Last updated: November 1, 2022
Truepic, (“Truepic,” “we,” “us,” or “our”) provides businesses (our “Clients”) a comprehensive photo and video verification platform. In providing these services, we process the Personal Information of our Clients’ customers (“Users”). Truepic respects the privacy of its Users. We want to be transparent about how we collect and use Personal Information in providing our (i) website (https://truepic.com) and all its subdomains, and all other websites owned, operated or maintained, directly or indirectly, by Truepic and its affiliated companies, (ii) our mobile applications, (iii) online mobile application management platform (together, the “Truepic Sites“) as well as the services we provide to our Clients (the “Truepic Services”). With respect to the Truepic Services, Truepic operates as data processor in that we process Personal Information as directed by our Clients and do not take an independent use of such data.
With that in mind, this Privacy Policy describes:
This Privacy Policy is intended to explain how Truepic collects and processes its Users’ Personal Information in the course of using the Truepic Sites and Truepic Services.
We will post any modifications or changes to this Privacy Policy on this page.
We collect Personal Information both directly from you and from third parties. Personal Information is information about an individual that directly or indirectly identifies the person or household (“Personal Information”). Personal Information does not include ‘anonymous data’ (i.e., information which does not relate to an identified or identifiable individual) or ‘anonymized data’ (i.e., previously identifying information where the identity of individual has been permanently removed). Personal Information does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
Personal Information We Collect From You
When you use Truepic’s application or application management platform, we collect your Personal Information on behalf of our Clients, business partners, and third parties. For example, when you take a picture as part of an insurance claim, we collect your Personal Information on behalf of your insurance provider.
We also collect your Personal Information when you interact with us directly on our website. We collect this information through webforms and cookies and similar technologies as described in Section 6 of this policy.
Personal Information that we collect from you is outlined in the table below.
Personal Information We Collect from Third Party Sources.
In addition to the Personal Information that we collect directly from our Users, we also collect publicly available Identity Data and Contact Data from social media sites.
Aggregated Consumer Information.
We also collect, use and share “Aggregated Consumer Information“such as statistical or demographic data for any purpose. Aggregated Consumer Information may be derived from an individual’s Personal Information, but once aggregated, no longer constitutes Personal Information. For example, we may aggregate certain Technical Data and Behavioral Data to calculate the percentage of Users accessing a specific feature of the Truepic Sites.
We use the Personal Information we collect for the following business and commercial purposes:
There are certain circumstances under which we may disclose information to third parties. For example, we may share information:
Truepic is based in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as those of your country of residence. Truepic complies with legal requirements for cross-border data protection, including through the use of European Commission-approved Standard Contractual Clauses and similar contract language required under applicable data protection laws.
The table below describes who we share Personal Information with, what we share and why we share it.
Some jurisdictions require that we obtain a consent prior to sending marketing messages.
A user can ask us to stop sending marketing messages at any time by:
Where a user opts out of receiving these marketing messages, this opt-out will not apply to service-related communications or any processing of an individual’s Personal Information involved in sending such communications. Service-related communications may include emails relating to the management of a user’s account, an individual’s use of the Truepic Sites or Services, updates to this Privacy Policy, etc.
Third-party Marketing.
We do not provide your information to third parties for their direct marketing purposes.
Do Not Track.
We may collect information about your usage and activity through cookies as described above. Some web browsers or smartphones have the ability to set “Do Not Track” requests to block user activity from being tracked across web pages or devices. The Truepic sites do not recognize “Do Not Track” browser signals.
We will retain Personal Information only for so long as reasonably needed for the purposes set out above unless a longer retention period is required by law.
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of an individual’s computer or mobile device by a website. We may use both session cookies (which expire once individuals’ close their web browser) and persistent cookies (which stay on an individual’s computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Truepic Sites.
We use two broad categories of cookies:
How We Use Cookies
The Truepic Sites uses the following types of cookies for the purposes set out below:
Disabling cookies
A user can typically remove or reject cookies via browser settings. This can be done by following the instructions provided by the web-browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until a user changes these settings.
If an individual does not accept our cookies, the individual may experience some inconvenience in the use of the Truepic Sites. For example, we may not recognize the computer or mobile device in use and may require a new log in every time our Users visit the Truepic Sites.
For more information on how to customize browser Cookie settings, please visit the relevant link below:
For further information about cookies, including how to see what cookies have been and how to manage and delete them visit allaboutcookies.org.
You can also prevent the use of Google Analytics relating to your use of the Truepic Sites by downloading and installing the browser plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en-GB
The Truepic Sites and Services are intended for Users who are 18 years or older and we do not knowingly collect information from children under 18 years old. If we become aware that we have collected information from a child under 18 years old, we will delete such information from our records. If you are a parent or legal guardian and believe your child has given us information and you did not provide consent, please email us at privacy@truepic.com for assistance.
The California Consumer Privacy Act (CCPA) provides additional privacy protections for California consumers, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). Many other states have or will soon adopt similar privacy laws. We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honor a right if doing so would violate applicable law.
If you are a Client or partner of Truepic and have questions about your ability to see the data used to login to our systems, we ask that you direct your question to the person that owns the business relationship. If you are a User and want to see what data we may have obtained about you on behalf of one of our Clients, kindly reach out to that individual Client – keeping in mind that any information that we have is typically provided by Clients and/or their Users.
Regardless of where you reside, you may access those rights with respect to Truepic by clicking the link entitled “data subject access request” in the footer at the bottom of this page, or calling our California privacy helpline at +1 (888) 572-0516. As a California data subject, if you make a subject access request as set out in this policy, you are entitled to see and delete the personal information that we have about you. We will confirm your request within 10 business days and make a good faith attempt to fulfill your request within 45 days.
The CCPA and most other state laws define personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.
We may take reasonable steps to verify your request. We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request.
You may make an access or deletion request via an authorized agent by having such agent follow the process outlined above. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. And we will attempt to verify your request. We require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.
While most of our Clients are located in the United States, their Users may use the Truepic Service while travelling outside the U.S. where different privacy and data protection laws apply. For example, the General Data Privacy Regulation (“GDPR”) affords additional rights to EEA data subjects and the UK, Switzerland and Brazil have each enacted similar data protection laws to the GDPR. Places such as Canada and Japan have also adopted similar data protection laws. For the purposes of this privacy policy, we’ll refer to the GDPR to indicate the respective data protection laws in each of those places and use the term “personal data” which is very similar to the Personal Information defined herein.
The Truepic Sites and Services collect a limited data set on data subjects located outside of the United States (e.g., in the UK, EEA, Switzerland.) We typically collect this data when our Clients’ Users leverage the Truepic Sites and Services from outside the U.S. For example, if a User accesses the Truepic Sites and Services from outside the U.S. to upload a photo after a car accident, this will may implicate the data protection laws of the place from which the User is currently located.
As an EEA, UK, or Swiss data subject (and in many other places), you have the right – partly under certain conditions:
You may access those rights with respect to Truepic by contacting us at privacy@truepic.com and/or as you login to our systems as a Client or User. We may receive certain personal data from the personnel of our Clients and partners where such personnel is located in the EEA or other places outside of the United States. For example, some Clients and partners may provide email and login credentials to login to our systems. We encourage the personnel of such partners to first reach out to the person that manages the business relationship between Truepic and your organization. If you are a User and want to see what data we may have obtained about you on behalf of one of our Clients, kindly reach out to that individual Client – keeping in mind that any information that we have is typically provided by Clients and/or their Users.
The legal basis for processing data collected via Truepic.com is our legitimate interest. Where we rely upon legitimate interest, we have assessed the processing is not high risk, does not involve the processing of sensitive data or the creation of intrusive profiles. The rest of the personal data processed via the Truepic Sites and Services is processed as a “data processor” – meaning that we process such data per the instructions of our Clients and for no other purpose.
The security of your information is important to us, including but not limited to the Personal Information collected via the Truepic Sites and Services. Truepic has implemented reasonable security measures to protect the information, both during transmission and once it is received. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security. If you have any questions about these security practices, please email privacy@truepic.com.
The Truepic Sites may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Information. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Truepic Sites, we encourage you to read the privacy policy of every site you visit.
Nothing in this Privacy Policy restricts our ability to:
To contact us or make a complaint regarding this Privacy Policy or our practices in relation to Personal Information, please contact us at: privacy@truepic.com or write us at Truepic, 402 W Broadway, Suite 400/PMB#5021, San Diego, CA 92101.
Truepic, Inc., 2022