STATEMENT:

This Privacy Policy explains how TrueChoice Solutions, Inc. (“TCS”) collects Personal Data (defined below) via any and all Websites associated with TCS (a “Site” or collectively the “Sites”).  The Sites post or link directly to this Privacy Policy (or via offline means) and include both Websites created and/or maintained by TCS as well as Websites created, maintained and/or sponsored by TCS service providers.  This Privacy Policy also explains how TCS protects such data and the choices you have concerning TCS’ use of such data.

Please read this Privacy Policy carefully.  TCS may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. Please review the “LAST UPDATED” legend at the top of Site’s Privacy Policy Webpage to determine when this Privacy Policy was most recently revised.

For the purposes of this Privacy Policy, “TrueChoice Solutions”, “TCS”, "we", "us", and "our" means TrueChoice Solutions, Inc.

You do not have to provide us with any Personal Data to visit a Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of a Site.

CALIFORNIA PRIVACY:

This section of the privacy policy provides information to California (“CA”) residents whose personal information is processed pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), whether through a website or data analysis tool. It describes the types of data TrueChoice Solutions, collects, and the purposes for which that information is collected.

This section does not apply to Personal Information that is protected under federal financial privacy laws. Personal Information does not include information that is publicly available or that has been de-identified or aggregated.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT:

TYPES OF DATA COLLECTED:

We gather Personal Data and Other Data (as described below).

PERSONAL DATA DEFINITION:

Personal data is information that identifies you or can be used to identify or contact you; e.g., your name, email address, work or home address, or phone number ("Personal Data").

OTHER DATA DEFINITION:

Other data is information that identifies the method by which you are connecting to the Site and information about your interaction with the Site ("Other Data").

COLLECTION OF PERSONAL DATA:

• TrueChoice Solutions may collect Personal Data voluntarily provided by you, including in emails to a Site, online forms, online applications, surveys, promotion participation, or through offline means.
• TrueChoice Solutions collects offline information through various means. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in a Site’s or Sites’ products and/or services. If we acquire such a list for use, we seek to obtain appropriate representations from the other party that the listed individuals have opted in to receiving promotional messages from any acquirer of such list.

USE OF PERSONAL DATA COLLECTED:

We may use Personal Data for the following purposes:

• Fulfillment of Requests. TrueChoice Solutions may use Personal Data about you to deliver products and services and/or provide you with information about products and services you’ve ordered.
• Other Communications. From time to time, a Site may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If you would prefer that we not send electronic marketing messages to you, please see the "Your Choices" section below.
• Incentive Programs fulfillment. We ask you for certain Personal Data when you wish to claim an incentive for interacting with the Site. Such Personal Data is used to verify your eligibility to claim such an incentive and in order to fulfill the delivery of such an incentive.
• Internal Business Purposes. We may also use Personal Data about you for our internal business purposes, such as data analysis, customer support, customizing and improving the content and layout of a Site, development of marketing and promotion plans and materials, statistical analysis of user behavior, product development, administering individual accounts, and meeting government regulatory requirements.
• Administrative Communications. TrueChoice Solutions reserves the right to use Personal Data to send to you important information regarding a Site or Sites, your account status, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of a Site. Because this information may be important to your use of a Site, you may not opt-out of receiving such communications.

COLLECTION AND USE OF OTHE DATA:

• Monitoring Data: TrueChoice Solutions and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, location information, and other statistical data involving the use of a Site ("Monitoring Data"). We use Monitoring Data to help us understand who uses a Site and to improve and market it. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
• Aggregated Data: Additionally, we may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site; for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.

• TrueChoice Solutions uses cookies and Tool technologies (defined below) to understand how a Site is used and to customize and enhance the Internet experience of individual users. When you revisit a Site, TrueChoice Solutions may recognize you by a Tool and customize your experience. We believe cookies and Tool technologies add value to the user experience.

  • Cookies: To enhance the Internet experience on the Site, TrueChoice Solutions and our service providers may use ‘cookies’ on the Site. Cookies are data that a web server transfers to an individual's computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users' ongoing access to and use of a Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie or cookies from a particular web site to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about the procedure you are required to follow in order to disable cookies can be found on your Internet browser provider’s web site. We expect our service providers to honor any decision by you to block or disable cookies in connection with the Site.
  • Tools: We and our service providers may also use various common Internet tools such as “Flash,” “JavaScript,” or similar technologies (together, "Tools") in connection with Site pages and email messages in certain formats to among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened.

YOUR CA PRIVACY RIGHTS:

As a California resident, beginning after January 1, 2021, you may have certain rights over the Personal Information we have about you, depending on the type of relationship you have with us.

We do not offer an opt-out of sale link on our homepage for the purposes of the CCPA. We may share Personal Information with our service providers, with third parties with whom we jointly offer products or services, with third parties from whom you request a product or service through us, in the context of a merger, acquisition, bankruptcy, or other corporate transaction, or as otherwise permitted by the CCPA.

YOUR CHOICES:

We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.

• If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by sending an e-mail to unsubscribe@truechoice.io
• If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an e-mail to unsubscribe@truechoice.io

We will comply with your request(s) as soon as reasonably practicable. Please note that if you exercise the second option as described above, we will not be able to remove your Personal Data from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Data (i.e., to which we have already provided your Personal Data as of the date that we implement your request). Further, please note that requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing-related emails from TrueChoice Solutions. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.

If we intend to use your Personal Data for a purpose that is incompatible with the purposes detailed in this Privacy Policy, or if we intend to disclose it to a type of third party not previously identified, we will notify you and offer you the opportunity to opt-out of such uses and/or disclosures.

HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL DATA:

Should you like to review, correct, update, suppress, delete, or otherwise limit our use of your Personal Data that has been previously provided to us, you may make a request by contacting us using the information provided in the “Contact Information” below. We will comply with your request as soon as reasonably practicable and consistent with applicable law.

LINKS:

A Site may contain links to other web sites, including social media sites. Linked sites are not under TrueChoice Solutions’ control and we are not responsible for the privacy practices or the contents of the linked site. We provide links only as a convenience, and TrueChoice Solutions does not endorse or control, and is not responsible for, the privacy practices or the content of these linked sites.

If you provide any Personal Data through any third-party web site, your transaction will occur on that third party's web site (not a Site) and the Personal Data you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. Please note that this privacy policy does not address the privacy or information practices of any third parties, including, without limitation, affiliated entities that do not post or link directly to this privacy policy.

SECURITY MEASURES:

TrueChoice Solutions has established reasonable organizational and technical measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. If you have reason to believe that your interaction with us is no longer secure, please notify us of the problem immediately by contacting us using the information provided below in "Contact Information.”

DATA INTEGRITY:

TrueChoice Solutions will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Privacy Policy, or authorized by you. TrueChoice Solutions will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you). TrueChoice Solutions depends on you to update or correct your Personal Data whenever necessary.

RETENTION PERIOD:

We will retain Personal Data about you for the period reasonably necessary to fulfill the purposes outlined in this Privacy Policy and consistent with retention periods required or permitted by law.

CROSS BORDER TRANSFER OF PERSONAL DATA:

We will retain Personal Data about you for the period reasonably necessary to fulfill the purposes outlined in this Privacy Policy and consistent with retention periods required or permitted by law.

ENFORCEMENT:

TrueChoice Solutions will periodically review its compliance with this Privacy Policy. TrueChoice Solutions will also review and respond to any formal written complaints that we receive from you. Please contact us at the address listed below in “Contact Information.”

USE OF A SITE OR SITES BY MINORS:

Sites are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through Sites.

SENSITIVE PERSONAL DATA:

We request that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, racial or ethnic origin, political views, religious beliefs) on or through this Site or otherwise to us.

CONTACT INFORMATION:

Any questions or concerns regarding TrueChoice Solutions data security practices should be addressed to:

Security and Compliance Department
TrueChoice Solutions, Inc.
1270 Ave of the Americas, 8th Floor
New York, NY 10022
Phone: +1 (212) 660-0300 ext. 3922
E-mail: privacy@truechoice.io

If you choose e-mail the department, please mark the subject heading of your e-mail as “Privacy Policy Question” or, if applicable, “Personal Data update request”.