Who we are

Our website address is: https://truesource.io

Effective Date: August 27, 2021

Welcome, and thank you for your interest in TrueSource Technologies, Inc. (“TrueSource”), and our website(s), products, services, and applications (the “Services”). This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information. If you have any questions about this Privacy Policy, you can email us at support@truesource.io.

When you clicked “accept” or “agree” in connection with registering your account, we made available to you this Privacy Policy and the information handling practices described here. This Privacy Policy only covers TrueSource’s practices regarding personal information, and not information more generally. We may use aggregated, anonymized data that we derived from your personal information before you deleted it, but not in a manner that incorporates any of your personal information or would identify you personally.

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy. You may, of course, decline to share certain personal information with TrueSource, in which case TrueSource may not be able to provide to you some of the features and functionality found on the Services.

Information TrueSource Collects

We collect information to provide better Services to all our users. When you’re not signed into a TrueSource account, we store the information we collect with unique identifiers tied to the browser, application, or device you’re using. When you’re signed in, we collect information that we store with your TrueSource account.

Things You Create or Provide to Us

When you create a TrueSource account or otherwise use the Services, you provide us with personal information that includes your name and a password. You may also provide your mailing address and home/mobile phone number, or other personal information.

Your provision of this personal data is required for you to enter into the Terms of Use, as well as a contract with us. If you do not provide the minimum amount of personal data required to register an account, including your name and email address, you cannot use the Services, as this information is necessary for contractual reasons. Certain parts of the Services also require you to provide a mobile phone number, which is needed to protect against fraud and abuse. Please see “European Requirements” below for further information on the bases of our processing your personal information.

We also collect the content you create, upload, or receive from others when using our Services. This includes things like messages you write and receive, forum posts, and datasets.

Information We Collect as You Use Our Services

Your apps, browsers & devices

We collect information about the apps, browsers, and devices you use to access our Services or open one of our HTML emails by using different types of technology, including “clear gifs” or “web beacons.” This “automatically collected” information may include Internet Protocol address (also known as “IP address”) or other device address or ID, web browser or device type, the web pages or sites that you visit just before or just after the Services, the pages you view on the Services, and the dates and times that you visit the Services.

We use various technologies to collect and store information, including cookies, pixel tags, local storage, such as browser web storage or application data caches, databases, and server logs.

Your activity

We collect information about your activity in our Services, which may include:

• Views and interactions with content and ads.
• People with whom you communicate or share content.
• Which data products you view or download.

Cookies and web beacons

When you use the Services, we send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. For example, we use cookies to ensure proper navigation between pages on the Services. TrueSource may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services.

Persistent cookies can be removed. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. If you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

We may also implement on the Services third-party content, such as advertising or analytical services, that use “clear gifs,” “web beacons,” or other similar techniques, which allow the third-party content provider to read and write cookies to your browser or implement similar tracking mechanisms. This information is collected directly by the third-party, and TrueSource does not participate in that data transmission. Information collected by third parties in this manner is subject to that third party’s own data collection, use, and disclosure policies. We currently implement services provided by Google Analytics, Hubspot, and Hotjar.

Linked accounts

When you link an account you may have on a third-party service (such as a third party social networking site or email provider) to your TrueSource account, TrueSource collects certain information stored in connection with that account that you have configured that service to make available, including your email address, provider ID, first and last name, and profile picture. By linking your accounts in this manner, you authorize TrueSource to access and use your account on the third-party service in connection with your use of the Services.

Why TrueSource Collects Information

TrueSource uses the information we collect for the following purposes:

Provide Our Services

We use your information to deliver our Services, like hosting data products you upload or access. For example, we use the IP address assigned to your device to send you the data you requested, such as loading a data product. Another example is that we use unique identifiers stored in cookies on your device to help us authenticate you as the person who should have access to your TrueSource account.

Maintain & Improve Our Services

We also use your information to ensure our Services are working as intended, such as tracking outages or troubleshooting issues that you report to us. For example, we continuously monitor our systems to look for problems. And if we find something wrong with a specific feature, reviewing activity information collected before the problem started allows us to fix things more quickly.

And we use your information to make improvements to our Services – for example, to understand and analyze the usage trends and preferences of our TrueSource account members and to improve the way the Services work and look.

For example, we use cookies to analyze how people interact with our Services, which can help us build better products. It may help us discover that it’s taking people too long to complete a certain task or that they have trouble finishing steps at all. We can then redesign that feature and improve the product for everyone.

Develop New Services

We use the information we collect in existing Services to help us create new features and functionality.

Provide Personalized Services

We use the information we collect to customize our Services for you, including remembering your information so that you will not have to log-in again the next time you visit the Services if you haven’t signed out. We also use data to provide customized third party content and information. In addition, we may use the information we collect to provide personalized and relevant content and advertising, for example showing you events near your location based on your IP address.

Measure Performance

We use data for analytics and measurement to understand how our Services are used. For example, we analyze data about your visits to our sites to do things like optimize product design, monitor and analyze the operation and effectiveness of the Services and related activities, and monitor aggregate site usage metrics such as total number of visitors and pages viewed. We use a variety of tools to do this, including Google Analytics. Google Analytics relies on first-party cookies, which means the cookies are set by TrueSource. You can opt-out from Google Analytics by clicking here.

Communicate with You

Protect TrueSource, Our Users, and the Public

We use the information to help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm TrueSource, our users, or the public. For example, we collect and analyze IP addresses and cookie data to protect against automated abuse. This abuse can take many forms, such as sending spam to TrueSource users or launching a Distributed Denial of Service (DDoS) attack.

We also analyze your content to help us detect abuse such as spam, malware, and illegal content. When we detect spam, malware, illegal content, and other forms of abuse on our systems in violation of our policies, we may disable your account or take other appropriate action. In certain circumstances, we may also report the violation to appropriate authorities.

Managing and Deleting Your Information

Managing, Reviewing, and Updating Your Information

When you’re signed in to your TrueSource account, you can always review and update information by visiting your account profile.

Exporting, Removing, & Deleting Your Information

You can export a copy of content in your TrueSource account if you want to back it up or use it with a service outside of TrueSource by contacting us here: support@truesource.io. You may update, correct, or delete your profile information and preferences at any time by accessing your account settings page or editing your TrueSource account profile through the Services.

You can also delete your uploaded data products by using the available tools in our Services. If desired, you can delete your entire TrueSource account by choosing that option in your account settings page.

Please note that while your deletions are reflected promptly in active member databases, in some cases, we retain data for limited periods when it needs to be kept for legitimate business or legal purposes. See “Data Retention” below for more information.

There are other ways to control the information TrueSource collects whether or not you’re signed in to a TrueSource account, including configuring your browser to indicate when TrueSource has set a cookie in your browser. You can also configure your browser to block all cookies from a specific domain or all domains. But remember that our Services rely on cookies to function properly.

Data Retention

Information Retained Until You Remove It

As we describe above, you can delete your entire TrueSource account or selectively delete your uploaded data products by using the available tools in our Services. In some cases, rather than provide a way to delete data, we store it for a predetermined period of time. For each type of data, we set retention timeframes based on the reason for its collection.

Information Retained For Extended Time Periods for Limited Purposes

Sometimes business and legal requirements require us to retain certain information for specific purposes for an extended period of time. For example, when you create a data product, we may retain this information for a longer period of time for legal purposes. Reasons we might retain some data for longer periods of time include:

• Security, fraud & abuse prevention
• Financial record-keeping
• Complying with legal or regulatory requirements
• Ensuring the continuity of our services

Enabling Safe and Complete Deletion

When you delete data in your TrueSource account, we immediately start the process of removing it from the product and our systems. First, we aim to immediately remove it from view. For example, if you delete a data product you made, we will immediately remove that from the public-facing TrueSource website.

We then begin a process designed to safely and completely delete the data from our storage systems. Safe deletion is important to protect our users and customers from accidental data loss. Complete deletion of data from our servers is equally important for users’ peace of mind. This process generally takes around 2 months from the time of deletion. This often includes up to a month-long recovery period in case the data was removed unintentionally.

Each of our storage systems from which data gets deleted has its own detailed process for safe and complete deletion. This might involve repeated passes through the system to confirm all data has been deleted, or brief delays to allow for recovery from mistakes. As a result, deletion could sometimes take longer when extra time is needed to safely and completely delete the data.

Our services also use encrypted backup storage as another layer of protection to help recover from potential disasters. Data can remain on these systems for up to 6 months.

As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and timeframes defined in this article. We maintain systems designed to detect and remediate such issues.

Sharing Your Information

When You Share Your Information

Many of our Services let you share information with other people, and you have control over how you share. Any information that you voluntarily choose to include in an area of the Services accessible to other TrueSource members or the public, such as a public profile page or any posting, will be available to other TrueSource members who access that content or the public (as applicable). This also applies to information you choose to make available through features that connect to third-party services, if applicable.

Also, if you communicate directly with another TrueSource member, any information that you voluntarily choose to include in such communication with other TrueSource members will be available to such other members. Once you make your information available in any of these ways, it could be collected and used by the recipients without restriction. We urge TrueSource members to exercise common sense, prudence, and good judgment about what information to make available to others through the Services.

When TrueSource Shares Your Information

We do not sell your information. We do, however, disclose your personal information in connection with developing and maintaining the Services. We share your personal information in the following cases:

With your consent

We’ll share personal information outside of TrueSource when we have your consent. For example, if you give us permission to share your information with a third party who may be a prospective employer.

To operate data product sharing

TrueSource may disclose your personal information to the creators of other data products to enable our operation of creator collaboration. The terms of that disclosure are covered in the collaboration rules, which is a contract between you and the collaborating creator.

For external processing

We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer support. These third parties may have access to or process your personal information as a result of performing the services they were engaged to perform.

For legal reasons

We will share personal information outside of TrueSource if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, legal process, or enforceable governmental request.
• Enforce our Terms of Use, including investigation of potential violations, and take precautions against liability.
• Detect, prevent, or otherwise address fraud, abuse, security, or technical issues.
• Protect against harm to the rights, property or safety of TrueSource or our affiliates, our users, or the public as required or permitted by law.
• Protect the security or integrity of the Services and to protect or enforce third party rights.

We may share non-personally identifiable information publicly and with our partners — like publishers, advertisers, developers, or rights holders. For example, we share information publicly to show trends about the general use of our Services.

If TrueSource is involved in a merger, acquisition, or sale of assets, we’ll continue to ensure the confidentiality of your personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Our Commitment to Data Security

TrueSource uses a variety of physical, managerial, and technical safeguards designed to improve the security of our systems and your personal information.

If TrueSource learns of a security breach, we will notify you in accordance with applicable law.

Third-Party Websites

The Services contain links to websites and services provided by third parties. Any personal information you provide on third-party sites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links are displayed on the Services. We encourage you to learn about third parties’ privacy and security policies before providing them with personal information.

Our Commitment to Children’s Privacy

Protecting the privacy of children is especially important. For that reason, TrueSource does not knowingly collect or maintain personal information from persons under 13 years old, and no part of the Services is directed to persons under 13. IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER.

If TrueSource learns that personal information of children under 13 years old has been collected on the Services without verifiable parental consent, then TrueSource will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has obtained a user account on the Services, then you may alert TrueSource at support@truesource.io and request that TrueSource delete that child’s personal information from its systems.

If you are between the ages of 13 and 16 years old, you may not use the Services until TrueSource has received verifiable parental consent for your use of the Services. If you are between the ages of 13 and 17 years old or under the age of contractual majority in your country, you also may not collaborate with other creators until TrueSource has received verifiable parental consent for your collaboration with other creators.

Compliance & Cooperation with Regulators 

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data Transfers

Your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data, such as the European frameworks described below.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

European Requirements 

If European Union (EU) data protection law applies to the processing of your information, you can exercise your right to request access to, update, remove, and restrict the processing of your information. You also have the right to object to the processing of your information or export your information to another service. Please contact us at support@truesource.io to exercise these rights.

If you have any questions, you may contact our data protection office at support@truesource.io. If you have concerns regarding your rights under local law, you can contact your local data protection authority.

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage these settings in your TrueSource account.

When we’re pursuing legitimate interests

We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

• Providing, maintaining, and improving our Services to meet the needs of our users
• Developing new products and features that are useful for our users
• Understanding how people use our Services to ensure and improve the performance of our Services
• Customizing our Services to provide you with a better user experience
• Marketing to inform users about our Services
• Providing advertising to make many of our Services freely available for users
• Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our Services
• Protecting against harm to the rights, property or safety of TrueSource, our users, or the public as required or permitted by law
• Performing research that improves our Services for our users and benefits the public
• Fulfilling obligations to our partners like developers and rights holders
• Enforcing legal claims, including investigation of potential violations of our Terms of Use

When we’re providing a service

We process your data to provide a service you’ve asked for under a contract. For example, we process your information in connection with data products you create.

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to a legal process or an enforceable governmental request.

Model Contract Clauses

The European Commission has approved the use of model contract clauses as a means of ensuring adequate protection when transferring data outside of the EEA. By incorporating model contract clauses into a contract established between the parties transferring data, personal data is considered protected when transferred outside the EEA or the UK to countries that are not covered by an adequacy decision.

We rely on these model contract clauses for data transfers.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

We comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from European Economic Area member countries and the United Kingdom as well as Switzerland, respectively. TrueSource remains responsible for any of your personal information that is shared under the Onward Transfer Principle with third parties for external processing, as described in the “Sharing Your Information” section.

If you have an inquiry regarding our privacy practices in relation to our Privacy Shield certification, we encourage you to contact us at support@truesource.io. TrueSource is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC). You may also refer a complaint to your local data protection authority and we will work with them to resolve your concern. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.

As of July 16, 2020, we no longer rely on the EU-U.S. Privacy Shield to transfer data that originated in the EEA or the UK to the U.S.

California Requirements

If the California Consumer Privacy Act (CCPA) applies to your information, we provide these disclosures and the tools and contact information described in this Privacy Policy so you can exercise your rights to receive information about how TrueSource collects, uses, and discloses your personal information, to request access to and deletion of your information, and not to be discriminated against for exercising your privacy rights. You can exercise your rights by using these tools, which allow you to access, review, update and delete your information, and you may contact us at support@truesource.io to export and download a copy of it. You can also read more about TrueSource’s data retention periods in the “Data Retention” section, and the process we follow to delete your information.

TrueSource does not sell your personal information. We only share your information as described in the “Sharing Your Information” section of this Privacy Policy.

The CCPA requires a description of data practices using specific categories. The below sections use these categories to organize the information in this Privacy Policy.

Categories of personal information we collect:

Identifiers such as your name, phone number, and address, as well as unique identifiers tied to the browser, application, or device you’re using.

Information you create or provide, such as the content you create, upload, or receive from others when using our Services (like messages you write and receive, posts, notebooks, and data products).

Commercial information such as your payment information.

Internet, network, and other activity information such as views and interaction with content and ads; and information about the interaction of your apps, browsers, and devices with our services (like IP address).

Geolocation data, such as IP address.

Information stored in third-party service accounts that you link to your TrueSource account and that you have configured the third party service to make available.

Business purposes for which information may be used or disclosed:

Protecting against security threats, abuse, and illegal activity. TrueSource uses and may disclose information to detect, prevent and respond to security incidents, and to protect against other malicious, deceptive, fraudulent, or illegal activity. For example, to protect our services, TrueSource may receive or disclose information about IP addresses that malicious actors have compromised.

Auditing and measurement. TrueSource uses information for analytics and measurement to understand how our services are used, as well as to fulfill obligations to our partners like publishers, advertisers, developers, or rights holders. We may disclose non-personally identifiable information publicly and with these partners, including for auditing purposes.

Maintaining our services. TrueSource uses information to ensure our services are working as intended, such as tracking outages or troubleshooting bugs and other issues that you report to us.

Research and development. TrueSource uses information to improve our services and to develop new products, features, and technologies that benefit our users and the public.

Use of service providers. TrueSource shares information with service providers to perform services on our behalf, in compliance with our Privacy Policy and other appropriate confidentiality and security measures. For example, we may rely on service providers to help provide customer support.

Advertising. TrueSource processes information, including online identifiers and information about your interactions with advertisements, to provide advertising.

Legal reasons. TrueSource also uses information to satisfy applicable laws or regulations and discloses information in response to legal processes or enforceable government requests, including to law enforcement.

Parties with whom information may be shared:

Other people with whom you choose to share your information, like a public profile page or a forum posting.

Third parties to whom you consent to sharing your information, such as collaborating creators to enable your participation in the collaboration.

Service providers, trusted businesses, or persons that process information on TrueSource’s behalf, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

Law enforcement or other third parties, for the legal reasons described in “When TrueSource Shares Your Information.”

If you have additional questions or requests related to your rights under the CCPA, you (or your authorized agent) can contact TrueSource at support@truesource.io.

Contact information

If you have questions, you can contact TrueSource at support@truesource.io. You can also contact your data protection authority if you have concerns regarding your rights under your local law.

Changes and Updates to this Privacy Policy

We change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date the last changes were published and if changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

Our amended Privacy Policy will become effective on a going-forward basis as stated in the Terms, except that (i) unless you agree otherwise, we will use your personal information in the manner described in the Privacy Policy in effect when we received that information and (ii) if you do not agree with any changes to the Privacy Policy, you must terminate your TrueSource membership and cease use of the Services. Your continued use of the Services after a revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of the Privacy Policy.

TrueSource Contact Information

Please contact TrueSource with any questions or comments about this Privacy Policy, your personal information, our use and disclosure practices, or your consent choices through TrueSource Support at support@truesource.io.