Trustle collects information about you when you use our Website or App to access our services, and other online services (collectively, the “Services”) and through other interactions and communications you have with us or our Coaches and Clinicians.
HIPAA is a set of laws that applies to healthcare information. We’re not a healthcare provider so those laws don’t apply to us.
HIPAA DISCLAIMER: TRUSTLE IS NOT A HEALTHCARE PROVIDER AND DOES NOT PROVIDE MEDICAL CARE, ADVICE, DIAGNOSIS, TREATMENT OR SERVICES AND YOUR USE OF OUR SERVICES DOES NOT CREATE A PATIENT/PHYSICIAN RELATIONSHIP. AS SUCH, WE SPECIFICALLY DISCLAIM ANY REPRESENTATION OR WARRANTY THAT TRUSTLE’S SERVICES, AS OFFERED, COMPLY WITH THE FEDERAL HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA”). TRUSTLE ONLY MAINTAINS THE MINIMUM DATA NECESSARY TO PROVIDE OUR SERVICES AND DOES NOT STORE OR MAINTAIN YOUR PROTECTED HEALTH INFORMATION (PHI) AND IS NOT COMPLIANT
We collect and store the data that we need to run the service including the information you provide to sign up, and information you send to your team, and information about how you use the service. Children (under 13 years old) are not allowed to sign up and so we don’t collect information from them.
1. Children’s Privacy
Our Services are intended for users who have attained the age of majority where they reside (18 years of age or older in most jurisdictions). Furthermore, we do not knowingly collect personally identifiable information (PII) from persons under the age of 13 in the United States (“U.S.”), or under the age of 16 in the European Union (“EU”), the “Protected Age”. If you are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.
2. Information Provided Directly By You
We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, order a subscription to our Services, message your Coach or Clinician, complete a Trustle form, survey, questionnaire or application, contact customer support, make a purchase, join or enroll for an event or otherwise communicate with us in any manner. This information may include, without limitation: name, date of birth, e-mail address, physical address, business address, phone number, profile photograph, credit card or other method of payment information, or any other personal information you choose to provide.
3. Information Collected Through Your Use of Our Services
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users, Coaches, Clinicians and us. The following are situations in which you may provide Your Information to us:
We also automatically collect information via the Website or App through the use of various technologies, including, but not limited to Cookies and Web Beacons (explained below). We may collect your IP address, browsing behavior and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.
4. Information Collected From Other Sources
We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your Trustle account with a social media service, e.g. LinkedIn, Facebook or Twitter, or if you engage with a separate App or Website that uses our API, or whose API we use, we may receive information about you or your connections from that Site or App. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, your contact names, e-mail addresses, phone numbers, and other identifiers and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your personal privacy settings with the social network.
5. Aggregated Data
6. Cookies, Log Files and Anonymous Identifiers
7. Table of Cookies
Our Cookie table below lists some of the Cookies on our sites. Please note that the names of Cookies and other technologies may change over time.
8. Device Information
When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
9. Do Not Track Settings
Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting Cookies, as browsers with a “do not track” feature enabled may still accept Cookies. There currently is no accepted standard for how to respond to this signal, and we do not take any action in response to this signal.
We do our best to look after your information. If something goes wrong we will do our best to fix it, and will let you know.
10. Protective Measures We Use
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Although we take measures to secure your information, we do not promise, and you should not expect, that your personal information, or searches, or other information will always remain secure. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
We use Chargebee and Stripe to manage your subscription and payment processing. We don’t store any of your financial information.
11. Payment Information
We will never sell your information to a third party (for example for advertising.)
We primarily use your information to provide you with the service. We also use it to improve the service. We would only ever share it with a third part if it was clear that this was a part of the service you were signing up for.
In cases of harm or child abuse we would share it with law enforcement.
12. How We Use Information We Collect
Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not sell, rent, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared.
We will use this information in order to:
Additionally, we may use the information we collect about you to:
13. How We Share Information We Collect
14. Sharing Information With Law Enforcement
15. Analytic Services Provided By Others
We don’t promise anything with regard to sites we link to from our website.
16. Links to Third-Party Websites
Your data may be held overseas, and unfortunately there is no consensus as to how to respond to the ‘do not track’ setting in browsers so we ignore it.
17. International Privacy Practices
In order to provide our Services to you, we may send and store your personal information outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including countries that may not, or do not, provide the same level of protection for your personal information.
We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Union (“EU”) or European Economic Area (“EEA”) and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EU and EEA to the extent feasible under applicable law.
You can ask us at any time to:
- Delete your info
- Edit your info
- See what info we’re holding on you
- Stop sending you promotional content
18. Account Information
You may correct your account information at any time by logging into your online account. If you wish to cancel your account, please log into your account and follow any directions that are provided there, or email us at firstname.lastname@example.org Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law.
19. Promotional Information Opt Out
20. Your California Privacy Rights
21. Your Access and Rights to Your Personal Information
You have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your data will be held for as long as you have an account. We will delete your data a year after you close your account unless we need the information for business/legal purposes.
22. Our Information Retention Policy
Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 1 year and may retain the information for as long as needed for our business and legal purposes. We will only retain your Personal Data for so long as we reasonably need to unless a longer retention period is required by law (for example for regulatory purposes).