Last Updated: December 1st, 2020
What Personal Information We Collect
Personal information is any information that could, alone or together with other information, personally identify, or otherwise be reasonably linked or connected with, a particular consumer or household (“Personal Information”). Information such as a username and password, an email address, a real name, an Internet protocol (IP) address and a photograph are examples of Personal Information. We collect Personal Information when you voluntarily provide it through our Services, or when you provide it to us through the following other means:
- when you engage with our content on social media;
- through your interactions with our mobile app;
- by opening/clicking/responding to email marketing;
- through third-party tracking pixels on the platform; and
- through single-sign-on, which allows you to log into the Trufan.io website and enables us to collect data through that process social media data, including, without limitation:
- your username;
- who you follow;
- your followers;
- whom you subscribe to; and
- your account profile picture.
We may collect Personal Information when you:
- contact us through email, telephone, mail; or other correspondence;
- register for or request a service we provide or which we make available to you through our Services;
- register or link an account on our website;
- upload content to our website;
- create an account on the Services, which may include your name, address, email, phone number, date of birth, photo, payment or banking information, and government ID;
- enter into a sweepstakes, contest, or promotional prize draw (each a “Sweepstakes”) held through our Services;
- fill out questionnaires on our Services or which are sent to you;
- communicate with the Company;
- provide access to linked accounts, including Twitch and YouTube;
- submit information about product purchases;
- submit information about your business, including financial information;
- engage with our content on social media;
- interact with our platform, website and mobile app; and
- interact with our company on social media
We may collect the following Personal Information:
- your full name;
- contact information, such as your address, telephone number, or email address;
- your physical location and/or shipping address (if you win any deliverable prize);
- your date of birth;
- your photo;
- your username on the Services;
- your username from third party accounts which you have linked to our Services (each such account, a “Linked-Account”);
- your account profile picture;
- your Linked-Account profile picture;
- video submitted to us by you;
- audio submitted to us by you;
- social media data, including without limitation: who you follow, your followers, subscribers and who you subscribe to;
- your payment and banking information;
- information provided by third-party payment processors such as Stripe or PayPal;
- your location;
- your site activity history, behaviors, preferences, settings; and
- any other Personal Information that you choose to submit to us.
We collect certain information when you:
- register an account;
- update your profile, account settings, profile picture, etc.;
- Opting in to email and SMS marketing communications;
- enter a Sweepstakes;
- winning a Sweepstakes;
- claim a prize;
- create and administer a Sweepstakes;
- draw winners for your Sweepstakes;
- register for a paid account on the platform;
- open, click on, or otherwise engage with email or SMS marketing content; and
- follow/unfollow users on the platform.
This information may include:
- information about how, when, and where you use our Services;
- error logging, event recording and user experience data;
- whether you have entered a Sweepstakes;
- entry methods used for Sweepstakes; and
- the settings you use on our Services.
We also collect information about you from third parties. We may obtain this information from sources such as:
- our business partners;
- our clients and customers;
- third-party service providers, including:
- Facebook (social media authentication platform and Facebook pixels for adverting retargeting);
- Google (advertising pixels);
- Instagram (social media authentication platform);
- Twitch (social media authentication platform);
- Twitter (social media authentication platform);
- YouTube (social media authentication platform);
- Google analytics (for tracking usage data, analytics and statistics); and
- ActiveCampaign (for email marketing automation and customer attribution);
- other users of the Services;
- banking or other financial services providers;
- insurance providers;
- the entities that are administrating the Sweepstakes (the “Sponsors”); and
- publicly available sources.
How We Collect Information Through Technological Means
When you use our Services, we may collect information that is automatically sent to us by your web browser or your device which runs our applications. This information may include your domain name, and your IP address. We may also collect other information, such as the type of browser you use, which of our site’s pages you view, and the files you request. Additionally, we may also collect other technical and system log information from you, such as:
- the hardware you use to interact with our Services;
- operating system and version information;
- software you use;
- API access tokens;
- mobile network information;
- pages you view on our Services;
- your unique device identifier;
- your system activity;
- software debug and crash information; and
- referral website address used to access our website.
We use this information to improve our understanding of how users use our Services, and to improve our Services. The amount of information that is sent to us by technological means depends on your browser or device and settings you use. Please refer to the instructions provided by your browser or device if you want to learn more about what information it sends to Services you use, or how you may change or restrict this.
- to improve functionality and performance of our Services, including tailoring our Services to increase relevancy of content displayed to you;
- to provide you with services;
- to facilitate your transactions on the Services;
- to authenticate users of our Services;
- to provide us with insights on how users use our Services and other analytics, such as traffic on our Services;
- to remember your settings and preferences; and
- to deliver relevant advertisements to you based on your interests, preferences, and activities. Cookies also help to avoid delivering the same advertisements to you too many times and measure the usefulness of advertisements you have been delivered. Information gathered by Cookies may be shared with third parties, including advertisers. This means that sometimes you’ll see our Services advertised elsewhere on the internet.
How We Use and Disclose Information Collected from You
- to deliver our Services to you;
- to register your account on the Services;
- to verify and authenticate your Account information;
- to validate your reputation on certain platforms;
- to verify ownership of Sweepstake’s prizes by the Sponsor;
- to supply you with requested goods, products or services;
- to send you informational, administrative, or promotional communications if you explicitly consented to receive these communications;
- to communicate with you and to enable other users to communicate with you;
- to respond to your inquires and provide you with customer support;
- to increase the security and safety of our Services and users;
- to carry out and facilitate Sweepstakes;
- to facilitate delivery of Sweepstakes prizes to the applicable winners;
- to serve you relevant advertisements and content;
- to collect and disburse payments;
- to perform analytics on our Services;
- for any other purposes that are disclosed to you and to which you consent;
- to process your entry into Sweepstakes; and
- for any purpose required by law.
Each time you enter a Sweepstakes, we may publicly disclose on our website and app that you have entered that Sweepstakes, and this may include our sharing your username and profile picture with the public. At that time, we may also disclose your Personal Information to the Sponsor, the entity that provides the prize(s) and/or the beneficiary charity of such Sweepstakes (collectively, the “Third-Party Participants”) for the following purposes:
- The Sponsor may use the Personal Information in administrating the. Sweepstakes. (For example, the Sponsor will need Personal Information to match a winning draw with the user who submitted it.)
- The Sponsor may need to disclose Personal Information of winners to comply with local Sweepstakes law. (For example, certain states require sweepstakes administrators to submit winners lists to the office othe Secretary of State).
- The charity may need to disclose Personal Information to fulfill its compliance requirements as a non-profit organization.
- Sponsors may disclose your name, username or Linked-Account username, photo, profile picture or Linked-Account profile picture, and prize won on their stream or in other publicity.
- Third-Party Participants may use your Personal Information for their marketing purposes.
Each time you redeem an entry to a Sweepstakes, we may publicly disclose on our website and app and in any other publicity: (a) that you redeemed an entry; (b) the entry method you used; (c) the number of entries you redeemed; (d) the time you redeemed your entries; (e) your username or Linked-Account username; and (f) your profile picture or Linked-Account profile picture. If you register on our Services, but fail to enter a Sweepstakes, we may also publicly disclose that fact.
In addition to information described in the paragraph above, other information of yours may be disclosed on our Services’ activity stream. This information may include: (a) XP that you have earned and the reason therefor; (b) groups or circles you have been added to; and (c) entries you have earned for undertaking various actions and the actions that earned you those entries.
If you post a comment to our Website, the information that you post, including any personal information that you post, may be available generally to the public.
If you win a Sweepstakes, your email and physical address may be delivered to one or more Sponsors in order to allow them to deliver your prize. Further, we may publicly disclose on our website and app and in any other publicity: (a) your username or Linked-Account username; (b) your profile picture or Linked-Account profile picture; (c) your name; (d) the prize you won; (e) your approximate location; (f) your prize won; and (g) your photo.
We also combine, analyze, process, and store information we collect from you for the purposes of facilitating and improving our Services. We may transfer information we collect from you to third party service providers that assist us with carrying out any of these purposes.
We work with payment services providers to collect payments and disburse funds from and to users of our Services. As a result, we will share your Personal Information and other payment information with third party payment service providers (including Stripe, PayPal, and Tiltify) to the extent necessary to make such payment collections and fund disbursements.
We may share certain aggregated, non-personally identifying information with others about how our users, collectively, use our Services.
Some or all of the information we collect may be stored or processed in jurisdictions outside of Canada. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
We reserve the right to transfer Personal Information to a third party in the event that we merge with or are acquired by a third party, or as part of the negotiations leading up to such merger or acquisition. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.
We may also disclose your Personal Information for legal compliance purposes, to cooperate with or carry-out investigations, and in compliance with any court order or subpoena.
While the entities donating the prizes may receive your Personal Information and use your Personal Information for purpose stated herein, we do not sell our users’ Personal Information to third parties.
How We Protect Personal Information
The security of your Personal Information is important to us. We are committed to ensuring your Personal Information is protected and will use industry-standard security measures, including Secure Socket Layer (SSL) technology, to do so. Personal Information may only be accessed by persons within our organization who require such access to provide you with the services indicated above. Financial transaction information is kept but anonymized. All personal information is stored in a password secured database inside a VPC (Virtual Private Cloud).
No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. In the event of a data breach that affects your Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected users without undue delay.
Storage and Processing of Information
We keep track of Personal Information by storing it in a relational database, with all Personal Information tied to specific user records.
Information collected through your use of the Services may be processed or stored in the United States, Canada, Europe or any other country in which We maintain facilities. We may transfer information that we collect about You, including personal information, to affiliated entities or to other third parties across borders and from your country of jurisdiction to other jurisdictions throughout the world.
We Store Personal information for as long as necessary in order to provide the Services and fulfill the purposes discussed above. Please note that in some cases means that such Personal Information may be retained by Us indefinitely as long as you have an account with Us. You may also contact us at any time to delete your Personal Information, including any account information you have submitted to us, as set out below in this agreement.
Third Party Collection of Information
Do Not Track
Do Not Track is a privacy option that people can set in certain web browsers. Do Not Track is a way for individuals to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or other online services. However, we do not recognize or respond to Do Not Track requests, and we have no special monitoring services to identify which browsers are using Do Not Track options and which do not.
As a user of our Services, you have the following rights as they relate to Personal Information:
- the right to know what Personal Information about you is collected.
- the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
- the right to request that we delete any of your personal information that we collected from you and retained (subject to certain exceptions).
- the right to know whether and to whom your Personal Information is sold and/or shared, and you have the right to opt out of having your Personal Information sold.
- the right to not to be charged a different price or receive different services where exercising the other rights described above (subject to certain exceptions).
Accessing Your Personal Information
Registered customers can use their profile pages to access and control certain information we collect. Personal information accessible through user profile pages includes username, email address, profile picture, region/location, integration preferences, connected accounts, opt-in/out of marketing and contact preferences.
You may also request access to Personal Information by submitting a support request—accessible through the web portal or by direct request—using the or by contacting our privacy offer by email at firstname.lastname@example.org or by telephone, toll free, at 1-888-605-0550 Once we receive and confirm your request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclose your Personal Information for a business purposes, the Personal Information categories that each category of recipient obtains.
Deletion of Personal Information
If you would like to cancel your account or delete your User Personal Information, you may do so in your user profile. You may also request that we delete your Personal Information by submitting a support request or by contacting our privacy offer at email@example.com or by telephone, toll free, at 1-888-605-0550. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity or prosecute those responsible for such activities;
- debug products to identify and repair errors that impair existing intended functionality;
- exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law;
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
- enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- comply with a legal obligation; or
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
You can opt out all marketing communications by (i) clicking the “Unsubscribe” link at the bottom of emails, or (ii) changing your account settings on the platform. It may take up to 30 days before we are able to process your opt-out request. Once we have processed the request, you will not receive any more marketing communications unless you opt back in.
If we process your Personal Information and you do not have an account, then you may, subject to applicable law, access, update, alter, delete, or object to the processing of your personal information by contacting us by email at firstname.lastname@example.org or by telephone, toll free, at 1-888-605-0550
Response Timing and Format
We endeavor to respond to requests within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Trufan.io is compliant with the European Union’s General Data Protection Regulation (“GDPR”), in place as of May 25, 2018. As such, EU citizens providing us with their Personal Information have the following rights, in compliance with the GDPR:
- a right to information and access to their Personal Information, including information on whether and how Your Personal Information is being processed;
- You have a right to access to your Personal Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected please contact us using the contact information provided below.
- a right to have your Personal Information deleted if you withdraw your consent to our collection or storage of such Personal Information;
- a right to restrict the manner in which your Personal Information is processed;
- a right transfer Your Personal Information another service provider or entity without hindrance; and
- a right to object at any time to the processing of their Personal Information.
Trufan.io is the ‘data controller’ and data ‘processor’ for users of Services as defined by the GDPR. Questions or concerns about your data collection practices can be forwarded to our data protection officer or EU representative at the contact info listed at the end of this policy.
THE SERVICES ARE NOT AIMED AT INDIVIDUALS UNDER 13. IF YOU ARE UNDER 13 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS OUR SERVICES AT ANY TIME OR IN ANY MANNER.
We do not knowingly collect or maintain personal information from people under 13 years old. If we learn that personal information of people under 13 years old has been collected on or through our Services, we will take appropriate steps to delete this information.
If you are the parent or legal guardian of a child under 13 years old who uses our Services, then please contact us at the address below to have your child’s account terminated and personal information deleted.
Changes to our Privacy Statement
How to Contact Us
Our privacy officer/data protection officer is Aanikh Kler and can be reached at:
Toll-Free Telephone: 1-888-605-0550