Privacy Policy
I. Introduction
Effective Date: June 7, 2024
TRUE MANUFACTURING CO., INC., its subsidiaries and affiliates (collectively “TRUE”) has developed this Privacy Policy to explain how we may collect, retain, use, process, share and transfer your personal data when you visit our websites, purchase our products, or use our services. This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our websites, products, and services.
II. Our Commitment to Privacy
Our privacy commitments are fundamental to the way we run our business. These commitments apply to everyone who has a relationship with us – including customers, partners, and website visitors. TRUE is committed to providing you with the best overall experiences in all our products and services. We strive to strike the right balance between using your data to ensure the quality of those experiences and protecting your privacy.
III. Scope
This policy applies to all information we collect about you, information we collect directly from you, information we automatically collect, information we collect through our application(s) and information we collect from third parties.
IV. Personal, Anonymous and Aggregate Information
Personal data, also referred to as PII or personally identifiable information is information that identifies or reasonably can be used to identify you. Anonymous information (i.e. information that doesn’t or can’t be reasonably used to identify you specifically) and aggregate information (i.e. information taken from many peoples’ data that is combined into groups or categories) are not considered personal data. Examples of personal data include your: (i) Name, (ii) Mailing address, (iii) Email address, (iv) Phone number, (v) Date of birth or age, (vi) Credit/debit card number, (vii) Purchase information, (viii) Mobile device information, (ix) How you use our sites and mobile applications, (x) Geo-location related information, and (xi) Social media information. Anonymous information is information that doesn’t identify you and can’t reasonably be used to identify you specifically. Finally, aggregate information is information taken from many people’s data and combined into anonymous groups or categories.
V. The Personal Data We Use
Subject to limitations explained in this policy, TRUE may collect and use the following information:
-Your name and other personally identifying information
-Communication preferences and details
-Login and authentication information
-Online profile information
-Online activity
-Purchasing information
-Payment methods and history
-Information about the device(s) you use
-Information about your usage of our services
-Support information
-Cookies
-Copy of identification document (for credit approval or insurance purposes only)
-Payment information
-Subscription preferences
-Financial and credit history (for credit approval purposes only)
-Location information and GPS data
-Any other information you upload or provide to us.
VI. How We Use Personal Data
We use your information, including personal data, to provide you with the best products, service, and overall experience that we can. We may combine your information with other information that we have about you, that is publicly available and/or that we have obtained from third parties (either individually or in aggregate). We also use your personal data to support our business functions, such as credit approvals, fraud prevention, marketing, and legal functions. To do this, we combine personal and non-personal data, collected online and offline, including information from third party sources.
VII. Opting Out of Data Usage
If we intend to use your personal data for purposes other than those listed in this policy, or if we intend to disclose it to a third party acting as a controller not previously identified, we will only do so with your explicit consent.
VIII. Third-Party Processing
We will only share information we collect with our business partners and other third party partners as needed to supply our products or services. TRUE does not sell your PII. Sensitive information will only be shared for non-marketing purposes. When we provide sensitive information or other personal data to our business partners and other third parties, we require them to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which it was provided to them. “Non-marketing purposes” includes, but is not limited to, (1) Validating your identity, (2) Conducting statistical or demographic analysis, (3) Processing, fulfilling and tracking purchases or other transactions, (4) Complying with legal and regulatory requirements, (5) Customizing your experience on our websites and in person, (6) Protecting and defending against legal actions or claims, (8) Preventing fraud, (9) Collecting debt, (10) Satisfying contractual obligations, (11) Evaluating employment applications and (12) Cooperating with law enforcement or other government agencies for purposes of national security, public safety or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest.
IX. Retention of Personal Data
We follow applicable laws governing the retention of your data. The factors that influence how long we retain your data include:
(1) which information is needed to provide products, services and experiences to you,
(2) which information is needed to ensure secure payment, contact you and the data needed to serve any advertising based on personal interests and preferences.
We retain the data we collect from you for different periods of time depending on its classification and purpose. Data retention rules fall into one or more of the following categories:
(i) Information that we delete after a specific period of time or in response to an event – we store this data for a predetermined period of time. We set retention timeframes based on the reason for its collection and compliance with applicable law.
(ii) Information retained for specific business or legal purposes – Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when we process a payment for you or when you make a payment to us, we will retain this data for longer periods of time as required for tax or accounting purposes.
(iii) You may have the right to request deletion of personal information we collect from you based on your residence or citizenship, for example the EEA, Switzerland, UK and certain US States. You submit a request to delete your personal information by emailing us at [email protected].
X. Your Rights – EEA, UK and Switzerland
If you are a resident in the European Economic Area (“EEA”), Switzerland or UK you have the right to: opt-out of some collection or uses of your personal data, including the use of cookies and similar technologies and the use of your personal data for marketing purposes and the anonymization of your personal data for data analyses, access your personal data, rectify it, restrict or object to its processing, or subject to exemptions under law, request its deletion, receive the personal data you provided to us to transmit it to another company, withdraw any consent provided and where applicable, lodge a complaint with your supervisory authority.
Our employees in EEA have the right to lodge any complaints or concerns with the local data protection authority. You can find a list of the European DPAs here: https://ec.europa.eu/newsroom/article29/items/612080/en
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us by emailing [email protected].
XI. Your Rights – USA
TRUE honors web browser “Do Not Track” signals and similar mechanisms. You may request access to your PII, correct or delete PII and opt-out of the sale of your personal data, as applicable, by emailing [email protected].
XII. Your Rights – Canada
If you are a resident of Canada, you have the right to access your personal data and rectify it, withdraw any consent provided and, where applicable, lodge a complaint with your supervisory authority.
XIII. Exercising Your Rights
You may exercise any applicable rights described above by emailing us at [email protected]. If you wish to lodge a complaint with a supervisory authority, in Europe you may contact the necessary supervisory authority. In Canada you may contact the relevant supervisory authority. We may require additional information from you to verify your identity and residence before we can process your request. We also reserve the right not to restrict access to your information or to limit your rights (e.g., if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal data even if you withdraw your consent.
XIV. Adequate Protection
TRUE will take appropriate steps to make sure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and values. Also, transfers will be limited to countries which are recognized as providing an adequate level of legal protection, or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.
XV. Conflicts between Law and this Policy
If there is a conflict between this policy and an applicable law, applicable law will apply to you.
XVI. Impact of Automated Decisions
We will not take any action that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
XVII. Information Sharing with Authorities
TRUE will cooperate with law enforcement and regulatory officials and will disclose personal data in response to lawful requests.
XVIII. Sensitive Personal Data Use & Optout
If you send us sensitive personal data, we will only use that information for the purposes that you sent it. If there is an unanticipated use for the collected information not previously disclosed in this policy, we will post the policy changes on this website to keep you notified. You will then have the option to opt out of these new uses by emailing [email protected], sending your opt out preference via mail to 2001 E. Terra Lane, O’Fallon, Missouri 63366, Attn: True Privacy, or by calling 800-325-6152. If you are concerned about how your information is used, it is a good idea to periodically check this website.
XIX. Complaints
In certain jurisdictions, you have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal data. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us by emailing [email protected].
XX. Tracking Technologies
- Cookies. Cookies keep track of your visits to websites and activity online. A cookie is a small piece of data that is stored on your computer, tablet, or phone. TRUE uses cookies and similar technologies to improve our services. Cookies are not required for certain parts of our services such as to browse our website. Depending on the applicable laws of the region where you are located, you can choose not to allow some type of cookies. You may manage your cookies in your browser settings. If you are a resident of EEA, UK or Switzerland, your browsers’ settings may be set to decline cookies and alert you to opt-in when a website is attempting to place a cookie on your computer. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.
When your browser or device allows it, we use both session cookies and persistent cookies to better understand how you interact with our services, to monitor aggregate usage patterns and to personalize and otherwise operate our services such as by providing account security, personalizing the content we show you.
- Pixels. Pixels, like cookies, allow us to provide you with a superior website experience. Pixels are tiny or transparent images that allow us to establish a communication between you and a web server, which collects certain information about your computer or device. This information may include your IP address, browser type, operating system type and identifiers that have been stored in cookies. We may use beacons on our sites to count the number of visitors to our sites and to recognize users by accessing unique identifiers stored in cookies that we have set on their computers or devices. Being able to access these identifiers enables us to provide a personalized experience on our sites. We may also include beacons in advertisements or in email messages to determine how these are acted on.
XXII. Automatic Collection During Website Session
We use the data we collect during your time on our websites to improve your future experience. The data collected during the course of browsing our websites will be analyzed and used to generate statistics that help us improve our website, products and services to you.
XXIII. Restriction on Children’s Information
We do not knowingly collect personal data online from minor children under the age of 18 or sell their personal information. Adults who interact with TRUE websites should take care not to provide any information about children under the age of 18. To learn more about the Children’s Online Privacy Protection Act (COPPA) please visit the Federal Trade Commission’s (FTC) website at https://www.ftc.gov/.
XXIV. Legal Basis for Processing
We will only collect, use and share your personal data where we are satisfied that we have a legal basis to do so. In these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights.
XXV. Worldwide Transfer
TRUE may share customer information within our family of companies for a variety of purposes, such as providing you with the latest information about our products and services and offering you our latest promotions. To facilitate our global operations, TRUE may transfer personal data from your home country to other locations across the world. To protect your personal data, we will only transfer data to countries that provide an adequate level of personal data protection. If the data is transferred to countries without adequate protection, we will use additional safeguards to ensure your data is protected.
XXVI. GDPR Rights
If you are an EU citizen or resident, you have the following rights under GDPR: (i) request access to your personal data, (ii) request rectification of your personal data, (iii) request erasure of your personal data, (iv) request restriction of processing of your personal data, (v) request data portability, (vi) object to the processing of your personal data (including objection to profiling) and (vii) withdrawal of your consent at any time. Below please find further information on your rights to the extent that the GDPR applies. Please note that these rights might be limited under the applicable local data protection law.
XXVII. Definitions
– “Personal data”, “personal information”, or “PII” means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly — in particular, by reference to an identification number or to one or more factors specific to their physical, physiological, mental, economic, cultural or social identity.
– “Special Categories of Personal Data” pertains to personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and the processing of data concerning health or sexual orientation.
– “Sensitive personal data” either indicates “special categories” (see above), or is personal data of which the sensitivity level has been assessed and classified, indicating potential severe impact on an individual when confidentiality of such data is breached.
– If applicable under CPRA, “Sensitive personal information” means: (A) personal information that reveals your social security, driver’s license, state identification card, or passport number; account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of your mail, email and text messages, unless we are the intended recipient of the communication; genetic data; and the processing of biometric information for the purpose of uniquely identifying you; (B) personal information collected and analyzed concerning your health; or (C) personal information collected and analyzed concerning your sex life or sexual orientation. Note that “Sensitive personal information” excludes information that is made publicly available. You have the right to limit our use of your Sensitive Personal Information in certain circumstances. To exercise this right, email us at [email protected] under the Subject Line “Limit the Use of my Sensitive Personal Information” via mail to 2001 E. Terra Lane, O’Fallon, Missouri 63366, Attn: True Privacy, or by calling 800-325-6152.
– “Anonymization” is the deletion or changing of personal data in such a way that it can no longer be foreseeably assigned to a certain or ascertainable individual or only with a disproportionately high effort in terms of time, cost, and work.
– “Pseudonymization” is the replacement of an individual’s name and other identifiable characteristics with a label to prevent identification of the individual by unauthorized parties or to render such identification substantially difficult. Pseudonymization techniques include certain levels of masking, redaction, tokenization and/or encryption of personal data.
– “Consent” is any freely given, specific and transparently, unambiguous, well-informed indication of the will of the individual, whereby the individual agrees that their personal data may be processed. Particular requirements about consent can arise from the respective national laws. Where possible, consent is obtained in an explicit manner (unambiguously).
