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Privacy Policy

The Customer Connections program allows consumers' favorite merchants to communicate with their customers, which may include sending special offers and operating a referral and loyalty program. True Conversions, LLC. ("True Conversions") provides the technology (the "True Conversions Technology") that runs Customer Connections services (the "Services") for merchants who are or become clients of True Conversions's services ("Clients"). True Conversions and its Clients respect the personal privacy of the end users of the Services (such as individual consumers). This Privacy Policy describes how True Conversions uses the information of people who visit this website and how True Conversions and its Clients use information relating to consumers and other end users of the Services.

This Privacy Policy applies to True Conversions's website (www.True Conversions.com) (the "Website"), to True Conversions's app for mobile devices (the "True Conversions App"), to True Conversions's tablets at Clients' sites, and to information submitted or uploaded to True Conversions by an end user (e.g., through Facebook, other social media sites or otherwise) or uploaded to True Conversions by a Client (each, a "True Conversions Access Portal"). This Privacy Policy also applies to information gathered by True Conversions as end users use the Services, but it does not apply to any other services or websites that may be offered by True Conversions or a Client, or to any third party sites that may be accessible from the a True Conversions Access Portal or through the Services. Further, this Privacy Policy does not apply to Facebook, Twitter, or any other third party sites through which the Services may be delivered. To understand how any third party treats your information (including your information related to the Services), you should contact such third party or read its privacy policy. We encourage you to read this entire Privacy Policy before using True Conversions's Website or the Services, or submitting or uploading information through any True Conversions Access Portal.

Do not use the Website, the True Conversions App, any other True Conversions Access Portal or the Services if you are unwilling to accept the terms and conditions of this Privacy Policy. By using any of such True Conversions Access Portals or the Services, you agree to the terms of this Privacy Policy. When you submit information to True Conversions or use the Services, you consent to the collection, storage, use, and disclosure of that information in accordance with this Privacy Policy.

After reading this Privacy Policy, which is incorporated into and is a part of the Merchant Terms (the True Conversions Application Contract) and the User Terms of Service ("User Terms"), you will know:

  1. What information True Conversions collects from you;
  2. How True Conversions and Clients use and may disclose information obtained through any of the True Conversions Access Portals or the Services;
  3. What choices you have about how True Conversions and Clients treat your information;
  4. How True Conversions and Clients protect your privacy;
  5. What True Conversions and Clients do about children visiting the True Conversions Application;
  6. How comments you may make are handled;
  7. How you can contact True Conversions and Clients.

Information True Conversions And Clients Collect From You

Active Information Collection

From Clients and Prospective Clients. True Conversions actively collects information from Clients and prospective Clients who visit our Website or who become a Client by accepting the Merchant Terms, both (i) by permitting them to communicate directly with True Conversions through the Website, via email, or otherwise and (ii) when they sign up (on the Website or otherwise) to become a True Conversions Client. Some of the information that a Client submits that is required for such Client to register to become a Client could identify the Client and its officers, such as business name and address, credit card or bank information (for billing purposes), type of business, telephone number, email address, zip code and names of responsible officers or employees. We refer to such information as "Identifiable Business Information." In addition, Client may be asked to answer additional questions that are optional ("Optional Information").

We will inform Clients which questions are optional. If a Client does not submit the required information to sign up for True Conversions's Services or does not accept the Merchant Terms or agree to operate in accordance with the User Terms and this Privacy Policy in connection with the Services, Client will not be able to use the Services.

When a Client uses True Conversions's Services, True Conversions will collect information related to the Client's business and customers, as described in the Merchant Terms, the related User Terms and this Privacy Policy.

From Consumers and Other End Users. True Conversions actively collects information from our visitors both by asking specific questions, by allowing you to upload information through other tools (such as Facebook Connect), and by permitting you to communicate directly with us through the Website, via email or otherwise. If you sign up to use the Services, via any True Conversions Access Portal, or if a Client signs you up for its Customer Connections Program, some of the information that you submit (directly or via an upload), or that is submitted for you by a Client, is required to register you to use the Services. Some of such information could identify you personally, such as your first and/or last name, telephone number, email address, zip code and birthdate. Such information is called "Personally Identifiable Information." In addition, you may answer additional questions on the registration form that are optional, or a Client may submit such information for you ("Optional Information"). Such optional questions may include demographic information and/or additional Personally Identifiable Information, such as your name (if not previously provided), gender, financial information or other information.

You will be informed which information on the registration form is optional. If you do not submit the required registration information or a Client does not submit it for you, you will not be able to use the Services. If you do not answer optional questions, you still can use the Services, but you will not be able to earn rewards that may be awarded to people who answer the optional questions and we may not be able to tailor the Services as closely to your interests.

True Conversions and Client may offer you, directly or through Facebook, Twitter, other social media sites, or other third parties, the opportunity to participate in activities related to the Services, such as responding to surveys, entering a contest or sweepstakes, playing games or providing information to our customer service representatives. If you choose to participate in such activities (when offered) True Conversions or Clients may collect additional Personally Identifiable Information or other information from you.

When you visit the Website, the True Conversions App, use the Services, or participate in activities that are part of the Services, True Conversions and Clients may collect information related to such activities. True Conversions does not intentionally collect Personally Identifiable Information about you other than (i) such information that you provide us as described above, either directly through a True Conversions Access Portal or through permissions you authorize with social media sites which are used in conjunction with the Services (e.g., Facebook, Twitter and other sites), or (ii) information submitted to True Conversions for you by one or more Clients. True Conversions may, however, keep track of your responses to Offers, visits to and purchases from Clients and associate that information with your registration information, including your Personally Identifiable Information (see "Program Information Collection," below).

Collection and use data through Google Login (OAuth): True Conversions collects the following personal information from Clients: Google Contacts

Sign up and Login with Google:

It is important to remind every Client that True Conversions do not retrieve any emails messages or documents from Client's Google accounts. True Conversions only communicates with Google servers through the Gmail's API (OAuth). Client can revoke access at any time. Contacts are retrieved only for synchronization purpose and are immediately hashed. For further information do not hesitate to contact us. Information gathered this way True Conversions use to:

  1. Facilitate and administer business services Clients have requested through our applications.
  2. Populate Client's Google Contacts data in customer management tool.
  3. If Client provide us personal information about others, or if others give us your information, True Conversions will only use that information for the specific reason for which it was provided to us.

Passive Information Collection

As you navigate through the Website or the True Conversions App or use the Services, True Conversions may collect certain information passively (that is, information may be gathered without you actively providing the information) using various technologies and means, such as navigational data collection and geolocation data. Like most website operators, True Conversions, its advertisers and third party service providers may track IP addresses, use both session and persistent cookies, and assign Internet tags. True Conversions also automatically gathers information about the areas you visit on the Website and the True Conversions App and collects operational information about the technology you use, such as your browser, type of computer or mobile device, operating systems, Internet service provider and the domain names of the websites from which you linked to the Website or the True Conversions App and to which you go after viewing such sites. If you activate geolocation applications, True Conversions may have access to and store your geolocation information related to the Services.

In addition, when you visit the Website or the True Conversions App, True Conversions may store some information on your computer or mobile device. This information will be in the form of a cookie or similar file and will help us in many ways. For example, cookies allow us to tailor the Website, the True Conversions App and the Services or other offerings to you in a way that better matches your interests and preferences. Most Internet browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. True Conversions and its Clients do not collect Personally Identifiable Information automatically, but we may tie information collected automatically to your previously submitted Personally Identifiable Information.

The Website and the True Conversions App may contain electronic images known as web beacons—also referred to as single-pixel gifs—that permit True Conversions and/or its Clients to count users who have visited the Website or the True Conversions App and for other related statistics—(e.g., recording the popularity of certain Website or True Conversions App content and verifying system and server integrity). Web beacons are not used by True Conversions or Clients to access your Personally Identifiable Information; they are used solely to compile aggregated statistics concerning the use of the Website and the True Conversions App. Web beacons collect only a limited set of information including a cookie number, the time and date of a page view, and a description of the page on which the web beacon resides.

The reason True Conversions collects passive information is that it helps us understand which areas of the Website and the True Conversions App are most popular, which areas may require improvement and what technologies are being used by our visitors. This information helps True Conversions to update and improve the Website and the True Conversions App and our Services. True Conversions also uses this information for security purposes, to detect and to block security breaches and to provide you with a safer online environment.

Program Information Collection

True Conversions may also keep track of, and associate with your Personally Identifiable Information and Optional Information, activities you engage in offline that relate to the Services, such as which Offers you respond to (for example, by purchasing the goods or services that are the subject of the Offer) and loyalty rewards you earn from offline purchases. All of the information described in this paragraph is called "Client Participation Data." True Conversions may use Client Participation Data for a number of purposes, including keeping track of rewards points (if offered by the Client), categorizing you with respect to your response to Offers and rewards programs of each Client, and marketing goods or services of Clients, True Conversions or third parties to you. True Conversions will offer you the option not to receive such marketing messages.

If True Conversions permits certain Clients with which (or by which) you are registered to do so, such Clients may also keep track of Client Participation Data and use it as described above, including marketing goods or services of Clients, True Conversions or third parties to you. Any Client given permission to use Client Participation Data will agree to offer you an option not to receive such marketing messages.

In addition to the foregoing, True Conversions will have access to information regarding your registration with and participation in the Offers and loyalty programs offered by all Clients for which, or by which, you are registered ("Program Participation Data"). Program Participation Data may be used by True Conversions to keep track of loyalty points that you have accrued with each Client True Conversions works with, which may allow you to check all of those programs you are enrolled in on one page of the Website. True Conversions may also use Program Participation Data for purposes such as categorizing you with respect to various merchants or types of merchants, Offers and loyalty programs and for sending you marketing messages for goods or services of True Conversions or other merchants or service providers. True Conversions will offer you the option not to receive such marketing messages. To do so, you should go to the Website and elect not to receive marketing messages.

Third Party Information Collection

Currently, the True Conversions Technology is hosted on the Website and the True Conversions App, and also on Facebook's platform. In the future, the True Conversions Technology could be hosted on other social media or other locations. Depending on the choices you make when you register, Offers may be sent to you through Facebook, Twitter or other social media, and additional social media applications may in the future be included with our services (e.g., geolocation information). Information related to you, your use of the True Conversions Technology and the goods and services provided by True Conversions and Clients may be available to Facebook, Twitter and other third parties such as the operators of various social media or other sites.

The privacy policies of such social media and other sites, and sites that you may link to from the True Conversions Technology, are not under the control of True Conversions or Clients. Neither True Conversions nor any Client has any responsibility or liability for the use of your personal information by Facebook, Twitter, other social media companies or any other third parties. True Conversions and Clients are also not responsible for the collection, storage or use of your information by such third parties, for their privacy policies or for their security practices. If you would like information on any other party's privacy policy, you should contact that party directly, and we encourage you to do so.

This Privacy Policy is applicable only to information you submit to True Conversions (directly or through uploads authorized by you), that is submitted to True Conversions for you by a Client, or that True Conversions collects from the True Conversions Technology or the Services. If you link from the True Conversions Technology or the Services to websites controlled by one or more Clients, you should be aware that your activities on those sites are subject to the separate privacy policies of the respective Clients applicable to those particular sites. If a Client does not maintain a website with a privacy policy, you should ask such Client about its privacy policies.

True Conversions may hire third parties to assist our marketing efforts by placing True Conversions ads on other websites or search engines. We may also use third parties to display ads of unrelated companies on the Website or any other True Conversions Access Portal. Such third party marketers or advertisers may use cookies to serve ads based on your prior visits to the Website and other sites. True Conversions does not have any control over such cookies. You may be able to modify your browser settings to decline such cookies. If you decline cookies that affect your use of the Website some features may not be available or may not operate properly. For example, if you access the True Conversions Services through Facebook, ads you may see framing the Services or presented in association with them are controlled by Facebook. You should review the Facebook Privacy Policy and/or contact Facebook for information regarding such advertising, including whether any such advertisements may solicit, or contain technology to collect, information about you.

Data Retention

True Conversions and the third parties will retain personal data collected for as long as required to do what we say we will in this policy, unless a longer retention period is required by law. Customers can delete their own content.

How True Conversions And Clients Use And May Disclose Information Obtained Through The Services

Internal Use Of Personally Identifiable Information

Except as otherwise stated, True Conversions may use information collected via any True Conversions Access Portal or the Services to improve the content of the Website and the True Conversions App, the Services (or similar or related services), to customize the Website and the True Conversions App to your preferences, to communicate information to you if you have requested it (such as your accrued rewards points), for our marketing and research purposes (including marketing other services provided by True Conversions, Clients or third parties), and for any other purpose specified in this Privacy Policy. You can opt out of receiving such marketing messages through the "Settings" tab in the True Conversions App and by choosing the opt-out option provided in email messages.

You provide Personally Identifiable Information when you register for the Services through any True Conversions Access Portal (for example, on the registration page or through an upload you authorize), and a Client may send True Conversions such information for you. True Conversions may combine any such information with Client Participation Data and/or Program Participation Data, as described above under "Program Information Collection."

True Conversions may provide Personally Identifiable Information and Optional Information you have provided to True Conversions (directly or through an upload), or that has been submitted to True Conversions by a Client on your behalf, to certain Clients with which (or by which) you are registered, and that have been permitted such information access by True Conversions. When and if permitted by True Conversions, such Clients may use that information to send you messages, independently of the Services, about their goods and services and about the goods and services of other merchants. If you do not wish to receive such messages you may opt out of receiving them by choosing the opt-out option provided in such messages. All Clients granted such permission by True Conversions will agree not to provide your Personally Identifiable Information or Optional Information to third parties except as described in the next section.

Limited Disclosure Of Personally Identifiable Information To Third Parties

True Conversions will not disclose Identifiable Business Information or Personally Identifiable Information provided by end users or Clients or that True Conversions collects in conjunction with the Services, to third parties (i.e., to parties other than Clients with which (or by which) an end user is registered) without consent, except as described below. Clients have also agreed to limit disclosure of end users' Personally Identifiable Information to the following:

(A) to contractors or service providers True Conversions or a Client uses to support its business (such as programming, providing technical support, enhancing data usage, analyzing data and/or assisting with marketing, customer service and other administrative tasks), and only if True Conversions or the Client providing the information understands that such third parties will treat your personal information consistently with this Privacy Policy;

(B) in the event of a sale, merger, liquidation, dissolution, reorganization, assignment, or other transfer of stock or the business of a Client and/or True Conversions, respectively ("Sale of Business"). In the case of any Sale of Business, it is the obligation of the buyer to use the information of Clients and/or end users collected by True Conversions in accordance with this Privacy Policy. If the buyer changes this privacy policy it should do so only prospectively and after providing Clients and/or end users, as applicable, notice of the change;

(C) if required by law or in response to any judicial order, inquiry of any administrative agency; in response to a subpoena or an inquiry from law enforcement or governmental authorities; or

(D) if True Conversions or a Client believes the release of such information is necessary to protect the rights of True Conversions or the Client (including enforcing the Merchant Terms or User Terms) or to address or prevent illegal or harmful activity.

Other than as described above, True Conversions does not distribute Identifiable Business Information or Personally Identifiable Information to third parties, and Clients have agreed not to do so either. However, you understand that if you access the Services through Facebook or any other third party platforms, Facebook or the operator of such platforms will have access to your registration information and other information generated by your use of the Services, which may be aggregated with other information about you accessible to Facebook or the operator of such platforms, and may be stored and used by them, subject to the applicable privacy policy.

Neither any Client nor True Conversions will have any liability for disclosure of your information resulting from actions by Facebook or other social media companies or platforms, or from errors in transmission or the unauthorized intervention of third parties.

Information That Does Not Identify Your Business Or You Personally

True Conversions may provide aggregate statistics or information about its customers, sales, trends, loyalty program usage, online traffic patterns, related information or other statistical de-identified or aggregated information to third parties, but these statistics or information will not include any Identifiable Business Information or Personally Identifiable Information ("Non-Identifying Information"). Non-Identifying Information collected about end users, Clients and prospective Clients is also used by True Conversions and/or third parties we contract with to troubleshoot, operate and improve the Website, the True Conversions App and other True Conversions Technology, to assist us with marketing or ad placement, to cooperate with law enforcement activities or legal orders, to protect our rights (including enforcing the Merchant Terms and User Terms) or to address or prevent illegal or harmful activity. In addition, True Conversions may use all information submitted by end users, Clients or prospective Clients or that True Conversions collects about any of the foregoing that is Non-Identifying Information in any way True Conversions deems useful, including publishing statistics such as those described above to promote True Conversions or its Services.

Re-Marketing

True Conversions may use information that end users provide or that True Conversions collects about end users from their use of the Services or related to the True Conversions Technology, including their response to Offers from Clients, their participation in the rewards programs of Clients (if any) and/or other information, to send end users marketing messages related to goods or services True Conversions believes will be of interest to them. Such goods or services may be offered by True Conversions, Clients, or other third parties. Such marketing messages may be sent via email, mobile communications, Facebook, Twitter, other social media or otherwise, depending on how the end user has elected to receive Notes from various Clients. End users can opt out of receiving such marketing messages through the "Settings" tab in the True Conversions App and by choosing the opt-out option provided in email messages.

Choices End Users Have About How True Conversions And Clients Use Their Information

True Conversions strives to provide Clients, and True Conversions and Clients strive to provide end users, with choices regarding the information Clients and end users provide. True Conversions has created mechanisms to provide Clients and end users with the following control over their information:

(i) You may view and modify the Identifiable Business Information or Personally Identifiable Information and/or Optional Information you submitted through a True Conversions Access Portal, or that was submitted to True Conversions on your behalf by a Client. If you are a Client, you may modify the information you submitted when you signed up to become a Client as described in the Merchant Terms. If you are a consumer or other end user, you may modify the information you submitted when you registered, or when a Client registered you, by going to the Website. If an end user wants to stop receiving all messages through the Services, the end user will need to delete the True Conversions App from his or her mobile device, visit each social media company through which the user chose to have the Services provided (e.g., Facebook, Twitter, etc.) and delete True Conversions from each such social media company, and choose the opt-out option provided in messages sent via email. To stop receiving Notes from a particular Client (or from True Conversions itself), end users should opt out of such messages through the "Settings" tab in the True Conversions App and choose the opt-out option provided in emailed messages sent by such Client (or, in the case of True Conversions, by True Conversions). True Conversions keeps track of end users' transactions with Clients, as well as communications about Clients that end users makes through the True Conversions Technology (e.g., posting Offers to a Facebook page, sending Offers to friends). End users cannot delete information associated with such transactions and communications.

(ii) Marketing messages from True Conversions and, when and if permitted, Clients or third parties, will contain an option for the end user to choose not to receive such messages in the future.

(iii) If an end user does not wish True Conversions to collect cookies, he or she may set the browser to refuse cookies, or to alert the user when cookies are being sent. Please note that some parts of the True Conversions Services may then be inaccessible or may not function.

How Your Information Is Protected

True Conversions works hard to protect the personal information of end users, using both technical and procedural methods to maintain the integrity and security of our databases. These include the use of SSL encryption, firewalls, administrative access level controls and employee training. End users should keep in mind, however, that no Internet transmission or data storage is ever completely secure or error-free. While True Conversions believes it uses commercially reasonable security procedures, it cannot guarantee the security of any information submitted by end users, Clients or prospective Clients, information gathered about end users or information stored by True Conversions.

Each Client has agreed to abide by this Privacy Policy. True Conversions is not responsible for Clients' compliance with this Privacy Policy or for Clients' security policies and practices. Each end user acknowledges and agrees that True Conversions has no responsibility or liability for the security policies or practices of any Client, or for any security breach of any Client's systems or databases. Neither True Conversions nor any Client is responsible for the actions of any third party, including but not limited to Facebook, other social media sites or other sites, with whom information about you may be shared or who may otherwise obtain such information.

The safety and security of information of Clients and end users also depends on the user. Clients and end users should never share their True Conversions passwords, or any other password (including their Facebook passwords), with anyone else, and should notify True Conversions, Facebook or other relevant provider promptly if you believe your password security has been breached. Remember to log off of the Website and/or App before you leave your computer or mobile device.

The Website, True Conversions App or other sites through which end users may use the Services may contain links to other sites and/or resources over which True Conversions and Clients have no control. True Conversions and Clients make no representations or warranties with respect to the content, ownership, or legality of any such linked sites. Links to third party sites are provided solely as a convenience to end users and should not be construed as an affiliation with or endorsement by True Conversions or Clients of such third parties or any content, items, or services on third-party sites. Access and use of such other sites, including the content, items, or services on those sites, solely at the risk of the user, and neither True Conversions nor any Client has any responsibility or liability resulting from users' access or use of such other sites. These linked sites may collect personal information from users when entering their site. Any such collecting of information is not subject to the control of True Conversions or any Client. To ensure protection of privacy, users should always review the privacy policies of the sites they visit when linking from the Website, the True Conversions App or any other site associated with the Services.

End users acknowledge and agree that neither True Conversions nor any Client has any responsibility or liability for the availability of such external sites or resources, or for the content, advertising, products, or other materials available through such sites or resources.

What True Conversions And Clients Do About Children Visiting The True Conversions Application

The Website, the True Conversions App and the Services are not intended for children under the age of 13 and are not designed to attract anyone under the age of 13. Clients who use True Conversions's Services may sell goods or services for children that are intended to be purchased by adults. True Conversions will not knowingly collect Personally Identifiable Information from site visitors under the age of 13, and Clients have agreed that they will not knowingly collect such information. True Conversions and Clients encourage parents to talk to their children, including children between the ages of 12 and 18, about their use of the Internet and the information they disclose online. If a child of any age has provided True Conversions with Personally Identifiable Information, and a parent or guardian of that child would like this information deleted from True Conversions's records, such parent or guardian may contact True Conversions by going to the Website and clicking on the appropriate tab. True Conversions will then use reasonable efforts to delete the child's information from our databases.

How Public Comments Are Handled

End users may be allowed to post public comments, including comments about Clients and their goods and services, on Client's Facebook page or on other social media. Such capability is offered by Facebook or another social media company, and is subject to the privacy policy of Facebook or such other social media company. We encourage you to review such privacy policies before submitting any such comments. End users may also be allowed to post similar comments on the Website. Any messages posted in public access portions of Facebook, other social media sites or the Website may be read, saved, used and/or distributed by such social media companies, True Conversions, Clients and any other users of the sites. Any such postings may be re-posted by any of such users on other websites, used in blogs, etc., and may appear in web searches. Neither True Conversions nor any Client can control who views information so posted or what they do with it, so care should be used when sending any personal information to any public access site. True Conversions and Clients also cannot control and are not responsible for the accuracy, truthfulness or tastefulness of any information posted by other users on Facebook or other social media sites, on the Website or on any other public access site.

Contacting True Conversions

Questions, comments or concerns about this Privacy Policy or the information practices of this site, should be addressed to:

True Conversions LLC
7860 W Commercial Blvd #741
Lauderhill, FL 33351
954-271-1439
support@trueconversions.com

or directly to the Client to which such questions, comments or concerns relate. Please review this Privacy Policy carefully. If you do not agree with this Privacy Policy, your ultimate choice is not to use the Services. Remember, by registering with True Conversions or using any part of the Services (whether you registered for them or a client registered you with True Conversions), you accept and agree to the privacy practices described in this Privacy Policy.

Clients agree that this Privacy Policy is incorporated by reference with the Merchant Terms. End users agree that this Privacy Policy is incorporated by reference into the User Terms. By visiting the Website, using any of the True Conversions Access Portals, or using the Services (whether you registered for them or a client registered you with True Conversions), you accept that any dispute over privacy is subject to this Privacy Policy and the Merchant Terms or User Terms (as applicable), including but not limited to limitations on liability, disclaimers of damages, releases, waivers and application of the law of the State of Florida. If you have any concern about privacy issues, please contact True Conversions as directed above.

True Conversions and Clients reserve the right to update this Privacy Policy at any time. If this Privacy Policy is materially changed, the revised policy, or a notice that the policy has been revised, will be posted on the True Conversions Website and the True Conversions App. You are responsible for periodically reviewing the Privacy Policy, and should do so frequently, especially before you provide any Identifiable Business Information or Personally Identifiable Information. When True Conversions changes this Privacy Policy, we will also revise the "last updated" date at the end of this Privacy Policy. If True Conversions updates this Privacy Policy, continued use of the Services (following the posting of the revised Privacy Policy) means that you accept and agree to the terms of the revised Privacy Policy. True Conversions recommends that you periodically review this Privacy Policy.

This Privacy Policy was last updated on May 5, 2020.