This is the Privacy Policy (the “Privacy Policy” of www.trubloq.com) (referred to in this Privacy Policy as “Trubloq”, “we”, “us”, and “our”). Persons accessing our websites (the “Sites”) and/or customers using our Services are referred to as “Customer”, “you”, and “your”.
Please keep in mind that if you access and use our Services, then your access and use is governed by, and subject to, the Terms of Service [add link] to which you have agreed in order to use the Services. The Terms of Service incorporate this Privacy Policy. Any capitalized terms that are not defined in this Privacy Policy (that is, you don’t find them in quotes (“”) in this Privacy Policy) will have the meanings given to them in our then-current Terms of Service.
Your privacy is important to us. As part of our efforts to facilitate and make your experience with the Sites and our Services as user-friendly, enjoyable and productive as possible, we may collect and use certain information you provide to us. This Privacy Policy addresses the collection, use, and disclosure of information that we may gather during your use of the Sites and the Services (for example, all Usage Data, including your Account Data and Content).
Please review the entire Privacy Policy to learn the types of Personal Data we gather, how we use that Personal Data, what Personal Data is disclosed and to what Third Parties, and how we safeguard your Personal Data.
Please also check back periodically as this Privacy Policy may change from time to time. We will notify you of any material changes by publishing the new Privacy Policy through the Sites and/or the Services. The Personal Data we gather is and will be subject to the Privacy Policy in effect at the time the information is gathered. Should you have any questions or concerns at any time, please feel free to contact us.
This Privacy Policy applies only to our Sites and to our Services. This Privacy Policy does not apply to any websites managed, maintained, and/or hosted by Third Parties not directly affiliated with us that you may visit (for example, via a link provided through the Sites, contained in any communication transmitted in connection with the Services, or on a website maintained by any Third Party). Further, this Privacy Policy does not apply to any products or Services offered or provided by any Third Parties we do not own or control (for example, telecommunications carriers, other communications suppliers and Payment Processors). We do not monitor or control the policies or practices of Third Parties (whether as to privacy, security or anything else, including how they collect, process or store information and Personal Data), including other websites to which we may provide hyperlinks or of Third Parties to which we send Content in connection with the provision of the Services or to which we provide Account Data ancillary to the billing and payment for our Services. We encourage you to learn more about the privacy and data security policies and practices of Third-Party websites and services directly from such Third Parties (including telecommunications carriers, other communications suppliers and Payment Processors, as their policies and practices may differ from ours. Further, this Privacy Policy does not reflect the privacy practices of our customers. Even though we require our customers to comply with applicable Law, we are in no way responsible for such customers’ acts or inactions, including whether they comply with applicable Law and/or for their privacy policies or practices.
PLEASE REVIEW THIS PRIVACY POLICY AND THE TERMS OF SERVICE CAREFULLY BEFORE PROVIDING YOUR EXPLICIT AFFIRMATIVE CONSENT (“OPT IN”) TO PROCESS YOUR INFORMATION FURTHER. BY SUBMITTING YOUR INFORMATION TO US OR BY USING THE SITES AND/OR THE SERVICES, IT WILL BE CONSIDERED THAT YOU HAVE READ, UNDERSTOOD, AND THEN CONSENTED TO THE USES DESCRIBED IN THIS PRIVACY POLICY. If you do not wish to give your consent ( Opt In ), you should not access or use the Sites or the Services and you should not submit (and should not permit any Third Party, including any End User, to submit) your or any Third Party’s (including any End User’s or any End Customer’s) Personal Data to us.
This Privacy Policy applies to Trubloq’s practices regarding the collection, use, retention, disclosure and disposal of Personal Data (as defined below) provided by our customers and others using our Sites and/or Services. This includes your Personal Data as well as Personal Data of Third Parties (including End Users and End Customers) that you or others provide to us.
As you interact with and use our Sites and/or our Services, we may collect and use Personal Data received from you and others (including Personal Data of and from End Users and End Customers). We use the term “Personal Data” to refer to any information that identifies or can be used to identify you or another individual (including End Users and End Customers). Examples of Personal Data that we collect from our customers and/or user may include: name, user names and passwords, business entity names, telephone number, e-mail address, IP address and certain credit card and payment related information. Other Personal Data that we collect is identified in Section 3 below.
We use the term “Sensitive Personal Data” to refer to a smaller subset of Personal Data which is considered more sensitive to the individual, such as: race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometrical information, physical or mental health information, medical insurance data, or sexual orientation.
We do not want you to provide us with any Sensitive Personal Data. You agree that you will not provide us with any such Sensitive Personal Data and that you will ensure that no End Users or End Customers provide us with any such Sensitive Personal Data.
We obtain information about you from a variety of sources, including you, your interaction with our Sites and/or Services, and Third Parties.
If you use our Services or communicate with us (by telephone, chat, email, web forms, social media, API connections, or other means of communication), you may voluntarily, or be required to, provide us with certain information and Personal Data, including in the following ways:
If you do not provide us with Personal Data, your ability to use certain aspects of our Services may be limited.
We may collect your usage information about how you use our Services, including your access times, location, browser types and language, and Internet Protocol addresses. We may collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device's interaction with our Services. We also automatically receive and collect information about communications sent and received using our Services (for example, when a message is transmitted, or replied to via another message, using our Services, we automatically receive, collect and maintain information relevant to the message, including Content, receipts, telephone numbers, size, time of transmission, confirmations, and other message data) which may include Personal Data.
This type of information is collected automatically by our servers when you access our Sites or use our Services. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from Third Parties. It helps us to improve and to deliver better and more personalized Services, including by enabling us to:
The technologies we use for this automatic data collection may include:
We may also collect information about you from your interaction with and use of certain functionalities on our Sites or of the Services:
Messaging through the Services. The Services enable you and Third Parties (including your End Users and End Customers) to transmit messages to communicate with one another as permitted in the Terms of Service. In connection with the use of the Services, you and Third Parties may provide us with Personal Data and other information about you, your End Customers and End Users, and other Third Parties. For example, we may receive Personal Data and other information from message senders, telecommunications carriers and other communications suppliers, databases with information relevant to telephone numbers submitted to our Services, and other Third Parties. This information may include Content, telephone numbers, telephone numbers’ validity, types of telephone numbers (e.g., mobile or landline), device status (e.g., whether or not the device is currently available for messaging), roaming status, telecommunications carrier, country of location, and whether or not the number has been ported. We may, without obligation, review the Content of any messages transmitted to or through the Services as permitted in the Terms of Service, including in connection with providing support services and the investigation of complaints.
We may also collect information about you from Third Parties, including but not limited to third-party verification services, Payment Processors, credit bureaus, mailing list providers, and publicly available sources. This information may include your Social Security number or analogous identifier. We may also collect information about you from our channel partners, including our resellers, Third Party marketing partners, or Third-Party service providers we may engage to provide you with certain aspects of our Services or products, such as help desk service providers or hosting services. We may also collect information about you if you attend one of our trade shows or events, or from social networks, public sources, and our Third-Party analytics service providers.
Whenever we collect Personal Data from you, we may do so on the following legal bases:
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purpose.
We will use Personal Data only in ways that are compatible with the purposes for which it was collected or authorized by you (including as permitted in the Terms of Service in connection with our performance of the Services or otherwise). We will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. This Section provides additional information on how we use your Personal Data.
We use information to provide, maintain, personalize, monitor, and improve our Services, to analyze how you use the Services, to contact you, to allow others (including End Customers) to contact you through the Services, and to deliver the information and support, process, and fulfill your requests, including support, marketing, and administrative messages.
We may use information we collect to send you news and information about our Services and to communicate with you about products or Services. You may opt out of receiving promotional emails or text messages from us by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as messages about your Account or our ongoing business relations.
We may also use information about you (i) to track and analyze trends and usage in connection with our Services; (ii) to protect our rights or property; (iii) to compare information for accuracy; (iv) to verify your identity; (v) to investigate and prevent fraud or other illegal activities; and (vi) for any other purpose disclosed to you in connection with our Services.
Additionally, we use information that we collect about you or that you or others (including your End Users and End Customers) provide to us, including any Personal Data:
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.
We may use third-party service providers to process and store Personal Data in India and any other countries including storing data in cloud storage.
Your provision of Personal Data is required in order to use certain parts of our Services. If you fail to provide such Personal Data, you may not be able to access and use our Services or parts of our Services.
We will retain your Personal Data and your usage data as long as you have an account with us.
When you delete your account with us, we will delete all your personal data and usage data unless we require the same for the purpose mentioned above.
By providing an email address or telephone number on our Sites and/or within the Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Services related notices, or to provide you with information about our events, invitations, or related educational information.
For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be.
We currently provide the following “Opt-Out Opportunities”:
Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any Services related notices.
You may update or correct information about yourself by navigating to the ‘Manage Account’ page. You have the option to change the following data attributes:
You have the option to delete your account with us by clicking on the ‘Delete Account’ button present in bottom of ‘My Account’ page. Please be noted that you will be given 72 hours to revoke your decision (by responding to our email) to delete your account permanently and if you do not revoke your decision within 72 hours, your account will be permanently deleted. However, we may retain an archived copy of your records if it is required for the purpose of litigation, law enforcement requests or investigation and regulatory compliance.
You have the option to delete your usage data through the use of our ‘Redact API’. However, please be noted that we may retain your usage if we require them for the purpose mentioned above.
This Privacy Policy applies only to the Sites and the Services. This Privacy Policy does not apply to any websites managed, maintained, and/or hosted by Third Parties not directly affiliated with us that you may visit (for example, via a link provided through the Sites, contained in any communication transmitted in connection with the Services, or on a website maintained by any Third Party). Further, this Privacy Policy does not apply to any products or Services offered or provided by any Third Parties we do not own or control (for example, telecommunications carriers, other communications suppliers and Payment Processors). We do not monitor or control the policies or practices of Third Parties (whether as to privacy, security or anything else, including how they collect, process or store information and Personal Data), including other websites to which we may provide hyperlinks or of Third Parties to which we send Content in connection with the provision of the Services or to which we provide Account Data ancillary to the billing and payment for our Services.
We cannot be responsible for the privacy practices or the content of any non-Trubloq websites or of any other Third Parties, and we do not control the practices of any of the Third Party websites or service providers to whose sites we link or whose services are ancillary to the Services. We encourage you to learn more about the privacy and data security policies and practices of Third Party websites and services directly from such Third Parties (including telecommunications carriers, other communications suppliers and Payment Processors, as their policies and practices may differ from ours. Further, this Privacy Policy does not reflect the privacy practices of our customers. Even though we require our customers to comply with applicable Law, we are in no way responsible for such customers’ acts or inactions, including whether they comply with applicable Law and/or for their privacy policies or practices.
Additionally, some content or applications, including advertisements, on or through our Sites or Services are served by Third Parties, including advertisers, ad networks and servers, content providers and application providers. These Third Parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Sites or Services. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your activities over time and across different websites and other services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these Third Parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
We are committed to complying with applicable Law, regulations and mandatory government standards regarding the protection of Personal Data.
Since we are a global organization, Personal Data and any additional information submitted may be used globally in connection with employment, business processes within Trubloq, or communicating with our clients. Therefore, Personal Data may be transferred to other Trubloq-related entities worldwide, where it will be processed in accordance with this Privacy Policy and applicable privacy laws.
If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards to ensure that your Personal Data is protected as per current Data Privacy Laws. It is our policy to, where required by applicable Law, execute a Data Processing Addendum with all Third Parties with whom we may share Personal Data.
We are very concerned with safeguarding your information. We employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms.
Please note that no security system is impenetrable. Accordingly, we do not guarantee the security of our databases, nor that information you supply will not be intercepted while being transmitted to us over the Internet or other network. Any information you transmit to us, you do at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or within our Services. Where we have given you (or where you have chosen) a password or other Credentials for access to certain parts of our Services, you are responsible for keeping this password and other Credentials confidential. We ask you not to share your password or other Credentials with anyone.
If legally permitted, we will notify you of any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) via email or conspicuous posting through the Sites in the most expedient time possible and without unreasonable delay, as consistent with (i) the legitimate needs of Law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Some web browsers may be configured to send “Do Not Track” signals to websites, or users may use similar mechanisms, to indicate a user’s preference that certain web technologies not be used to track the user’s online activity. Our sites do not accept or process such Do Not Track signals or similar mechanisms.
We are committed to protecting the privacy of children. Our Services are not intended for anyone under the age of 13. If you are under 13, do not use or provide any information on or through our Services. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under 13, please contact us so that we can delete the child's information. Our Services will never knowingly accept, collect, maintain or use any information from a child under the age of 13. If a child whom we know to be under the age of 13 sends Personal Data to us online, we will only use that information to respond directly to that child or notify parents.
We encourage you to periodically review our Privacy Policy to be sure you are familiar with the most current version.
We will notify you of any material changes by publishing the new Privacy Policy through the Sites and/or the Services. We will not make new use of any Personal Data which we gathered from individual users prior to any such significant change in our Privacy Policy without first obtaining the user's consent for any new uses.
If you have a complaint about our use of your information, we would prefer you to contact our Privacy team at support@trubloq.com or our privacy officer at regulaion@trubloq.com directly in the first instance so that we can address your complaint.
