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Privacy Policy
TrueFire, Inc. (“TrueFire,” “our,” “us,” or “we”) wants to help you better understand how we
collect, use, protect, and share your Personal Data. This Privacy Policy is designed to help you
understand your privacy choices when you visit our Website or use our Mobile App or any of
our Services. It does not apply to other websites or services that we do not control, including
websites or services of other TrueFire Users.
This Privacy Policy is incorporated into, and forms an integral part of, the TrueFire Terms of
Service (“Terms of Service”). Please note that our services may vary by region.
We encourage you to read this Privacy Policy carefully and take the time to get to know our
privacy practices. By accessing the Website, Mobile App, and/or the Services, you are bound by
all terms and conditions in the Terms of Service and this Privacy Policy. If you do not wish to be
bound, you may not access the Website, Mobile App, and/or the Services.
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Definitions.
- Information Types.
- “Account Information” means data about how and when a User account is
accessed and the features used.
- “Browser Information” means provided by a browser, including
the IP address, the website visited, network connection, device
information, and other data, including Cookies.
- “Contact Information” means basic personal and business
information, such as first and last name, email address, postal address,
phone number, and may include social media account information.
- “Device Information” means information about your device, such
as device ID number, model, and manufacturer, version of your operating
system and geographical region, collected from any devices when
accessing our Website, using the Mobile App, or any of our Services.
- “Security Information” means User ID, password and password
hints, and any other security information used for authentication and
account access.
- “Usage Information” means information collected when you
interact with the TrueFire’s Website, Mobile App, or any of our Services,
including functionalities accessed, pages visited, and other interaction
data.
- “Automated Decision Making” means a decision made solely by automated
means without human involvement.
- “Controller” means an entity that determines the purposes and means of the
Processing of Personal Data.
- “Cookie” a small file that resides on your computer’s hard drive that often
contains an anonymous unique identifier that is accessible by the website that
placed it there, but is not accessible by other sites.
- “Mobile App” means the TrueFire Mobile Application available through third-
party app stores for mobile devices.
- “Personal Data” or “Personal Information” means information that (i) relates to an
identified or identifiable natural person, or (ii) identifies, relates to, describes, is
capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer or household.
- “Processing” means any operation or set of operations which is performed upon
Personal Data, whether or not by automatic means, including, but not limited to,
alteration, collection, organization, recording, retrieval, storage, transmission, and
use.
- “Processor” means the entity that processes Personal Data on behalf of the
Controller.
- “Services” means all TrueFire and/or JamPlay products, services, and materials
located on or accessible through the Website and Mobile App.
- “Third-Party Products” means any third-party information, website, product,
service, or materials referenced in, accessible through, or provided in connection
with, the Website or Services.
- “User” means an entity or natural person that completes registration information
to create a Member account for the Services on the Website or Mobile App.
- “Visitor” means an entity or natural person that visits or interacts with the
TrueFire Website.
- “Website” means the TrueFire website located at http://www.truefirestudios.com
(including all associated internet country codes) and all other TrueFire affiliate
websites.
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How Do We Collect Information and What Information Do We Collect?
- When a User interacts with our Website and/or Mobile App, TrueFire may collect
and control information such as Account Information, Browser Information,
Contact Information, Payment Information, Support Information, Device
Information, Security Information, Transaction Information, Usage Information
and set a Cookie.
- When Visitors browse our Website, or engage in communications with us online
or offline, we may collect and control, as applicable, Browser Information,
Support Information, Contact Information, and Usage Information submitted or
communicated to us.
- We may collect the following types of information from you or your device(s):
- identifiers, such as Browser Information, Device Information, and
Security Information;
- commercial information, such as Account Information, Contact
Information, and Usage Information;
- geolocation data, such as Browser Information and Device Information;
- other Personal Information, such as Support Information; and
- information derived from other categories, which could include your
preferences, interests, and other information used to personalize your
experience.
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How We Use the Information We Collect?
We use the information we collect in our role
as a Controller to:
- provide our Services;
- confirm identities;
- to present content from our Services in an effective manner for you and
your device;
- to allow you to participate in interactive features of our Services;
- to communicate with you, including required communications regarding
your account, security, or updates regarding our Services or policies, and
to send promotional communications;
- improve and personalize communications, interactions, and our Services,
such as push notifications regarding your activities;
- provide support such as debugging, troubleshooting, automated decision
making such as the detection of fraudulent Member account creation when
signing up for our Services;
- for advertising and marketing, invoicing, to resolve incidents related to the
use of our Website and Services;
- to comply with legal requirements,
- as may be necessary in a business transaction concerning the sale or
transfer of our assets; and
- in other cases where the Visitor has given express consent.
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How We Share the Information We Collect?
We will share your personal data with third
parties only in the ways that are described in this Privacy Policy. We do not sell, trade,
rent or disclose your information to others, except as provided herein:
- We provide and support some of our Services through contractual arrangements
with service providers and other third parties. We, and our service providers, use
your personal data to operate our Websites and to deliver Services. For example,
we must release your credit card information to the card-issuing bank to confirm
payment for products and services purchased on our Websites; and provide order
information to third parties that help us deliver the Services.
- We will also disclose personal data in the following circumstances: (i) if it is
required by law enforcement or judicial authorities, or to cooperate with a law
enforcement investigation; (ii) if we have a good faith belief that we are required
or permitted to do so by law or legal process; (iii) to protect our rights, reputation,
property or the safety of us or others; (iv) to defend or enforce our rights or your
obligations; (v) if the disclosure is required by mandatory professional standards;
(vi) to a third party with your prior consent to do so; or (vii) if we are under a duty
to disclose or share your personal data in order to enforce or apply any contracts
or agreement that may exist between you and us including this Privacy Policy and
terms of service. This includes exchanging information with other companies and
organizations for the purposes of fraud protection and credit risk reduction.
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Direct Marketing.
We currently do not share personal data with third parties for their
direct marketing purposes, nor allow for advertising on our Websites. We do however,
have third party services to advertise our Websites and Services in other networks to
drive traffic to our own network. These partners are: Amazon Associates, Doubleclick,
Facebook Custom Audience, Google Adwords, Google Publisher Tags and Linkedin
Ads.
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Public Information and Third Parties.
- Blog. We have public blogs on our Website. Any information you include in a
comment on our blog may be read, collected, and used by anyone. If your
Personal Information appears on our blogs and you want it removed, contact us.
- Social media platforms and widgets. Our Website includes social media features,
such as the Facebook Social Plugins, Facebook Connect, Google+ Platform,
Twitter and Twitter Syndication. These features may collect information about
your IP address and which page you are visiting on our Website, and they may set
a cookie to make sure the feature functions properly. Social media features and
widgets are either hosted by a third party or hosted directly on our Website. We
also maintain presences on social media platforms, including Facebook, Twitter,
and Instagram. Any information, communications, or materials you submit to us
via a social media platform is done at your own risk without any expectation of
privacy. We cannot control the actions of other users of these platforms or the
actions of the platforms themselves. Your interactions with those features and
platforms are governed by the privacy policies of the companies that provide
them.
- Links to third-party websites. Our Website may include links to other websites,
whose privacy practices may be different from ours. If you submit Personal
Information to any of those sites, your information is governed by their privacy
policies. We encourage you to carefully read the privacy policy of any website
you visit.
- Contests and sweepstakes. We may, from time to time, offer surveys, contests,
sweepstakes, or other promotions on our Websites or through social media
(collectively, "Promotions"). Participation in our Promotions is completely
voluntary. Information requested for entry may include Personal Information such
as your name, address, date of birth, phone number, email address, username, and
similar details. We use the information you provide to administer our Promotions.
We may also, unless prohibited by the Promotion's rules or law, use the
information provided to communicate with you, or other people you select, about
our Services. We may share this information with our affiliates and other
organizations or service providers in line with this privacy policy and the rules
posted for our Promotions.
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Cookies.
- Usage. TrueFire and its third-party service providers use cookies, web beacons,
and similar tracking technologies to recognize you when you visit our Website,
reUser your preferences, and give you a personalized experience. When you visit
our Website, we, or an authorized third party, may place a cookie on your device
that collects information, including Personal Data, about your online activities
over time and across different sites. Cookies allow us to track time of use, infer
preferences, and improve and customize your browsing experience.
- Persistence. We use session-based cookies on our Website. Session cookies are
deleted as soon as you close your web browser. A website may set a cookie if the
browser’s preferences allow it. A browser only permits a website to access the
cookies that it has set, not those set by other websites.
- Types.
- Essential. These cookies are necessary for our Website to work as intended.
- Functional. These cookies enable enhanced functionality, like videos. Without these cookies, certain functions may become unavailable.
- Analytics. These cookies provide statistical information on site
usage. For example, these cookies enable web analytics that allow us to
improve our Website over time.
- Targeting and Advertising. These cookies are used to personalize
content to enhance your experience.
- Control. It is possible to disable cookies through your device or browser settings,
but doing so may affect your ability to use our Website. For instance, we may not
be able to recognize your computer or mobile device and you may need to log in
every time you visit our Website. The method for disabling cookies may vary by
device and browser, but can usually be found in preferences or security settings.
Please use the following links for further instructions:
- Google Chrome
- Apple Safari
- Mozilla Firefox
- Microsoft Internet Explorer or Edge
- Other Resources. To find out more about cookies, including how to see what
cookies have been set and how to manage and delete them, visit
allaboutcookies.org, or aboutcookies.org.
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Third-Party Service Partners.
The following is a list of our third-party service partners
and their respective functions to our Website and Services:
- Amazon CDN; content delivery network of multimedia assets
- Intercom; customer messaging platform
- Google Shopping; reviews
- Nextopia; site search, navigation & merchandising
- Onesignal; mobile and web push notifications delivery
- Soundslice; interactive sheet music platform
- Zendesk; customer service and engagement platform
- Sumo; blog email notifications platform
- Delighted; NPS Surveys
- Symantec; Norton shopping guarantee and web theft protection
- Viblast; cross-platform HTML5 video streaming technology
- Vimeo; video player used for tutorial videos in Channel Manager
- GA Audiences, Google Analytics, Linkedin Analytics; website analytics
- Yotpo; reviews and marketing research
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Security.
- While we are dedicated to securing our Website and Services, you are responsible
for securing and maintaining the privacy of your passwords and account
information. We are not responsible for protecting Personal Data shared with a
third-party based on an account connection that you have authorized. Please
notify Customer Support as soon as possible if your username or password is
compromised.
- Unfortunately, no data transmission over the Internet or any wireless network can
be guaranteed to be 100% secure. As a result, while we strive to protect your
personal data, you acknowledge that: (a) there are security and privacy limitations
of the Internet which are beyond our control; (b) the security, integrity and
privacy of any and all information and data exchanged between you and us
through this Website cannot be guaranteed and we shall have no liability to you or
any third party for loss, misuse, disclosure or alteration of such information; and
(c) any such information and data may be viewed or tampered with in transit by a
third party.
- In the unlikely event that we believe that the security of your personal data in our
control may have been compromised, we will try to notify you. To the extent you
have provided us with your email address, we may notify you by email and you
agree to our use of email as a means of such notification.
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Data Subject's Rights. Depending on where you reside, you may have data subject rights
as set forth based on location of residency below.
- UK/UE/EEA Data Subject Rights under the General Data Protection Regulation
(GDPR). If you are a resident of the United Kingdom, European Union, or
European Economic Area (EEA), you may have certain data protection rights. We
aim to take reasonable steps to allow you to correct, amend, delete, object to the
processing, restrict the processing, request a transfer, or limit the use of your
Personal Information, You can exercise rights over your Personal Data against the
Controller by emailing us at privacy@truefire.com, subject “GDPR Data Subject
Request”. When collection is based on your consent, you have the right to
withdraw consent at any time, without affecting the lawfulness of processing
based on consent before its withdrawal by applicable law. If applicable by
national law, you have the right to lodge a complaint with a supervisory authority
if you believe that the processing of your personal data infringes your rights.
- California Consumer Privacy Act. If you are a California resident, or were within
the last year or at any point since January 1, 2022, you have the following rights
under applicable California law in relation to your Personal Information, subject
to certain exceptions:
- Right to Know. You have the right to, up to twice in a 12-month period,
request what Personal Information we collect, use, disclose, share, and/or
sell, as applicable.
- Right to Delete. You have the right to request the deletion of your
Personal Information that is collected by us.
- Right to Opt-Out of Sale. You have the right to opt-out of the sale of your
Personal Information by a business. However, as noted above, we do not
currently sell any Personal Information.
- Right to Non-Discrimination. You have the right not to receive
discriminatory treatment for the exercise of the privacy rights described
above.
- Right to Correct. You have the right to correct inaccurate Personal
Information that we maintain about you.
- Right Not to Be Discriminated Against. You have the right not to receive
discriminatory treatment by us for exercising your privacy rights,
including the right not to be retaliated against.
We do not sell or share (in the context of cross-behavioral advertising which
means the targeting of advertising to a consumer based on the consumer’s
personal information obtained from the consumer’s activity across businesses
including distinctly-branded websites, applications, or services) Personal
Information, and have not in the immediate twelve months. If we do, you will be
notified of it prior to or at the point of such collection for those purposes, and
provided a link to opt-out of the selling/sharing of Personal Information.
These rights are not absolute, and there may be cases when we decline your
request as permitted by law.
Any request you submit to us is subject to an identification and residency
verification process as permitted by the CCPA. To submit a request, please
contact us, or have your authorized representative, contact us at 1-800-222-3366, click
this link, or email us at
privacy@truefire.com, subject
“California Data Subject Request”. We. In the event you have an authorized
representative submit a request to delete, request to correct or request to know on
your behalf, you will have to provide written authorization demonstrating this
grant of authority, which can include a Power of Attorney. Authorized
representatives may not submit any other types of requests on your behalf.
For purposes of requests to delete, correct and to know, we will verify your
identity based on information we have collected about you, including your name,
address, and phone number, but will not fulfill your request unless you have
provided sufficient information that enables us to reasonably verify that you are
the consumer about whom we collected the Personal Information on. If we are
unable to verify your identity, we may deny your request.
- If you are 16 years of age or older, you have the right to direct us not to sell your
Personal Information at any time. We do not and will not sell Personal Information of consumers we actually know are less than 16 years of age unless
we received affirmative authorization from the consumer who is between 13 and
16 years of age, or the parent or guardian of a consumer less than 13 years of age,
to opt-in to the sale of their Personal Information. Upon the receipt of this request
to opt-in, we will inform the minor of the right to opt-out later and of the process
for doing so.
- We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine that the
request warrants a fee, we will tell you why we made that decision and provide
you with a cost estimate before completing your request.
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Do Not Track.
Do Not Track is a privacy preference that Users can set in their web
browsers. When a User turns on the Do Not Track signal, the browser sends a message to
websites requesting them not to track the User. At this time, we do not respond to web
browser “do not track” settings or signals. We deploy cookies and other technologies on
our Services to collect information about you and your browsing activity, even if you
have turned on the Do Not Track signal.
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Protecting Your Personal Information.
We implement security measures designed to
maintain the security of your Personal Information. These security measures are
implemented both during transmission of Personal Information and once received. The
security of your Personal Information is important to us. However, no method of
safeguarding information is completely secure. While we use measures designed to
protect Personal Information, we cannot guarantee that our safeguards will be effective or
sufficient. In addition, you should be aware that Internet data transmission is not always
secure, and we cannot warrant that information you transmit utilizing the Services is or
will be secure.
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Transfer of Data.
Your Personal Information may be transferred to—and maintained
on—computers located outside of your state, province, country or other governmental
jurisdiction where the data protection laws may differ from those in your jurisdiction. If
you are located outside the United States, please note that we transfer data, including
Personal Information, to the United States and process it there. By using the Services,
you understand and acknowledge that your Personal Information will be transferred to
and processed in the United States, which may have different data protection rules than in
your country. We will take steps reasonably designed to treat your Personal Information
securely and in accordance with this Privacy Policy, as further described below.
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Updates.
We may update this Privacy Policy from time to time in response to changing
legal, technical or business developments. When we update our Privacy Policy, we will
take appropriate measures to inform you, consistent with the significance of the changes
we make. We will obtain your consent to any material Privacy Policy changes if and
where this is required by applicable data protection laws. You can see when this Privacy
Policy was last updated by checking the “Date of Last Revision” date displayed at the top
of this Privacy Policy.
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Contact Us.
For more information about our privacy practices, if you have questions, or if
you would like to make a complaint, please contact us by e-mail at
privacy@truefire.com
or by mail using the details provided below:
TrueFire, Inc.
2500 Emerson Avenue South
St. Petersburg, FL 33712