improve, and develop the TrueSpace Platform and Services. This information is collected for the necessary purposes set out below:

• To carry out our Services and obligations from any contracts entered between you and TrueSpace, including billing and collections

• If you take one of our assessments, questionnaires, or surveys, we use that information to work with you to improve your business
• To notify you of Service and subscription expirations and renewals
• To provide customized, personalized content through our TrueSpace and Services
• To notify you about changes to our TrueSpace Services or policies
• To allow you to participate in new features and Services on our TrueSpace Platform
• To facilitate the delivery of content or advertisements that we feel may be relevant to you
• To communicate new or existing products or Services that we feel can help you
• For any other purpose with your consent

5. How We Share Information We Collect

TrueSpace customer information, user data, and Personal Data may be shared with certain third party companies for the purposes set forth below:

• TrueSpace works closely with Gallup® to develop enhanced Services. We will share your Personal Data that is collected when you take an assessment, questionnaire, or survey through our Services with Gallup®. TrueSpace has taken commercially reasonable measures to ensure that Gallup® understands its obligations to protect your Personal Data.
• TrueSpace may sometimes need to share your Personal Data, user data, or customer information to help facilitate technical and administrative aspects of TrueSpace’s Services (credit card processing, hosting, citation building & management). TrueSpace will take reasonable steps to ensure that these service providers are notified of their obligations to reasonably protect Personal Data on TrueSpace’s behalf. Notwithstanding the above, we cannot guarantee that such service providers will adhere to the contractual obligations or acceptable business practices.
• We may provide your anonymized and aggregated personally identifiable information to third parties for their marketing and/or advertising purposes.
• The TrueSpace Platform may allow you to connect with other websites, products, or services that we do not have control over. If you use these services, we will provide the third party with information about you to allow them to provide the service to you. We cannot speak to the privacy practices of these third parties, and we encourage you to read their privacy policies before deciding whether to use their services.
• TrueSpace may release information when we believe it is necessary in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We will also share your Personal Data where we believe it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, or protecting the safety of any person, provided that such interest is not overridden by your interests or rights and freedoms requiring the protection of your Personal Data.
• We may disclose certain Personal Data while negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets. We may sell information and Personal Data with any successor to all or part of our business.
• We may disclose Personal Data whenever you consent to the sharing.

6. Your Choices

You can always unsubscribe from our commercial or promotional emails, but if you continue to use the Services, we may still send you transactional and relational emails about your use of the Services.

You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the TrueSpace Platform and Services.

If you create an account to use the TrueSpace Platform and Services, you may be asked to choose a password for your account, in which case your account information shall be protected by your password. You should not disclose your password to any other person. You are responsible for maintaining the confidentiality of your password and are fully responsible for all activities that occur under your password or account. You can access and update information in your account profile at any time by logging into the account with your login name and password. Once you have logged in, you can update certain information such as your name, photo, email, password, billing information, and security preferences.

While you can prevent your device from sharing location information at any time through your device’s operating system settings, User location is important to your use of the TrueSpace Platform and Services and without it will affect your use of the TrueSpace Platform and Services.

If would like to terminate your account, please contact us through our customer support with your request. If you choose to terminate your account, we will deactivate it for you but may retain information from your account for a certain period of time and disclose it in a manner consistent with our practices under this Privacy Policy for accounts that are not closed. We also may retain information from your account to collect any fees owed, resolve disputes, troubleshoot problems, analyze usage of the TrueSpace Platform, assist with any investigations, prevent fraud, enforce our Terms of Use, or take other actions as required or permitted by law.

Where we are using your Personal Data on the basis of your consent, and where applicable under local law, you have the right to withdraw that consent at any time.

7. California Consumer Protection Act

This section of the Privacy Policy applies only to any natural person “enjoying the benefit and protection of laws and government” of California. If you live in California you have certain rights under the California Consumer Protection Act of 2018 (“CCPA”).

In accordance with the CCPA, this Privacy Policy discloses:

• what categories of Personal Data and the specific pieces of Personal Data we collect;
• how that Personal Data is collected and how we use it;
• the categories of Personal Data that are sold or shared with third parties;
• the categories or types of third parties with whom we share Personal Data.

As a California resident you can request a list of the Personal Data we collected from you, a list of the Personal Data we have shared with third parties, and a list of the names of third parties with whom we have shared your Personal Data. You may make such a request twice per year at no charge to you.

You may also request that we do not sell or disclose your Personal Data to third parties. However, to provide you with most Services and the TrueSpace Platform we need to share certain aspects of your Personal Data with our third party service providers, namely, Gallup. Accordingly, such request may affect how you use and access the Services we provide.

You may also request that we, and any third parties with whom we have shared your Personal Data, delete all your Personal Data. Be advised that we may limit, postpone, or deny your request in order to: (i)facilitate any transaction that you initiate with us; (ii)comply with a legal requirement or process; (iii)comply with our security and safety measures; and (iv)comply with any other exception provided under the CCPA.

To make any of the foregoing requests, email us at support@truespace.com with the subject line “California Consumer Protection Act.”

8. EU General Data Protection Regulation

This section of the Privacy Policy applies only to any natural person who is a resident of the European Union (“EU”). As a resident of the EU, you have certain rights under the General Data Protection Regulation (“GDPR”).

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data includes:

• As necessary to fulfill our responsibilities under our agreements with you (e.g., to provide Services);
• As necessary to comply with our legal obligations (e.g., to prevent or detect fraud);
• As necessary for our legitimate interests, including our interest in providing secure services and improving the TrueSpace Platform; and
• Where you have consented to data processing or to receiving marketing communications, which may subsequently be withdrawn at any time.

You can choose not to provide us with information, even though it might be needed to facilitate the Services or to take advantage of such features as your full use of the TrueSpace Platform.

The nature of our business means that the Personal Data collected through our website and services will be transferred to the United States. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard data protection contractual clauses to ensure that any transferred Personal Data, remains protected and secure.

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, you may opt-out by one of the following methods:

• selecting the "Unsubscribe" link in any promotional email; or
• contacting us here support@truespace.com

Even if you opt out of getting marketing messages, we may still send you transactional messages. These include responses to your questions.

If you receive promotional emails from a third party, you will need to separately opt-out with them.

You can request access or correction to your Personal Data. You can request a copy of the Personal Data we hold about you and check that we are lawfully processing it or to request a rectification if it is not accurate, complete, or updated.

You can request erasure of your Personal Data. You can ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. We may postpone or deny your request if your Personal Data is in current use for which it was collected or for other legitimate purposes such as compliance with legal obligations.

You can object to and request restriction of processing of your Personal Data. You can ask us to suspend the processing of your Personal Data or you can object at any time on legitimate grounds to the processing of this personal information.

If you object to such processing, TrueSpace will no longer process your Personal Data for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise or defense of legal claims.

To make any of the foregoing requests, email us at support@truespace.com with the subject line “GDPR Request.”

For purposes of GDPR and similar data protection regimes, we generally act as a Data Controller, meaning we determine the purposes and means of processing your personal information.

9. Storage of Your Information

When you take one of our assessments, questionnaires, or surveys you grant us certain rights to the information you provide us. Please review our Assessment Agreement. Generally speaking, for so long as we hold your Personal Data we will employ customary industry practices to protect your Personal Data. However, no method of transmitting or storing electronic data is completely secure, and therefore we cannot warrant or guarantee that such information will never be accessed or used by, or released to, unauthorized third parties or in a manner that is inconsistent with this policy.

The nature of our business means that the Personal Data collected through our TrueSpace Platform and Services will be transferred to the United States. Information we maintain is stored within the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This site is subject to U.S. laws, which may not afford the same level of protection as those in your country. Also, the TrueSpace personnel and the third parties to whom we disclose Personal Data are located in the United States.

10. Miscellaneous

TrueSpace reserves the right, at its sole discretion, to alter this Privacy Policy at any time without prior notice to any User, including to comply with privacy laws, regulations, and/or our own or industry standards, business practices, or otherwise. We encourage you to review this Privacy Policy each time you access or use the TrueSpace Platform or Services. Your use of the TrueSpace Platform or Services at any time, including after any change to this Privacy Policy, indicates your acceptance of this Privacy Policy and any change made to this Privacy Policy.

We take reasonable precautions to protect the privacy, accuracy, and reliability of any information you provide and to protect such information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Personal Data is stored within databases that are controlled by us or by our service providers. As we deem appropriate, we use security measures consistent with industry standards, such as firewalls and encryption technology, to protect your information. However, since no security system is impenetrable, we cannot guarantee the security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. As a result, you transmit any information to or from the TrueSpace Platform and Services at your own risk.

We understand and share your concerns regarding your children’s access to Internet and the Internet’s access to your children. The TrueSpace Platform and Services are not directed to children. Consistent with the Children’s Online Privacy Protection Act of 1998 (COPPA), we do not knowingly request or accept Personal Data submitted to the TrueSpace Platform by any visitor under 13 years of age. If we become aware that an individual under age 13 has provided information to TrueSpace through the TrueSpace Platform, we will make commercially reasonable efforts to delete such information from our databases.

This Privacy Policy shall be governed by the laws of the State of Colorado, without regard to conflicts of law principles. Any action relating to this Privacy Policy must be filed and maintained in a state or federal court of competent jurisdiction located in Denver, Colorado, and each User consents to exclusive jurisdiction and venue in such courts for such purpose. TrueSpace makes no representation that this Privacy Policy and such practices comply with the laws of any country outside the United States.

If you have any questions or comments about this Privacy Policy or our privacy practices, or to report any violations of this Privacy Policy or abuse of the TrueSpace Platform or the Services, please contact us by mail or email at the following:

Attn: Privacy Concerns

Address: 4600 S Ulster Street Suite 1450, Denver, CO 80237

E-mail: support@truespace.com