Privacy Policy-03-03-2022

Truss may obtain various types of personal data about users of the Services and non-customer Site visitors. This data may include:

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• Contact information (name, address, phone number, and email address);

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• Information about products ordered or provided;

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• Information collected through Internet-based and e-commerce activities such as information obtained from log files, cookies, clear gifs, images, and scripts;

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• Customer service and demographic data such as gender, income level, and information about your prior experiences with Truss’s products;

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• Information collected from our third-party service providers; 

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• Information required to make the Truss services operate for our customers, including for example employer, bank account or related financial information; and 

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• Other transaction-related data.

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We also may use certain tracking technologies described below to collect, store, or accumulate certain non-personally identifiable information concerning your use of the Services, including your browsing history, preferences, internet addresses, unique identifiers, device types, device location, and other similar information.

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When providing the Services we may also collect the following information about your computer or other device, including:

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• Device information, such as the type of device, operating system version, processor type, disk space, memory space, and number of drivers;

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• Information about software on your computer, including the version of certain software programs and when they were installed and/or upgraded; and

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• Information collected from logs, configuration files, registry keys, and other system or software-level information, such as IP address, MAC address, IDFA or IDFV, device and browser settings, webpages and mobile applications you use, advertisements you see and interact with, and certain website usage information.

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The data collected under this Section II is generally anonymous and aggregated. However, if Truss needs to have further information to diagnose certain kinds of problems or to monitor your computer for certain events, Truss will ask you for permission to collect this additional information.

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As part of accessing the Services, you may be asked to provide log-in or similar information so that Truss can aggregate data from multiple locations and repositories to display to you within the Services. We work with third parties to enable the transfer of that information to the holders of that data, and your provision of information to those third parties is in accordance with the privacy policies of those third parties. Links to those privacy policies are available for your review prior to the provision of any information, and we advise you to consult them directly. Truss does not maintain, store, or otherwise use in any fashion the information you provide via such third parties, except as necessary to provide the Services. 

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Truss requires certain data in order for the Services to function on your device or computer.  We use analytics software to help us better understand and improve the functionality of the Service, improve them, and tailor your experience.  This software may record information such as how often you use the Services, the events that occur within the Services, and aggregated usage and performance data.  We do not link the information we store within the analytics software to any personally identifiable information you submit within the Services.

We will retain your information for as long as your account is active and as needed to provide the Services. We will retain and use your information as reasonably necessary to conduct our business, comply with our legal obligations, resolve disputes, and enforce our agreements.

You hereby agree that Truss may use the personal data you submit in order to:

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• Accomplish its business purposes, including to deliver or provide the Services, establish or maintain customer and business relationships, improve the Services, provide access to Internet-based and e-commerce activities, perform accounting functions, and conduct other activities as necessary or appropriate in connection with the Services.

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• Market its products and services to you, and the products and services of its third-party partners, including to send you information about products, services, or promotions.

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• Opt-Out:  You may opt out of these promotional communications by following the instructions in each message, or by contacting us at privacy@trusspayments.com.

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• Send you service updates, announcements, and alerts related to the Services, including notices of security incidents, downtime, or planned maintenance. You may not opt-out of these service communications. If you do not wish to receive them, you have the option of deactivating your account and ceasing your use of the Services.

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In addition, Truss may transfer or disclose personal data to our service providers under written contracts as needed for such service providers to perform services on our behalf, including to fulfill our obligations to you. Service providers and business partners that are provided information under this section will not use personal data for any other purposes. If Truss has knowledge that a Truss business partner or service provider is processing your personal data in a way that is contrary to this Privacy Policy, Truss will take reasonable steps to prevent or stop such processing. In such case, you agree that Truss will not be held liable for the misuse of your data.

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Truss may transfer or disclose personal data, including your contact information, to its affiliates, licensees, partners, and other third parties as appropriate in accordance with the terms of written agreements for legitimate business purposes.

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Truss will, in its sole discretion, disclose your personal data to third parties in certain additional limited cases:  (1) when 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 the rights of Truss or its customers and vendors; (2) when we believe in good faith that the law requires us to do so; (3) to a subsequent owner, co-owner, or operator of a Site, Services, or applicable database or in connection with a merger, consolidation, or restructuring, or the sale of substantially all of our interests and/or assets, or other corporate change, including during the course of any due diligence process; and (4) in situations involving threats to the physical safety of any person.

Your data is of the utmost importance to us.  We use Secure Sockets Layer (SSL)/Transport Layer Security (TLS) and other transmission technologies to encrypt your personal data so it cannot be read in transit. In addition, we use secure technology, privacy protection controls, and restrictions on employee access to safeguard your personal information in storage. We restrict access to personal information on a need-to-know basis to employees and authorized services providers who require access to fulfill their job requirements.  As noted in Section II above, the provision of information to third parties as part of the Services is governed by those third parties’ privacy policies and we do not guarantee the security of information you transmit to them.

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Please note that although we employ industry-standard security measures to safeguard the security of your personal information, no transmissions made on or through the Internet are guaranteed to be secure. Therefore, we cannot ensure the absolute security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.

Because of the manner in which we offer our Services, we cannot provide them to customers who do not permit our use of cookies or whose browsers are set to reject cookies.

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We and our marketing partners, affiliates, or analytics or service providers use technologies such as cookies, beacons, tags, browser and device fingerprinting, network traffic monitoring, active scripting, recognition technologies, and scripts, to analyze trends, administer the Services, track users’ movements when using the Services, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

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We may not control those tracking technologies and are not responsible for them. However, you consent to potentially encountering third-party tracking technologies in connection with use of our Services and accept that our statements under this Privacy Policy do not apply to the tracking technologies or practices of such third parties.

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There may be other tracking technologies now and later devised and used by us in connection with the Services. Further, third parties may use tracking technologies in connection with our Services, which may include the collection and storing of information about your online activities over time and across third-party websites or online services.

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We may partner with one or more third parties to either display advertising via the Services or to manage advertising on other sites. Our third-party partner(s) may use tracking technologies to gather information about use of the Services and other websites to serve you targeted ads.  You may be able to opt-out by visiting:  http:/www.networkadvertising.org/managing/opt-out and/or http:/www.aboutads.info/choices.

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Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We do, however, work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.

If you click on a link to a third-party site, you will leave the Services you are using and be redirected to the site you selected. Because we cannot control the activities of third parties, we do not accept responsibility for any use of your personal data by such third parties, and we do not guarantee that they will adhere to the same privacy policies as Truss. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party site that is linked to the Services, you should read that third-party site’s privacy statement before providing any personal data.

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If you use a public or semi-public discussion forum on any of the Sites or via the Services, you should be aware that any personal data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personal data you choose to submit in these forums. You may remove your post along with your personal data you submit within these forums by contacting us at privacy@trusspayments.com.

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Our Services may include social media features, such as the “Share This” button that allows you to like us on Facebook or share our content on Twitter. These features may collect your IP address and which page or information you are visiting or accessing via our Services, and they may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the applicable company.

1. Categories of Personal Information We Collect

Along with the information in the Privacy Policy as a whole, the CCPA requires us to describe the information we collect in certain “categories.”  The categories we collect now or in the future may include:

• Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, employer, account name, or other similar identifiers);

• Commercial information (such as transaction data and financial account and management information);

• Internet or other network or device activity (such as browsing history and information on interaction with a website, application, or advertisement);

• Geolocation data (at an IP-based or city/state/zip level);

• Inference data about you drawn from the data in this section (based on user profile information);

• Legally protected classifications (such as age and gender);

• Other information that identifies or can be reasonably associated with you (e.g., information you voluntarily provide as you use the Services, such as additional profile information or user-generated content).

2. The Sources From Which the Categories of Personal Information Are Collected

We collect personal data directly from information you provide to us; indirectly from our affiliates, service providers, and other vendors; and indirectly through your interactions with websites or advertisements.

3. Business Purposes for Our Collection of Personal Information

The following is a list of the business purposes for our collection of information.

• Provide the Services you have requested, including invoicing and accounting;

• Respond to your requests for information and provide you with more effective and efficient customer service;

• Provide you with updates and information about the Services;

• Contact you by email, postal mail, or phone regarding our Services and third- party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you;

• Customize the advertising and content you see via the Services;

• Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services;

• Secure our websites and applications, and resolve technical issues being reported;

• Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and

• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

4. Sharing of Categories of Personal Information

We may share categories of personal information to accomplish the various business purposes above and as described throughout this Privacy Policy.

5. CCPA Rights Disclosure

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If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

• Inform you about the categories of personal information we collect or disclose about you and the categories of sources of such information;

• Inform you about the business or commercial purpose for collecting personal information and the categories of third parties with whom we share/disclose personal information (which is also disclosed in this Privacy Policy);

• Provide you with the specific pieces of personal information we collect about you; and

• Delete personal information we have about you.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. You may only make such a request twice within a twelve-month period. Requests are generally free; however, we may charge a reasonable fee or deny your request if it is manifestly unfounded, excessive, or repetitive.

To make a CCPA request, please contact us at privacy@trusspayments.com. We will request information, which at a minimum will include your name and email address, to verify your identity. We may request additional information to verify your identity before responding to a request. Under the CCPA, you may have an authorized agent submit a request on your behalf, and we will collect certain authorization and verification information from the agent and you in such circumstances.

The CCPA further provides you with the right to receive information about the financial incentives that we offer to you, if any, and the right not to be discriminated against for exercising your rights under applicable law.

If you would like further information regarding your legal rights under California law, please contact us at privacy@trusspayments.com.

6. California Do Not Sell Notice and Information Request

If you are a California resident, the CCPA provides you with the right to opt out of the "sale" of your "personal information." We may allow some of our advertising partners to collect certain pieces of information from our site visitors, such as device identifiers, cookies, advertising IDs, IP addresses, and usage activity, so that we and our partners can deliver ads that are more relevant to you. This type of information sharing with our advertising partners may be considered a "sale" under the CCPA. If you want to opt out of these activities, please contact us at privacy@trusspayments.com.  Please note that some or all of the Services may not function if you choose to opt out of such activities.

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If you are a California resident, California Civil Code Section 1798.83 allows you to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for the third parties’ direct marketing purposes in the 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 in the immediately preceding twelve calendar months. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy inbox at privacy@trusspayments.com.

You can access, update, or correct your information, or otherwise ask us questions about this Privacy Policy by contacting us at privacy@trusspayments.com. 

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We may update this Privacy Policy from time to time to reflect changes to our information practices. When we make changes to this Privacy Policy, we will revise the “Posted” and “Effective” dates at the beginning of this Privacy Policy. If the changes to the Privacy Policy are material, we will notify you a notice on the Site, via the Services, or via email if we have your email address on file.