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1. Who is responsible for your data
For personal data collected through www.truperformance.us, our marketing and our recruiting, the controller is Tru Performance, 600 N Broad Street, Suite 5 #3151, Middletown, DE 19709, USA, together with its affiliates in India and the United Arab Emirates where they decide how the data is used.
When we act for our clients. When we process personal data on behalf of a client as part of our services (for example, running a client’s marketing platforms, customer support, finance and accounting, staffing or IT support), we act as a processor. The client is the controller, and we process that data only on the client’s documented instructions under a data processing agreement that meets Article 28 GDPR. Please direct requests about that data to the relevant client.
Contacting us from the EEA, UK or Switzerland. You can contact us directly about any matter relating to your personal data using the details below.
Data protection contact. You can reach our privacy team at sales@truperformance.us.
2. Why we use your data and our lawful bases
| Purpose | Personal data | Lawful basis |
|---|---|---|
| Responding to inquiries and preparing proposals | Name, email, phone, company, message content | Steps at your request before entering a contract (Art. 6(1)(b)); our legitimate interest in responding to business inquiries (Art. 6(1)(f)) |
| Providing services to our clients’ business contacts | Business contact details, communications | Performance of a contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f)) |
| Sending newsletters and marketing emails | Email address, name, preferences | Consent (Art. 6(1)(a)), or legitimate interests where permitted for existing business contacts. You can opt out at any time. |
| Strictly necessary cookies (security, spam protection) | Device and connection data | Legitimate interests in keeping the Site secure (Art. 6(1)(f)) |
| Analytics, session recording, advertising and visitor identification cookies | Device, usage and interaction data, IP address, identifiers | Consent (Art. 6(1)(a)), collected through our cookie banner. You can withdraw consent at any time. |
| Recruiting | CV, contact details, work history and assessment notes | Steps at your request before entering a contract (Art. 6(1)(b)); legitimate interests in hiring (Art. 6(1)(f)) |
| Security, fraud prevention and legal claims | Logs, communications, records | Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
| Meeting legal, tax and accounting requirements | Contract and billing records | Legal obligation (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have balanced our interests against your rights and freedoms. You can ask us for more information about that assessment.
We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.
3. Cookies and consent
For visitors from the EEA, UK and Switzerland, we set only strictly necessary cookies until you make a choice in our cookie banner. Analytics (Google Analytics, Microsoft Clarity), marketing (HubSpot tracking, Leadfeeder, Apollo.io) and advertising (Google Ads, LinkedIn Insight Tag) technologies load only if you consent. You can change or withdraw consent at any time through the cookie settings link in the Site footer.
The full list of technologies is in Section 6 of our Privacy Policy.
4. Who receives your data
We share personal data with our affiliates in the United States, India and the United Arab Emirates, and with service providers acting as our processors (including hosting, Cloudflare, HubSpot, Google, Microsoft, Leadfeeder and Apollo.io), as described in our Privacy Policy. Some advertising and analytics providers, such as Google and LinkedIn, may act as independent controllers or joint controllers for certain processing. A current list of our main processors is available on request.
5. International transfers
We are based in the United States and operate delivery centers in India and the United Arab Emirates, so your personal data will be transferred outside the EEA, UK and Switzerland. When we transfer it to a country without an adequacy decision, we use:
- The European Commission’s Standard Contractual Clauses (2021), and the UK International Data Transfer Addendum or Swiss amendments where relevant, both between our own entities and with our service providers.
- The EU-US Data Privacy Framework, the UK Extension and the Swiss-US framework, where a US service provider is certified under them.
- Supplementary technical and organizational measures, such as encryption in transit and access controls.
You can request a copy of the relevant safeguards by contacting us (commercial terms may be redacted).
6. How long we keep your data
We keep personal data only as long as needed for the purposes above. Typical retention periods are set out in Section 8 of our Privacy Policy. Data processed on the basis of consent is deleted or anonymized when you withdraw consent, unless another lawful basis applies.
7. Your rights
Under the GDPR and UK GDPR you have the right to:
Access the personal data we hold about you and receive a copy.
Rectification of inaccurate or incomplete data.
Erasure of your data in certain circumstances.
Restrict our processing in certain circumstances.
Data portability: receive data you provided to us in a structured, commonly used, machine-readable format, or have it sent to another controller.
Object to processing based on legitimate interests, including profiling. You can object to direct marketing at any time, and we will stop.
Withdraw consent at any time, without affecting processing that took place before withdrawal.
Lodge a complaint with a supervisory authority, in particular in the country where you live or work, or where an alleged infringement took place. In the UK, this is the Information Commissioner’s Office (ico.org.uk). In Switzerland, it is the Federal Data Protection and Information Commissioner.
8. How to exercise your rights
Email sales@truperformance.us or write to us at the address above. Tell us which right you want to exercise and the email address you use with us. We may ask for information to confirm your identity.
We will respond within one month of receiving your request. If a request is complex or we receive many requests, we may extend this by up to two further months and will tell you why. We do not charge a fee unless a request is manifestly unfounded or excessive.
9. Changes to this notice
We may update this notice from time to time. The “Last updated” date at the top shows when it was last revised.