True Influence LLC respects your privacy.
Core activity of True Influence is to provide support to its customers in marketing B2B products by generating effective leads from the target markets.
It is True Influence’s policy to respect your privacy regarding any information we may collect through registration forms, resource libraries, advertising units, widgets, web sites and web pages, whether accessed via computer, mobile or tablet device, or other technology (collectively, the “Service”), collection and licensing of data through third parties we work with, and how such information may be used and/or shared with others, how we safeguard it, and your choices in controlling its use in connection with our marketing activities.
True Influence operates under a number of different brands, including BusinessTech Alert, SecurityTech Alert, HRTech Alert. All such brands are collectively called “Services”.
True Influence is 100% Can-Spam Compliant
True Influence has a zero tolerance spam policy. Any partner or publisher found to be using True Influence promotional offers for spam will be immediately cut-off from use of the product. If you know of or suspect any violators, please notify us immediately at email@example.com
Data Controller and Data Processor
We process two main types of personal data.
- Customer Data –
- Personal data that forms part of data that is provided by our customers
- Personal data that we collect / we engage third parties to collect on behalf of our customers using campaign information provided by the customer
- Personal data that we purchase from third parties based on customer mandated criterion
- Other Data –
- Personal data about our customers, service providers, visitors and other individuals that is collected and processed directly by us.
Our Customers are the controller of Customer Data. True Influence is the processor of Customer Data and the controller of Other Data.
- Customer Data
True Influence collects this data based on our customer’s instructions (also known as campaign information) through different channels including business partners (publishers) using relevant technology in web marketing, E mail marketing and Telemarketing.
The leads generated by the publishers are intelligently filtered to improve their quality and converted into actionable marketing targets before being passed on to the customers.
This data includes business contact information to match criterion provided by the customer.
- Other Data
We also collect data when you use our applications and websites
- Log Data – Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address
- Subscription Data – You provide personal data to us as part of signing up for our newsletter on our websites. We may also collect personal information from you when you use interactive features of the Websites, promotions, requesting customer support, or otherwise communicating with us.
- Contact Us Data – When you enquire about our products and services or request for demonstration of our product, we collect and store this data to communicate with you and respond to your enquiry.
Our purpose in collecting information is to help us provide you with better service, such as notifications about special offers and promotions, or other relevant content delivered through targeted advertising.
The trueinfluence.com website may also collect a recipient’s email address to help you to initiate and email the recipient you have selected. The recipient may contact us at firstname.lastname@example.org to request that we remove this information.
We collect data through cookies
How We Use the Information We Collect
Customer Data will be used by True Influence in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. True Influence is a processor of Customer Data and Customer is the controller.
True Influence may use the information we obtain, license and collect about and from you for a number of business purposes, including for example, to: better tailor website and promotional content to visitor interests; verify your profile information; deliver targeted advertising; inform our partners of your business-related interests; improve the Service for internal business purposes; help our advertising partners better understand the audience they are reaching; and for purposes we disclose at the time you provide your Personal Information.
Lawful basis for processing
We have lawful basis to process your personal data. We also use your consent as basis for lawfully processing your personal data.
We process your personal data only when we have a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the Data Protection Regulations.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where you have consented to a particular processing, you have a right to withdraw the consent at any time.
Types of HR Data Collected
True Influence collects certain Personal Data from its Employees and Job Applicants, including without limitation (collectively, the “HR Data”).
- home address,
- telephone number(s),
- date of birth,
- social security number or other government identification number,
- bank account details,
- job title,
- employment contracts,
- reviews and appraisals, competency assessments
- business travel details
- disciplinary records
- IP address, system-generated logs
- facts reported through the whistleblowing hotline or regular information and reporting channels,
- evidence gathered in the course of the investigation, report of the investigation and outcome of the report
Purpose of Collection and Use of HR Data
True Influence processes HR Data relating to its Employees and Job Applicants in the US, UK or EEA for recruitment and HR management purposes at a global level, including:
- Carrying out and supporting True Influence’s human resources functions and activities;
- Carrying out True Influence’s obligations under employment contracts and employment and benefits laws;
- Managing workplace safety and health;
- Administering employee participation in benefits, compensation, human resources and training plans and programs;
- Managing employee performance;
- Implementing compliance and discipline procedures, and investigating and reporting on Employee compliance and discipline;
- Complying with True Influence’s legal obligations and internal policies;
- Managing internal complaints or claims and litigation;
- Implementing and operating a whistleblower hotline;
- Managing and conducting True Influence’s business activities, including allocating company assets and human resources, project management, records management and compilation of audit trails or other reporting tools, managing mergers, acquisitions, sales, re-organizations or disposals and integration with purchaser;
- Operating IT and communication systems and monitoring Employee email and Internet usage to the extent permitted by applicable law
True Influence does not knowingly collect Personal or Usage Information from children under the age of 13 through https://www.trueinfluence.com, nor from any of our affiliates and partners. If you are under 13, please do not give us any Personal Information, and do not provide Personal Information to any website or web service without consulting your parent or guardian. If you have reason to believe that a child under the age of 13 has provided Personal Information to True Influence, please contact us, and we will seek to delete that information from our database.
True Influence is engaged in providing B2B services for customers to identify targets for the marketing of business products and in the process collects business contact data of companies and executives working in companies which are prospective customers for the products to be marketed.
True Influence and its business partners (publishers) collect the data based on campaign information provided by True Influence’s customers.
The publishers obtain the necessary consent from the data subjects with appropriate disclosures.
A fair opportunity is provided by the publishers to the data subjects to opt out.
True Influence has entered into necessary legally binding contracts with the publishers to ensure compliance of relevant regulations for collection, processing, storage and transfer of data.
Advertising / Behavioural Targeting; How to Opt-Out
We may use third party vendors to enhance the Service (e.g. for purposes of retargeting). When you opt out of the Service, True Influence will no longer use or share any of your Personal or anonymous Usage Information, unless you recently submitted Personal Information (within last 30 days) in order to access free content, in which case only the Content Provider associated with the content you recently acquired will have access to your information. Please contact True Influence at email@example.com to opt out of this option.
We may engage companies that provide services to help us with our business activities such as our blog and career pages. These companies are authorized to use your personal information only as necessary to provide these services to us.
Sharing of Information
Your data will be shared with other recipients in order to provide you with services.
While we aim to limit the sharing of your data, at times, it is necessary to share your data with certain service providers. Examples of when and for what purpose your data is shared include data center / hosting services, email marketing services, etc.
- Customer Data:
- Third Party Cloud Service Providers
- Publishers (who collect the data on our customer’s behalf)
- Tele-verifiers (who verifies accuracy of telephone numbers and emails shared by publishers)
- Email verifying software
- Other data
Cross-Border Data Transfers
Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region
The Service and the servers and facilities that maintain the data we hold, are operated in the United States. Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States.
True Influence offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the European
Union, and other international transfers of customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between True Influence and its Customers, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.
True Influence also certifies to the EU-US Privacy Shield Framework for data transferred from the EU to the United States. To read more about our participation in Privacy Shield, please review our Privacy Shield Notice below.
By using the Service, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.
Accountability for onward transfer
True Influence is responsible for the processing of personal data it receives under the EU U.S. Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf or providing data storage services.
Data Integrity & Purpose Limitation
Any personal information received from publishers in which personal data of EU citizens may be contained is treated as “EU Sensitive Data” and adequate technical and administrative controls are implemented across all the True Influence entities.
The personal information is used only for the purpose for which it has been collected and is shared within the organization on a need to know basis.
The technical and administrative controls ensure preservation of the confidentiality, integrity and availability of information as per the contractual obligations that True Influence has committed itself to.
True Influence maintain reasonable and appropriate security measures to protect data and information under its control from unauthorized access, disclosure, misuse, loss or alteration.
True Influence’s security measures include industry-standard technology and equipment to help protect your information, and True Influence maintains security measures to allow only the appropriate personnel and contractors access to your information as well as policies and procedures to support implementation of various security controls. Unfortunately, no system can ensure complete security, and True Influence disclaims any liability resulting from use of the Service or from third party hacking events or intrusions.
We will retain this information for as long as needed to provide services to any one of our
Customers or as otherwise authorized, directed or permissioned by our Customers. In addition, True Influence will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will retain this information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with the True Influence Data Retention Policy or as otherwise permitted applicable laws and regulation. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
Retention period for personal data and rationale for retention period is defined in True Influence’s ‘Data Retention Policy’.
Your GDPR Rights
You can request to access, update or correct your personal information. You also have the right to object to direct marketing.
You may have additional rights pursuant to your local law applicable to the processing. For example:
If the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.
If your personal information is processed under the Principles of the EU-U.S. Privacy Shield, you have the right to access to personal information about you that we hold and be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.
Your Rights to Control Data
Whenever you use our services, we aim to provide you easy means to access, modify, delete, object to or restrict use of your personal information
We strive to give you ways to access, update/modify your data quickly or to delete it unless we have to keep that information for legal purposes. Some rights can be accessed from within the True Influence application. For visitors, these rights can be exercised by contacting us with your specific request.
If you are based within the EEA, or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
- Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.
- Delete Data: You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to provide Services to you).
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g. if we have no legal right to keep using it) or to limit our use of it (e.g. if your personal data is inaccurate or unlawfully held).
- Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
If you wish to access, verify, correct, or update your personal Information collected through the Service, you may contact us at firstname.lastname@example.org
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
True Influence Services
True Influence also collects information under the direction of any one of its Customers, in which case it collects cookie identifiers from the individuals. If you are a customer of any one of our Customers and would no longer like to be contacted by our Customer that uses our Service, please contact the Customer that you interact with directly. We may transfer personal information to companies that help us provide our Service. Transfers to subsequent third parties are covered by the service agreements with our Customers.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the pertinent True Influence’s Customer (the data controller).
Other Web Sites
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, or a sale of our significant assets, we reserve the right to include any information we have among the assets transferred to the acquiring company.
Social Media Widgets
Our website includes social media features, such as the “Facebook Like” button, and Widgets, such as the “Share This” button or interactive mini-programs that run on our website. These features may collect your internet protocol address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement of the company providing them.
Our website offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Privacy Shield Notice for Data Transferred to the United States from the EU
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, True Influence is subject to the regulatory enforcement powers of the U.S. Federal Trade
Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, True Influence may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
True Influence’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, True Influence remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless True Influence proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, True Influence commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints regarding our Privacy Shield policy should first contact us at firstname.lastname@example.org .
True Influence has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your complaint involves human resources data transferred to the United States from the EU in the context of the employment relationship, and True Influence does not address it satisfactorily, True Influence commits to cooperate with the panel established by the EU data protection authorities (DPA Panel), as applicable and to comply with the advice given by the DPA panel, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.
Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction