1. Introduction
This Privacy Notice applies to all the products, services, websites and apps offered by TruVerus Inc., and other TruVerus Inc. affiliates (collectively "TruVerus Inc."), except where otherwise noted. We refer to those products, services, websites, and apps collectively as the "services" in this notice. Unless otherwise noted in your contract, our services are provided by TruVerus Inc. inside of Canada.
References in this Privacy Notice, to data, personal information or just information, are all references to Personal Data. Personal Data means information relating to a living individual who is, or can be, reasonably identified from information, either alone or in conjunction with other information (a "Data Subject").
If you want to identify your data controller please see the "Who is my data controller?" section below.
For a quick snapshot of how TruVerus Inc. treats personal information see our Privacy Basics.
2. Information we collect
2.1 Who are "you"?
We refer to "you" a lot in this Privacy Notice. To better understand what information is most relevant to you, see the following useful definitions.
Creators: You hold an account within a TruVerus Inc. service and you either directly create surveys, forms, applications, or questionnaires or you are collaborating on, commenting on, or reviewing surveys, forms, applications, or questionnaires within an account.
Respondents: You have received a survey, form, application, or questionnaire powered by a TruVerus Inc. service.
Panelists: You have signed up and agreed to take surveys sent to you by TruVerus Inc. on behalf of creators. We deal with panelists in an entirely separate section of our Privacy Notice, which you can read here.
Visitors: You are just visiting one of our websites because you are curious, or you have heard about us from our marketing and sales channels!
2.2 Information we collect about you.
(a) Contact Information.
You might provide us with your contact information, whether through use of our services, a form on our website, an interaction with our sales or customer support team, or a response to one of TruVerus Inc.’s own surveys or forms.
(b) Usage information.
We collect usage information about you whenever you interact with our websites and services. This includes which webpages you visit, what you click on, when you perform those actions, what language preference you have, what you buy and so on.
(c) Device and browser data.
We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, and browser type. If you are on a mobile device we also collect the UUID for that device.
(d) Information from page tags.
We use first party and third party cookies and tracking services that employ cookies and page tags (also known as web beacons) to collect data about visitors to our websites. This data includes usage and user statistics. Emails sent by TruVerus Inc. or by users through our services also include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We provide more information on cookies below and in our Cookies Notice.
(e) Log Data.
Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g. HTML pages, graphics, etc.), operating system versions, device type and timestamps.
(f) Referral information.
If you arrive at a TruVerus Inc. website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
(g) Information from third parties and integration partners.
We collect your personal information from third parties where, for example, you give permission to those third parties to share your information with us, where such information is publicly available online or through your device/browser data.
If you are a Creator, we may also collect:
Account Information
(h) Registration information.
You need a TruVerus Inc. account before you can use TruVerus Inc. services. When you register for an account, we collect your first and last name, username, password and email address. If you choose to register by using a third party account (such as your Google or Facebook account), please see "Information from third parties" below.
(i) Billing information.
If you make a payment to TruVerus Inc., we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number). If you provide a billing address, we will regard that as the location of the account holder to determine the TruVerus Inc. entity with whom you contract and the sales tax, if applicable, to be applied to your purchase.
(j) Account settings.
You can set various preferences and personal details on pages like your account settings page (or on your account settings page for our other products as applicable).
When you use our services, we may also collect the following data on your behalf for certain services:
(k) Address book information.
We may allow you to import email addresses and other contact information into an Address Book so you can easily invite people to take your surveys or fill in your form via our collectors. We do not use this data for our own purposes or to contact anyone, except at your direction.
(l) Survey/form/application data.
We store your survey/form/application data (questions and responses) for you and provide analysis tools for you to use with respect to this data.
(m) Profile information.
When you sign up for our services you are asked to provide us with information about yourself and to give us more detailed insights into who you are. This may include providing your photo so your administrator(s) and colleagues can identify you.
3. How we use the information we collect
3.1 Creator
We process personal data about you where:
You have consented;
We need to fulfill our contractual responsibility to deliver the services to you; or
We have a legitimate interest to:
improve the service experience; and
develop new products and service features.
In each of the instances where we describe how we use your data in this Privacy Notice, we have identified which of these grounds for processing we are relying upon.
You have consented to us using certain types of tracking and third party cookies on our websites. In particular:
Cookies and Similar technology. We or third party data and advertising platforms that we work with may use or combine multiple technologies, such as cookies, page tags, mobile identifiers and IP addresses to infer users' common identities across different services and multiple devices such as tablets, browsers, and mobile phones. We may do so, for instance, to tailor ads to users, to enable us to determine the success of our advertising campaigns and to improve upon them. These third party data and advertising platforms may sometimes use data that we provide to them in order to improve their technologies and their ability to match common devices to users. We also may use this technology to allow a Creator to measure the performance of their email messaging and to learn how to improve email deliverability and open rates. You can withdraw your consent at any time.
More details: The above data and techniques are used for personalized marketing, analytics, and related purposes. To learn more about interest-based advertising and how to opt-out of it, please see our Cookies Notice in Section 6. We use this data to personalize online marketing campaigns to be relevant to you and your interests in our services. By clearing your cookies in your browser settings, you will no longer see personalized messages in this way but you continue to see ads over the internet that are not based on the information you provided to TruVerus Inc. Depending on your geographic location you can also withdraw your consent using our in-product cookie management tools.
We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this Privacy Notice. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.
(a) Contact Information. We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (for as long as you do not opt-out).
More details: We use your email address to send you marketing (newsletters), unless you indicate a preference to opt-out and for general updates on your account. You can opt out of marketing communications at any time by clicking on the "unsubscribe" link in them and changing the relevant setting on your My Account page.
(b) How you use our services. We use information about how you use our services to improve our services for you and all users and to make recommendations to you and your organization about our other services.
More details: We collect information about the types of surveys/forms/applications you create (e.g. HR surveys), the types of plans you purchase and your account transactional behavior to build a profile about you so as to help direct you and your organization to other relevant features and services we offer and to optimize user experience.
We may also use usage information such as levels and nature of activity in your account and number of responses you are receiving to personalize the features and services we highlight for you and your organization in our Sites, improve user experience and to make recommendations to you and your organization about our services through our sales and marketing efforts.
(c) Device and browser data. We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based on your IP address.
More details: We collect this to help us improve your service experience through a specific device/browser by optimizing how the website looks in a particular browser, how your screen brightness affects your experience and to ensure the service operates optimally and as it should on different devices and browsers.
(d) Log data. We use log data for many different business purposes to include:
(i) To monitor abuse and troubleshoot.
(ii) To create new services, features, content or make recommendations.
(iii) To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services.
(iv) To fix bugs and troubleshoot product functionality.
(v) To investigate security issues.
More details: Your IP address is used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).
(e) Referral information. We use referral information to track the success of our integrations and referral processes.
(f) Third parties and integrations. We collect and use information from third parties and integration partners, where applicable to one of our services, to:
(i) Ensure you can sign-up to our service from a third party integration like Facebook/LinkedIn/Microsoft/Google/SSO;
(ii) To personalize our services for you; and
(iii) Ensure you can use our service in conjunction with other services.
See further information here on our API partners – for other TruVerus Inc. services see below or on the website for that service.
(g) Service and Marketing uses.
(h) Profiling. We combine information about you from third party sources with information we hold about you to create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve your service experience.
(i) Machine learning. We use machine learning techniques on certain data in order to provide users with useful statistics and more relevant insights from the data they have collected using our services and to optimize our marketing campaigns and for fraud detection.
(j) To manage our services we will also internally use your information and data, for the following limited purposes:
(i) To enforce our agreements where applicable;
(ii) To prevent or address potentially unlawful activities; and
(iii) To screen for and prevent undesirable or abusive activity.
(k) Legal uses. To respond to legal requests or prevent fraud, we may need to use and disclose information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
We collect and use the following on the basis that we have to use this information in order to fulfill our contract with you:
(l) Your Account Information. We need to use your account information to run your account, provide you with services, bill you for our services, provide you with customer support, and contact you or your organization about your service or account. We may also use billing information in aggregate to determine billing and payment trends and, as needed, to adjust or manage pricing at the individual level or across all service users. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You cannot opt out of these communications since they are required to provide our services to you.
(m) Your Profile. We process other aspects of your account information (like the personal information you provide about your job, your job title, and your marketing preferences) as well as information obtained from public sources, for legitimate interests like providing you with a personalized experience and relevant and useful marketing information as well as to make other product, feature and service recommendations to you and your organization to optimize the use of the services we offer. We also provide an opportunity for you to upload a photo so that your administrator(s) and colleagues can identify you.
You can object to us using your information as described above but in some cases, our ability to fully and properly provide our services to you may be impacted if you do not want us to collect or use the above data. Furthermore, your organization might control some of the data which you include in your profile and they can also edit or remove that information through the primary administrator(s) of that account.
In relation to Survey Data
(n) Your Content. We also use survey questions and responses on an aggregated or deidentified basis as described in this Privacy Notice. We will never sell individual response data or identify/contact individual respondents except on your request or where required by law. Feature descriptions will identify where this is feature linked. See our "Respondent" section.
Your plan's administrator(s) can transfer your survey questions and responses to, or share them with, other members in your team, including your plan's administrator(s) themselves. Your plan's administrator(s) can also delete your survey questions and responses. Your plan's administrator(s) may also have the ability to make changes to any aspects of your survey questions and analysis. Please refer to your organization's internal policies if you have questions about this.
Finally, if you use our survey tool, depending on the package you are on and the settings you have selected, your Respondents may reach the standard survey end page on completion of a survey. The end page is part of the TruVerus Inc. website. We may include our own research surveys and polling on this end page. These surveys are optional for any Respondent to take or skip.
3.2 Respondent
We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this Privacy Notice. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.
(a) Cookies (to include page tags). We collect information using cookies when you take a survey. These cookies are used to ensure that the full functionality of our survey service is operational, to ensure the survey operates appropriately and optimally. For more information please read our Cookies section below and our Respondent Cookies Notice. After completion of a survey, in most cases, you will be re-directed to our website and treated as a website visitor where other cookies may be used so you should read our Website Visitor section if this is of interest to you.
(b) Contact Information. We only use contact information to respond to an inquiry which you, as a Respondent, submit to us.
(c) How you use our services. We use information about how you use our services to improve our services for you and all users.
(d) Device and browser data. We use device data both to troubleshoot problems with our service and to make improvements to it. We also may infer your geographic location based on your IP address.
(e) Log data. We use log data for many different business purposes including the following:
(i) To monitor abuse and troubleshoot;
(ii) To create new services, features, content or make recommendations;
(iii) To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services; and
(iv) To fix bugs and troubleshoot product functionality.
(f) Third parties and integrations. We will collect and use information from third parties and integration partners to facilitate Creators in sending surveys/forms/applications/questionnaires to you.
(g) Machine learning. We will use machine learning techniques on response data, metadata (as described above) and cookie data, in order to provide Creators with useful and relevant insights from the data they have collected using our services, to build features, improve our services, for fraud detection and to develop aggregated data products. You can read more about this in relation to surveys below.
(h) To manage our services we will also internally use your information and data, for the following limited purposes:
(i) To enforce our agreements where applicable;
(ii) To prevent potentially illegal activities; and
(iii) To screen for and prevent undesirable or abusive activity.
(i) Legal uses. To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
Use of survey data
In general survey responses are controlled and managed by the Creator (the person who sent or deployed that survey). In those instances TruVerus Inc. is only processing those responses on behalf of the Creator.
Creator and Respondent trust is paramount to everything we do and so when we do use data about Respondents, we put Creators and Respondents first. When we do an analysis of response data we only do so once we aggregate and anonymize or pseudonymize the data.
We go into more detail below on how TruVerus Inc. uses survey data. A Creator has some controls over how we use responses in their Account settings and may have turned off our ability to apply machine learning to responses where it is linked to a specific product feature in some cases.
TruVerus Inc. uses data in the ways described below, for our legitimate interests as described in this section:
The data impacted by this section includes:
Survey type, question type and responses (at an aggregated and anonymized/pseudonymized level only)
Device data
Log data
TruVerus Inc. will use automated processes and machine learning, to analyze survey responses, which in turn helps us to:
Aggregate response data and activity:
We will do this so that we can identify trends, build product features that optimize responses, make product recommendations and provide guidance on which products and services work best in different scenarios.
Extract and analyze usage patterns:
By understanding Respondent interaction in different types of surveys we can:
improve our services and ease of use
undertake personalization for survey Creators and Respondents. If a Respondent does not want to be included in this personalization they can clear the cookies in their browser settings after taking a survey,
improve user experience, and
identify insightful data trends (which never identify any individuals).
3.3 Visitor
We process personal data about you where:
You have consented or;
We have a legitimate interest to:
improve the service experience; and
develop new products and service features.
In each of the instances where we describe how we use your data in this Privacy Notice, we have identified which of these grounds for processing we are relying upon.
When you have consented or we have a legitimate basis for doing so, we collect and use the following information about you:
(a) Contact Information. We use contact information to respond to your inquiries or send you information about our services, either where you have agreed to this at the point of providing your information or where you operate in a business which may be interested in our services and for as long as you do not opt-out.
(b) Cookies and similar technology. We or third party data and advertising platforms that we work with may use or combine multiple technologies, such as cookies, page tags, mobile identifiers and IP addresses to infer users' common identities across different services and multiple devices such as tablets, browsers, and mobile phones. We may do so, for instance, to tailor ads to users, to enable us to determine the success of our advertising campaigns and to improve upon them. These third party data and advertising platforms may sometimes use data that we provide to them in order to improve their technologies and their ability to match common devices to users.
As a result of the above data we collect, we also carry out the following processing for legitimate business interests pursued by us:
(c) User Profiles. We combine information about you from third party sources with information we hold about you to create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve our marketing/sales campaigns and website experience.
(c) Machine learning. We use machine learning techniques on certain data in order to optimize our marketing campaigns.
We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this Privacy Notice. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.
(e) Device data. We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based on your IP address.
(f) How you use our services. We use information about how you have interacted with our websites to improve our website services for you and all users.
(g) Log data. We use log data for many different business purposes including the following:
(i) To monitor abuse and troubleshoot;
(ii) To track your preferences and create new services, features, content or make recommendations personalized for you;
(iii) To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services; and
(iv) To fix bugs and troubleshoot product functionality.
(h) Referral information. We use referral information to track the success of our integrations and referral processes.
(i) To manage our services, we will also internally use your information and data, for the following limited purposes:
(i)To enforce our agreements where applicable;
(ii) To prevent potentially illegal activities; and
(iii) To screen for and prevent undesirable or abusive activity.
(j) Legal uses. To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
In some cases, as a former website visitor, we may not have any personal information about you.
4. Information you share
Many of our services let you share information with others. Remember that when you share information publicly, it can be indexable by search engines. Our services provide you with different options on sharing and deleting your content but we cannot delete content from search engines so you need to be careful about information you make public.
5. Information we share
We do not share your information or data with third parties outside TruVerus Inc. except in the following limited circumstances:
(a) If you are a Creator, your account information and data will be shared with the primary administrator(s) and your survey data may also be visible to other members in your team with whom you share your surveys or with whom you collaborate. Your administrator(s) will be able to view your account data, change your passwords, suspend, transfer or terminate your account or restrict your settings. Please refer to your organization's internal policies if you have questions about this.
(b) If you are using an email address on a domain owned by your employer or organization linked to your individual account, you may be asked to migrate to the organization’s account and your email address, name and account data will subsequently be visible to the primary administrator(s) for that account once you have been migrated. You may be notified in advance of this migration and given an opportunity to change the email address linked to your account if you are not using your account for business purposes.
(c) To help us provide certain aspects of our services we use our affiliates and trusted key partners – in particular, we engage third parties to:
(i) facilitate our collectors for sending surveys by email or text to Respondents. For email delivery, we use SparkPost and for text/SMS services we use Twilio. We share the relevant contact information for respondents (email address or phone number as applicable) with these third parties.
(ii) facilitate customers in making payments.
(iii) to detect fraud.
(iv) deliver and help us track our marketing and advertising content.
(v) help us track website conversion success metrics.
(vi) manage our sales and customer support services to you, including for resolving any disputes.
We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practices in privacy and security standards and we regularly review these standards and practices.
(d) On your instructions, we share your information or data if you choose to use an integration in conjunction with TruVerus Inc. services, to the extent necessary to facilitate that use. See further information here on our API partners.
(e) We also may have to share information or data for the following purposes:
(i) To meet any applicable law, regulation, legal process or enforceable governmental request;
(ii) To enforce applicable policies, including investigation of potential violations;
(iii) To detect, prevent, or otherwise address fraud, security or technical issues;
(iv) To protect against harm to the rights, property or safety of our users, the public or to TruVerus Inc. and/or as required or permitted by law; and
(v) To facilitate a sale, merger or change in control of all or any part of our company or business or in preparation for any of these events.
Where we use any third parties (subprocessor) to assist us in service delivery for you (the Creator), and they process your data as part of that service, we maintain a list of these third parties which is available here. This contains a list of all subprocessors used across all services covered by this Privacy Notice so please keep in mind that your service may only be impacted by a subset of these subprocessors.
6. Cookies
We and our partners use cookies and similar technologies on our websites. For more information see our Cookies Notice. For information about cookies used in our surveys please see Cookies used on Survey Pages. If you are a customer of TruVerus Inc. and separately use cookies or similar technologies in conjunction with any of our products and services, then you yourself will be responsible for complying with any laws related to the use of those technologies and this Privacy Notice is not applicable to that use by you.
We use certain cookies, as described in our Cookies Notice and here in our Privacy Notice, that you agree to when you use our sites and, in the case of some cookies, for legitimate interests of delivering and optimizing our services (where the cookie delivers essential functionality). Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies and similar technologies for several reasons:
(a) To gather metrics.
(b) To make our site easier to use. Creators: if you use the "Remember me" feature when you sign into your account, we store your username in a cookie to make it quicker for you to sign in whenever you return to our site.
(c) For security reasons. We use cookies to authenticate your identity and confirm whether you are currently logged into our site or determine if an incident impacts you.
(d) To provide you with personalized content. We store user preferences, your default language, device and browser information, your profile information which includes, the level of usage of service and the web-pages on our site which you visit, so we can identify you across devices and personalize the content you see.
(e) To improve our services and track our campaigns. We use cookies to analyze and measure your visits to and exploration of our websites and track referral data. This information helps us to develop and improve our services (it helps us focus on the parts of the service you seem most interested in), to optimize the content we display online and also to track the success of marketing campaigns.
(f) To advertise to you. We, or our service providers and other third parties we work with, place cookies when you visit our website and other websites or when you open advertising content online or emails that we send you, in order to provide you with more tailored marketing content (about our services or other services), and to evaluate whether this content is useful or effective. For instance, we evaluate which ads are clicked on most often, and whether those clicks lead users to make better use of our tools, features and services. If you don't want to receive ads that are tailored to you based on your online activity, you may "opt out" of many of the companies that are involved in such tailoring by going to [NTD – include web address]. Opting out in this way does not mean you will not see any ads; it just means that you will not see ads that have been tailored to you based on your activities and inferred preferences.
(g) Google Analytics. We use Google Analytics as a tool to measure the success of our advertising campaigns and referrals through third party advertising partners. The Google Analytics data collected for these purposes is aggregated and anonymous.
Where you have explicitly consented, or have not disabled third party advertising cookies (depending on your location), we will also use Google Analytics data to support display advertising, including re-targeting. In addition to customizing your preferences for these behaviors through steps we have outlined in our banners and privacy notices you can also customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center.
You can also choose to remove or disable cookies via your browser settings and, depending on your geographic location you can withdraw consent to non-essential cookies using the in-product cookie preferences tool.
7. Data Retention
If you are a Creator, we generally do not delete the data in your account as long as your account is active – you are responsible for and control the time periods for which you retain this data. You can read about this here for account use.
We also encourage Creators to actively review their data retention practices in their account and take care to retain data only as long as is strictly necessary.
We also describe the expiry periods for cookies on our websites in our Cookies Notice.
8. Safety of Minors
Our services are not intended for and may not be used by minors. "Minors" are individuals under the age of 19 (or under a higher age if permitted by the laws of their residence). TruVerus Inc. does not knowingly collect personal data from Minors or allow them to register. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.
9. Data Transfers and the General Data Protection Regulation (GDPR)
Your information and data may be processed in and transferred or disclosed in the Canada and countries in which our affiliates are located and in which our service providers are located or have servers. You can view where our affiliates are located on the Office Locations page. We ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into the appropriate back-to-back agreements. We apply our standard Data Processing Agreement to all our customer agreements and we use standard contractual clauses for the transfer of data as approved by the European Commission.
We have also provided a help article which answers some additional questions about data transfers to Canada.
General Data Protection Regulation (GDPR)
TruVerus Inc. certifies its compliance with the General Data Protection Regulation (GDPR). TruVerus Inc. is committed to subjecting all personal information received from the European Union (EU) member countries to the Regulation’s applicable principles.
TruVerus Inc. also complies with the onward transfer liability provisions of GDPR.
When TruVerus Inc. receives personal information under GDPR and then transfers it to a third-party service provider acting as agent on TruVerus Inc.’s behalf, TruVerus has certain liability under GDPR if both (i) the agent processes the information in a manner inconsistent with GDPR and (ii) TruVerus Inc. is responsible for the event giving rise to the damage. In certain situations, TruVerus Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security enforcement requirements.
Please contact TruVerus Inc. as described in Section 13 below if you have any concerns or complaints of any nature.
10. Changes to our Privacy Notice
We can make changes to the Privacy Basics and this Privacy Notice from time to time. We will identify the changes we have made on this page. In circumstances where a change will materially change the way in which we collect or use your personal information or data, we will send a notice of this change to all of our account holders.
11. Personalized marketing
You can opt-out from direct marketing in your account and we provide opt-out options in all direct marketing emails. Finally, if you do not wish to see personalized marketing content on the web related to our service you can clear the cookies in your browser settings. See our Help Center article on how to do this here.
12. Who is my data controller?
As mentioned above – all response data at an individual level is controlled by the Creator. TruVerus Inc. can be a data controller of data about Respondents only in the very limited ways described in the section here called "How we use the information we collect - Respondent". To the extent that is the case we have identified the correct controller below.
If you are located outside Canada, your data controller is [NTD – confirm if this is a different entity to TruVerus Inc.] to the extent that it is processing your personal data. For certain other services please see our Privacy Information Specific to Other Services page. For account holders through their organization, your organization controls some basic account level information which you input when setting up your account (like name, email address and profile photo). You can reach out to the primary administrator(s) of the account if you wish to delete, receive a copy, change or update that information.
13. Your rights
You may wish to exercise a right to obtain information about yourself or to correct, update or delete that information. For more information about these rights you can read about it here. Some of these rights may be subject to some exceptions or limitations in local law. Please note your rights and choices vary depending upon your location. We will take reasonable steps to verify your identity and we will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request) subject to the below for specific categories of person.
This section describes the rights you may have generally as a customer of any TruVerus Inc. service.
(a) Creator
Where you hold an account with any TruVerus Inc. service, you are entitled to a copy of all personal data which we hold in relation to you. You also may be entitled to request that we restrict how we use your data or object to some aspect of our treatment of your data. You can access a lot of your data in your own account when you log in. If you want to exercise your rights, please contact us here.
Depending on your plan type, TruVerus Inc. also enables you to export your own response data from our system in a variety of formats so that you can back it up or use it with other applications. Alternatively, for assistance in exporting you can contact us.
(b) Respondent
Where you have responded to a survey, form, questionnaire or application sent to you by a Creator using a TruVerus Inc. service, you will need to reach out directly to that individual or organization to discuss managing, deleting, accessing, restricting access to or otherwise withdrawing consent for use of the information which you provided to them in your responses. TruVerus Inc. does not control your response data and, accordingly, is not in a position to directly handle these requests in relation to that data. If you are having difficulties finding this Creator or if you have any other questions after reading this Privacy Notice, you can contact us through our support team and we will try our best to help you.
(c) Visitor
Where you have visited our website and you want to exercise any of the above rights please contact our support team here. Alternatively, if your request is for the right to be forgotten as it relates only to our use of cookies you can achieve this by clearing the cookies in your browser settings. See our Help Center article describing how to do this here.
(d) Third Party Agents
If you are a third party organization acting on behalf of a data subject (or class of data subjects) to exercise data subject rights, we do work with you. In this case:
(i) We ask you to follow our process outlined in this Privacy Notice for security reasons so that we can independently verify the Creator (if it is a Creator) making any requests to exercise their rights.
(ii) Where applicable, we directly interact with a Creator's registered email address, because we authenticate users with username and unique password and not with other identifying information (e.g. photo ID or similar).
Please do not share other forms of personal identification for data subjects with us when submitting requests.
(e) Other rights and choices
For rights and choices specific to Canadian consumers, please refer to our Region Specific Privacy Notice. Please note we will take reasonable steps to verify your identity and the authenticity of your request as described in that Notice.
14. Exercising your rights
Except as explicitly provided herein, please use the following contact information for privacy inquiries
TruVerus Inc.
2882 Gottingen Street
Halifax, Nova Scotia, B3K 3E2
Canada
Note that our contact form is the best way to make a rights request with us.
Complaints
If you are a resident in the European Union and you are dissatisfied with how we have managed a complaint you have submitted to us, you are entitled to contact your local data protection supervisory authority.