Privacy Policy
Trulvl, Inc. (“we”, “our”, “us”, or “Trulvl”) respects the privacy of its users and is fully committed to protect their personal data and use it in accordance with data privacy laws. This Privacy Policy describes how we collect, use, and process any personal data that we collect from you—or you provide to us—in connection with your use of our website (www.trulvl.com), the acquisition of our Products and use of our Services. By acquiring our Products or accessing or using our Services, you signify your understanding of the terms set out in this Privacy Policy.
Information We Collect
Where you are a User and for the purposes of providing, maintaining, or improving our Products and Services (including, to the extent permitted by applicable law, any matters in our legitimate interests with respect to the Services), we will confirm your identity, contact you, provide customer support (including via email, in the comment section of our social media channels or other platforms where you may reach us), operate your account with us and collect payment from you. For the aforementioned purposes, we collect information that may contain the following personal data:
Name;
Shipping information;
Email address and phone number;
Payment and billing information (payment method details);
Order handling information
If you have given your consent when registering your account, when subscribing to our newsletter or blog, or shared your email address or other personal data with us to receive any other information, we will process your email address to send you the informative and/or promotional materials, to which you have subscribed to, for example, newsletters, advertisements of our Products and other information about our Products and Services that you have requested. At any point in time you can unsubscribe from receiving the above-mentioned information in our email footers.
When you contact our support team through email or any other digital means, we will retain the resulting correspondence in perpetuity.
By using cookies and similar technology on our website, we may collect data such as information on your device, your preferences and information filled while visiting our website, your interaction with the website, and other information used for analytical, marketing, and targeting activities (including unique visits, returning visits, length of the session, actions carried out in the webpage).
As it is in our legitimate interests to ensure our network security, give you access to, and to improve our Products and Services, we also collect the following technical usage data:
How and when you access your account;
Information about the device and browser you use;
IP address and device data
Device information
- Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
- Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
- Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
- Disclosure for a business purpose: shared with our processor Shopify and vendors such as sales channels, payment gateways, shipping and fulfillment applications.
Order information
- Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
- Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
- Source of collection: collected from you.
- Disclosure for a business purpose: shared with our processor Shopify and vendors such as sales channels, payment gateways, shipping and fulfillment applications.
Customer support information
- Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
- Purpose of collection: to provide customer support.
- Source of collection: collected from you.
- Disclosure for a business purpose: shared with our processor Shopify and vendors such as sales channels, payment gateways, shipping and fulfillment applications.
Minors
We do not knowingly collect, maintain, disclose, or sell the personal information about users under the age of sixteen (16). If you are under the age of 16, please do not use our Services. If you are under the age of 16 and have used our Services, please contact us at support@trulvl.com so that we may delete your personal information.
Sharing Personal Information
We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:
- We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
- We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
In order for Trulvl to provide you with our Products and Services, we work with third parties (“Third Party Service Providers”) with whom we share personal data to support these Services.
Information you have provided to us during the acquisition of our Products or use of our Services, including technical usage data, is shared with third parties who provide hosting and server co-location services.
Information you have provided to us during the acquisition of our Products or use of our Services may be shared with third-party manufacturing services whom we engage to provide any Services.
Your email address and other contact details you have provided to us and your messages to our customer service is shared with communication, email distribution, and content delivery services as well as customer support system providers.
Information regarding your purchases and payments is shared with billing and payment processing services, fraud detection and prevention services, accounting and financial advisors.
Information regarding your use of our website and other information received from cookies and similar technology is shared with web analytics, session recording, and online marketing services.
Information on your account, purchases and preferences can be shared with marketing services.
Insofar as reasonably necessary to defend our legal rights, we may share your personal data with our legal advisors.
We will only share personal data to Third Party Service Providers that have undertaken to comply with obligations set out in applicable data protection laws.
In certain circumstances, we are required to share information with third parties to comply with legal requirements or requests, as well as to protect our, or a third party’s, lawful interests. We will also disclose your information to third parties in and outside your country only to the extent allowed by applicable law.
Behavioral Advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:
- We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
- FACEBOOK - https://www.facebook.com/settings/?tab=ads
- GOOGLE - https://www.google.com/settings/ads/anonymous
- BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Using Personal Information
We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.
Lawful basis
Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:
- Your consent;
- The performance of the contract between you and the Site;
- Compliance with our legal obligations;
- To protect your vital interests;
- To perform a task carried out in the public interest;
- For our legitimate interests, which do not override your fundamental rights and freedoms.
Retention
We may retain your personal data for as long as you have a Trulvl account or any of the abovementioned legal basis for personal data processing still exists. For example, if you unsubscribe from our marketing, newsletter, or blog emails, we will stop the processing of the personal data for such purposes. If you have initiated acquisition of our Products or used our Services without creating a Trulvl account, we will keep your personal data as long as necessary to comply with our legal obligation to retain information relating to provision of services, for example, tax purposes.
After terminating your relationship with us by deleting your Trulvl account or otherwise ceasing to use our Services, we may continue to store copies of your personal data as necessary to comply with our legal obligations, to prevent fraud and abuse, to enforce our agreements, and/or to protect our legitimate interests (to the extent that we are permitted by the applicable law to continue to store copies to protect our legitimate interests).
When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.
Automatic decision-making
If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.
We [DO/DO NOT] engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.
Services that include elements of automated decision-making include:
- Temporary deny list of IP addresses associated with repeated failed transactions. This deny list persists for a small number of hours.
- Temporary deny list of credit cards associated with deny listed IP addresses. This deny list persists for a small number of days.
Data Subject's Rights
If you are a User located in the European Economic Area or the United Kingdom, in accordance with European Union and United Kingdom data protection regulations, you have certain rights with respect to your personal data. You have the right to request access to your personal data; in certain circumstances to correct, amend, delete, or restrict the use of your personal data by logging into your Trulvl account or by reaching us using the contact information provided below. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we are not required to process your data to meet a contractual or other legal requirement). These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to retain, are permitted by law to retain, or have compelling legitimate interests in retaining (to the extent that applicable law permits us to retain such information based on our legitimate interests).
Furthermore, if you believe that we have unlawfully processed your personal data, you have the right to submit a complaint to the contact information provided below, or to your respective data protection supervisory authority.
GDPR
If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us at support@trulvl.com.
Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR White paper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.
CCPA
If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us at support@trulvl.com.
If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address above. You have the right to request deletion of your personal information that we collect and maintain. We will verify requests to exercise your California Privacy Rights requiring you to log into your Trulvl account. You have the right not to be discriminated against by us for exercising any of your rights under the CCPA.
Cookies
A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.
We use the following cookies to optimize your experience on our Site and to provide our services.
Cookies Necessary for the Functioning of the Store
| Name | Function |
|---|---|
| _ab | Used in connection with access to admin. |
| _secure_session_id | Used in connection with navigation through a storefront. |
| cart | Used in connection with shopping cart. |
| cart_sig | Used in connection with checkout. |
| cart_ts | Used in connection with checkout. |
| checkout_token | Used in connection with checkout. |
| secret | Used in connection with checkout. |
| secure_customer_sig | Used in connection with customer login. |
| storefront_digest | Used in connection with customer login. |
| _shopify_u | Used to facilitate updating customer account information. |
Reporting and Analytics
| Name | Function |
|---|---|
| _tracking_consent | Tracking preferences. |
| _landing_page | Track landing pages |
| _orig_referrer | Track landing pages |
| _s | Shopify analytics. |
| _shopify_fs | Shopify analytics. |
| _shopify_s | Shopify analytics. |
| _shopify_sa_p | Shopify analytics relating to marketing & referrals. |
| _shopify_sa_t | Shopify analytics relating to marketing & referrals. |
| _shopify_y | Shopify analytics. |
| _y | Shopify analytics. |
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.
Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioral Advertising” section above.
Do Not Track
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
Information Security
We seek to use reasonable organizational, technical, and administrative measures to protect the confidentiality, integrity, and availability of personal data. We encourage you to take care of the personal data in your possession that you process online and set strong passwords for your Trulvl account, limit access to your computer and browser by signing out after you have finished your session, and avoid providing us with any sensitive information.
Changes
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. Therefore, we encourage you to check this page frequently from time to time.
Contact
For more information about our privacy practices, if you have questions, or if you would like to express a concern, please contact us by e-mail at support@trulvl.com.
Last updated: June 28, 2021
If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://www.state.gov/bureaus-offices/under-secretary-for-management/bureau-of-administration/privacy-office/
