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1. Notice at collection: what we collect and why
The table below describes the categories of personal information we have collected in the past 12 months, where we got it, why we use it, who we disclose it to, and whether we sell or share it.
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| Category | Examples | Sources | Business purposes | Disclosed to | Sold or shared? |
|---|---|---|---|---|---|
| Identifiers | Name, email address, phone number, IP address, cookie and device IDs | You; your device; business data providers | Responding to inquiries, providing services, marketing, analytics, security, advertising | Affiliates, service providers, advertising partners | Shared and may be sold (IP address and online identifiers, with advertising and visitor identification partners) |
| Customer records (Cal. Civ. Code § 1798.80(e)) | Name, phone number, employer, job title, education and employment history (job applicants) | You; business data providers; public sources | Business communications, recruiting | Affiliates, service providers | No |
| Commercial information | Services you asked about or purchased, proposals and contract records | You; our records | Providing and managing services, billing | Affiliates, service providers, professional advisers | No |
| Internet or other electronic network activity | Pages visited, clicks, time on page, referring URLs, interactions with our ads and emails, session recordings | Your device and browser; cookies and similar technologies | Analytics, improving the Site, marketing, advertising, security | Service providers, advertising partners | Shared and may be sold (with advertising and visitor identification partners) |
| Geolocation data | Approximate location derived from your IP address (not precise geolocation) | Your device | Analytics, security, relevant content | Service providers, advertising partners | Shared (as part of IP address data) |
| Audio and electronic information | Recordings or transcripts of calls and video meetings, where you are told in advance | You | Service delivery, quality, training | Service providers | No |
| Professional or employment information | Job title, company, work history, CV contents | You; business data providers; professional networks | Business development, recruiting | Affiliates, service providers | No |
| Education information | Degrees and schools listed in a CV | You (job applicants) | Recruiting | Affiliates, service providers | No |
| Inferences | Interests and likely needs inferred from your interactions with the Site, our emails and ads | Derived from the categories above | Marketing, advertising, sales follow-up | Service providers, advertising partners | Shared |
| Sensitive personal information | We do not intentionally collect sensitive personal information through the Site | Not applicable | Not applicable | Not applicable | No |
Retention. We keep each category for as long as needed for the purposes above, then delete or de-identify it. Typical periods are listed in Section 8 of our Privacy Policy.
2. Selling and sharing
We do not sell personal information for money. However, we use advertising and analytics technologies from Google (Google Ads), LinkedIn (LinkedIn Insight Tag) and Apollo.io. These providers receive identifiers, internet activity and related inferences from your browser when you visit the Site. Under the CCPA, this may count as “sharing” personal information for cross-context behavioral advertising or as a “sale”.
We do not knowingly sell or share the personal information of consumers under 16.
3. Your California privacy rights
As a California resident, you have the right to:
Know and access: ask what personal information we have collected about you, the categories of sources, our purposes, the categories of third parties we disclose it to, and the specific pieces of personal information we hold.
Delete: ask us to delete personal information we collected from you, subject to legal exceptions.
Correct: ask us to correct inaccurate personal information.
Opt out of sale and sharing: tell us not to sell or share your personal information.
Non-discrimination and non-retaliation: we will not deny you services, charge different prices or give a different level of service because you exercised your rights. Job applicants will not face retaliation for exercising their rights.
4. How to opt out of sale and sharing
You can opt out in any of these ways:
- Click “Do Not Sell or Share My Personal Information” in the Site footer and turn off advertising and marketing cookies.
- Turn on Global Privacy Control (GPC) in your browser or extension. We treat a GPC signal as a valid opt-out request for that browser.
- Email us at sales@truperformance.us with the subject “Do Not Sell or Share”.
Because cookie-based opt-outs are tied to your browser, you will need to opt out again if you use a different browser or device, or clear your cookies. We do not need to verify your identity to process an opt-out request, and we act on it within 15 business days.
5. How to submit a request to know, delete or correct
Email: sales@truperformance.us
Phone: +1 631-366-7600
Mail: Tru Performance, 600 N Broad Street, Suite 5 #3151, Middletown, DE 19709, USA
Verification. To protect your information, we verify your identity before responding to requests to know, delete or correct. We do this by matching details you provide (such as your name and email address) with information we already hold. For requests for specific pieces of information, we may ask for additional details.
Authorized agents. You can use an authorized agent to submit a request. We will ask the agent for proof of your signed permission, and we may ask you to verify your identity directly with us, unless the agent holds a valid power of attorney.
Timing. We confirm receipt of requests to know, delete or correct within 10 business days and respond within 45 calendar days. If we need more time, we may extend this by up to another 45 days and will tell you why.
6. Residents of other US states
Residents of other states with consumer privacy laws (for example, Virginia, Colorado, Connecticut, Texas and Oregon) may have similar rights to access, correct, delete and obtain a copy of their personal data, and to opt out of targeted advertising, sale and certain profiling. You can exercise these rights using the methods above.
If we decline your request, you may appeal by replying to our decision email with the subject “Appeal”. We will respond within the time required by your state’s law. If we deny your appeal, you may contact your state Attorney General.
7. Contact us
For questions about this notice, contact us at sales@truperformance.us, call +1 631-366-7600, or write to Tru Performance, 600 N Broad Street, Suite 5 #3151, Middletown, DE 19709, USA.