August 27, 2018
This Policy describes the types of information that TRUX, Inc. (“we”, “us” or “our”) gathers from you and the other people who use TRUX (the “Users”), how we may use that information and how you can contact us regarding this Policy and your personal information.
Changes to Policy. We reserve the right to modify this Policy at any time, so please review TRUX frequently for any changes. Amendments to this Policy will be posted on the Site and will be effective when posted. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted, the changes to any amended or revised Policy by your continued access or use of our services or TRUX.
Your Consent. Please read this entire Policy carefully before using TRUX or providing us with any information. When you access or use TRUX, you consent to the collection, use and disclosure of your information in accordance with this Policy. By providing personal information to TRUX, all Users fully understand and consent to the collection, use and processing of such information by TRUX or third parties as set forth herein. If you do not agree to the terms of this Policy, you are not authorized to use TRUX.
Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:
- We have implemented appropriate security safeguards designed to protect your information in accordance with industry standards.
What Information We Collect
Personally Identifiable Information
TRUX collects personally identifiable information from our Users at several different points on TRUX, including, without limitation, when Users provide it to us by (i) contacting us through email, (ii) registering for use of TRUX or (iii) submitting information through any forms, interactive features or Services available on TRUX.
Personally identifiable information may include, but is not limited to, your name, mailing or billing address, telephone number, email address, credit card or other payment method information or any other information which might reasonably be used to identify you individually. When other information is directly associated with personally identifiable information, this other information becomes personally identifiable information for purposes of this Policy. We collect this personally identifiable information when you, at any point, manually enter it into any online form available on TRUX or voluntarily submit it to us in another manner. We may also store your personally identifiable information in our systems for use in other ways as described in this Policy.
In order for you to take full advantage of TRUX you may be asked to voluntarily provide your personally identifiable information to us. You may choose not to provide us with your personally identifiable information by simply not entering it on TRUX or not otherwise providing it to us. While you still will have access to TRUX even if you do not provide us with your personally identifiable information, you should understand that you will not be able to use certain of the Services or features available through TRUX that require you to enter your personally identifiable information in order to function.
Using Third-Party Services and Visiting Third-Party Sites. This Policy applies only to the Site and Services. The Site or Services may contain links to or otherwise interact with other websites or products not operated or controlled by us, including without limitation any payment processor (the “Third Party Sites”), including third party add-ons, applications and other software that could track your usage or collect personal information. The policies and procedures we described here do not apply to the Third Party Sites. If you decide to access any Third Party Sites or use services provided by any Third Party Sites, you do so at your own risk and your disclosure of your personal information on Third Party Sites is governed solely by the applicable Third Party Site’s policies. We suggest contacting those third parties directly for information on their privacy policies.
You allow us to receive information when you use your account to log in to a third-party web site or application. You also allow us to receive information about your visits and interaction with the sites and services of our partners that include our cookies and similar technologies, unless you opt out. You allow us to receive information when you send payment or receive refunds through our third-party payment processors for certain Services.
Non-Personal Information. If you do not input or otherwise submit any of your personally identifiable information, then the information we collect from you is limited. For example, we log your Internet protocol (“IP”) address in order to help us diagnose problems with our server, administer TRUX and track usage statistics. Your IP address may vary each time you visit, or it may be the same, depending on whether you access TRUX through an always-on type of Internet connection (such as cable or DSL), or through a dial-up connection. We match IP addresses to completed User registration forms for validation and error checking purposes. If you reached the Site by clicking on a link or ad from another site, then we may also log that information. This helps us maximize our Internet exposure and to understand the interests of our Users. In general, this information is used to generate overall anonymous reports on our Users that enable us to improve the effectiveness of TRUX.
Log Files, IP Addresses, and Information About Your Computer and Mobile Device. When you visit or leave our Services (whether as a Member or Site visitor) by clicking a hyperlink or when you view a third-party site that includes our plugin or cookies (or similar technology), we automatically receive the URL of the site from which you came or the one to which you are directed. Also, advertisers receive the URL of the page that you are on when you click an ad on or through our Services. We also receive the IP address of your computer or the proxy server that you use to access the Internet, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing TRUX using a mobile device), and the name of your Internet service provider or your mobile carrier. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information on our mobile applications and for fraud prevention and security purposes. Most mobile devices allow you to prevent real time location data being sent to us, and of course we will honor your settings.
User Activity Tracking
We employ software technology that enables us to track certain aspects of a User’s visit to TRUX. This technology helps us better manage content on TRUX by informing us what content is effective. The software uses two methods to track User activity: 1) “trackers” and 2) “clear gifs.” Trackers are pieces of executable code that are embedded in a website that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in websites and emails that track whether or not a User has viewed a particular page or email. User activity information may be associated with additional information about a User’s session, such as IP Address and the type of browser used, and personally identifiable information, if provided by the User.
Advertising Technologies and Web Beacons. We target (and measure the performance of) ads to Members, Site visitors and other Users both on and off of our Services through a variety of ad networks and ad exchanges, using the following, whether separately or combined:
- Advertising technologies on and off of our Services, like web beacons, pixels, ad tags, cookies, and mobile identifiers as permitted by mobile platforms;
- Member-provided profile and contact information and categories (for example: “product managers in Texas”);
- Your use of our Services (for example: your search history, which pages you visit, your clicking on a TRUX ad, etc.) and log files generated as described in the Log Files Section;
- Information from 3rd parties (for example: advertising partners, publishers and data aggregators) which we use in addition to the information from our cookies (and similar technologies), your profile and use of our Services.
We may share your personal information with any third-party advertisers or ad networks for advertising. Note that your profile is visible to other Members and through public search depending on your settings. Also, advertising partners may associate personal information collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we contractually require such advertisers to obtain your explicit opt-in consent before doing so.
How We Use the Information We Collect
We may use the information (whether or not personally identifiable) that you provide to us to, among other things:
- Make your next use of TRUX more personalized.
- Process or complete transactions requested by you.
- Contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests.
- E-mail information and offers to you.
- Mail information and offers to you.
- Make telephone calls and send text messages to you with information and offers.
- Provide your information to third parties to fulfill services you have requested or that may be of interest to you.
- Compile anonymous statistical information and analysis.
- Provide compiled anonymous information to third parties.
- Provide, sell, or rent your information to third parties for advertising purposes.
- Permit you to access certain web-based programs or applications on TRUX.
- Help administer and protect the security of TRUX.
- Facilitate the processing by third parties of payment for online purchases or other transactions.
- Prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities.
You should be aware that any personal information that is voluntarily posted by you to a public area of TRUX (for example: a message board) may be viewed and used by other Users.
TRUX Communications. We communicate with you through email, notices posted on the TRUX web sites or apps, and other means available through the Services, including mobile text messages and push notifications. Examples of these communications include: (1) welcome and engagement communications – informing you about how to best use our Services, new features, updates about other Members you are connected to and their actions, etc.; (2) service communications – these will cover service availability, security, and other issues about the functioning of our Services; (3) promotional communications – these include email and may contain promotional information directly or on behalf of our partners, including job opportunities and information from companies that are hiring. These messages will be sent to you based on your profile information and messaging preferences. You may change your email and contact preferences at any time by signing into your account and changing your TRUX email settings.
Please be aware that you cannot opt out of receiving service messages from us.
Communications From Us
We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will contact you either through email, telephone, postal mail or through the Service.
When it is necessary to do so, we will send you service-related announcements, primarily via email. For example, if our service is temporarily suspended for maintenance, we may send you an email. Generally, you may not opt out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account by emailing email@example.com.
We may make available a Service either directly or through third parties by which you can receive messages on your wireless device via short message service (“SMS Service”). Your provider’s standard data and messaging rates apply to all SMS correspondence. All charges are billed by and payable to your mobile service provider. You represent that you are 18 years of age and the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges.
Program subscribers may opt out of the SMS Service by replying with the keyword “STOP”, “END”, or “QUIT”. This process impacts only the future delivery of our SMS message offering and will not unsubscribe you from other SMS programs to which you may have subscribed. Program subscribers may receive assistance for the SMS Service by replying with the keyword “HELP” to the message received.
User Communications. Many communications that you initiate through our Services (for example: an invitation sent to a non-Member) will list your name and primary email address in the header of the message. Messages you initiate may also provide the recipient with aggregate information about your network (for example: how many people are in your network). Other communications that you initiate through the Services, like a request for an introduction, will list your name as the initiator but will not include your personal email address contact information. Once you have connected with an individual, regardless of who sent the invitation, your contact information will be shared with that individual.
Service Development; Customized Experience. We use information and content that you and other Members provide to us to conduct research and development for the improvement of our Services in order to provide you and other Members and Users with a better, more intuitive experience and drive membership growth and engagement on our Services and to help connect professionals to economic opportunity.
We also customize your experience and the experiences of others on our Services. For example, when you sign in to your account, we may display the names and photos of new Members who have recently joined your network or recent updates from your connections and companies you follow. We try to show you content, such as news and presentations, that is relevant to you, your industry, or your profession. We also use Members information and content for invitations and communications promoting our Services that are tailored to the recipient.
Sharing Information with Affiliates. We may share your personal information with our affiliates (meaning entities controlled by, controlling or under common control with us) as reasonably necessary to provide the Services. You are consenting to this sharing. We may combine information internally across different Services that we offer.
Sharing Information with Third Parties. We offer a “public profile” feature that allows you as a Member to publish portions of your profile to the public Internet. This public profile will be indexed and displayed through public search engines when someone searches for your name. You may choose the parts of your profile that search engines index or completely opt out of this feature in your TRUX account settings. However, third-party search engines may not automatically update their caches, which may contain old public profile information. Unless you delete them, your profiles on the Site are always viewable on the respective Services.
The visibility of your professional profile to other Members depends on your degree of connection with the viewing Member, the subscriptions they may have, their usage of the Services, access channels and search types (for example: by name or by keyword).
We support “middleware” providers that offer archiving solutions to firms subject to legal and regulatory archiving requirement.
We may establish subsidiaries or other related companies, merge with or be acquired by another company, or sell substantially all of our assets (including substantially all assets to which other of our agreements relate) to another company. If that happens, we may disclose to them your personally identifiable information, in which case we will request them to abide by this Policy. We may also disclose some personally identifiable information to a potential acquirer.
Payment Processors. We may disclosure your personal information to third-party payment processors to prevent detect, mitigate, and investigate potentially illegal acts, fraud and/or security breaches and to assess and manage risk, including to alert you if fraudulent activities have been detected in your accounts; provide customer services, including to help service your account or resolve disputes; facilitate the processing of payment and related services you purchased.
Consent to the Use of Third Party Providers
Please understand that we may contract with third parties to provide various services to TRUX relating to TRUX on an outsourced basis rather than performing those services ourselves. For example, we may (i) contract with an email provider to handle the distribution of email messages to Users, (ii) contract with a web site hosting provider to host TRUX for us or (iii) contract with a third party to provide call center services to facilitate communication in connection with our services. We may also contract with various validation services to confirm contact information you provide. By using TRUX, all Users consent to us providing all information (whether or not personally identifiable) received or collected from those Users to such third-party providers for the purpose of enabling the third-party provider to provide these outsourced services to us. In addition, all Users consent to the collection, maintenance, and processing of their information (whether or not personally identifiable) by us and these third-party providers.
We will share information provided by Users (whether or not personally identifiable) with certain third parties in our network so that they can contact you with information about the Services in which you have expressed interest. In order to provide the Services available to you on this Site, we may also supplement your information (whether or not personally identifiable) with information from third-party sources with whom we have contracted for the purpose of verifying the contact information you have provided. You have the option not to have your information shared with third parties by not requesting these Services.
We may also share information about Users (whether or not personally identifiable) with third parties so that we can offer you a broader range of services and information to meet your needs. If you would prefer not to have your information shared with third parties, you may opt out by emailing firstname.lastname@example.org.
Further, by registering on this Site, you agree that your registration constitutes an inquiry and/or application for purposes of telemarketing laws, and notwithstanding that your telephone and/or cell number may be listed with the federal Do-Not-Call Registry you expressly opt-in to: (a) receive an offer or service from one or more of our partners or affiliates; (b) receive future information about products and services from us, our partners, affiliates and other third parties to whom we may provide your information; (c) permit us, our partners, affiliates and other third parties to contact you pursuant to the business relationship we have established using the information you provided to us for any purpose such as contacting you by email address, phone and/or mobile phone number (including use of automated dialing equipment), text (SMS) message or any means of communication for any purpose that, among other things, your wireless device may be capable of receiving (for example: mms, video etc. ). You may revoke authorization for us to contact you by such means at any time (see the SMS Service section above and the Opting Out; Access to Collected Information below).
Surveys & Contests. From time to time, we may request personally identifiable information from Users via surveys or contests. Participation in these surveys or contests is completely voluntary, and the User therefore has a choice whether or not to disclose personally identifiable information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be shared with the contest or survey sponsors to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of TRUX. Though we may use an intermediary to conduct these surveys or contests, these intermediaries will not use the Users’ personally identifiable information for any secondary purposes.
Polls and Surveys. Polls and surveys may be conducted by us, Members, or third parties. Some third parties may target advertisements to you on the results page based on your answers in the poll. We or third parties may follow up with you via email or messages delivered through our Services. We may use third parties to deliver incentives to you to participate in surveys or polls. If the delivery of incentives requires your contact information, you may be asked to provide personal information to the third party fulfilling the incentive offer, which will be used only for the purpose of delivering incentives and verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive. Your consent to use any personal information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it. We are a member of the Council of American Survey Research Organizations (“CASRO”) and abide by CASRO guidelines for market research. You may opt out of participating in surveys by changing your settings to stop receiving these inquiries and requests.
Testimonials and Advertisements Placed Through TRUX Ads. If you provide any testimonials about our goods or services or place advertisements through the ads, we may post those testimonials and examples of advertisements you place in connection with our promotion of these services to third parties. Testimonials and advertisements may include your name and other personal information that you have provided.
Your Choices and Obligations
Rights to Access, Correct, or Delete Your Information, and Closing Your Account. You have a right to (1) access, modify, correct, or delete your personal information controlled by us regarding your profile, (2) change or remove your content, and (3) close your account. You can request your personal information that is not viewable on your profile or readily accessible to you (for example, your IP access logs) through our customer service. If you close your account(s), your information will generally be promptly removed from the Services.
Please note: Information you have shared with others (for example: network updates, content sharing) or that others have copied may also remain visible after you have closed your account or deleted the information from your own profile. In addition, you may not be able to access, correct, or eliminate any information about you that other Members copied or exported out of our Services because this information may not be in our control. Your public profile may be displayed in search engine results until the search engine refreshes its cache.
Opting Out; Access to Collected Information. This Policy describes our uses of your information. If you do not agree to our uses of your personally identifiable information as we have described in this Policy, you are not required to provide that information to us. In addition, if we send emails to you, you may opt out of receiving non-administrative emails from us simply by responding to the opt-out link provided on all email communications from TRUX. You may review, update and delete any personal information that you have provided to us through this Site by emailing email@example.com.
TRUX Policy Regarding Children Under the Age of 13
TRUX complies with the Children’s Online Privacy Protection Act (COPPA). COPPA requires that web site operators never knowingly collect personally identifiable information from anyone under the age of 13 without prior verifiable parental consent. The Site is not intended for children under the age of 13, and we do not knowingly collect or use personally identifiable information from children under the age of 13. If we discover personal data from a child under the age of 13, we will eliminate that data.
You are not permitted to use TRUX if you are under the age of 13. By using TRUX, you agree to provide us with accurate information concerning your age or identity if we request it. You also agree not to assist children under the age of 13 in accessing TRUX or to attempt to contact children under 13 through TRUX.
California’s Shine the Light Law. California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.
Security. TRUX will take reasonable measures to secure the personally identifiable information Users provide to us. However, TRUX cannot guaranty the security of any information you submit to us and you do so at your own risk. All personally identifiable information is protected by password and accessible only to authorized TRUX personnel. However, there is a possibility that Internet transmissions containing a User’s personally identifiable information may be intercepted by others. There is no way for us to ensure the privacy of User information before it arrives at TRUX or after it leaves TRUX.
Cookies and Tracking
Online Behavioral Advertising by TruxNow and Others
If you would like to opt out of this program, please visit the Network Advertising Initiative opt-out page located at http://www.networkadvertising.org/choices.
“Do Not Track” Signals
If you have any questions about this Policy please contact us via email at firstname.lastname@example.org.
- To opt out and unsubscribe from email communications: send an email to email@example.com with “unsubscribe” in the subject line
- To cancel or correct your personal information: send an email with your User Name and the notice “My User Information” in the subject line to firstname.lastname@example.org
- To express or ask questions regarding privacy concerns: send an email to email@example.com
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Framingham, Massachusetts 01701