Your privacy is very important to us. We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. Please read this privacy policy to learn more about the ways in which we use and protect your personal information.
Trufina, Inc is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site www.trufina.com. Because we want to demonstrate our commitment to our users' privacy, we have disclosed our privacy practices to TRUSTe for review to ensure our compliance with best practices.
Questions or Concerns
If you have questions or concerns regarding this statement, you should first contact Customer Support by phone at 301-951-8998, fax at 301-951-8998, by email, or by mail at 73 Franklin Street, Annapolis, MD 21401. If you do not receive acknowledgment of your inquiry or it is not satisfactorily addressed, you should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process (http://www.truste.org/consumers/watchdog_complaint.php). TRUSTe will serve as a liaison with the Web site to resolve users concerns. However, please understand the TRUSTe program covers only information that is collected through this Web site.
Overview
The privacy practices of this statement apply to our services available under the domain and subdomains of www.Trufina.com (the "Site"). By visiting this website you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access our Site.
This Privacy Policy describes the information, as part of the normal operation of our services, we collect from you and what may happen to that information. Although this policy may seem long, we have prepared a detailed policy because we believe you should know as much as possible about Trufina's practices so that you can make informed decisions.
By accepting the Privacy Policy and the User Agreement in registration, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Trufina User Agreement. This Privacy Policy is effective upon acceptance in registration for new registering users, and is otherwise effective on July 1st, 2004 for all users.
1. A Note Regarding Children.
Children (persons under the age of 18) are not eligible to use the Site unsupervised and we ask that children do not submit any personal information to us. If you are under the age of 18, you may only use this Site in conjunction with and under the supervision of your parents or guardians.
2. Information We Collect.
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose.
In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. Once you give us your personal information, you are not anonymous to us. If you choose to use our services, we will require you to provide contact and identity information (name and email address), billing information, and other personal information as indicated on the forms throughout the Site. Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature.
Under some circumstances we may require some additional financial or personal information, such as, but not limited to: if you are registering using an email account at a free email service, or you have moved within the last year. We use your financial information, including credit card information to verify the accuracy of your name, address, and other information, as well as to bill you for your use of our services.
We automatically track certain information based upon your behavior on the Site. We use this information to do internal research on our users' demographics, interests, and behavior to better understand, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on the Site or not), which URL you next go to (whether this URL is on the Site or not), your computer browser information, and your IP address.
We use data collection devices such as "cookies" on certain pages of the Site to help analyze our web page flow, measure promotional effectiveness, and promote trust and safety. "Cookies" are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a "cookie". We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Site and you may be required to reenter your password more frequently during a session.
As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole.
We do link this automatically-collected data to personally identifiable information. IP addresses are tied to personally identifiable information to better protect you from fraudulent access to your account.
Additionally, you may encounter "cookies" or other similar devices on certain pages of the Site that are placed by third parties. For example, if you view a web page created by another party, there may be a "cookie" placed within that web page. We do not control the use of cookies by third parties.
If you choose to change, view or share your profile on the Site, we collect information about your changing, viewing and sharing behavior.
If you establish a credit account with us to pay the fees we charge, we collect some additional information, such as a billing address, a credit card number and a credit card expiration date.
If you choose to post messages in our message areas or leave feedback for other users, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect such information into a file specific to you.
If you register for Trufina on another web site or use a web site providing a service for Trufina or a web site that helps facilitate your activity on Trufina, that web site may provide personal information about you and your transactions back to Trufina.
3. Our Use of Your Information.
We use your personal information to facilitate the services you request. We use your personal information in the file we maintain about you, and other information we obtain from your current and past activities on the Site to: resolve disputes; troubleshoot problems; help promote safe interactions between users; collect fees owed; measure consumer interest in our products and services, inform you about online and offline offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our User Agreement; and as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems or resolve disputes, and in particular we may examine your personal information to identify users using multiple User IDs or aliases. We may compare and review your personal information for errors, omissions and for accuracy.
You agree that we may use personal information about you to improve our marketing and promotional efforts, to analyze site usage, improve our content and product offerings, and customize the Site's content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.
You agree that we may use your personal information to contact you and deliver information to you that, in some cases, are targeted to your interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the Site. By accepting the User Agreement and Privacy Policy, you expressly agree to receive this information. If you do not wish to receive these communications, we encourage you to opt out of the receipt of certain communications on the notification preferences page within your own personal profile. You may make changes to your notification preferences at any time.
4. Our Disclosure of Your Information.
We do not disclose any personally identifiable information collected through the site whether publicly listed elsewhere or not, except as disclosed in this statement or as required by law.
As a matter of policy, we do not sell or rent any of your personal information to third parties.
We may disclose personally identifiable information we collect to third-parties to process credit card transactions, to complete the Trufina ID verification process, or to otherwise enable the functions of our service. These third parties are prohibited from using your personally identifiable information for any other purpose.
Trufina reserves the right to disclose to third parties aggregate usage statistics that do not contain personal information. In no event will Trufina include personal information in any such disclosure.
There are a number of separate services offered by third parties that we refer to as external service providers that may be complimentary to your use of the Site (e.g. email, instant messaging, online auctions, online dating, online commerce). If you choose to use these separate services, disclose information to the external service providers, and/or grant them permission to collect information about you, then their use of your information is governed by their privacy policy. We do not disclose your personal information to external service providers unless you provide your explicit consent. With your consent we may provide some of your personal information to the external service provider offering such services, for your convenience. To prevent our disclosure of your personal information to an external service provider, you can decline such consent or simply not use their services. Because we do not control the privacy practices of these third parties, you should evaluate their practices before deciding to use their services. Users who register on a Trufina co-branded web site grant Trufina permission to pass your email address and User ID back to that co-branded web site. The use of your email address and User ID by the co-brand web sites is limited by their applicable privacy policies.
When registering to be a full Trufina member you are required to enter the last four digits of your social security number so that we may accurately prove your identity. When you enter the four digits, we encrypt it using secure socket layer technology (SSL). We do not track this number in any log files, and only keep a copy in your personal record, in an encrypted form.
Legal Requests. Trufina cooperates with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights, to help protect you and the Trufina community from bad actors. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, state, telephone number, email address, User ID history, and viewing and sharing history without a subpoena. Without limiting the above, in an effort to respect your privacy and our ability to keep the community free from bad actors, we will not otherwise disclose your personal information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to: prevent imminent physical harm or financial loss; or report suspected illegal activity. Further, we can (and you authorize us to) disclose your name, street address, city, state, zip code, country, phone number, email, and company name to Trufina business partners under confidentiality agreement, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, piracy, or other unlawful activity.
Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they collect from the Site. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.
5. Your Use of Other Users' Information.
In order to facilitate interaction among all Trufina community members, our Site allows you limited access other users' contact and other personal information upon their approval.
By entering into our User Agreement, you agree that, with respect to other users' personal information that you obtain through the Site or through a Trufina-related communication or Trufina-facilitated transaction, Trufina hereby grants to you a license to use such information only for: (a) Trufina-related communications that are not unsolicited commercial messages, (b) using services offered through Trufina (e.g. messaging, notification, and fraud complaints), and (c) any other purpose that a user expressly agrees to after you tell them the purpose you would like to use it for. In all cases, you must give users an opportunity to remove themselves from your database and a chance to review what information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personal information about another user to any third party without our consent and the consent of that user. You agree that other users may use your personal information to communicate with you in accordance with this Section. Note that law enforcement personnel, Trufina business partners, and other rights holders are given different rights with respect to information they access.
Trufina and our users do not tolerate spam. Therefore, without limiting the foregoing, you are not licensed to add a Trufina user to your mail list (email or physical mail) without their express consent. To report Trufina related spam to Trufina, please contact us using our webform.
6. Use of Email Tools.
You may not use the email services that we offer to send spam or otherwise send content that would violate our User Agreement. We do not permanently store email messages or the email addresses sent from these tools.
If you choose to use our referral service to tell a friend about our site, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Trufina stores this information for the sole purpose of sending this one-time email.
Your friend may contact us by email to request that we remove this information from our database.
7. Control of Your Password.
You are responsible for all actions taken with your User ID and password, including fees charged to your account. Therefore we do not recommend that you disclose your Trufina password to any third parties. If you choose to share your User ID and password or your personal information with third parties, you are responsible for all actions taken with your account and therefore you should review that third party's privacy policy. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password as detailed in Section 8.
8. Accessing, Reviewing and Changing Your Personal Information.
We offer you the ability to automatically review and change the information you submit to us by logging into the Site and entering in the new information yourself. Generally, we will not modify your personal information based on your request because it is very difficult to authenticate your account manually. You can change your user Id, email address, contact information, financial information, and user preferences by going the preferences and setup section in MyTrufina. You must promptly update your personal information if it changes or is inaccurate.
Upon your request, we will deactivate your account, contact information, billing information, shipping information, and financial information from our active databases. To make this request, email us. Such information will be deactivated as soon as reasonably possible based on your account activity and in accordance with our deactivation policy and applicable law.
We will retain in our files some personal information you have requested to remove to prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our User Agreement and comply with legal requirements as is permitted by law. Therefore, you should not expect that all of your personal information will be completely removed from our databases in response to your requests. However, such personal information will be deactivated from member viewing and will only be available to select Trufina personal.
9. Other Information Collectors.
Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are sharing or viewing on our site or other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. Since Trufina does not control the privacy policies of third parties, you are subject to the privacy policies of that third party. We encourage you to ask questions before you disclose your personal information to others.
10. Security.
Your information is stored on Trufina Inc.'s servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, including encryption, "firewalls" and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by users inside and outside the company. However, "perfect security" does not exist on the Internet.
11. Choice/Opt-out
Our users are given the opportunity to 'opt-out' of having their information used for purposes not directly related to our site at the point where we ask for information. For example, our sign up form has an 'opt-out' mechanism so that those who sign up for our service, but don't want any marketing material, can keep their email address off of our lists.
Users who no longer wish to receive our newsletter, special offers, and promotional communications may opt-out of receiving these communications by emailing us. The user may also opt-out by contacting us at 301-951-8998, fax at 301-951-8998, or by mail at 73 Franklin Street, Annapolis, MD 21401.
11. Notice.
This policy was effective as of February 16, 2006. We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms shall automatically be effective 30 days after they are initially posted on the Site. In addition, we will notify you in accordance with your Notification Preferences.
