Effective October 1, 2024

This Legal Disclaimer & Privacy Policy (this “Privacy Policy”) is a part of our Terms of Use, and it describes our policies on the collection, use, and disclosure of information about you in connection with your use of our products and/or the TRUTHGUARD website, including those offered through our websites, emails, and mobile applications (collectively, the “Site”). The terms “we”, “us”, “our” and “the Company” refers to TRUTHGUARD, Inc., a company organized under the laws of the State of Texas in the United States of America. When you use the Site, you consent to our collection, use, and disclosure of information about you, including information that may be considered personal data, as described in this Privacy Policy.

USE OF OUR SITES OR PROVISION OF ANY PERSONAL INFORMATION CONSTITUTES AGREEMENT TO THIS PRIVACY POLICY. DO NOT USE THE SITE OR PROVIDE INFORMATION (OR ALLOW OTHERS TO DO SO ON YOUR BEHALF) IF YOU (AND YOUR PRINCIPAL IF YOU ARE ACTING AS AN AGENT) DO NOT AGREE WITH ALL THE TERMS OF USE INCLUDING THIS PRIVACY POLICY AND ANY APPLICABLE SUPPLEMENTAL PRIVACY POLICY.

Information We Collect

We collect and store information from or about you when you directly provide it to us. This happens when you provide your name, email address, native language, organization name, job title, city, state / province, region, age, locations for internet access and devices used and other information through the Site. Additional information about what we collect is available in any supplemental privacy policies for particular activities. It is always your choice, or the choice of anyone acting for you, whether to provide personal information. However, some must be provided to participate in certain programs or activities, so the decision not to provide information might limit or eliminate certain functions of the Site or the ability to participate. Other information is up to your good judgment, e.g., do not provide personal information about yourself that could be misused by others in a chat room, bulletin board, blog or similar forum and do not provide personal information about others without their permission.

We may also receive information about you through from our service providers and business partners, including companies that assist with analytics, hosting, technical support and other services which we use to personalize your Site experience.

Policy Regarding Information You Provide About Others

Do not supply personal information about others unless you are authorized or required to do so by applicable law or contract and you consent to the Terms of Use (including this Privacy Policy) on behalf of yourself and the “data subject” (the person about whom you supply personal information). Before supplying personal information about others (except as otherwise allowed by law or contract), you must make available for the data subject’s review, and obtain their written consent to, said Terms of Use and policies. By submitting any personal information about others, you represent and warrant that you are authorized to do so and that you did all of the foregoing before submitting the information. If applicable law allows you to supply the information without doing the foregoing, you represent and warrant that you have abided by that law and that it allows us to receive and disclose the information under this Privacy Policy without any further action on our part. You agree to indemnify, defend and hold us harmless against any failure by you to comply with this paragraph.

Information We Collect That You Do Not Provide

We use google analytics in the app and website. The user’s IP address may be logged as part of our ‘quality control’ process, used when debugging.

What We Generally Do with Personal Information Collected

In general, we use personal information we collect to pursue our mission and operations and to engage in the activity (and related activities) for which we collect it. Specifically, we may use your personal information to:

• operate, maintain, and optimize the Site and your account;

• improve the quality and types of services that we deliver;

• diagnose problems with and identify any security risks, errors, or needed enhancements to the Site;

• to provide you with information regarding our products and services;

• support the tracking and recovery of the Company’s products;

• contact you for feedback or conduct research about the Site;

• to provide data and analytics to third parties as described in this Privacy Policy;

• to provide you with information regarding our products and services;

• fulfill our obligations to you and to respond to any questions or requests;

• understand and analyze how you use our Site and what products and services are most relevant to you; and

• contact you about material changes regarding our Terms of Use or Privacy Policy.

Subject to applicable law, we reserve the right to make all lawful, worldwide uses of personal information, including without limitation, to: collect, use, access (or bar access), process, fulfill, disclose, display, share, respond to legal process or otherwise exercise our rights under applicable law, transfer, store, verify, enforce, delete, and otherwise deal with personal information, and information other than personal information.

How We Share Personal Information Collected

We may share information about you with the following third parties:

• We share your personal data as necessary for any third party to provide services associated with the Site, including to provide measurement and analytic services. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).

• We may disclose your personal data to our business partners and affiliates with whom we have contracted to provide you with products or services that may be of interest to you. For example, your personal information may be shared with business partners with whom we jointly offer products and services. We require our business partners and affiliates to agree in writing to maintain the confidentiality and security of the personal data they obtain on our behalf.

• We may share information with our corporate affiliates, parents and/or subsidiaries.

• We may ask for your explicit consent to share certain information with third parties.

We may also share information about you in the following contexts:

• We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Site; or (c) protects our rights, reputation, property, or that of our users, affiliates, or the public..

• We may share information from or about you with our parent companies, subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy. If we reorganize or another company acquires the Company or all or substantially all of our assets, that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.

• We aggregate personal data in a way that makes it impracticable to use that data to identify a particular person; we also sometimes maintain individual data records with personal identifiers removed, and maintain in a manner in which it is impracticable to relink it to any particular individual. In this Privacy Policy, we refer to such data as “Anonymized Data” and do not consider it to be personal data. We may use Anonymized Data in order to create statistical information regarding the Site and its use, which we may then share with third parties.

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Controlling Your Personal Data

• In order to process your personal data, we rely on your consent or our legitimate interests to process your data. You may withdraw your consent or object to the use of our personal data at any time, but you may no longer be able to access the Site.

• Other users may be able to identify you, or associate you with your account, if you include personal data in the content you post publicly. We are not responsible for, and this Privacy Policy does not apply to, information you choose to post publicly.

• Please note that the Site may contain links to unaffiliated third-party sites. We suggest you read the privacy policies on or applicable to all such third-party services.

• You can adjust your privacy settings by contacting us. If you receive a marketing email from us, you can unsubscribe from such emails at any time by following the instructions provided within those emails.

Data Retention and Your Ability to Update Personal Information

You can close your account by contacting us (see “Contact Information”). Once your account is closed, no further data will be collected, but we may retain information about you for the purposes authorized under this Privacy Policy, unless prohibited by law.

To the extent our systems require your personal information, in general, they provide the ability for you to update and correct your information. If you have any questions about what personal information about you the Company retains, please contact us (see “Contact Information”). The Company endeavors to keep your personal information accurate and up to date. If your personal information has changed, you may submit your new information there as well.

We keep personal information for as long as we think is necessary or advisable and we reserve the right to retain it to the full extent not prohibited by law. We may discard personal information in our discretion, so you should retain your own records, and not rely upon our storage of any personal information or other data.

Information Security

We use commercially reasonable efforts to follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect information about you, we cannot guarantee its absolute security.

Consent to International Transfer and Disclosure of Personal Information

This website is owned and operated by TRUTHGUARD, Inc., which is located in the United States. We are involved in programs and activities in a variety of countries. By using the Site, you agree that the Company and those with whom we share personal information (“Recipients”) may disclose and transfer your personal information worldwide (including outside the European Economic Area, if you are based in the European Economic Area) for any purpose relating to our or their mission, operations, programs, or otherwise that is not prohibited by this Privacy Policy.

Consent to Electronic Notice If There is a Security Breach

If we or a Recipient is required to provide notice of unauthorized access or other invasion of certain security systems, you agree that we (or they) may do so when required (or voluntarily) by posting notice on our Site or sending notice to any email address we have for you, in our (or their) good faith discretion. You agree that notice to you will count as notice to others for whom you are acting and agree to pass the notice on to them.

Children

We do not want to collect information from children. Do not provide any personal information unless you are at least 16 years of age, and please caution your children not to provide any. If you become aware that a child has provided us with personal data without parental consent, please contact us (see “Contact Information”). If we become aware that a child under 16 has provided us with personal information without parental consent, we take steps to remove such information and terminate the applicable account.

Identity Theft

If you believe you are a victim of identity theft entitled by law to request information from us, please contact us (see “Contact Information”) and we’ll explain what information we require in order to respond. After receiving that information, we’ll supply (without charge) information we then have that we are legally required to provide (subject to applicable law and reserving all rights and defenses).

Your California Privacy Rights

California Civil Code Section § 1798.83 permits California residents that are users of our Site to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to us (see “Contact Information”).

EEA Users

We endeavor to be fully compliant with the General Data Protection Regulation (GDPR). We may act, depending on the circumstances, as either or both a Controller and a Processor of personal data (as these terms are defined in the GDPR). We act as the Controller of information that we ask you to provide to register your email address/create an account and information that we collect when you use the Site. We act as the Processor of user-generated content and information provided to us by third parties or other websites.

EEA users have the right to request access to personal data, as well as to seek to update, delete or correct their personal data. You can usually do this using the settings and tools provided in your Site account. If you cannot use the settings and tools, contact us for additional access and assistance.

Modifications to this Privacy Policy

We may occasionally update this Privacy Policy. You can see when it was last updated by looking at the effective date at the top of this page. If we make any significant changes we'll post them prominently on our website and notify you by other means as required by law. Your continued use of the website after a revision to the Privacy Policy indicates your acceptance and agreement to the current Privacy Policy. We recommend that you periodically review the Privacy Policy to make sure you understand and are up-to-date on how we're keeping your information safe.

Contact Information