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Privacy Policy

Last update: 02/01/2024
1

Introduction

Privacy is a fundamental human right, one that we value and respect. We prefer to interact with individuals making tips to Truthwave anonymously, and in the case we have to handle personal data, we minimize the collection, use, and disclosure in an effort to preserve your privacy.

We at Truthwave (“Truthwave”, “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Notice (“Notice”) covers our personal data handling practices and describes your rights regarding your personal data.

Unless we link to a different policy or notice, this Privacy Notice applies when you use or access Truthwave websites, applications, and services (“Services”). It also applies to individuals with whom we conduct business.

2

Data Collection

We collect certain data from you directly, like information you enter into a form or otherwise disclose about yourself. We also collect some data automatically through the computer, like your IP address and data about your device when you connect to our services. All data listed in this section is subject to the following processing activities: collecting, recording, structuring, storing, altering, retrieving, encrypting, pseudonymizing, erasing, combining, and transmitting.

2.1

Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. In most cases, the data collected is not associated with an identifiable individual, but it is possible that some of the data may be linked to you where we are required to know your identity, for example to facilitate legal requirements like tax reporting. Below are some examples to help you better understand the data we collect.

Category of Data
Description
Legal Basis for Processing
Profile Data
When you interact with us, we will create a profile associated with you that may include your email address or other unique identifier so that we may communicate with you. We may also save information you disclose in your communications with us.
  • Performance of contract
  • Legitimate interests (communication, service provisioning, support services
Payment Data
In the event that you are eligible for a payment, we may collect and process data relating to that payment and taxes as required by law.
  • Performance of contract
  • Legitimate interests
  • Legal obligation
B2B Administrative Data
If you are a service provider or business partner to Truthwave, we will collect data that is required to communicate with you and conduct business with you. This may include information like your name, business contact information, billing and financial information.
  • Performance of contract
  • Legal obligation
  • Legitimate interests (payment facilitation, legal compliance, organizational administration)
Site Visitor Data
If you visit the Truthwave website, we may collect information about your visit in order to communicate with you and to track the performance of our site. This may include data elements like IP address, device information, cookie data, site usage data.
  • Legitimate interests (operation of the website, communicate, site and service improvement, security and anti-fraud)
Email List
To reach our audience and members, Truthwave maintains an email list which you can opt into or out of at any time. We may use your contact information to communicate with you.
  • Legitimate interests (communication)
2.2

Data We Collect through Automated Means

When you access the Services, including browsing our website, we collect certain data by automated means, including:

Category of Data
Description
Legal Basis for Processing
System Data
Technical data about your computer or device, like your IP address, device type, operating system type and version, device identifiers, browser, browser language, domain and other systems data, and platform types.
  • Performance of contract
  • Legitimate interests (service provisioning, customer and technical support, fraud prevention and security, communication, product improvement)
Usage Data
Usage statistics about your interactions with the Services, including browsing sessions, content accessed, pages visited, features used, and data relating to your use of the Services.
  • Legitimate interests (service provisioning, user experience improvement, product improvement)
Approximate Geographic Data
An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.
  • Legitimate interests (user experience improvement, fraud prevention, legal compliance, and security)

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your profile.

2.3

Data from Third Parties

If you are a service provider to Truthwave, in addition to information you submit to us, we may collect certain business contact information from third-party commercial sources.

3

How We Get Data About You

In most cases, we will process your data because you have affirmatively chosen to provide your data to us. For data we collect using automated means, we use tools like cookies, tags, java script, and similar tracking technologies. We encourage you to use anonymizing and privacy-preserving technologies like encrypted anonymous email and connecting to our Services using a virtual private networks (VPNs).

3.1

Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to facilitate your use of our Services. Cookies allow us to remember things about your visits to Truthwave, like your preferred language, and to make the site easier to use. We do not associate cookies with an identifiable individual. To learn more about cookies, visit https://cookiepedia.co.uk/all-about-cookies.

We may also use automated data collection tools like tags and scripts (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 2.2) when you use the Services.

3.2

Why We Use Data Collection Tools

We try to minimize the amount of data we collect from you, and we do not engage in behavioral advertising and do not use Data Collection Tools in relation to any social media sites or services. Truthwave uses the following types of Data Collection Tools for the purposes described:

  • Strictly Necessary: These Data Collection Tools enable you to access the Services, provide basic functionality (like logging in or accessing content), secure the site, protect against fraud, and detect and prevent abuse or unauthorized use. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.
  • Functional: These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services.
  • Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional.

4

What We Use Your Data For

We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, and as required by law or necessary for safety and integrity of the Services. We retain your data for as long as it is needed to serve the purposes for which it was collected or as required by law.

We use the data we collect through your use of the Services to:

  • Provide and administer the Services, including to facilitate your submission of tips to us and taking action on those tips. (Profile Data; System Data; Usage Data; Approximate Geographic Data);
  • Process payments (Profile Data; Payment Data);
  • Communicate with you, including electronically (Profile Data; System Data; Approximate Location Data);
  • Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse (Profile Data; Payment Data; System Data; Usage Data; Approximate Geographic Location);
  • Improve our Services and develop new services and features (all data categories);
  • Promote the Services (Usage Data);
  • As required or permitted by law (all data categories); and/or
  • As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services (all data categories).
5

Who We Share Your Data With

As indicated above, we will not share your personal data with third parties except to the extent necessary to provide or secure the Services. We may also share your data if it is required for legal compliance or as part of a corporate restructuring. We may share your data with third parties under the following circumstances:

  • With Service Providers, Contractors, and Agents: Some third-party companies who perform services on our behalf may have access to your data. This includes organizations that provide services like cloud hosting, software services, payment processing, fraud and abuse prevention, data analysis, and customer services and support. Service providers, contractors, and agents are required to use your data solely as we direct, to provide our requested service. (All data categories)
  • With Truthwave Affiliates: We may share your data across Truthwave organizations that are related by common ownership or control to enable or support us in providing the Services. (All data categories)
  • For Security and Legal Compliance: While we are committed to preserving anonymity where possible and practical, in certain situations, we may be compelled to disclose your data (all data categories) to third parties if we have a good faith belief that the disclosure is:
  • Required as part of a judicial, governmental, or legal inquiry, order, or proceeding;
  • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
  • Reasonably necessary to enforce our Terms of Use, Privacy Notice, and other legal agreements;
  • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
  • Reasonably necessary in our discretion to protect against harm to the rights, property, or safety of Truthwave, Truthwave users, Truthwave employees, members of the public, or our Services;
  • Reasonably necessary to disclose to our auditors and/or legal advisors for legitimate purposes; or
  • Required or permitted by law.
  • During a Change in Control: If Truthwave undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we will take appropriate measures to continue to protect your anonymity and identity, but may need to share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence). (All data categories)
  • After Aggregation or Anonymization: We will make reasonable efforts to ensure your identity remains unknown to us, but certain circumstances may remain out of our control, including for example, if you choose to disclose your identity to us. Where possible and practical, data we collect will be aggregated and/or anonymized so that your identity cannot reasonably be attributed to it. Aggregated or anonymized data may be used for any purpose. (All data categories)
  • With Your Permission: With your consent, we may share data to third parties outside the scope of this Notice. (All data categories)
6

Security

Truthwave takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that the Services or any information provided to us in connection with the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it.

As with any Internet-based system, there is always a risk of unauthorized access, so it’s important to protect your accounts and identity through the use of security controls like multifactor authentication (MFA), strong rotating passphrases, encryption, and virtual private networks (VPNs). Contact us using the information below if you suspect any unauthorized access to the accounts you use to communicate with us. However, due to the anonymous nature of the Services, we cannot guarantee that we will be able to take action.

While using the Services, you may encounter links to other sites and services. We have no control over their privacy practices and encourage you to exercise caution before downloading any data, clicking any link, or accessing any site or service that is not known and trusted by you.

7

Your Rights

You have certain rights around the use of your data. These rights vary depending on your location.

7.1

Your Choices About the Use of Your Personal Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

  • If you have provided consent for us to process your personal data, you may withdraw your consent at any time.
  • The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.

If you have any questions about your data, our use of it, or your rights, contact us at privacy@truthwave.com.

7.2

Accessing, Updating, and Deleting Your Personal Data

You can request to access, update, or delete your personal data:

  • To request to access, correct, or delete your personal data, please write to us at privacy@truthwave.com. Please allow up to 30 days for a response. For your protection, we may require you to be logged in to make the request or that the request be sent from the email address associated with your account. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.
7.3

Our Policy Concerning Children

Minors are not permitted to use the Services. If we learn that we’ve collected personal data from a minor, we will delete it. Parents who believe we’ve unintentionally collected data about their minor child should contact us for help deleting that information.

8

Jurisdiction-Specific Rules

If you live in California, you have certain rights related to accessing and deleting your data, as well as learning who we share your data with. If you live in Australia, you have the right to make a formal complaint with the appropriate government agency. Users outside of the United States should note that we transfer data to the United States and other areas outside of the European Economic Area.

8.1

Users in California

Users who are California residents have certain rights under the California Consumer Privacy Act of 2018, as amended, (“CCPA”). If you are an eligible California user, included in these rights are:

  • “Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
  • “Right to Correction” — You have the right to have inaccurate personal information about you corrected.
  • “Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
  • “Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, Truthwave will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
  • “Right to Opt-Out” - You have the right to opt out of the sale or sharing of your personal information for behavioral advertising. Truthwave does not engage in the sale or sharing of your personal information within the meaning of the CCPA.

For more information about the personal information we collect and how we collect it, please see the sections above entitled “What Data We Get” and “How We Get Data About You.”

To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers who have access to your personal information, please see the sections above entitled “Data Collection” and “Who We Share Your Data With.”

As a California resident, you also have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. Truthwave does not engage in direct marketing. However, if you would like to make a request, you may do so by emailing us at privacy@truthwave.com with the phrase “California Shine the Light”.

Since there is no widely accepted standard for the browser-initiated Do Not Track signal, we do not currently recognize or respond to Do Not Track signals. Because Truthwave does not sell or share your personal information within the meaning of CCPA, we do not process Global Privacy Control browser signals.

8.2

Users in Nevada

Truthwave does not sell its users’ personal information or personal data. Nonetheless, Nevada residents have the right to submit a request that we do not sell your covered personal information, which you can do by emailing privacy@truthwave.com.

8.3

Users in Australia

If you are an Australia resident and you have a complaint, you may refer it to the office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by visiting www.oaic.gov.au; forwarding an email to enquiries@oaic.gov.au; telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001. You may contact our privacy team at privacy@truthwave.com to make a complaint about a breach of the Australian Privacy Principles which will be responded to within 30 days.

8.4

Users in the European Economic Area (“EEA”), Switzerland, and United Kingdom (“UK”)

If you are located in the EEA, Switzerland, or UK, you have the right to request access to your data in a portable format and to request the rectification, erasure, restriction of processing, or objection to processing of your personal data. Additionally, if you are located in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with your supervisory authority.

Personal data is processed outside of the EEA, Switzerland, and UK by Truthwave and its affiliates and service providers. We use the Controller-to-Processor Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the EEA, Switzerland, and UK to third countries and have entered into data processing agreements with our service providers to restrict and regulate their processing of your data.

8.5

Users Outside of the U.S.

In order to provide the Services to you, we must transfer your data to the United States and process it there. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries.

9

Updates & Contact Info

If you live in California, you have certain rights related to accessing and deleting your data, as well as learning who we share your data with. If you live in Australia, you have the right to make a formal complaint with the appropriate government agency. Users outside of the United States should note that we transfer data to the United States and other areas outside of the European Economic Area.

9.1

Modifications to This Notice

From time to time, we may update this Notice. Changes become effective the day they’re posted unless otherwise stated. Please contact us via email with any questions or concerns. As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of the revised Notice. The revised Notice supersedes all previous Notices.

9.2

Interpretation

Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.

9.3

Questions

If you have any questions, concerns, or disputes regarding our Notice, please contact the Truthwave Privacy Team at privacy@truthwave.com.

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