Privacy Policy

Welcome to Truepic, Inc’s Privacy Policy.

Last updated: June 19th 2018

What does this Privacy Policy Cover?

TRUEPIC respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available 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) mobile applications, (iii) online mobile application management platform (together, the “TRUEPIC Sites”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

  • Who we are and how to contact us.
  • Your rights relating to your Personal Data.
  • Marketing communications preferences.
  • What Personal Data we collect.
  • How we use your Personal Data and why.
  • What happens when you do not provide necessary Personal Data?
  • Personal Data from Third Party Sources.
  • How we use cookies and other tracking or profiling technologies.
  • Who we share your Personal Data with.
  • Processing outside Europe.
  • How we keep your Personal Data secure.
  • How long we store your Personal Data.
  • Our policy on children.
  • Third party links.

This Privacy Policy aims to give you information on how TRUEPIC collects and processes your Personal Data through your use of the TRUEPIC Sites, including any data you may provide through TRUEPIC Sites.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.

Who we are and how to contact us.

Who we are.

Truepic, Inc., is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “TRUEPIC”, “we”, “us” or “our” in this Privacy Policy).

Our address is: TRUEPIC, 7660 Fay Ave, STE H 376, La Jolla, CA 92037, United States of America.

How to contact us.

You can contact us by emailing: [email protected].   

Our EU Representative

Our EU representative can be contacted directly by emailing them at the following address: [email protected].

Your rights relating to your Personal Data.

The rights you have in connection with Personal Data

By law you have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data.  We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of the TRUEPIC Sites. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown above. 

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, in certain circumstances we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: [email protected].

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority.

Marketing communications preferences.

You can ask us to stop sending you marketing messages at any time by:

  • following the opt-out links on any marketing message sent to you; or
  • contacting us at any time using the contact details shown above.

Where you opt out of receiving these marketing messages, this opt-out will not apply to service-related communications (and any processing of your Personal Data involved in sending such communications). As examples, these service-related communications may include: emails we may have to send you relating to the management of your account for the TRUEPIC Sites, your use of the TRUEPIC Sites, updates to this Privacy Policy etc.

What Personal Data we collect.

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified. 

It does not include ‘anonymous data’ (i.e., information which does not relate to an identified or identifiable individual) or ‘anonymised data’ (i.e., previously identifying information where the identity of individual has been permanently removed).

However, it 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).

Category of Personal Data collected

What this means

Identity Data

Your first name, surname, maiden name, last name, username or similar identifier.

Contact Data

Your email address and telephone numbers.

Profile Data

Your username and password, preferences and feedback tied to your account on the TRUEPIC Sites.

Image Data

The images, videos, graphics and other content you upload to the TRUEPIC Sites for certification and authentication and any metadata attached or related to such content (including the creator, date, time, device, and location of where such content was captured, together with certain contextual media relating to that content. Where we refer to “contextual media” relating to content, as some examples of what this means, we may capture: multiple frames before and after an image is taken using the TRUEPIC applications to help ascertain movement of the camera device, as well as ambient light sensor and barometric pressure information.

Transaction Data

Any details about payments to and from you and other details of subscriptions and services you have purchased from us.

Marketing and Communications Data

Your preferences in receiving marketing from us and our third parties and your communication preferences.

Technical Data

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the TRUEPIC Sites or use our services.

Aggregated Data

We also collect, use and share “Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate certain Technical Data and Behavioural Data to calculate the percentage of users accessing a specific feature of the TRUEPIC Sites. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it (as listed below in the table below), 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 update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data? 

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases: 

  • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

Generally we do not rely on your Consent as a legal basis for using your Personal Data.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose

Category(ies) of Personal Data involved

Why do we do this

Our legal basis for this use of data

Account creation and maintenance

  • Identity Data
  • Profile Data
  • Contact Data

To register you as a new customer and to maintain your account on the TRUEPIC Sites.

Contractual Necessity.

Service provision

  • Identity Data
  • Profile Data
  • Image Data
  • Contact Data
  • Technical Data

To provide you with the services and functionalities of the TRUEPIC Sites, including to:

  • authenticate and store the creator, date, time, device, and location of where content you upload to the TRUEPIC Sites is captured, as well as other information that enables us to verify an image; and
  • make the Image Data associated with content you upload to the TRUEPIC Sites publicly available through a URL that can be shared and accessed by third parties you share that URL with.

Contractual Necessity.

Payment Processing

  • Identity Data
  • Contact Data
  • Transaction Data

To process and manage payments, fees and charges for any subscriptions you may purchase to the TRUEPIC Sites (or any paid-for portion(s) thereof).

Contractual Necessity.

Fraud Prevention

  • Identity Data
  • Contact Data
  • Technical Data

To keep the TRUEPIC Sites, our services and associated systems operational and secure.

Legitimate Interests.

We have a legitimate interest in ensuring the ongoing security and proper operation of our services, the TRUEPIC Sites and associated IT services and networks.

Troubleshooting

  • Technical Data

To track issues that might be occurring on our systems.

Legitimate Interests.

It is in our legitimate interests that we are able to monitor and ensure the proper operation of the TRUEPIC Sites and associated systems and services.

Marketing

  • Identity Data
  • Contact Data
  • Marketing and Communications Data

To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

Legitimate Interests.

We have a legitimate interest in providing you with updates on the TRUEPIC Sites and related offers where you have purchased or shown interest in similar services from us.

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the TRUEPIC Sites).

In this case, we may have to stop you using the TRUEPIC Sites have with us but we will notify you if this is the case at the time.

Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third party data source

Publicly available?

Category(ies) or other types of personal data received.

Social Media sites

Yes

  • Identity Data
  • Contact Data 

How we use cookies & other tracking or profiling technologies.

Cookies.

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your 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:

  • first party cookies, served directly by us to your computer or mobile device; and
  • third party cookies, which are served by our partners or service providers on the TRUEPIC Sites.

Cookies we use

The TRUEPIC Sites uses the following types of cookies for the purposes set out below:

Type of cookie

Purpose

Essential Cookies

These cookies are essential to provide you with services available through the TRUEPIC Sites and to enable you to use some of its features. For example, they allow you to log in to secure areas of the TRUEPIC Sites and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow the TRUEPIC Sites to remember choices you make when you use the TRUEPIC Sites, such as remembering your language preferences, remembering your log-in details and remembering the changes you make to other parts of the TRUEPIC Sites which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit the TRUEPIC Sites.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to the TRUEPIC Sites and how users use the TRUEPIC Sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the TRUEPIC Sites. The information collected is aggregated – it includes the number of visitors to the TRUEPIC Sites, the websites that referred them to the TRUEPIC Sites, the pages they visited on the TRUEPIC Sites, what time of day they visited the TRUEPIC Sites, whether they have visited the TRUEPIC Sites before, and other similar information. We use this information to help operate the TRUEPIC Sites more efficiently, to gather broad demographic information and to monitor the level of activity on the TRUEPIC Sites.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how the TRUEPIC Sites works. You can find out more information about Google Analytics cookies here:  https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.

You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on the TRUEPIC Sites or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings. 

If you do not accept our cookies, you may experience some inconvenience in your use of the TRUEPIC Sites. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit the TRUEPIC Sites.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

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: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

Recipients

Category(ies) of Personal Data we share.

Why we share it

Location(s)

Our Hosting Provider

  • All Categories

We outsource the hosting of the TRUEPIC Sites. This means that all categories of Personal Data that we process will be held and stored on the servers of our hosted service provider.

  • Worldwide

Service Providers

  • Identity Data
  • Contact Data 
  • Technical Data
  • Marketing and communications data

Our service providers provide us with IT and system administration services.

  • Worldwide

Professional advisers

  • Identity Data
  • Contact Data

Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.

  • The United States
  • United Kingdom

Persons to whom you send a URL relating to your Image Data

  • Identity Data
  • Image Data
  • Technical Data

To enable those persons to whom you send the relevant URL to see the Image Data and confirm the authenticity of the relevant piece(s) of content you uploaded to the TRUEPIC Sites.

  • Worldwide

Processing outside Europe.

We are a U.S.-based company. Although we do not have an establishment within the European Economic Area (“Europe”), because we target the TRUEPIC Sites at individuals who are located in Europe, the GDPR (which is a European piece of data protection legislation) applies to us.

For this reason, we take appropriate steps to ensure that when we process your Personal Data (despite the fact that we are not based in Europe) we do so in accordance with the GDPR.

In addition, where we transfer your Personal Data to any of the third parties outlined above, we also take appropriate steps to ensure that we have implemented appropriate safeguards to ensure that such protection is maintained and is not undermined as a result of that disclosure.

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data.

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes).

Our policy on children.

The TRUEPIC Sites is not intended for children below 16 and we do not knowingly collect any Personal Data to such children.

Third party links.

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 Data. 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.

Truepic, Inc., 2018