Your first name, surname, maiden name, last name, username or similar identifier.
Welcome to Truepic, Inc’s Privacy Policy.
Last updated: June 19th 2018
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:
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.
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, 7817 Ivanhoe Ave, Suite 210, La Jolla, CA 92037, United States of America.
You can contact us by emailing: privacy@truepic.com.
Our EU representative can be contacted directly by emailing them at the following address: EURep@truepic.com.
By law you have the right to:
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.
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: privacy@truepic.com.
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.
You can ask us to stop sending you marketing messages at any time by:
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.
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).
Your first name, surname, maiden name, last name, username or similar identifier.
Your email address and telephone numbers.
Your username and password, preferences and feedback tied to your account on the TRUEPIC Sites.
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.
Any details about payments to and from you and other details of subscriptions and services you have purchased from us.
Your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
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.
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.
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.
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:
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.
Category(ies) of Personal Data involved
Why do we do this
To register you as a new customer and to maintain your account on the TRUEPIC Sites.
Our legal basis for this use of data
Contractual Necessity.
Category(ies) of Personal Data involved
Why do we do this
To provide you with the services and functionalities of the TRUEPIC Sites, including to:
Our legal basis for this use of data
Contractual Necessity.
Category(ies) of Personal Data involved
Why do we do this
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).
Our legal basis for this use of data
Contractual Necessity.
Category(ies) of Personal Data involved
Why do we do this
To keep the TRUEPIC Sites, our services and associated systems operational and secure.
Our legal basis for this use of data
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.
Category(ies) of Personal Data involved
Why do we do this
To track issues that might be occurring on our systems.
Our legal basis for this use of data
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.
Category(ies) of Personal Data involved
Why do we do this
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.
Our legal basis for this use of data
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.
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.
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.
Publicly available?
Yes
Category(ies) or other types of personal data received.
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:
Cookies we use
The TRUEPIC Sites uses the following types of cookies for the purposes set out below:
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.
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.
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.
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
The table below describes who we share your Personal Data with, what we share and why we share it.
Category(ies) of Personal Data we share.
Why we share it
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.
Location(s)
Category(ies) of Personal Data we share.
Why we share it
Our service providers provide us with IT and system administration services.
Location(s)
Category(ies) of Personal Data we share.
Why we share it
Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.
Location(s)
Category(ies) of Personal Data we share.
Why we share it
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.
Location(s)
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.
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.
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).
The TRUEPIC Sites is not intended for children below 16 and we do not knowingly collect any Personal Data to such children.
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
