Information We Collect
We may collect or process the following types of information about you. The specific information we collect about you will vary depending on how you interact with us.
- Contact information and personal identifiers, such as your name, address, email address, telephone number, and username or social media handle.
- Device identifiers, such as information about your device like your MAC address, IP address, or other online identifiers.
- Demographic information, such as your age, sex, ethnicity, and gender.
- Biometric information, such as facial geometry if you use certain of our virtual try-on applications.
- Professional or education information.
- Commercial information, such as the products or services you have purchased, returned or considered, and your product preferences.
- Payment information, such as your method of payment and payment card information (including payment card number, delivery address and billing address).
- Identity verification information, such as photo identification for in-store pick-ups at one of our retail stores, loyalty member ID, and authentication information (like passwords).
- Online or network activity information, such as information regarding your interaction with our websites, mobile applications, digital properties, and advertisements, information about your browsing and search history on our websites or mobile applications, and log file information like your browser type and webpages you visit.
- Geolocation information, such as information that can help identify your physical location (like your GPS coordinates or the approximate location of your device).
- Audio and visual information, such as recordings of your voice when you call our customer service and images we record through video surveillance in our offices.
- Health and medical information, information that you voluntarily provide in response to surveys or questionnaires, including physical characteristics or descriptions, and other data related to your body, diet, activities, or physiology.
User content, such as your communications with us and any other content you provide (including photographs and images, videos, reviews, articles, survey responses, and comments).
How We Collect Information
- Trulu collects personally identifiable information when you register for a Trulu account, when you use certain Trulu products or services, when you visit Trulu pages and when you enter contests, promotions or sweepstakes.
- If you register to become a Trulu Affiliate, Super Affiliate or customer, we may ask for your name, email address, birth date, gender, zip code, social security number and/or tax identification number. Once you register with Trulu and sign into our services, you are no longer anonymous.
- Trulu also automatically receives and records information on our server logs from your browser including your IP address, Trulu cookie information and the page you requested.
- Trulu also collects personal information related to your participation in our events. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event.
How We Use Information
Trulu uses information we collect about you for a variety of purposes, including:
- Processing your customer, Affiliate or Super Affiliate application, account creating, authentication, and management (managing user logins, passwords and profiles);
- Carrying out our rights and obligations arising from any agreements entered into between you and us (including to process, fulfill and notify you of the status of your product order, to process one-time or recurring payments, to process your product return and exchange request, and to provide you customer service);
- Changes to our policies and plans and other administrative matters;
- Preventing and detecting fraud against you or us;
- Sending you the latest marketing information about Trulu, our events, product/service specials, where you have consented to be contacted for such purposes;
- Creating promotional materials, statistical analysis, policies, marketing plans and strategies, company and intra-group communications, or other related business issues;
- Performing analytics in order to provide you with better services, to know your preferences and targeted communication;
- Improving existing products and services, researching and developing new products and services;
- Facilitating and improving your use of the Trulu Site;
- Complying with applicable laws and regulatory requirements and assisting with any governmental or police investigation; and
- Other purposes directly relating to any of the above.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you, seek your appropriate consent, or we will explain the legal basis other than the consent which allows us to do so.
Information Sharing and Disclosure
- Trulu restricts access to nonpublic information about its Affiliates, super Affiliates and customers to those persons employed by or contracted with Trulu who have a legitimate business need to know that information in order to provide products or services to its Affiliates, Super Affiliates, and customers.
- Trulu may share your personal information with:
- Affiliates and Super Affiliates. We may share your personal information with the Affiliate or the Super Affiliate who referred you and may need access to your personal information in order to monitor their sales activity and business development.
- Service Providers.We may transfer personal information to service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that process credit card payments, fulfill orders, and that provide website and application functionality, hosting, analytics, customer support including through automated virtual agent and live person chat, advertising and marketing services.
- Parties to a corporate transaction.We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation).
- Other third parties.In addition, we may disclose personal information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity, (iv) when disclosure of your personal information is otherwise required or permitted by law, or (v) with your consent.
Retention of Personal Information
Trulu may use “cookie” technology to obtain non-personal information from its online visitors. Cookies are information files that your web browser automatically places from your computer when you visit a website. Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. We do not extract personal information in this process nor do we provide this information to third parties. Cookies allow us to customize your user interface to speed up the navigation process and to make the Site experience more meaningful, fun and efficient. You can switch off cookies by setting your browser preferences, but you may not be able to utilize the features of our Site.
Your Privacy Rights and Choices
- TRANSPARENCY, ACCESS, CORRECTION, AND DELETION
Depending on where you reside and other legal limitations, you may have the right to (1) request more information about the categories and specific pieces of personal data we collect, use, disclose, and sell about you, (2) request access to your personal data, (3) request deletion of your personal data, (4) request correction of inaccurate personal data, and (5) opt out of certain processing activities. We will not discriminate against you if you choose to exercise any of your privacy rights.
- DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information that we collected 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 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 YOUR RIGHTS
To exercise the access, data portability, data correction, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Emailing us at Legal@Trulu.com
- Calling us at 800-281-4469
- Signing into your account and complete the form.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. Your 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.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 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 the verifiable consumer requests receipt. 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 useable 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 solicit personal information from or market to persons under the age of 16.
We will not discriminate against you for exercising any of your rights. Unless permitted by applicable laws, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by applicable laws that can result in different prices, rates, or quality levels. Any law-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Certain portions of the Site may require registration. If you register with the Site, you will receive a password and account number upon completing the registration process. You are responsible for maintaining the confidentiality of the password and account and are fully responsible for all activities that occur under your password or account. You agree to (a) immediately notify Trulu of any unauthorized use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session.
- Your Trulu Account Information is password-protected for your privacy and security.
- In certain areas Trulu uses industry-standard SSL-encryption to protect data transmissions.
In the instance in which the Materials on the Site are available in several languages and there are inconsistencies between the content of the different texts, the version in English will prevail.
We reserve the right, without notice and in our sole discretion, to terminate your license to use the Site and to block or prevent future access to and use of the Site. If any provision of these Site terms shall be deemed unlawful, void or for any reason unenforceable, then that provision shall be deemed severable from these Site Terms and shall not affect the validity and enforceability of any remaining provisions.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
If you are a California resident, California law requires us to disclose the following additional information with respect to our collection, use, and disclosure of personal data. If you are a California resident, this section applies to you.
Collection and Use of Personal Information
We may have collected and disclosed your personal information to certain categories of third parties within the last twelve (12) months:
|Category||Examples||Collected and Disclosed to Third Parties|
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||
|B. Personal information categories listed in the California Customer Records statue (Cal. Civ. Code 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||
Please refer to “How We Collect Information” and “How We Use Information” sections to see how we obtain and use the categories of personal information listed above.
Collection and Use of Sensitive Personal Information
We may collect certain categories of personal information that may be considered “sensitive personal information” under California law. Trulu only collects sensitive personal information with your consent and only uses the sensitive personal information for the use disclosed at the time of collection. For example, we may collect your bank card information to process your payment. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
Sharing Personal Information
We do not sell or share your personal information for monetary consideration. Certain advertising practices, such as those described in the “How We Use Information” section, may be considered a “sale” under California law when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We do not allow third parties who purchase the personal information we hold from to resell it unless you have received explicit notice and an opportunity to opt-out of further sales. Please refer to above “Information Sharing and Disclosure” section for more information.
Your California Rights and Choices
California residents have the following rights with respect to their personal information:
- To know what personal information is collected.
- To access personal information.
- To correct personal information.
- To delete personal information.
- To opt-out of the “sale” of personal information.
- To opt-out of “sharing” of personal information for cross-context behavioral advertising.
- To limit the use of sensitive personal information.
- To non-discrimination.
Please refer to above “Your Privacy Rights and Choices” section for more information about your privacy rights and how to exercise them.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Legal@Trulu.com.