Updated: May 5, 2021

Ello Privacy Policy

Plain-English Privacy Policy

Welcome to Ello! We wanted to provide you an easy to understand version of our privacy policy as well as the legal version to the right. This applies to all our services including our website and mobile app.

Ello Technology, Inc. (“Ello”, “we” or “us”) is committed to protecting your privacy.  This Privacy Policy describes how we collect, store, use and distribute information through our software, website, documentation, and related services (together, the “Services”).

Capitalized terms not defined in this Privacy Policy have the meaning as set forth in the Terms of Service for the Services, which can be found at www.helloello.com/terms

1. Consent

By using the Services, you consent to the use of your Personal Information as described in this Privacy Policy.  If you are not of legal age to form a binding contract (in many jurisdictions, this age is 18), you may only use the Services and disclose information to us with your parent’s or legal guardian’s express consent. Review this Privacy Policy with your parent or legal guardian to make sure you understand it.  Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent.  We do not actively collect Personal Information for the purpose of sale of such information in a way that specifically identifies the individual (i.e. we don’t sell customer lists).  You may withdraw your consent to our processing of your Personal Information at any time.  However, withdrawing consent may result in your inability to continue using some or all of the Services.  

What we collect from you

We collect and store the data that we need to run the service including the information you provide to sign up, which includes information you share about your child to help us tailor our services. We also collect billing information so we process your payment.  

We use cookies and other common analytics tools on our website and in our app as part of our marketing efforts and to improve our product. This includes the Facebook Pixel - a tool used by most website to help with their advertising. With this, Facebook collects data about your web browsing. You can stop Facebook collecting this data through their website.

2. Collection of Information

Registration Information

When registering for the Services, we may require you to provide certain personally identifiable information, such as your name, email, phone, address, child’s first name, child’s grade and reading level, and child’s interests (these are referred to below as your “Registration Information”).  Your Registration Information, together with any other information we gather through the Services that may be used to identify, contact, or locate you individually, are collectively referred to herein as your “Personal Information.”

Billing Information

When purchasing the Services, we will require you to provide financial and billing information, such as billing name and address, mailing address, and credit card number (“Billing Information”).

Data

You may be able to create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages or other materials using our Services (this is collectively referred to below as “Data”).  Some of this Data may be stored and maintained on our servers.  

Usage and Analytics Information

We may also collect information through the use of commonly-used information-gathering tools, such as cookies, log files, and Web beacons. Collectively, this information is referred to as “Usage and Analytics Information.”  

Cookies

We use standard browser cookies to allow us to remember details of a user session. For example, we may use cookies to make it easier for the user to resume a recent session without re-entering their log-in details.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Log Files

As is true of most websites, we gather certain information automatically to analyze trends in the aggregate and administer the Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), your browser type, the pages and files you viewed, your operating system, your actions in connection with our Services, and date/time stamps associated with your usage.

Web Beacons

We use web beacons alone or in conjunction with cookies to compile information about your usage of the Services and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or Service tied to the web beacon, and a description of a website or Service tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. We also use web beacons to operate and improve the Services and our email communications.

3. Facebook Pixel

We use the “advertising pixel” from Facebook Inc. (“Facebook”) on our website. This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy at https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads

How we use your information

We use your information for three purposes: to provide the service, to collect payment, and as part of our marketing efforts.

4. Use of Information

We use the information we collect in the following ways:

Information Collected
Use
Registration Information
We use this information to manage your account, to provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or request feedback, for identification and authentication purposes, for service improvement, and to address issues like malicious use of the Services.  We may also use Registration Information for limited marketing purposes, namely, to contact you to further discuss your interest in the Services, and to send you information about us or our partners.
Billing Information
We use Billing Information to manage your account, to provide the Services, to process and deliver orders, and to check the financial qualifications of prospective customers and to collect payment for the Services. We may use a third-party service provider to manage credit card processing. If we do so, such a service provider will not be permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on our behalf.
Data
We use this information for the purpose of administering and improving our Services to you. We may also use this information in a de-identified, anonymous way in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Services, for the Services’ technical administration, and to increase the Services’ functionality and user-friendliness.
Usage and Analytics Information
We use this information to analyze overall trends, to help us improve the Services, to track and aggregate non-personal information, and to provide the Services. For example, we use IP addresses to monitor the regions from which customers and visitors navigate the Websites.  

If we plan to use your Personal Information in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy.  See further the section of this Privacy Policy entitled “Amendment of this Privacy Policy”.

Who do we share your information with?

We will never sell your information to anyone (for example for advertising purposes). The only time we share information is if we use third parties to help us provide or improve the services OR if we’re required to legally.

5. Disclosures & Transfers

We will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further below).

From time to time we may employ third parties to help us provide and/or improve the Services.  These third parties may have access to or process your information as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities.  We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

What is the privacy policy outside of the US?

You can’t use the service outside of the US. Sorry.

6. Non-US Users

These Services are hosted in the United States and are intended primarily for visitors located within the United States. If you choose to use the Services from other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your Personal Information outside of those regions to the United States for storage and processing.  By providing your Personal Information through the Services, you consent to such transfer, storage, and processing.

Protecting your information

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. You need to keep your password safe!

7. Security.

The security of your Personal Information is important to us.  We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment.  We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us.  We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information.  For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information.  Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.  

What happens if I use Ello to share information?

Anything you choose to share is your responsibility.

8. Sharing Information with Third Parties

You may be able to share Personal Information with third parties through use of the Services.  The privacy policies of these third parties are not under our control and may differ from ours.  The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be.  If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

How long we hold on to your info

Your data will be held for as long as you have an account. We will only keep it for as long as needed for the intended purpose.

9. Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.  We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.  All retained Personal Information will remain subject to the terms of this Privacy Policy.  Please note that if you request that your Personal Information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.

Can you change your privacy policy?

Yes, but we’ll let you know beforehand.

10. Amendment of this Privacy Policy

We reserve the right to change this Privacy Policy at any time.  If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice.  Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective 30 days from their posting on www.helloello.com/privacy or via email to your listed email address.  Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account.  The date on which the latest update was made is indicated at the top of this document.  We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes.  Your continued use of the Services signifies your acceptance of any changes.

Can I see what information you have on me, and change it if needed?

Yes. Just email support@helloello.com

11. Access and Accuracy

ou have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information.  Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user.  In such circumstances we will provide reasons for the denial to you upon request.  We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate.  As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information.  Having accurate Personal Information about you enables us to give you the best possible service.

12. Notice to California Consumers

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.  We do not share your personally identifiable information with third parties for the third parties’ direct marketing purposes unless you provide us with your express consent to do so.

What information do you collect from my child? And what do you do with it?

The most important section!

We have the information you provide us as part of the sign up process which we use to tailor and provide the service.

IF you give us permission, we may then collect audio recordings of your child. This is optional and the service will work without this, although you may miss out on some features.

We use this audio for two reasons, you can give us permission for both or just one of these uses:

  1. To provide addition features to your child, such as being able to hear themselves read.
  2. To improve our product more generally. The audio data would be anonymized to the extent possible.

13. Children

This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by children under the age of 13 (“Child” or “Children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding Children’s personal information. For more information about COPPA and general tips about protecting Children’s online privacy, please visit OnGuard Online.

Collection: Ello collects information about Children directly from their parents and guardians (“Parents”), who provide us with their Child’s first name, grade, reading level, family situation, home environment, school, activities and interests (“Parent-Supplied Information”). In addition, if Parents enable the “Individual Service Improvement” and/or “General Service Improvement” settings in the Ello App, then Ello may collect spoken audio files of Children while they are reading books during use of the Ello App (“Audio Recordings”).

Use and Disclosure

Parent-Supplied Information: Ello uses Parent-Supplied Information in order to provide Parents and their Children with custom tailored services, including preparing a custom-tailored box of books for the Child to read and enjoy each month as part of our Subscription Service.  

If Individual Service Improvement is Enabled: If a Parent enables the “Individual Service Improvement” setting in the Ello App, then Ello may store and process Audio Recordings in order to enhance and improve the Services specifically for the Parent’s Child.  Such improvements and enhancements shall consist of:

  1. In-app reading support functions for the Child, such as playback features and real time word accuracy analysis.
  2. Analytics to measure the Child’s reading proficiency and progress, such as analysis of words spoken per minute, or identification of the most common mistakes made by the Child.
  3. Customizations to the Ello App to make it work better for the specific Child, such as training Ello’s models and algorithms to better pick up the Child’s speech patterns. 

Unless a Parent also enables the “General Service Improvement” setting in the Ello App, Ello shall not use Audio Recordings for other purposes without the Parent’s express written consent.

If General Service Improvement is Enabled: If a Parent enables the “General Service Improvement” setting in the Ello App, then we may also use Audio Recordings on an anonymized and aggregated basis to improve our Services generally.

Miscellaneous: All information pertaining to a Child shall also be treated as part of the Parent’s “Personal Information” and may be shared as described in the “Disclosure” section above for business transfers; to vendors and service providers; to comply with legal requirements; and also pursuant to a Parent’s instructions.

Parental Consent: Ello obtains verifiable parental consent before collecting personal information from your Child by requiring you to provide your credit card information (in connection with an actual financial transaction) at the time of subscribing to our Services. If you do not consent, then we will not collect, use or disclose any personal information about your Child, and your Child will not be allowed to use our services in any way.  If you are not using our Services for any other purposes and do not provide consent within a reasonable time from the date the direct notice was sent to you, we will also delete your online contact information from our records.

Parental Choices and Controls: At any time, you can refuse to permit us to collect further Personal Information from your Child in association with your account, and can request that we delete from our records the Personal Information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You can contact Ello to request access to, change, or delete your Child’s personal information by sending an email to us at support@helloello.com. A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information belonging to Children when it is no longer needed for the purpose for which it was collected.

13. Contact Us

You can help by keeping us informed of any changes such as a change of email address or telephone number.  If you would like to access your information, if you have any questions, comments or suggestions, if you find any errors in our information about you, or if you have a complaint concerning our compliance with applicable privacy laws, please contact us at support@helloello.com or by mail at:

 Ello Technology, Inc.
2447B Mission St, San Francisco, CA, 94110

Plain-English Privacy Policy

Welcome to Trustle! We wanted to provide you an easy to understand version of our privacy policy as well as the legal version to the right. This applies to all our services including our website and mobile app.

We at Trustle Inc. respect the privacy of your personal information and, as such, make every effort to ensure your information is protected and remains private. As the owner and operator of our Service, the website www.trustle.com (the “Website”) and the mobile application Trustle (the “App”), hereafter collectively referred to in this Privacy Policy as “Trustle”, “us”, “our” or “we”, we have provided this Privacy Policy to explain how we collect, use, share and protect information about the users of our Service,  p (hereafter referred to as “user”, “you” or “your”).  For the purposes of this Agreement and our Terms of Service, any use of the terms “Trustle”, “us”, “our” or “we” includes Trustle Inc., without limitation.

We will not use or share your personal information with anyone except as described in this Privacy Policy.

This Privacy Policy, which is incorporated into the Trustle Terms of Services Agreement accessible here (insert link to the Terms of Services page here), will inform you about the types of personal data we collect, the purposes for which we use the data, the ways in which the data is handled and your rights with regard to your personal data.

For the purpose of this Privacy Policy the Data Controller of personal data is Trustle Inc. and our contact details are set out in the Contact section at the end of this Privacy Policy. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which, and the manner in which, any personal information are, or are to be, processed.

For purposes of this Privacy Policy, “Your Information” or “Personal Data” means information about you, which may be of a confidential or sensitive nature and may include personally identifiable information (“PII”) and/or financial information. PII means individually identifiable information that would allow us to determine the actual identity of a specific living person, while sensitive data may include information, comments, content and other information that you voluntarily provide.

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.

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by sending you a notice to your registered email address and by posting the revised Privacy Policy on the Site and in the App. If the changes to the Privacy Policy are significant, the email notice we send you will require you to accept the revised Privacy Policy terms. Those changes will go into effect on the “Last updated” date shown at the end of this Privacy Policy. By continuing to use the Site or Services, you consent to the revised Privacy Policy. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.

BY CHECKING THE BOX ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THIS PRIVACY POLICY AND PROVIDING EXPLICIT CONSENT AT THE TIME OF YOUR REGISTRATION FOR YOUR ACCOUNT, AND BY ACCESSING OR USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, MANIPULATION, STORAGE, DISCLOSURE AND OTHER USES OF YOUR INFORMATION (COLLECTIVELY, “USE OF YOUR INFORMATION”) AS DESCRIBED IN THIS PRIVACY POLICY AND OUR TERMS OF SERVICE WHICH MAY BE ACCESSED HERE TRUSTLE.COM/TERMS. IF YOU DO NOT, OR NO LONGER, AGREE WITH OR CONSENT TO THIS PRIVACY POLICY AND OUR TERMS OF SERVICE YOU MAY NOT ACCESS OR USE OUR SERVICES. FURTHERMORE, FOR USERS OF OUR SERVICES PROVIDING INFORMATION FROM THE EUROPEAN UNION, WE RELY UPON THE LEGAL GROUNDS FOUND IN THE SECTION ENTITLED “THE LEGAL BASIS AND REASONS FOR COLLECTION AND PROCESSING YOUR PERSONAL INFORMATION” FOUND HEREINAFTER IN THIS PRIVACY POLICY

HIPAA

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

What we collect

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:

  1. When you fill out forms or fields through our Services;
  2. When you register for an account with our Service;
  3. When you create a subscription for our Services;
  4. When you order products or services from, or through our Service;
  5. When you provide responses to a survey;
  6. When you answer questions on a questionnaire;
  7. When you join or enroll in an event through our Services;
  8. When you sign up for any newsletters or other materials through our Services;
  9. When you provide information to us through a third-party application, service or Website;
  10. When you communicate with us or request information about us or our products or Services, whether via email or other means;
  11. When you participate in any of our marketing initiatives, including, contests, events, or promotions; and
  12. When you participate in forums, communities, reviews or provide or post user generated content or other submissions.

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

We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Data as this data does not directly or indirectly reveal your identity. If we ever combine Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as PII which will only be used in accordance with this Privacy Policy.

Cookies and technical use

We use cookies on our website as part of our marketing efforts. We may also look at the hardware and software you use when using our service.

6. Cookies, Log Files and Anonymous Identifiers

  1. When you visit our Services, we may send one or more Cookies – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website browsing equipment for record keeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. Cookies allow the Sites to remember important information that will make your use of the site more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Sites regardless of whether you are logged in to your account or not.
  2. Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Site.
  3. Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).
  4. When we use session Cookies to track the total number of visitors to our Site, this is done on an anonymous aggregate basis (as Cookies do not in themselves carry any personal data).
  5. We may also employ Cookies so that we remember your computer when it is used to return to the Site to help customize your Trustle web experience. We may associate personal information with a Cookie file in those instances.
  6. We use Cookies to help us know that you are logged on, provide you with features based on your preferences, understand when you are interacting with our Services, and compile other information regarding use of our Services.
  7. Third parties with whom we partner to provide certain features on our Site or to display advertising based upon your Web browsing activity use Cookies to collect and store information.
  8. Our Website may use remarketing services, to serve ads on our behalf across the internet on third party websites to previous visitors to our Sites. It could mean that we advertise to previous visitors who haven’t completed a task on our site. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, use Cookies to serve ads based on your past visits to our Website. Any data collected will be used in accordance with our own privacy policy, as well as Google’s privacy policies. To learn more, or to opt-out of receiving advertisements tailored to your interests by our third parties, visit the Network Advertising Initiative at networkadvertising.org/choices.
  9. Trustle may use third-party services such as Google Analytics to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including Cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager here https://adssettings.google.com/authenticated?hl=en. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on here https://tools.google.com/dlpage/gaoptout. For additional information on how Google uses data when you use Google partners’ sites or apps, go here: https://policies.google.com/technologies/partner-sites.
  10. You can control the use of Cookies at the individual browser level. Use the options in your web browser if you do not wish to receive a Cookie or if you wish to set your browser to notify you when you receive a Cookie. You can easily delete and manage any Cookies that have been installed in the Cookie folder of your browser by following the instructions provided by your particular browser manufacturer. Consult the documentation that your particular browser manufacturer provides. You may also consult your mobile device documentation for information on how to disable Cookies on your mobile device. If you reject Cookies, you may still use our Website or App, but your ability to use some features or areas of our Service may be limited.
  11. Trustle cannot control the use of Cookies by third parties (or the resulting information), and use of third party Cookies is not covered by this policy.
  12. We automatically collect information about how you interact with our Services, preferences expressed, and settings chosen and store it in Log Files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or App/Site functionality, and to document your consent to receiving products, services or communications from us or our partners. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as PII for purposes of this Privacy Policy.
  13. When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your account is collected using these Web Beacons.

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.

Protecting your information

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.

Payment processing

We use Chargebee and Stripe to manage your subscription and payment processing. We don’t store any of your financial information.

11. Payment Information

Trustle uses a secure third party payment processing gateway to collect, store and process payment information. That information is provided directly to our third party payment processors whose use of your personal information is governed by their Privacy Policy. Trustle does not store this information on our Website or servers.

What we do with your 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:

  1. Evaluate your registration and on-boarding information so that we can appropriately match you with your Coach and Clinician;
  2. To establish initial and continuing contact with your Coach and Clinician;
  3. To provide your Coach and Clinician with the information and data they required to provide you with our Services;
  4. Provide users with our customer support including, but not limited to, fulfilling subscription orders, processing refunds, confirming emails related to our services, setting reminders and responding to requests for information and transactions.
  5. Track your payment history and to contact you for account and promotional purposes.
  6. Contact you and provide you with important notices.
  7. Analyze, improve and manage our Services and operations.
  8. Resolve problems and disputes, and engage in other legal and security matters.
  9. Detect and prevent fraud.
  10. Enforce our Terms of Service and any terms and conditions of any agreements for our

Additionally, we may use the information we collect about you to:

  1. Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Trustle and other companies, where permissible and according to local applicable laws.
  2. Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties.
  3. We may transfer the information described in this Privacy Policy to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Privacy Policy.

13.  How We Share Information We Collect

  1. We may share the information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:
  2. With third party Service Providers to enable them to provide the Services you request;
  3. With companies that perform services for us, such as processing payments and managing our data;
  4. With other users or the general public if you submit content in a public forum, such as your reviews, comments or other features of our Services that are viewable by the general public;
  5. With third parties with whom you choose to let us share information, for example other websites or apps that integrate with our API or Services, or those with an API or Service with which we integrate.
  6. With Trustle subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes;
  7. With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
  8. In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
  9. With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our user agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Trustle or others;
  10. In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
  11. If we otherwise notify you and you consent to the sharing; and
  12. In an aggregated and anonymized/de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any personal information.
  13. We may disclose Your Information:
  14. To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
  15. To our third-party vendors and service providers so that they may provide support for our internal and business operations, including for the processing of payments, handling of data processing, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and our Services maintenance and security. These companies are authorized to use Your Information only as necessary to provide these services to us and are contractually obligated to keep Your Information confidential;
  16. To third parties when you engage in certain activities through our Services that are sponsored by them, such as purchasing products or services offered by a third party, electing to receive information or communications from a third party, or electing to participate in contests, sweepstakes, games or other programs sponsored, in whole or in part, by a third party. When we disclose Your Information to these third parties, Your Information will become subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of Your Information;
  17. As required by law or ordered by a court, regulatory, or administrative agency;
  18. As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;
  19. If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency;
  20. To enforce our Terms of Service, this Privacy Policy, and any other applicable agreements and policies;
  21. To enforce or protect our legal rights.

14.  Sharing Information With Law Enforcement

  1. Trustle is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If Trustle receives a request for user account information from a government agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency.
  2. Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer Communications or Records), Trustle may disclose user account information to law enforcement, without a subpoena, court order, or search warrant, in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone. Trustle will not release more information than it prudently believes is necessary to prevent harm in an emergency situation. The following are some examples of circumstances that might warrant this voluntary disclosure:
  3. Duty to Warn and Protect. If the user discloses a plan or threat to harm themselves, we will notify legal authorities. In addition, if they disclose a plan to threaten or harm another person, we will notify legal authorities.
  4. Abuse of Children and Vulnerable Adults. If the user discloses, or it is suspected, that there is abuse or harmful neglect of children or vulnerable adults (i.e. the elderly, disabled/incompetent), we will notify legal authorities.
  5. Prenatal Exposure to Controlled Substances. We will report to legal authorities any admitted prenatal exposure to controlled substances that could be harmful to a mother or a child.

15.  Analytic Services Provided By Others

We may allow others to provide audience measurement and analytics services for us. These entities may use Cookies, Web Beacons, software development kits (SDKs), and other technologies to identify your device when you visit our Site and use our Services, as well as when you visit other online sites and services.

Links from our website

We don’t promise anything with regard to sites we link to from our website.

16. Links to Third-Party Websites

  1. Our Services, as well as the email messages sent with respect to our Services, may contain links or access to websites operated by third parties that are beyond our control. Links or access to third parties from our Services are not an endorsement by us of such third parties, or their websites, applications, products, services, or practices. We are not responsible for the privacy policy, terms and conditions, practices or the content of such third parties. These third-parties may send their own Cookies to you and independently collect data.
  2. If you visit or access a third-party Website, application or other property that is linked or accessed from our Services, we encourage you to read any privacy policies and terms and conditions of that third party before providing any personally identifiable information. If you have a question about the terms and conditions, privacy policy, practices or contents of a third party, please contact the third party directly.

Where your data is held

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.

By checking the box acknowledging that you have read and agree to this Privacy Policy, and providing explicit consent at the time of your registration for your account, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and assume the risk that the protection of such information may be different and may be less protective than those required under the laws of their residence or location.

Your rights to change, delete and edit your info

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 support@trustle.co 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

You may opt out of receiving promotional messages from us at any time by following the instructions in those messages sent to you or by contacting us at any time using the Contact Us information at the end of this Privacy Policy. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.

20. Your California Privacy Rights

  1. California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year.
  2. If you are a California resident and would like to make such a request, please submit your request in writing to: support@trustle.co

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.

  1. Right to Access Your Personal Data. You have the right to access information held about you for the purpose of viewing and in certain cases updating or deleting such information. Furthermore, if you prefer that Trustle does not share certain information as described in this Privacy Policy, you can direct Trustle not to share that information. We will comply with an individual’s requests regarding access, correction, sharing and/or deletion of the personal data we store in accordance with applicable law. To make changes to your account affecting your personal information contact us at the email address in our Contact section below. For any deletion, non-sharing or update request, we will make the changes as soon as practicable, however this information may stay in our backup files. If we cannot make the changes you want, we will let you know and explain why.
  2. Right of Correction or Completion of Your Personal Data. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.
  3. Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request information deletion please contact us at the email address in our Contact section below.
  4. Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.
  5. Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable and commonly used format. To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.
  6. Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at the email address in our Contact section below.
  7. Right to Complain. If you’re based in the EU, you can file a complaint with the supervisory authority in your Member State. By way of example, if you reside in the United Kingdom you can file a complaint with the Information Commissioner’s Office here https://ico.org.uk/.

How long we hold on to your info

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).

Contact Us

If you have any questions or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.

Contact name: Data Protection Officer

Email: support@trustle.com