At Truesend, your privacy and security are paramount. This privacy policy (“Privacy Statement”) explains how we collect and utilize your information as you interact with our services, encompassing both our email marketing platform and our website. This policy should be read alongside our Terms of Use to ensure a complete understanding of our data practices and service terms.
Scope of the Privacy Statement:
1.1 This Privacy Statement describes how Truesend (collectively “Truesend” , “we” , “us” , “our”) collects, uses, discloses and protects information. The scope of our policy extends to 3 major areas:
- Information we collect from Customers when they register for use, or interact with our Service. Here, Truesend acts as a Data Controller
- Information processed by Trusend on behalf of the User (“Users”) through use of the Service, especially relating to their email subscribers and campaign data. Here, Truesend acts as a Data Processor
- Information collected from website visitors and interactions on our website truesend.com
1.2 Protecting privacy is fundamental to Truesend. We ensure transparency and stringent compliance with applicable data protection and privacy laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as applicable. When collecting and processing information about Users or visitors of our website, we are, in accordance with the European Union (“EU”) data protection laws, qualified as “data controller” and “data processor”. This states that Truesend is responsible for deciding how they hold and use personal data.
1.3 The data controller establishes the purposes (reasons) and means (methods) of processing personal data and holds the ultimate responsibility for ensuring its proper management. In most cases, this data controller is the company that receives an individual's personal data directly from them.
1.4 A 'data processor' refers to an entity that provides services to the data controller and, in doing so, receives personal data either directly from the controller or on their instruction to facilitate the execution of those services.
Definitions
2.1 “We”, “us”, and “our” refer to Truesend.
2.2 “You”, “your” and “yours” refer to the User.
2.3 “Personal Data” refers to any information related to an identified or identifiable natural person.
2.4 “Controller” refers to an entity that establishes the purposes and methods of Processing of Personal Data.
2.5 “Processor” refers to a natural or legal person, entity, agency, public authority or any other body that processes Personal Data on behalf of or as permitted by the Controller.
2.6 “Processing” of data refers to the operations or set of operations that can be performed upon Personal Data provided by Users, Subscribers or Visitors whether or not by automatic means. This includes operations such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of Personal Data. We may interpret “Process”, “Processes” and “Processed” similarly.
2.7 “User” means a person or entity registered with Truesend to use and avail its services.
2.8 “Visitor” refers to a person or entity visiting, engaging or interacting with our website truesend.com
2.9 “Subscriber” refers to a person or entity that contacts Truesend through our website trusend.com or through our Services.
2.10 “Service” or “Services” refers to any product or service provided by Trusend in accordance with Truesend’s Terms of Use.
Our Data Collection Methods
3.1 Truesend gathers user data to enable the subscribed Services on its platform, which allows for the personalization and effective delivery of its features. The collection of user data is vital for operational functionality as well as improvement of services provided.
3.2 The mandatory or optional nature of the data provided (in order to complete the Users’ registration and to render the Services) 1 is denoted at the point of collection using an asterisk.
3.3 Truesend collects data from its Users, Visitors and Subscribers as follows:
- Information provided directly: We collect information and data when a sign up form or data collection form is filled. Data is also collected when a User contacts use directly via email or any other communication methods as specified on our website truesend.com
- Information collected automatically: Our Services collect personal information from your interactions through automatic recording processes that involve our company and our service providers and business partners. This information can relate to you, the device you're using (computer or mobile), and your specific activities within our Platform and Website.
- Information collected from third party sources: Personal data concerning you may be provided to us by third parties following your expression of interest in our services to them. We may also acquire personal information about you from other third-party entities where your consent has been granted or where applicable law allows for such transfer. The handling and processing of personal information received from these third parties are governed by the terms of this Privacy Statement, consistent with any additional limitations specified by the information provider. The nature of our third-party sources is subject to variation based on your engagement with the Truesend Platform.
3.4 To ensure the optimal performance of our Services, Truesend employs the following tracking technologies:
- Cookies: These are small data files that websites store on your computer's hard drive for record-keeping. While most web browsers are configured to accept cookies by default, you can modify this setting in your browser. However, please note that disabling cookies may limit your ability to fully utilize all of Truesend's functionalities. We use cookies to enhance your Truesend experience by remembering information so you don't need to re-enter it repeatedly. We also use them to analyze website traffic metrics such as page views, time spent on the site, and the number of visitors.
- Web Beacons: We may embed single-pixel GIFs (also known as web beacons) in the emails we send. These allow us to gather information about when you open our emails, your IP address, your browser or email client type, and other similar details. The data collected from web beacons helps us generate reports on the performance of our email campaigns and identify areas for improvement.
- Unique Identifiers and Similar Tracking Technologies: Truesend may utilize other tracking technologies to administer the Services, monitor your navigation within the Services, analyze usage trends, track user behavior, deliver targeted advertisements, and gather demographic information. These technologies also assist us in measuring the effectiveness of our email campaigns and enhancing our features for specific customer segments.
3.5 Log Data Monitoring: When you access our platform, we may collect log data. This data can include details such as your IP address, browser type and version, the specific pages you visit on Truesend, and other user statistics. If you access Truesend using a mobile device, the log data may also include the type of device, your mobile device's unique identifier, the IP address of your device, your mobile operating system, and other mobile-specific statistics.
3.6 Third-Party Analytics and Advertising Services:We may engage third-party services, such as Google Analytics, to collect and analyze log data. This helps us understand how to improve Truesend and, occasionally, to deliver targeted online advertising. Our third-party advertising partners may use cookies or other tracking technologies to present you with advertisements on other websites based on your browsing activity and interests.
What data do provide us
4.1 Personal Data provided by Users, Subscribers and Visitors
- Account Profile Data and Contact Information: Information is collected when an account is created, a subscription is activated or any other information is uploaded on the Trusend Platform. Account Profile Data includes details such as name, title and honorifics, professional title/ designation and company name, profile photo, purchase history, demographic information, preference, subscription data, username and account credentials. Contact Information includes contact email address, billing and mailing addresses, billing information (payment information) and phone number.
- Identity Verification Information: Truesend collects information to verify User identity which includes name, date of birth, government identification (Aadhaar Card number, PAN card number, social security number, social insurance number, etc.), driver;s license, passport number or any other government issues identification details or similar information.
- Information related to System/ Service setup: Truesend may require additional business related data to set up your account and Services. We collect information such as organization name, organization address, organization geographic location, IP addresses, browsing activity, web server logs or any other such information necessary for Account or Service set up.
- Records of communications, feedback, survey data, and related data: personal information of Subscribers such as name, email address, phone number and any other personal information that they share when they reach out to Truesend for contact or any support, feedback, participation in product research/ training or communicate/ interact with us in any other way. Information such as call center recordings, call monitoring recordings, chat and text records, voicemails, photographs and video images.
- Marketing data: includes contact information such as email addresses and preferences regarding receiving marketing communications.
- Business and Financial Information: includes details about your business, transactions, payroll details, payment details, details about customers, vendors, or employees and/or investment information.
- Information from interactions with experts and chatbots: Information shared when a User contacts an expert for consultation is collected which includes the questions/ queries asked, the details about the account provided and the guidance provided by them. Furthermore, details are also collected via chatbots, digital assistants or any other interactive bots across the Truesend Platform.
- Device and Contact data; when permissions are granted on the device settings, certain Platform features may have access to contact and device details.
- Business connection data: We might collect info about you when you interact with Truesend through our users. If you're a customer, vendor, or potential customer of someone using Truesend and you interact with our Platform, we'll use this info to suggest things about you to our users. Our users might also directly give us business connection data about you, which we explain later under ‘Other users’.
4.2 Information collected automatically during interactions with the Truesend Platform
- Device Information: device information such as IP addresses, log information, device type and unique device identifiers may be collected
- Usage information: Data about your usage of the Truesend Platform such as the pages you viewed, services/ features you interacted with, your browser type and any details about the links and communications with which you interacted, may be collected.
- Location information: if permitted, Truesend may collect location data like precise location information or device motion information.
- Information stored locally: some web enabled desktop services may store computer information as they are synchronized. Information such as device information, product usage, and error reports may be collected and personal information may be stored locally on the device.
- Communication Interaction data: We or our third-party partners may gather information from your email, communication, and social media providers regarding your engagement with our messages (e.g., whether you open or forward emails or texts). This collection may involve the use of pixel tags (also known as clear GIFs), which can be embedded invisibly within our emails.
- Online behavior data: We might automatically collect certain personal info about how you use and interact with our websites, our customers' websites or online stores, social media, and marketing campaigns we or our customers run. This can include your device's info (like IP address and unique IDs), what pages you look at, search results, links you click, and if you're a customer contact, whether you saw, received, opened, or clicked on a campaign we sent (and if it bounced or was marked as spam).
4.3 Information collected from third party sources
We may receive personal information about you from other third parties if you've consented or if applicable law permits. We ensure that any personal information obtained from these sources is protected and processed according to this Privacy Statement, and we adhere to any additional restrictions imposed by them. The specific third parties we receive information from may change depending on your usage of the Truesend Platform.
- Linked third party services: if you choose to sync a non-Truesend account/ service with your Truesend account, we will receive information from that account/ service according to your preferences. The collected information may include bank account details, social media information, purchase history or business sales records.
- Payment Gateway providers: Information may be provided to us by supporting payment gateways like Stripe, Razorpay or PayPal. Bank account data, payment history and other payment related information may be provided by payment gateway providers.
- Data providers: information may be provided to us by data licensors that provide demographic and preference information to us.
- Public databases: we collect individual and household demographic information and preference information from publicly available sources such as open government databases, social media platforms and others.
4.4 Non personal Data collected by Truesend includes:
- Browser and device details: We may collect non-personal information about your device and browser, such as your location, device type and model, browser and operating system details, access times and dates, browsing activity, screen resolution, plugins, add-ons, and the service version you're using.
- Service usage and external data: We also collect information about how and when you use our services, which we may store and connect with other data we have about you. Additionally, we may obtain information about you or your Data Subjects from external sources like public databases, social media, third-party data providers, and our marketing partners. This could include time, date, browser type, demographics, device information (type, model, operating system, IP address), location, online behavior (like social media activity, page views, search results, and links), your actions, anonymous usage data, referring/exit pages and URLs, submitted and inferred preferences, and click counts.
4.5 Truesend wants you to know that we do not process or store your credit card information. When you make a payment, your credit card details are securely transferred to our third-party payment gateway, Stripe, Razorpay or PayPal.
Lawfulness of Data Processing
Truesend is highly committed to protecting and safeguarding its Users’ privacy rights and freedom. We only collect data as permitted by the User and process it to the extent we have a legal basis to do so. Truesend relies on the legal basis to process Personal Data as follows:
- Explicit consent from the data subject: when a data subject (person who provides personal data) states explicit consent to providing data by checking a box (while sign-up or downloading product information) or manually filling their personal data in a sign-in form to be contacted by our sales department or User onboarding department.
- Performance of a Contract: this includes a User’s involvement in a legal contract for the provision of services as well as signing or negotiating a contract for the purpose of receiving a service.
- Compliance with legal obligations: Legal obligations can relate to misuse of services, cooperation with formal disclosure requests, and retention of financial data and customer account data.
- Legitimate Interest: refers to direct or indirect marketing activities to existing Users, Subscribers or Visitors on an opt-out basis. In cases of data processing based on legitimate interest, the processing is not high.
Purposes of Data Utilization
6.1 Truesend utilizes the collected personal and non-personal data based on whether you are a Visitor or a User
6.2 Website Visitors: Personal and non-personal data of website visitors is strictly used to interact with the visitor, as well as facilitating live chat to provide relevant and apt help and support. Data collected includes
6.3 Customers/ Users: When a visitor converts to a User, collected information is used to provide relevant services. As part of the purpose, the data is used as follows:
- To establish and maintain primary platform accounts and associated sub-accounts as well as to administer secure access credentials and authorization protocols for the accounts.
- To deliver our core service functionalities and optimize its performance based on User requirements. This includes the execution of identity verification processes and the authentication of domains, IP addresses, email addresses, etc. used within the Truesend Platform.
- To provide a real time log of your usage within the Truesend Platform and its features. This ensures transparency and provides insightful data regarding your account activity.
- To give relevant responses and support in response to any requests, inquiries or communication raised which may concern technical support, sales information or other related matters.
- To manage billing cycles, track payments and facilitate collection of payments associated with your subscription or any other paid plan services
- To effectively communicate with you regarding our services which may include newsletters, marketing communications, service announcements, special offer information and updates regarding the Truesend Platform subject to your communication preferences and applicable legal requisites.
- To investigate, prevent and manage any fraudulent activities and to address any breaches of the stipulated Terms of Use, ensuring the integrity and security of the Truesend Platform and its User base.
With whom do we share data
We will only transfer your Personal Data as described in this Privacy Policy. We may transfer your Personal Data to:
7.1 To operate and improve Truesend, we work with various business partners, suppliers, subcontractors, and agents who provide services for us. This includes consultants like auditors, lawyers, tax advisors, and analytics and search engine providers who assist with Platform optimization. We also engage Personal Data Processors, such as IT companies, advertising and marketing companies, and accounting firms. We require these processors to handle your Personal Data with the same level of responsibility as we do and only according to our instructions.
7.2 We may be legally obligated to provide your personal data to state and local government institutions, law enforcement and investigative bodies, courts, and other dispute resolution entities, as well as individuals performing legally assigned functions, in accordance with the procedures outlined by the laws of the Republic of Lithuania and other applicable legislation. We will provide these entities with legally mandated information or information specifically requested by them as per legal requirements.
7.3 Your data may also be shared with other third parties, such as payment service providers.
7.4 In the event of a potential business sale, merger, joint venture, or other form of business combination, we may disclose relevant information to the involved companies.
7.5 We use Stripe, Razorpay and PayPal as a payment intermediary service to receive payments and to manage credit card processing. Stripe is not permitted to store, retain, or use billing Information except for the sole purpose of credit card processing on our behalf. For more information about the processing of your payment data, please refer to the privacy policy of Stripe.
Your rights over the data
8.1 You have certain rights concerning your Personal Data that we collect and process. These rights include:
- Right to Access: You have the right to request information about the specific pieces of Personal Data we have collected about you. Upon your request, we will provide this data in a portable and, where technically possible, easily usable format.
- Right to Know: You have the right to confirm whether we have collected Personal Data about you and to receive details about that data, including the categories of personal data we collect, the sources of that data, the purposes for processing it, and the categories of third parties with whom we share it.
- Right to Deletion: You have the right to request the deletion of your Personal Data, subject to the conditions and exceptions outlined in Clause 11 of this Privacy Policy.
- Right to Opt-Out of Targeted Advertising: You have the right to opt out of the sharing of your Personal Data with third parties for cross-context behavioral advertising. You can exercise this right by visiting our Cookie Settings and adjusting your preferences for functional, performance, and targeting cookies accordingly.
- Right to Object to Processing: You have the right to object to the processing of your Personal Data, including profiling activities, under certain circumstances.
- Right to Correction: If the Personal Data we process about you is inaccurate, you have the right to update and correct this information directly within your Truesend account.
- Right to Non-Discrimination: If you choose to exercise any of your rights under applicable privacy law, you have the right not to receive discriminatory treatment from us as a result.
8.2 To ensure transparency and empower you with control over your personal information held by Truesend, we offer you the option to know what data of yours we store. If you wish to do so, please contact us at abuse@truesend.com.
Security of Your Information
9.1 Our Security Measures: Truesend implements reasonable precautions and technical and organizational security measures designed to provide a level of security appropriate to the potential risks. We follow industry best practices to protect your Personal Data from unauthorized or unlawful security breaches that could lead to accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Our goal is to maintain the security and confidentiality of your data. However, it's important to understand that no security measures can guarantee absolute protection against all potential threats. By using our Service, you acknowledge and agree that you understand and accept these inherent risks.
9.2. Your Responsibilities: As a customer, you are responsible for reviewing the information provided by Truesend regarding our data security practices and independently determining if our Services meet your specific requirements and legal obligations under applicable Data Protection Laws. Furthermore, you are responsible for ensuring the secure use of our Services, including safeguarding your account login credentials, protecting the security of Personal Data during its transmission to and from the Services, and taking appropriate measures to securely encrypt or backup any Personal Data you upload to our Services.
Contact Us
10.1 To ensure transparency and empower you with control over your personal information held by Truesend, you can contact us at info@truesend.com, for an queries