TrueContext Privacy Policy

TrueContext Inc., including its affiliates and subsidiaries (each, “TrueContext” and collectively, “we”), is committed to the protection of the personal information that we collect and/or maintain during the course of providing our services to you, including our delivery of the TrueContext application (aka the “TrueContext Service“).

All collection, use, and management of personal information by TrueContext is governed by this Privacy Policy (the “Policy“). We wrote this Policy to help you understand what information we collect, how we use it and the choices that you have in relation to your personal information. As used in this Policy, “personal information” means information about an identifiable individual and the “Website” means truecontext.com.

As explained further below, if you access and use the Website, the TrueContext Service or other TrueContexts services (collectively, “our services“), you consent to the collection, use and sharing of your personal information in accordance with this Policy, which includes our Cookie Policy.

Our services are not intended for use by children; they should only be accessed by individuals who are using our services for business purposes and are at least 18 years old.

1. How We Collect and Use Your Personal Information

When you access the Website and/or agree to use our services, you voluntarily give us certain personal information. This can include your name, email address, phone number, company name, IP address, cookie identifiers and any other personal information that you provide to us. Additionally, we may collect personal information about you via the Website or other online activities, such as:

1. If you respond to a job posting at TrueContext, we will collect certain personal information which may include your contact information, your employment history and education history, your LinkedIn profile information or other information contained in a resume or cover letter, or similar employment-related materials. We will use this information for the purpose of processing and responding to your application in relation to both current and future career opportunities.
2. If you contact us with a question, comment, or complaint (which may include a TrueContext Service issue), we may collect your name and contact information (such as your email address or mailing address) to respond to your request. We will keep a record of such communications in case we need to assist you again in the future.
3. If you request a free trial or a demo, register for free training, download content or register for a webinar, we may collect your name, job title, email address, your preferences such as language and time zone, the types of communication you would like to receive from us and certain information about your company such as company name and address. We will use this information to contact you and otherwise facilitate your free trial, demo, training, content download and/or webinar participation.
4. If you participate in a message board, forum, chat room or other community service, we may collect your name and email address and certain information about your company such as company name and address, as well as any comments, suggestions, and other feedback you provide as postings. We may use your comments, suggestions, or feedback to monitor and/or improve our services and our Website. Please remember that any information that you provide in these comment areas is accessible to the public and you should exercise caution when deciding to disclose any personal information about yourself or anyone else. For clarity, we are not responsible for any personal information you choose to submit to a message board, forum, chat room or other community service.
5. If you enter a contest or promotion sponsored by TrueContext or participate in one of our surveys, contests or events (such as webinars and in-person events), engage with us in relation to customer research or request information from us about our services, we may collect information about you in regards to the survey, contest, event, research activity or inquiry such as your name, email address, telephone number, and certain information about your company such as company name and address. We may associate such information with your individual customer account and use it to facilitate your participation in the survey, contest, event or research activity; to respond to your inquiry; and/or to improve your overall customer experience by helping us better understand our customers.
6. We may use your name, user name, email address, and company name/address as a unique Single Sign-On (SSO) identifier for the purpose of authentication to facilitate your ability to gain access to multiple TrueContext’s systems, websites, apps and platforms via only one sign-on process using only one set of credentials.
7. If you sign up to receive TrueContext emails on certain pages of our Website, or if you have provided your contact information to us for the reasons set out in (iii), (iv) or (v) above, we may also send you mail or e-mail regarding services that we believe are of interest to you. If you do not want to receive such mailings from us, you may “opt-out” by managing your email preferences via use of the unsubscribe mechanism in any of our emails.

It is important to note that while you can generally visit the Website without telling us who you are or submitting any personal information, we do create and record certain technical information automatically. Some of the types of technical information we automatically collect include:

1. Cookie Data: Our Website, like many other commercial websites, uses a standard technology called a “cookie“. A cookie is a small piece of data (text file) that a website – when visited by a user like you – asks your browser to store on your device (such as your computer or smart phone) in order to remember information about you, your preferences (such as your language of choice) or your device information, when you return to it. Such cookies are set by us and are called “first party cookies”. We also use “third-party cookies” (which are cookies from a domain different than the domain of the website you are visiting) for our advertising and marketing efforts. While cookies themselves do not contain any personal information, by linking the information we store in cookies to personal information you submit while on our Website, they allow us to offer you a better user experience. Cookies help make your visit to our Website more user friendly by allowing us to analyze usage information, feedback, support queries, and survey responses to help us better understand your use of the Website and make improvements to our services. When you browse our Website, we may use a cookie to help us provide you with better customer service by (i) identifying your browser as one that has visited our Website before; and (ii) saving and remembering any preferences that you may have set during previous visits to our Website. Any personal information collected about you through our use of cookies will be treated in accordance with this Policy.
   
   If you do not want cookies sent to or stored on your system, most Internet browsers will allow you to delete or reject cookies and/or be notified when you receive a cookie (which will then give you the opportunity to decide whether you want to accept the cookie or not). You can manage your consent preferences at any time to accept or reject the use of various categories of cookies which are not strictly necessary through our Privacy Preference Center (Customize settings). Note that if you disable cookies and similar technologies, some features of our services (including the Website) may not work as intended. Many of the interactive functions offered by websites are dependent on cookies and disabling or blocking cookies can prevent these services from working or reduce their usefulness.
   
   Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies as soon as you visit the Website. If you continue to use the Website, you agree to our use of cookies, as explained in our Cookie Policy.
2. Web Beacon Data: This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.
3. Log Data: Our servers automatically record certain information (“log data”) including information that your browser or mobile app sends whenever you visit a website. This log data may include your IP (Internet protocol) address, the address of the web pages you visited and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website.
4. Device Information: In addition to log data, we may also collect information about the device you are using, including what type of device it is, what operating system you’re using, device settings, unique device identifiers, and crash data. Whether we collect some or all this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please also check the policies of your device manufacturer or software provider.
5. Third Party Advertisers: We may use third parties to serve our advertisements on other websites. These companies may use cookies, tracer tags or web beacons to (i) collect information (such as web pages you visit and your response to ads) when you visit our Website and use that information to serve advertisements tailored to your interests on our Website or other third-party websites and/or (ii) for analytical purposes to better understand digital interactions with our services.
6. Sites and Services of Others: Our Website may contain links to other websites that are provided and maintained exclusively by third parties. We carefully select the third party websites to which we link; however, as such third party websites are not subject to this Policy and are governed by their own privacy policy and terms of use, we are not responsible for such third parties’ content or privacy practices. We encourage you to read the privacy policy of every website you visit as the operations of linked websites may also collect your personal information and information generated with cookies when you link to these websites.

2. Consent and Acceptance of this Policy

By using our Website, the TrueContext Service or other TrueContext services, you certify that you (i) have read and understood this Policy; and (ii) accept all the terms conditions described in this Policy, including without limitation, terms and conditions relating to our collection and processing of your personal information and our use of cookies. Depending on the situation, TrueContext may obtain consent to the collection of personal information in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of our Website, the TrueContext Service or other TrueContext services, or when you approach us to obtain information, inquire about or request services from us. We will indicate when your consent is required as a condition of obtaining a service.

3. Sharing Personal Information

As a matter of practice, and in compliance with California Consumer Privacy Act (“CCPA”), and General Data Protection Regulation (“GDPR”), TrueContext does not disclose, trade, rent, sell, share or otherwise transfer personal information provided to us to any third party. For clarity, personal information provided to us is processed only by us, except as set out in this Policy and, in the case of personal information provided to us via the TrueContext Service, as provided in the Subscription Agreement between TrueContext and our customers.

We may share and disclose information (including personal information) in the following instances:

Employees: Our employees may need to access information about you in order to perform their job. For example, a customer support representative would need access to your account to validate your identity and respond to your question or request; our email communications team would need access to your contact information to ensure this information is sent correctly and any unsubscribe requests are properly managed; and our security staff would need to review information to investigate attempted denial of service attacks, fraudulent account activity, or other attempts to compromise our services. All our employees are required to agree to maintain the confidentiality and protect the privacy of your personal information.

Service Providers, Partners and Sub-Processors: We currently do not share personal information with third parties for their direct marketing purposes without your permission. We may disclose or transfer personal information to our partners, consultants, sub-processors and suppliers who provide services on our behalf (collectively, our “service providers“); however, these service providers are (i) only given the information they need to perform their designated functions; (ii) not authorized to use or disclose personal information for their own purposes; and (iii) required to agree to obligations consistent with this Policy and any other appropriate confidentiality and security measures deemed necessary by us.

Customer Organisation: If your employer or an entity purchases services on your behalf, we may disclose personal information such as your name and email address and information relating to your use of the TrueContext Service to such employer or entity.

Sale of Business: TrueContext may disclose or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure, or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of TrueContext, or of any of the business or assets or shares of TrueContext.

Legal Obligations: We and our service providers may provide personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable law. We may also disclose personal information where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons, data or property. We will attempt to notify you about legal demands for your personal information when appropriate in our judgment, unless prohibited by law or court order, or when the request is an emergency.

4. Safeguarding and Data Security

We understand that data security is an important issue, and we are committed to safeguarding all personal information provided to us in accordance with applicable regulatory requirements and professional standards. Access controls are in place to limit access to your personal information to those who need it to perform their jobs. We regularly monitor our systems for possible vulnerabilities and attacks, and we use physically secure facilities, password protection, standard security practices and tools and well-defined internal policies and practices; however, we cannot warrant the security of any personal information you share with us. Despite our efforts, there is no guarantee that your personal information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5. Retention

To fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law or regulation, we retain the personal information that is provided to us only for such periods as we believe is useful, taking into consideration the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of the personal information, the purposes for which we need to process your personal information (including whether we can achieve such purposes through other means), and all applicable legal, regulatory, tax, accounting, or other requirements, as well as any contractual requirements that may apply (such as your Subscription Agreement with TrueContext). In some cases, as described in your Subscription Agreement with TrueContext, we may choose to retain certain personal information in a depersonalized or aggregated form.

6. Storage

Personal information provided to TrueContext by way of the TrueContext Service is stored in the United States. However, certain personal information that you share with us and allow us to store on your behalf in the United States may be transferred to and/or processed by (i) staff or service providers operating in Canada in relation to order fulfillment, payment processing and/or the provision of professional and support services; and/or (ii) service providers operating in Thailand and/or Bulgaria in relation to technical support matters.

Website and other personal information that we collect via our Website or other means may be transferred to, stored, and processed at various locations around the world, by staff who work for us or for one of our service providers. Such staff may be engaged in, among other things, providing demos, managing contests or other promotions, and making hiring decisions on behalf of TrueContext.

7. Accuracy and Access

We give you many choices about the collection, use and sharing of your personal information, including advertising opt-outs and communication controls. If you submit personal information via our Website or otherwise provide us with your personal information, you may submit a written request and satisfactory identification to our Privacy Officer (see “Contact Information” below) and request: (i) access to your personal information; and/or (ii) updating to, or correction of, your personal information. You may also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.

If we are unable to comply with your request of erasure for specific legal reasons, we will notify you at the time of your request.

Please note that you cannot opt out of receiving service messages from us, including security and legal notices. If you find any errors in your personal information, please contact our Privacy Officer as soon as possible.

We try to respond to all Policy and personal information requests within 30 days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made several requests. In this case, we will notify you.

8. Contact Information

Please contact the Privacy Officer with any questions or concerns that you may have about this Policy or our personal information practices. Our Privacy Officer may be contacted via email at privacyofficer@truecontext.com. You can also reach us by physical mail using the following address:

TrueContext Inc.
Attention: Privacy Officer
250-2500 Solandt Road
Ottawa, Ontario, CANADA
K2K 3G5

9. Policy Changes

This Policy was last updated on November 28, 2023.

We reserve the right to modify this Policy from time to time to guarantee its compliance with all applicable law. The revised Policy will be posted on the Website. If you continue to use the Website after these changes are in effect, you will be deemed to have agreed to them. We encourage you to periodically check this Policy to ensure that you are aware of the most recent version.

10. Change Log

For your ease of reference, below is a high-level summary of all material changes to this Policy since it was first drafted in October 2017.