Effective Date: May 28, 2018
In keeping with TrueFire's commitment to comply with the various rules and regulations relating to safeguarding and protecting Personal Data it receives from its customers in the United States, in the European Union, and elsewhere, TrueFire has chosen to undertake a good faith effort to comply the European Union's GDPR and the obligations it imposes on controllers and processors of EU Personal Data, and to incorporate the privacy terms required for GDPR compliance herein.
Information We Collect About You
We collect several types of information about visitors and/or users of our Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Websites or App.
(a) We will collect and process your personal data when you register for a Service, create an account, subscribe to a newsletter, submit feedback, enter a contest, fill out a survey, or send us a communication. When ordering products or services on the Websites or App, you may also be asked to provide a credit card number and other payment-related information. Depending upon the activity, some of the information we ask you to provide is required to use the Services (e.g. registering an account) and some is voluntary. If you do not provide data when needed for a particular activity, you will not be able to engage in that activity.
We also collect your Internet Protocol ("IP") address. We use your IP address to diagnose problems with our servers and/or software, to administer our Services, and to gather demographic information.
(c) When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best version of the application to provide you. We do not ask you for, access, or track any location-based information from your mobile device at any time while downloading or using our App or Services.
(d) When you contact us for customer support we may collect additional information to resolve your issue to improve your customer service experience.
(e) We are not a site targeted at children or those under the age of 16. If you are a school and you use a TrueFire service for children under the age of 16, or the equivalent minimum age in the relevant jurisdiction, you are responsible for obtaining consent from the parents/legal guardians of each child you wish to allow to participate in using any of our Services. A child using our Services will be able to participate in certain limited activities (such as taking online educational and informational courses).
How We Use Your Information
We use information held about you in the following ways:
To present content from our Services in an effective manner for you and for your computer or mobile device
To provide you with information, products or services that you request from us or which we feel may interest you
To allow you to participate in interactive features of our Services, when you choose to do so
To carry out our obligations arising from any contracts entered into between you and us, including for billing and collection
If you pay for Services using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company
To allow our contractors, service providers and other third parties who provide data processing services to us and with whom the sharing of your Personal Information is necessary to undertake the work e.g. to process billing, analyze data, host data, provide customer support, and to deliver online and offline marketing communications that we think will interest you.
To contact you about our Services
Disclosure of Your Information
(a) 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 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.
Public Information and Third Parties
Blog. We have public blogs on our Websites. 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 Websites include 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.
Cookies and Tracking Technologies
We and our service partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send to you. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the IP address, browser, email client type and other similar details.
We use this information to measure the performance of our email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.
Here are our third-party service partners and function to our Websites 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
Scarab Research - For personalized online shopping experiences and recommendations
Yotpo - For reviews and marketing research
Updating or Correcting Personal Data
We offer settings to control and manage the personal data we have about you, including the ability to:
Amend or Rectify Data: You can edit some of your personal data through your account. You can also ask us to amend your data in certain cases, particularly if it is inaccurate.
Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
Cancelling your Account and Deleting Personal Data
You may choose to let your subscription lapse, in which case we will retain your information for a reasonable period of time in case you choose to re-subscribe.
You may choose to close your account in which case we will delete your information, including your learning history, within 60 days of your request. However, we may retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), comply with contractual obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.
Choices Regarding Control of your Personal Data
You can access some of the information that we collect about you. For example, by logging into your account, you can access information regarding recent orders from the Websites; certain personal data we maintain about you; your communication preferences; and your payment settings.
With respect to your communications preferences, you can unsubscribe from newsletters by following the instructions included in the newsletter you receive, or you can log into your account and update your newsletter and email subscription options. If your email address has changed and you would like to continue to receive newsletters, you will need to access your account, update your email address information in your account, and sign-up again for the newsletter. Administrative emails regarding purchases, downloads and other administrative communications are handled separately and not included in the request to opt-out of marketing or news communications.
Lawful Basis for Processing Data
Where we process data based on consent, we will ask for your
explicit consent. Where we rely on contract, we will ask that you agree to the
processing of personal data that is necessary for entering into or the
performance of your contract with us.
We may process your personal data for the purposes
of our legitimate interests or for the legitimate interests of third parties
(e.g., your employer or company), provided that such processing shall not
outweigh your rights and freedoms. For example, we may process your personal
Protect you, us or others from threats (such as security threats or fraud);
Comply with laws that apply to us;
Enable or administer our business, such as for quality control, consolidated reporting, and customer service;
Manage corporate transactions, such as mergers or acquisitions;
Understand and improve our business or customer relationships generally.
Access by you to your account is available through a password and/or unique username selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone, that you change your password often using a combination of letters and numbers, and that you ensure you use a secure web browser. We cannot be held accountable for activity that results from your own neglect to safeguard the secrecy of your password and username. If you share a computer with anyone, you should always log out of your account after you are finished in order to prevent access to your information from subsequent users of that computer.
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.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the App, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any personal data you submit within the App.
2500 Emerson Avenue South
St. Petersburg, FL 33712