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Truffle Live Privacy Policy

 

Last revised: April 2021

Introduction

 

Our Users' privacy is important to us. Our Privacy Policy was designed to make important disclosures about how to collect and use our Users' content and information and how to use the Service to share such information with other Users.

Trufflelive encourages you to read the Privacy Policy carefully and use it to make informed decisions. By using the Service, you agree to the terms of this Privacy Policy.

Your continued use of the Service constitutes your agreement to this Privacy Policy and any amendments.

Our Terms of Use take precedence over any conflicting provision of this Privacy Policy.

 

 

How to contact us?

 

If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at DPO@trufflelive.com or by sending a letter to:

You may contact our representative in the EU by the following contact details: DPO@trufflelive.com

 

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time.

 

 

What Information We Collect?

 

Registration Information.

During the registration process to the Service we request certain personal information from you, including your name, email address, mobile phone number and your contacts details (collectively "Personal Information"). If you intend to receive revenues from the Company (subject to its policies), you will be asked to provide a copy of your governmental-issued ID.

 

Contact list.

You can provide us, subject to applicable laws, with a permission to collect the phone numbers and contact persons names  in your address books , including those of users of our Services and their other contacts. This information allows us to identify which of your contacts in your device’s address book are also TruffleLive users so that we can add them to your TruffleLive contacts, and update your TruffleLive contacts in case your contacts who are not yet using TruffleLive sign up later. If any of your contacts are not yet using our Services, we will manage this information for you in a way that ensures those contacts cannot be identified by us.

 

If you grant us access to your device’s address book, we will be able to (i) filter your in-app feed to show only users appearing on your contact list; (ii) allow you to easily create groups with your friends, by suggesting you the option to add your contacts when you create a group; (iii) allow you to initiate audio and video calls with contacts that are on your contact list; (iv) notify you when your contacts have joined the app; and (v) allow you to manage your profile visibility, by deciding who will be able to see your profile and groups (everyone or only contacts).

 

Device identifiers and device data.

When you visit or access the Service, we also collect your IP address, device unique ID, your precise geolocation and other information transmitted by your device including among other things the type of browser and operating system your device uses, and the domain name of the website from which you linked to the Service, in order to enhance the functionality of our Service.

 

Location information.

The Company collects information about your general location (such as city and country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is precisely located. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that you are either interested in a place or that you might be at the place – this information does not actually tell us where your device is precisely located.

In addition, the Company collects the precise location of your device (using GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, Beacons signals and cell tower ids that can be used to derive or estimate precise location, or other geo-location data), when location services have been enabled by the end user (you typically have to choose to turn on device-based location services).

 

Google Advertising ID.

The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we will collect and use it for advertising and user analytics purposes. By downloading or using our Service you explicitly agree that we may associate your Advertising ID with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID, we will use other identifiers.

 

You acknowledge and agree that any personal information that you make available via the Service including, but not limited to, your username, your name, email address, geo-location data and the content you post (including your User Submission) is available to the public. You are responsible for protecting and enforcing your rights in and to your User Submission.

 

Cookies and Other Technologies.

We and our trusted partners use cookies and other technologies in our related services, including when you visit our site or access our Service. As is true of most applications, we gather some information automatically and store it in log files.

 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a web site. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests. You can find more information about cookies at www.allaboutcookies.org. You may remove our cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Service may not operate properly and your online experience may be limited. In some of our messages, we use a "click-through URL" linked to information and content. When you click on such links, they may pass through a third party web server before arriving at the destination page on our Application or on one of our partner's websites. Trufflelive or its trusted partners may track this click-through data to help us determine interest in particular topics, measure the effectiveness and performance of our customer communications and promotions.

 

Use of Anonymous Information

We store on our servers or our cloud servers, use or share Anonymous Information (i.e. information which does not enable identification of an individual user, i.e. non-Personal Information, aggregated information or Personal Information in non-human readable form; e.g. anonymous or aggregated information concerning the way our user community interacts with the Service) in any of the above circumstances, as well as for the purpose of providing and improving our services, aggregate statistics, marketing purposes and conduct business and marketing analysis, and enhance your experience with the Service. If we combine Personal Information with Anonymous Information, the combined information will be treated as Personal Information for as long as it remains combined.

 


How we use the information held by us?

 

We use your Personal Information for the purposes listed below:

 


Data Sharing

 

We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.

 

We share Personal Information with any of the following recipients:

 

In addition to the purposes listed in this Privacy Policy, we share Personal Information with those Recipients for any of the following purposes:

 

 

 

International Data Transfers

 

We may transfer or disclose Personal Information to our subsidiaries, affiliated companies, subcontractors or such other trusted third party service providers or partners, who are located in different jurisdictions across the world, for the purpose of: (a) storing or processing such information on our behalf or to assist us with our business operations and to provide and improve our Application's services; (b) performing research, technical diagnostics, analytics or statistical purposes. Information collected by Trufflelive may be stored and processed in your region, in Hong Kong, the United States, or in any other country where Trufflelive or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities. 

If we provide any information about you to any such entities, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy and applicable law.

 

 

Third party collection of information

 

Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties on our system or other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. For example, when making a payment by credit card our third party processors such as the Apple Store and Google Play Store, they may collect your credit card information and other information necessary for processing/authorizing your credit card payments. These payment companies may also provide certain of your details to us - but this shall not include your credit card number.

 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties to which we may disclose information as set forth in this Privacy Policy. The Service may also enable you to interact (whether directly or through link) with third party websites, mobile software applications and services that are not owned or controlled by us (each a "Third Party Services(s)"). We are not responsible for the privacy practices or the content of any Third Party Services. Please be aware that the Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

 

Children’s Privacy

 

The Services are not directed at children under the age of consent (namely, below the age where consent must be given or authorized by the holder of parental responsibility over the child, as required under the applicable law in the jurisdiction you reside in (“Age of Consent”)). If you are under the Age of Consent you may use the Services only if consent is given or authorized by the holder of parental responsibility.

                            

If Trufflelive learns that personal information of persons under the Age of Consent has been collected on or through the Services without parental or guardian consent, Trufflelive will take appropriate steps to delete this information unless it is needed to comply with any legal or statutory obligation.

 

If you are the parent or legal guardian of a child under the Age of Consent who has become a member, then please contact help@trufflelive.com to have that child’s account terminated and the personal information deleted.

 

 

Conditions for Processing of Personal Information

 

We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.

 


Retention of Personal Information

 

If you have registered with an account through our Services, the Company will retain your Personal Information during the period your account is active. In addition, the Company will retain your Personal Data for additional periods, to enable the Company to meet its legal obligations under applicable laws or regulations, Know-Your-Customer and Anti-Money Laundering regulations.

In addition, the Company may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Company’s legitimate interests, such as fraud prevention and record keeping.

If for any reason you wish to delete your Personal Information, please send us an e-mail to: DPO@trufflelive.com, and we will make reasonable efforts to address your request.

 

What are Your Rights?

 

If you reside in the EU or in other locations that provide you with the below rights, you may contact us at any time by email (at: DPO@trufflelive.com), and request:

 

  1. To access or delete any Personal Information relating to you;
  2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
  3. That we will restrict any further use of your Personal Information;
  4. That we will provide the Personal Information you volunteered to us in a machine-readable format;
  5. To object to the processing your Personal Information (such as for marketing purposes);
  6. To withdraw your consent to our processing activities (provided that such processing activities rely on you consent, and not on a different legal basis);
  7. Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significant affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including any legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.

 

How we keep your information secured

 

We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Changes to the Privacy Policy

 

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on our services and/or we will send you an e-mail regarding such changes to the applicable e-mail address that you provided to us. Such substantial changes will take effect fourteen (14) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of our services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

CALIFORNIA RESIDENTS

This part of the Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, "CCPA").

 

  1. Categories of Personal Information We Process?

In the 12 preceding months, we have collected and disclosed the categories of Personal Information as listed in the above sections "What Information We Collect?" and "With Whom We Share Information?"

We do not sell (as this term is defined under the CCPA) any Personal Information.

We may share or transfer Personal Information to third parties as assets that are part of a merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of the Company. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Information under the CCPA.

 

  1. Sources of Personal Information

In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

 

  1. User Rights under the CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Personal Information

You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business purpose for sharing your Personal Information, if applicable.

 

Deletion Requests

You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.

 

Exercising Your Rights

You can exercise your rights (such as access and deletion) by submitting a verifiable consumer request to our email address: DPO@trufflelive.com or by sending a mail to our physical address specified in the HOW TO CONTACT US section.

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:

You may only request a copy of your data twice within a 12-month period.

If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at DPO@trufflelive.com.

 

Response Timing and Format

Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.

Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.

 

Designating Agents

You can designate an authorized agent to make a request under the CCPA on your behalf if:

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

 

  1. Non-Discrimination

Unless permitted by the CCPA, we will not: