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.
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.”
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”).
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.
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.”
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.
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.
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.
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.
We use your information for three purposes: to provide the service, to collect payment, and as part of our marketing efforts.
We use the information we collect in the following ways:
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.
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.
You can’t use the service outside of the US. Sorry.
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.
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!
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.
Anything you choose to share is your responsibility.
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.
Yes, but we’ll let you know beforehand.
Yes. Just email email@example.com
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.
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.
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:
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”).
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:
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 firstname.lastname@example.org. 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.
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 email@example.com or by mail at:
Ello Technology, Inc.
2447B Mission St, San Francisco, CA, 94110
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).