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Privacy Policy

Welcome to Truepic, Inc’s Privacy Policy.

Last updated: February 10, 2021

What Does This Privacy Policy Cover?

Truepic, (“Truepic,” “we,” “us,” or “our”) provides businesses 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) mobile applications, (iii) online mobile application management platform (together, the “Truepic Sites“) and explain our privacy practices.

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.

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

 

What Personal Information We Collect

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”). The California Consumer Privacy Act’s definition of Personal Information can be found here. 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 customers, 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.

 

Category of Personal Information collected

What this means

Identity Data

First name, last name, maiden name, username, or similar identifier.

Contact Data

Email address and telephone numbers.

Profile Data

Username and password, preferences and feedback tied to Truepic accounts.

Image Data

The images, videos, graphics and other content uploaded 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, and ambient light sensor and barometric pressure information.

Transaction Data

Any details about payments, subscriptions, and services users have purchased from us.

Marketing and Communications Data

User preferences for receiving marketing from us and our third parties and user communication preferences.

Technical Data

Internet protocol (IP) address, user 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 used to access the Truepic Sites or use our services.

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.

 

How We Use Personal Information

We use the Personal Information we collect for the following business and commercial purposes:

 

Purpose

Category(ies) of Personal Information Involved

Why We Use Data For This Purpose

Account Creation and Maintenance

·  Identity Data

·  Profile Data

·  Contact Data

To register new users and to maintain a user’s account on the Truepic Sites.

Service Provision

·  Identity Data

·  Profile Data

·  Image Data

·  Contact Data

·  Technical Data

To provide the services and functionalities of the Truepic Sites, including to: authenticate and store the creator, date, time, device, and location of where content a user uploads to the Truepic Sites is captured, and other information that enables us to verify an image; and make the Image Data associated with content a user uploads to the Truepic Sites publicly available through a URL that can be shared and accessed by third parties a user shares that URL with.

Payment Processing

·  Identity Data

·  Contact Data

·  Transaction Data

To process and manage payments, fees and charges for any subscriptions a user purchases to the Truepic Sites (or any paid-for portion(s) thereof).

Fraud Prevention

·  Identity Data

·  Contact Data

·  Technical Data

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

Troubleshooting

·  Technical Data

To track issues that might be occurring on our systems.

Marketing

·  Identity Data

·  Contact Data

·  Marketing and Communications Data

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

 

Who We May Share Personal Information With

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

Recipients

Category(ies) of Personal Information We Share

Why We Share It

Our Hosting Provider

All Categories

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

Service Providers

·  Identity Data

·  Contact Data 

·  Technical Data

·  Marketing and Communications Data

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

Professional Advisers

·  Identity Data

·  Contact Data

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

Persons to Whom a User Sends a URL Relating to an Individual’s Image Data

·  Identity Data

·  Image Data

·  Technical Data

To enable those persons to whom a user sends the relevant URL to see the Image Data and confirm the authenticity of the relevant piece(s) of content uploaded to the Truepic Sites.

Marketing Communications Preferences

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 (and 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, updates to this Privacy Policy etc.

 

How Long We Store Personal Information

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 (for example for regulatory purposes).

 

How We Use Cookies & Other Tracking or Profiling Technologies

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:

Type of Cookie

Purpose

Essential Cookies

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

Functionality Cookies

These cookies allow the Truepic Sites to remember choices individuals make when they use the Truepic Sites, such as remembering an individual’s language preferences, remembering an individual’s log-in details and remembering the changes am individual makes to other customizable parts of the Truepic Sites. These cookies provide a more personal experience and avoid individuals having to re-enter an their preferences every time they 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 an individual uses 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 and New Relic for this purpose. Google Analytics uses its own cookies. It is only used to improve how the Truepic Sites works.

You can discover more information about Google Analytics cookies here:  https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.

You can discover more about how Google protects an individual’s data here: www.google.com/analytics/learn/privacy.html.

New Relic provides a platform for monitoring the performance of web and mobile applications. You can learn more about New Relic cookies here: https://docs.newrelic.com/docs/browser/new-relic-browser/page-load-timing-resources/new-relic-cookies-used-browser.

Social Media Cookies

These cookies are used when an individual shares information using a social media sharing button or “like” button on the Truepic Sites or links an individual’s account or engages with our content on or through a social networking website such as Facebook, Twitter, or LinkedIn. The relevant social network will record when a user does this.

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

 

Our Policy on Children

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 [email protected] for assistance.

 

California Notices

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. Our website does not recognize “Do Not Track” browser signals.

 

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 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.

 

Legal Disclaimer

Nothing in this Privacy Policy restricts our ability to:

 

How to Contact Us

To contact us or make a complaint regarding this Privacy Policy or our practices in relation to Personal Information, please contact us at: [email protected] or write us at Truepic, 7817 Ivanhoe Ave, Suite 210, La Jolla, CA 92037.

Truepic, Inc., 2021