Privacy policy

/Privacy policy
Privacy policy 2018-03-12T08:25:44+00:00

Privacy policy

Effective: January 1st, 2010
Last Update: February 20, 2018

Truth Technologies, Inc. (“Truth Technologies”, “we” or “us”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union member countries. Truth Technologies has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

In compliance with Privacy Shield Principles, Truth Technologies commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Truth Technologies at: privacy@truthtechnologies.com

Truth Technologies has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Notice

What Personal Information Truth Technologies Collects or Receives: Truth Technologies may receive personal information from our clients in connection with the services Truth Technologies provides to them, and such personal information may include name, address, date of birth, country of residence, citizenship/nationality, and other information they specifically provide to us on a case-by-case basis. In addition, Truth Technologies may collect personal information such as name, title, firm, address, e-mail address, phone number and other non-identifiable information from persons who have requested information from us or expressed interest in our products and services. Personal information may be provided to or collected by Truth Technologies electronically, over the Internet, physically or through a third party.

How Truth Technologies Uses Personal Information: Personal information sent to Truth Technologies by our clients is used exclusively for the purposes of providing those services to our clients for which they have contracted with Truth Technologies. Truth Technologies does not share, transmit, disclose, rent or sell any such personal information to any other parties. Furthermore, personal information we collect from you will be used by Truth Technologies exclusively for the purpose of providing and improving Truth Technologies’ services to you, or informing you of additional products and services of Truth Technologies which we think will be of interest to you.

Non-personal Information: Other information gathered through this website is purely statistical, such as what web pages are visited most often. This information is useful to Truth Technologies and enables us not only to improve and upgrade our website but also to refine our product lines and marketing. This information is anonymous in nature.

No Collection of Sensitive Information: We do not collect sensitive information (e.g., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual).
Questions Regarding Our Information Policies: If you have any questions or complaints regarding Truth Technologies’ information collection and handling policies and procedures, you may contact us at: privacy@truthtechnologies.com

Choice

If you request information from us, you will be given the choice at that time to opt out of receiving future communications from us on information, products, or services that may be of interest to you.

If you have provided us with your personal information in the past, and you do not wish to receive further communications of information, products, or services from us, you can opt out by contacting us via mail or email at:

Truth Technologies, Inc.
5621 Strand Boulevard, Suite 305
Naples, FL 34110 USA
-or-
privacy@truthtechnologies.com

If you provide personal information to Truth Technologies as part of a service we provide to you or your organization, or one of Truth Technologies’ clients, we do not share, transmit, disclose, rent or sell that personal information to any third parties.

Onward Transfer

Other than as described below, information provided to Truth Technologies as part of our business services is not disclosed, transmitted, shared, rented or sold to any third parties.

If you provide us with personal information in order to receive information from us, we do not disclose, transmit or share that information with any third parties, except that we may disclose, transmit or share that information with third parties we have retained to assist us and who are working under our instructions, including, but not limited to, business partners, advertisers or vendors, and then only for the purposes of fulfilling our contractual obligations to you or alerting you to information, products, and services pertaining to Truth Technologies offers that may be of interest to you. Any third party with which Truth Technologies may share personal information for these purposes must demonstrate that they also subscribe to the Privacy Shield Principles or agree in writing that they provide at least the same level of privacy protection as is required by the Privacy Shield Principles, and they are required to notify us if they can no longer meet this obligation.

Truth Technologies remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on our behalf do so in a manner inconsistent with the Principles, unless Truth Technologies proves that it is not responsible for the event giving rise to the damage.

Truth Technologies does not share, transmit, disclose, rent or sell personal information to any third party organization for such third party’s commercial use.

Right of Access

You have the right to contact Truth Technologies at any time to review the personal information about you that we hold. You may correct, amend, or delete that information where it is inaccurate or has been processed in violation of the Privacy Shield Principles. Your rights in this regard may be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated. To exercise your rights with regard to access as provided under Privacy Shield Principles, please contact us at privacy@truthtechnologies.com.

Security

Truth Technologies employs reasonable precautions within our company – including physical, electronic, and procedural safeguards – designed to help secure the privacy of all personal information we retain, and protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data. Should you become aware of any violations of privacy or wish to inquire about how we secure private information, please contact us at the address before (see Section Enforcement).

Data integrity

Personal Information that Truth Technologies collects from you is limited to that personal information that is relevant for the purposes for which it has been collected and processed. In addition, personal information provided by Truth Technologies’ clients in connection with the services we provide them is relevant and compatible with the service we are contracted to provide to our clients. However, because such personal information is provided by our clients and we have no contractual right to alter, amend, update, or otherwise clean up such information, Truth Technologies does not undertake to update, clean-up, amend or otherwise alter any data it receives. Provided such information is compatible with the services we provide, Truth Technologies accepts all information provided to it by its clients in connection with their use of our services and we record it as it is received by us, regardless of the state of such information.

Enforcement

Truth Technologies’ participates in a SAS-70 audit of our security policies and procedures. As part of this independent accounting firm audit Truth Technologies we re-examine all aspects of our operations to ensure strict adherence with the Privacy Shield Principles.

In compliance with the Privacy Shield Principles, Truth Technologies commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy or compliance with the Privacy Shield Principles should first contact Truth Technologies at:

Truth Technologies, Inc.
5621 Strand Boulevard, Suite 305
Naples, FL 34110 USA
-or-
privacy@truthtechnologies.com

Truth Technologies has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Truth Technologies is subject to the investigatory and enforcement powers of the Federal Trade Commission, which is the competent supervisory body under the Privacy Shield program. Where a complaint cannot be resolved by any of the before mentioned recourse mechanisms, individuals may have a right under certain conditions to invoke binding arbitration under the Privacy Shield Panel (as provided for under Privacy Shield Annex I) as recourse mechanism of ‘last resort’.

Truth Technologies’ adherence to the EU-US Privacy Shield Principles may be limited (a) to the extent necessary to meet applicable national security, public interest, or law enforcement requirements, e.g. in the course of lawful requests by public authorities (b) by statute, government regulation, or case law that creates conflicting obligations or explicit authorizations, provided that, in exercising any such authorization, an organization can demonstrate that its non-compliance with the Principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization; or (c) if the effect of EU data protection law, or Member State law is to allow exceptions or derogations, provided such exceptions or derogations are applied in comparable contexts.

If Truth Technologies transfers personal information to non-agent third parties acting as a controller, Truth Technologies will apply the Notice and Choice Principles unless a derogation for specific situations under European data protection law applies and will obtain assurance from these parties that they will provide the same level of protection as is required under the Privacy Shield Principles.

Truth Technologies reserves the right to update and revise this Privacy Policy at any time. You can determine if this Privacy Policy has been revised since your last visit by referring to the “Effective Date of Current Policy” date at the top of this page. Your use of Truth Technologies’ service, products and/or websites constitutes your acceptance of the terms of this Privacy Policy as amended or revised by us, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.

We value your opinion as to this Privacy Policy. Please feel free to contact us with your privacy concerns. Truth Technologies can be reached at:

Truth Technologies, Inc.
5621 Strand Boulevard, Suite 305
Naples, FL 34110 USA
-or-
privacy@truthtechnologies.com

Policies and procedures

Last Update: February 12, 2018

  1. Definitions. Capitalized terms used in, and not otherwise defined in these Policies and Procedures, have the meanings ascribed to them in the Agreement between Truth Technologies, Inc. (“TTI”) and Subscriber (“Agreement”).
  2. Performance. TTI will use commercially reasonable efforts to update, augment and maintain the Content, as compiled from selected public records and other sources. Subscriber accepts all Service, Content and Data provided by TTI on a “AS IS” basis, with no warranty or guarantee as to the truth, accuracy or completeness of the Service, Content and Data. THERE ARE NO WARRANTIES, EXPRESS OR IMPLIED, BY TTI AND THE INFORMATION PROVIDERS IN CONNECTION WITH THE SERVICE, CONTENT OR DATA, INCLUDING, BUT NOT LIMITED TO, WARRANTIES FOR MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OF THIRD PARTY RIGHTS, OR THAT THE SERVICE, CONTENT OR DATA IS CORRECT, ERROR FREE, COMPLETE, AND/OR CURRENT AND UP TO DATE, OR THAT THE SERVICE, CONTENT OR DATA WILL BE SECURE, TIMELY DELIVERED, UNINTERRUPTED, FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR WILL SUFFICIENTLY OPERATE IN COMBINATION WITH ANY OTHER HARDWARE, SOFTWARE SYSTEM OR DATA.
  3. Support. TTI will offer e-mail support through the Sentinelâ„¢ Web site at https://sentinel.truthtechnologies.com and https://cayman.TruthTechnologies.com. All support e-mails submitted during regular business hours will be answered within one (1) business day.
  4. Interruption of Service.
    1. Scheduled Interruptions. Subscriber acknowledges that the Service may be temporarily interrupted or curtailed due to equipment modifications, upgrades, relocations, repairs and other similar activities during the operation and upgrade of the Service. Subject to the terms of Subscriber’s Agreement, no reduction of payments will be made in the case of scheduled interruption of the Service, provided such interruptions do not exceed 24 hours during any consecutive 30-day period, excluding planned maintenance (i.e. planned Downtime) or regularly scheduled and/or planned Content updates.
    2. Data Source Update. TTI uses the following update schedule for data sources: Monday – Friday: World-Check, OFAC, HMT, EU.
    3. Force Majeure. TTI will not be liable for loss or damage resulting from any delay or non-performance due to any cause or causes beyond its reasonable control, including an act of the Subscriber, malfunctioning or nonfunctioning of equipment, a delay in transportation, acts of God, fire, flood, earthquake, storm, war, sabotage, riot, civil commotion, or because of any law, rule, regulation, order or other action by any public authority, provided TTI (i) gives the Subscriber written notice of such cause promptly, and (ii) uses its reasonable commercial efforts to correct such failure or delay.
    4. Internet connectivity. Because Subscriber will access the Service over the public Internet, temporary disruptions of network connectivity will occur from time to time. Internet traffic is usually routed through many different Internet backbone providers on the way to its destination. TTI will not be liable for interruption or delays in transmission or errors or defects in transmission or failure to transmit when caused by any Internet backbone provider.
    5. Liability. Except as otherwise expressly provided in Subscriber’s Agreement, in no event shall TTI be liable for any damages due to interruption of Service except for a pro-rata refund of fees actually paid by Subscriber for the Service and then only in any amount in proportion to the actual downtime attributable to such interruption of Service.
  5. Audit. Subscriber understands and agrees that in order to ensure compliance with applicable law; TTI reserves the right to conduct periodic reviews of Subscriber’s activity and may, on a random basis, contact Subscriber to provide documentation of executed searches using the Service. TTI shall also investigate all legitimate reports of abuse or misuse of the Service.
  6. Notification.
    1. Data Breach. In the event of a data breach, Subscriber whose data was affected by the breach will be notified by TTI.
    2. Law Enforcement Requests for Disclosure. Subscriber shall be notified of any legally binding request for disclosure of the Personal Data by a law enforcement authority unless otherwise prohibited, such as a prohibition under law to preserve the confidentiality of a law enforcement investigation.
  7. Conflict. In the event of any conflict between the terms of Subscriber’s Agreement and these Policies and Procedures, the terms of Subscriber’s Agreement shall control unless such Agreement provides otherwise.