This Privacy Policy sets out how Tru Labs Inc., and its affiliates and subsidiaries (“truflation”, "we", "us", "our") processes personally identifiable information (“Personal Information”) that we gather when you are accessing or using the Services provided through our website https://truflation.com and the Company’s Platform, it also describes your data protection rights, including the right to object to some of the processing which we carry out.


This Privacy Policy does not however cover the use of cookies by any third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services.


Your use of truflation’s Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in our Terms of Service.



By using or accessing our website and/or the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the ways described herein.



Scope of this Privacy Policy



This Privacy Policy covers our treatment of Personal Information that we gather when you are accessing or using our Services, but not to the practices of companies we do not own or control, or people that we do not manage such as third-party websites.


We may gather various types of Personal Information from our users and we use this Personal Information internally in connection with improving the provision of our Services, for example, troubleshooting, data analysis, improvements to our service, customer services, personalisation of user experience, marketing, compliance with laws and regulations. We may also share some Personal Information with third parties, but subject to the terms herein.



Our right to update and amend


We may need to change this Privacy Policy from time to time for the purposes of improving our Services and to comply with the appliable law. Any and all amendments or modifications to this Privacy Policy will be effective immediately upon being announced on our website or the Company’s Platform. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used.



Types of information we may collect directly from you


​We may receive and store any information you knowingly provide to us, including for example:



Identity data: First name, surname, date of birth, facial recognition via forward-facing camera




Contact data: Email address (or other contact details) which we may use to contact you.



Services related data: Your data that you provide to us when you report a problem or ask a question in respect of our Services or when you request further services from us. If you contact us, we may keep a record of that correspondence.


Technical data: This includes for example:



  • Location information: We may collect and process data about your actual location.


  • Device information: We may collect information about the device you use to access the Services, including your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile network information, telephone number and other technology on the devices you use to access our Services.


  • Log information: We may automatically collect and store certain information about your use of the Services in server logs (see Cookie Policy below)


Types of third-party data we may collect directly from other sources


We may also collect certain of your Personal Information from third party sources, whether they are publicly available or not (for example from social media), and such Personal Information may include your identity and contact data.



Automatic collection of data



When you enter our website at https://truflation.com and interact with certain parts of our Services, we automatically receive and record information on our server logs from your browser or device, which may include your internet protocol (IP) addresses, geolocation data, device identification, “cookie” information, the type of browser and/or device you use to access our Services, and the page or feature you requested. We typically collect this information through a variety of tracking technologies, including cookies, embedded scripts, web beacons, file information and similar technology (collectively, “tracking technologies”). “Cookies” are identifiers we transfer to your browser or device that allow us to recognise your browser or device and tell us how and when pages and features in our website are visited and by how many people.


​For further information about cookies, visit www.allaboutcookies.org. Many browsers are set to accept cookies until you change your settings. You may however remove or reject cookies via your browser settings by following the instructions provided to you. Your browser may also offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked.



Our website may use some or all of the following types of cookies. If you do not accept our cookies, you may experience some inconvenience in your use of our website or Services.


Necessary Cookie: These cookies are essential to provide you with services available through our website and to enable you to use some of its features. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with the Services.



Functionality Cookies: These cookies are used to recognise you when you return to our website and allow our website to remember choices you make when you use our website. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website. We also use these cookies to obtain information about your visit, including items you viewed or searched for, page response times and download errors.



Analytics and Performance Cookies: These cookies are used to collect information about traffic to our website and how users use our website. The information gathered via these cookies does not directly identify any individual visitor. However, it may render such visitors indirectly identifiable. We use this information to help operate our website more efficiently, for example, by ensuring that users are finding what they are looking for easily, as well as to gather broad demographic information and to monitor the level of activity on our website.



Thirty Party Cookies: Please note that certain third parties may also use cookies, over which we have no control. If you would like to disable these "third party" cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to that third party's website and setting your cookie preferences to stop any further cookies being written to your device.



Our handling and usage of your Personal Information



For the purposes which we use or share your Personal Information, we will rely on one of the following legal bases:


  • to comply with a legal or regulatory obligation.

  • we have your specific consent to carry out the processing for the Purpose in question.

  • it is necessary to protect our legitimate interests, which will override your interests and fundamental rights.



We will process your personal information if you give us your consent willingly or in accordance with the law. You give your consent to us through the use of our website and Services. We will only disclose your personal information if (a) the law requires it, (b) we have a public duty to disclose the information, (c) our or your legitimate interests require disclosure; or (d) you agreed that we may disclose your information.



We do not generally rely on your consent as a legal basis for using your Personal Information, other than in the context of direct marketing communications.


​To the extent we do use Personal Information, we use such information to provide and improve the Services, optimise our technology, refine the experience of truflation users, and innovate ways to forward our mission. Without your personal information, we may not be able to provide or continue to provide you with the Services that you need.



Sharing of your Personal Information



We only share your Personal Information with other organisations with your express consent and as described in this Privacy Policy. You hereby expressly agree that we may share your Personal Information with the following third parties as described below:​



  • Affiliated Businesses: We may share your Personal Information with the affiliated businesses to the extent that it is related to their provision of any products or services in connection with our Services. But we have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all of these business’ or websites’ policies.


  • Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide the Services to you.


  • Business Transfers: We may buy or sell assets and share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.


  • Third Party Services: We may use third party services to grow our business, to improve and monitor our Services and so on. These services may collect and retain some information about you, such as the IP address assigned to you on the date you use the Services.


  • Compliance with laws and regulations: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of truflation, our employees, our users, or others.



Protecting your Personal Information


We strive to protect the privacy of the Personal Information we hold in our records, but we cannot unfortunately guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. You are also responsible for the safety and security of your own Personal Information. We urge you to take steps to keep your Personal Information safe by, for example, not disclosing it in an unsecured manner.



We also seek to protect Personal Information by refraining from collecting Personal Information where possible. But these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.


By using our Services, you acknowledge that you understand and agree to assume these risks.



HONGKONG RESIDENTS


If you are a Hong Kong resident, Hong Kong Data Privacy Law may provide you with additional rights regarding our use of your Personal Information. To learn more about your Hong Kong privacy rights, visit https://www.pcpd.org.hk/english/data_privacy_law/ordinance_at_a_Glance/ordinance.html




Any questions


​If you have any questions or concerns regarding this Privacy Policies, please send us a detailed message to info@truflation.com, and we will try to resolve your concerns.