Effective Date: May, 2022
Updated Date: July, 2023
This Privacy Policy applies to personal information processed by Truv Inc. (“Truv”, “we”, “us”, “ours”) through our website, Truv’s platform, and our related online and offline offerings, which may be include the electronic retrieval of data by Truv from third party platforms that host your data to be shared with a “Client” who is a third-party entity with whom you have a contractual relationship. Your information will be referred hereinto as “Data.” For California residents see here.
To make this Privacy Policy (“Policy”) easier to read, our website truv.com, our Truv platform, and related offerings are collectively called the “Services.”
This Policy explains what personal information and other data we collect through the Site, our mobile applications, and our Services, how we use and share that data, and your choices concerning our data practices.
Please read this Policy carefully. You understand that by accessing our website or using our Services you accept the terms and conditions established in this Privacy Policy.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third party websites or applications is at your own risk.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
The categories of personal information we collect depend on how you interact with our Services. Unless specified otherwise, all Data requested by the Services is mandatory and failure to provide this Data may make it impossible for Truv to provide the Services. In cases where we specifically state that some Data is not mandatory, you are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Any use of Cookies – or of other tracking tools – by the Services or by the owners of third-party services used by us serves the purpose of providing the Services, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
You acknowledge that you are responsible for the Data obtained, published or shared with us and confirm your consent to provide the Data to Truv.
Employment and/ or Income Verification Information. When you use our Services directly or through a third-party service provider’s app to verify your employment, or income, we collect your name, email address, birthdate, and login credentials to access the third-party platforms that host your data. We collect the following information from the third-party platforms that host your data on your behalf: your name, address, email, phone number, birthdate, Social Security number, details about your employment history, income history, bank account information, compensation, and other relevant information. Additionally, you accept and acknowledge you have authorization to share the aforementioned login credentials with us, and grant us your consent to access it.
Direct Deposit. When you use our Services directly or through a third-party service provider’s app to switch the bank account to which your direct deposits shall be credited, we may collect your account number, routing number, account type, distribution type, distribution amount and recent direct deposit activity, paycheck history, annual salary information.
Financial Account Aggregation. When you use our Services directly or through a third-party service provider’s app to connect your financial account to such a service provider, we may collect your name, email address, phone number, social security number, date of birth, username, password, security token, account number, routing number, branch number, currency, current and available balance, credit limit, transaction history, transaction type, transaction location, transaction status. Depending on the Service you or the third-party service provider’s app use, and how the data is made available, the data collected from your financial accounts may include data from all accounts (e.g., checking, savings, credit card, and joint accounts) accessible through a single set of account credentials.
Insurance Verification. When you use our Services directly or through a third-party service provider’s app to process an insurance verification we may collect your name, email address, phone number, username, password, account number, insurance provider name, insurance coverage
Your Communications with Us. We collect personal information from you such as your email address, phone number, or mailing address when you request information about our Services, sign up for marketing from us, register for our newsletter, request customer service or support, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features. We may offer interactive features such as blogs and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein.
Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Truv and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with Truv.
Upon request of a User. We obtain personal information only upon request of a client that has demonstrated to have a permissible purpose under the FCRA to request information on that specific consumer. The FCRA requires a user to certify to Truv that it has duly obtained the explicit written consent from the consumer to request personal data before Truv is enabled to share such information.
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, mobile carrier, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services.
Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
Analytics. We may use analytic tools to enable us to monitor and analyze web traffic and can be used to keep track of your behavior. We may use the following analytic service providers:
Matomo - Matomo is an analytics software used by the Services to analyze data directly without the help of third parties. Personal Data processed: Trackers; Usage Data [1].
Google Analytics (Google LLC) - Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of the Services, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data processed: Trackers; Usage Data. Place of processing: United States –Privacy Policy –Opt Out.
You can opt out of Google Analytics’ collection and processing of data generated by your use of our website by following the instructions here.
Displaying content from external platforms.This type of service allows you
to view content hosted on external platforms directly from the pages of
this Application and interact with them. This type of service might still
collect web traffic data for the pages where the service is installed,
even when Users do not use it. We may use the following service
provider:
Google Fonts (Google LLC) - Google Fonts is a typeface
visualization service provided by Google LLC that allows this Application
to incorporate content of this kind on its pages. Personal Data processed:
Trackers; Usage Data. Place of processing: United States –Privacy
Policy.
Hosting and backend infrastructure. This type of service has the purpose
of hosting Data and files that enable the Services to run and be
distributed as well as to provide a ready-made infrastructure to run
specific features or parts of the Services.
Some services among those listed below, if any, may work through
geographically distributed servers, making it difficult to determine the
actual location where the Personal Data are stored. We may use the
following service provider:
Amazon Web Services (AWS) (Amazon Web
Services, Inc.) - AWS is a hosting and backend service provided by Amazon
Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy
policy of the service. Place of processing: United States –Privacy
Policy.
Remarketing and behavioral targeting. We do not use the information
collected on your behalf from the third-party platforms that host your
Data for marketing purposes. We may use the Data you enter on our website
and consent to receive marketing, advertisement, and/or promotional
communications by us. For which we use this type of service that allows us
to inform, optimize and serve advertising based on your past use of the
Services. This activity is facilitated by tracking Usage Data and by using
Trackers to collect information which is then transferred to the partners
that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services providers of this kind usually offer the possibility to opt out
of such tracking. In addition to any opt-out feature offered by any of the
service providers below, you may learn more on how to generally opt out of
interest-based advertising within the dedicated section "How to opt-out of
interest-based advertising" in this document. We may use the following
service provider:
LinkedIn Website Retargeting (LinkedIn Corporation)
- LinkedIn Website Retargeting is a remarketing and behavioral targeting
service provided by LinkedIn Corporation that connects the activity of
this Application with the LinkedIn advertising network.
Personal Data processed: Trackers; Usage Data. Place of processing: United
States –Privacy
Policy –Opt
Out.
Traffic optimization and distribution. This type of service allows the
Services to distribute their content using servers located across
different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the
way these services are implemented. Their function is to filter
communications between the Services and your browser.
Considering the widespread distribution of this system, it is difficult to
determine the locations to which the contents that may contain Personal
Information of the User are transferred. We may use the following service
provider:
Cloudflare (Cloudflare Inc.) - Cloudflare is a traffic
optimization and distribution service provided by Cloudflare Inc. The way
Cloudflare is integrated means that it filters all the traffic through the
Services, i.e., communication between the Services and your browser, while
also allowing analytical data from the Services to be collected. Personal
Data processed: Trackers. Place of processing: United States –Privacy Policy.
Managing contacts and sending messages. This type of service makes it
possible to manage a database of email contacts, phone contacts or any
other contact information to communicate with you. These services may also
collect data concerning the date and time when the message was viewed by
you, as well as when you interacted with it, such as by clicking on links
included in the message. We may use the following service provider:
Sendgrid
(Sendgrid) - Sendgrid is an email address management and message
sending service provided by Sendgrid Inc. Personal Data processed:
Trackers. Place of processing: United States –Privacy Policy.
Tag Management. This type of service helps us to manage the tags or
scripts needed on the Services in a centralized fashion. This results in
the users' Data flowing through these services, potentially resulting in
the retention of this Data. We may use the following service provider:
Google
Tag Manager (Google LLC) - Google Tag Manager is a tag management
service provided by Google LLC. Personal Data processed: Trackers. Place
of processing: United States –Privacy
Policy.
We take appropriate security measures to prevent unauthorized
access, disclosure, modification, or unauthorized destruction of your
information.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Truv, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. The updated list of these parties may be requested from the Owner at any time.
Additionally, may obtain information about you from other sources, including from third party services and organizations. For example, when you use our Services to verify your employment, we may collect information on your behalf related to your employment history from the payroll provider of your previous employer.
We use your personal information for the purpose of generating a consumer report where you are informed about the particular purpose for which Truv will collect your information and the intended use of the same at the time you complete the corresponding background notice, and verification forms. For the avoidance of doubt, the information is collected for the purpose of providing the Services, such as i) conducting a background check for employment, income and/or insurance related purposes previously authorized by you; ii) manage your direct deposit configurations of your paycheck; iii) authorize direct deductions from your paycheck to repay any kind of loans as authorized and instructed by you . In the event you do not wish to be subject of a consumer report, background check, or any of the Services described in this Privacy Policy you should not provide your consent to Truv and/or Truv’s client or third-party service provider and should abstain from responding to the background check notice, verifications and forms. Additionally, there may be a variety of business purposes for which your information may be used, including:
Marketing Our Products and Services. Whenever you grant us with your consent for marketing purposes, e.g., by subscribing to our newsletter, we may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
Social Media Interaction. The Services may include links to our social media, which include but are not limited to Facebook, Twitter, and Instagram. Whenever you choose any of these options, such features may collect your IP address, and may trigger a cookie to enable such features to function correctly. In such a case, even when the Social Media features and widgets may be hosted in our Services, especially our webpage, your interactions with these Social Media features and widgets are ruled by the privacy policy of the third-party providing it, and we have no control or responsibility over.
How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:
We may share your personal information with the following categories of third parties:
Employment and/or Income Verification Parties. When you use our Services to verify your employment and/or income history, you are instructing Truv to share your name, employment history, income history, bank information, and other relevant information with the third party requesting this information (“Employment and/or Income Verification Party”). Once your personal information has been shared with the Employment and/or Income Verification Party, it will also be subject to the Employment and/ or Income Verification Party’s privacy policy. We are not responsible for the Employment and/ or Income Verification Party’s processing of your personal information. Additionally, prior to processing your information the Employment and/or Income Verification Parties shall prove Truv that they have obtained your consent for Truv collecting and sharing your information for the purposes of employment and/or income verifications.
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.
Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested.We may also provide personal information to business partners with whom we jointly offer products or services.
Affiliates. We may share personal information with Truv’s affiliated entities.
Advertising Partners. Through our Services, we may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.
APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Truv does not transfer personal data to third parties outside the
United States. We make no representation that our Services are appropriate
or even available outside the United States and its territories, and where
such access may be illegal and/or prohibited. In the event you are
accessing and using the Services outside the United States you are aware
and consent for Truv to process your personal data and information under
the terms and conditions of this Privacy Policy.
General. You may be able to opt out of certain uses of your personal information.
Email Communications. If you receive an unwanted email from us, you can contact us at the contact information displayed at the bottom of this policy, and request to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Service or this Privacy Policy).
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law; and (viii) lodge a complaint before the competent data protection authority. Truv maintains strict procedures to offer maximum possible accuracy of your information and will conduct reinvestigations about the accuracy and completeness of your information whenever you request it, prior to your proper identification.
If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
You must know that, however, should your Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Data for direct marketing purposes, you may refer to the relevant sections of this document.
We store 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, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, and pursuant to the terms and conditions established in the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq., as amended) and the California Investigative Consumer Reporting Agencies Act (Cal. Civ. Code § 1786 et seq.)
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using the Services or 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 the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act/Consumer Privacy Rights Act (“CCPA,” “CPRA”). Personal information does not include publicly available information from government records; de-identified or aggregated consumer information; and information governed by the federal Gramm-Leach-Bliley Act (GLBA), the federal Fair Credit Reporting Act, the California Financial Information Privacy Act, or the Driver’s Privacy Protection Act. We do not knowingly collect data on any consumer that is 16 years of age or younger.
We may collect “sensitive personal information,” however we do not sell or share such information.
In the last 12 months, we may have collected the following categories of personal information:
For each of the above categories, Truv uses the California Personal Information for a variety of business purposes such as:
Truv may also use the information Truv collects for our own or our service providers’ other operational purposes, purposes for which Truv provides you additional notice, or for purposes compatible with the context in which the California Personal Information was
Subject to certain exemptions, the CCPA provides California consumers the following rights:
You may request to exercise your Rights by contacting us that Contact listed below.
As required under applicable law, Truv will take steps to verify your identity before granting you access to information or acting on your request. Truv may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. Truv may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, Truv will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. Truv will require the agent to provide proof of that written permission. To the extent permitted by law, Truv may require you to verify your own identity in response to a request, even if you choose to use an agent.
If you are an authorized agent submitting a request on behalf of a California Party, please make a request as outlined below under “Contact Us”.
You do not need to create an account with us to submit a request to know or delete.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us using the contact information included in the section above called “Exercising Your Rights to Know or Delete.”
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We do not sell the personal information we collect.
We may revise this Privacy Policy from time to time at our sole
discretion. If there are any material changes to this Privacy Policy, we
will notify you as required by applicable law. You understand and agree
that you will be deemed to have accepted the updated Privacy Policy if you
continue to use the Services after the new Privacy Policy takes effect.
If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at: support@truv.com or +1 (855) 730-1221
[1] Usage Data
Information collected automatically through the Services(or third-party services employed in the Services), which can include: the IP addresses or domain names of the computers utilized by you while using the Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by you, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Services with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment.