I. Introduction
Trusona provides identity verification services and multi-factor authentication on behalf of our customers. During the initial enrollment process of our mobile application, we receive a variety of data from our customers in regards to identity information that is collected from government-issued identity proofing documents. We respect the consumers’ online privacy and are committed to following industry privacy standards and directives.
Trusona also collects information about people who visit the company’s main website, trusona.com. We use the anonymous information collected from the company website for marketing and advertisement purposes.
This privacy policy describes the nature of how the data we collect is stored and secured while at Trusona.
II. Personal Data We Collect and Data Sources
Covered Data Processing Activities
This Privacy Policy applies to the processing of Personal Data that we collect in the following ways, as detailed in this section.
We collect information about you when you provide it to us, when you interact with our websites and electronic systems, and when you attend events and visit our offices, and when other sources provide it to us, as further described below.
Information you provide to us
Based on our current practices (and including our practices over the last 12 months), we collect the following categories of information about you:
Internal Data: We collect contact and/or professional data about you in person, through communications, including communications from you or your colleagues, and through our websites. For example, you provide your contact and professional information to us when you sign up to learn more about Trusona’s products and services, download content, register for an event, and visit our offices. If you attend an event, we may also receive contact and professional details about you when you choose to scan your attendee badge or by providing a business card or other method where you share Personal Data with us. Typically, contact data includes your name and contact methods, such as telephone number, email address, and mailing address, and professional data includes details such as the organization you are affiliated with, your job title, and industry.
Biographical, Community, and Support-related Data: We may also collect various types of biographical, community, and support-related Personal Data from you via our help center and community support forums. For example, if you register for an online community that we host, we may ask you to provide a username, photo and/or biographical information, such as your occupation, organization name and areas of expertise. Additionally, you may provide Personal Data to us when you create user-generated content (for example, by posting in a forum), provide Trusona with feedback, or when you participate in interactive features, trainings, online surveys, contests, promotions, sweepstakes, activities, or events. You may also be asked to provide contact information, a summary of the problem you are experiencing, and any other information that would be helpful in resolving a customer support request.
Job Applicant Data: You provide your contact and professional information, including your resume with educational and work background, when you apply for a job with Trusona. You may also provide us with sensitive information, like your Social Security Number or other government identifier, racial or ethnic origin, or other such Personal Data in connection with your job application.
Audio, Electronic, or Visual Data: If you attend a Trusona in-person or virtual event or agree to be recorded in a telephone or video meeting, we may record some or all of that event or meeting. For events, we may document the event in various ways, such as by taking photos at the event, interviewing you at the event, or recording your participation in a live question and answer or other interactive session. We use this information for business and marketing purposes to better inform the public about Trusona, its events, and provide testimonials about our products and services.
One common technology we use to collect metadata that may be considered Personal Data is our use of cookies. Cookies are small text files that are placed on your web browser and that help us recognize your browser or device as a unique visitor in different ways based on the type of cookie. The three main types of cookies are:
Essential cookies. Essential cookies are required for website functionality and security. For example, authentication, security, and session cookies may be required for our website or products to work.
Functional cookies. We use functional cookies to help enhance our websites’ performance, for market research, or other analytics or advertising that is not tied to a specific individual. For example, we may use Google Analytics to help us track how many individuals visited our website. We may also utilize HTML5 local storage cookies for the reasons described in this section. These types of cookies are different from browser cookies in the amount and type of data they store and how they store it.
Targeting or advertising cookies. We use targeting and advertising cookies to help us understand our marketing efforts and to reach potential customers across the web. For example, we contract with third-party advertising networks that may track your activity over time and across different channels, including our websites, email activity, and other websites and applications that display advertisements. They may use this tracking information to understand and predict your interests, to display an advertisement for Trusona on another website, or email you with a marketing communication for an Trusona product.
Trusona as a Business
As with most websites, whenever you visit a Trusona website, take a Trusona training, engage with the Trusona Community, or when you interact with Trusona promotional content, Trusona may receive both Personal Data about you from information-gathering tools and passive information collection on our websites, including Personal Data from our websites you visit or emails we send. This information collection typically includes information such as cookies, beacons, demographic information, company and role details, market research and publicly-available information, IP address, device and browser details, usage information, timestamps, pages viewed, searches, interaction with and action taken by you on our websites or content, as well as other non-Personal Data. If you sign up to participate in specific programs, such as the Trusona Ideas forum, we may analyze usage data related to your use of our Service along with the data you choose to provide to us through Trusona Ideas to provide you with a better customer experience.
We use the information we collect as a business to analyze and predict results arising from our sales and marketing efforts, improve the performance of our websites, products and services and customer support, identify potential customers, opportunities, and potential new product areas, ascertain trends, improve our websites’ functionality, improve our security, and provide us with general business intelligence, including through the use of machine learning technology. We may also combine the metadata and usage information collected from our websites with other information to help further the purposes described in the previous sentence.
Intentional Disclosures to Third Parties
As part of the functionality we make available on our websites and to better reach our customers and prospective customers, there may be categories of third parties that are authorized by us to operate on our websites and access your Personal Data, such as your contact data, IP address or cookies. Depending on your location, (for example, for visitors from California and the European Union), Trusona only shares Personal Data with such third parties if you agree to such sharing through a website banner or form. In other parts of the world, this information may be automatically collected when you visit our websites. These categories of third parties include, but are not limited to, advertising networks and social networks.
III. How We Use Personal Data
How we use the Personal Data we collect depends in part on how you choose to communicate with us, how you use our websites and interact with us, and any preferences you have communicated to us. In general, we use your Personal Data as is necessary to run our business and carry out our day-to-day activities. In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Data to accomplish the following tasks (and we have done so during the 12 months preceding the effective date of this Privacy Policy):
Communicate with you about our products and services and facilitate other interaction. We may use your Personal Data, such as contact data, Ancillary Data, and metadata, to send you transactional communications, notices, updates, security alerts, and administrative messages regarding our products and services that may be useful to you and your organization. We will respond to your questions, provide tailored communications based on your activity and interactions with us, and help you use our products and services effectively.
Support safety, security, and manage operations. We use Personal Data, such as contact data, Ancillary Data and other metadata, about you and your use of our products, services, and offices to verify accounts and activity, monitor suspicious or fraudulent activity, assist our customers in their monitoring of suspicious or fraudulent activity, and identify violations of policies regarding the use of our products and services. We also process Personal Data for security and operations management reasons, such as to register visitors to our offices, including to manage non-disclosure agreements that visitors may be required to sign.
Market and promote our products and services. We use your Personal Data, such as contact data, Ancillary Data, and other metadata, about how you use the products and services to send promotional communications that may be of specific interest to you and your organization, including by email and by displaying Trusona marketing communications on other companies’ websites and applications, as well as on third-party platforms like Facebook, Twitter, and Google. These communications are aimed at encouraging engagement and maximizing the benefits that you and your organization can gain from Trusona’s products and services, including information about new products and features, survey requests, newsletters, and events we think may be of interest to you and your organization.
Manage contests or promotions and customer appreciation. Trusona may occasionally run contests or other special promotions or make available opportunities or other tokens for customer appreciation, and if you register for these, we may process your Personal Data, such as contact information, biographical information, and contract-related data to perform our contract with you. Trusona may also use the Personal Data, such as contact data, collected in these contests, promotions, and for customer appreciation as well as to send you promotional material about Trusona and our partners.
Recruiting. We process your Personal Data, such as contact, job applicant, and biographical data, to assess your application and to evaluate and improve the recruitment system, our application tracking and recruitment activities. We also use your Personal Data to communicate with you regarding your application or opportunities at Trusona that appear over time that we believe may be of interest to you. We also use your Personal Data to send you new hire and employee experience information. We may verify your information, including through reference checks and, where allowed, background checks.
Other purposes for our legitimate interests: Where required by law or where we believe it is necessary to protect our legal rights, interests, or the interests of others, we may use your Personal Data in connection with the management of our business, including but not limited to, for operational purposes, legal claims, compliance, regulatory, and audit functions, protecting against misuse or abuse of our products and services, and protecting personal property or safety. For example, we may review compliance with applicable usage terms in our customer contracts, assess capacity requirements for our products, websites, and offices, improve your user experience, respond to requests by you for support or for contact, or identify customer opportunities.
Other purposes with your consent: We may use your Personal Data if you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote our products and services or record phone calls for quality and training purposes, with your permission.
If we process your personal data for a purpose other than that set out above, we will provide you with information prior to such processing.
Legal Bases for Processing Personal Data (for European Economic Area Individuals)
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis or bases for doing so under applicable EU laws. The legal bases depend on the products and services that your organization has purchased from Trusona, how such products and services are used, and how you choose to interact and communicate with Trusona’s website, systems, and whether you attend Trusona events. This means we collect and use your Personal Data only where:
- We need it to operate and provide you with our products and services, provide customer support and personalized features, and to protect the safety and security of our products and services;
- It satisfies a legitimate interest of Trusona’s (which is not overridden by your data protection interests), such as for research and development, to provide information to you about our products and services that we believe you and your organization may find useful, and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to comply with a legal obligation.
If you have consented to our use of Personal Data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your Personal Data because we or a third party (for example, your employer) have a legitimate interest to do so, you have the right to object to that use; however, in some cases, this may mean that you no longer use our products and services.
IV. Trusona’s Security Posture & Measures Taken
Security is a critical priority for Trusona. We maintain a comprehensive, written information security program that contains industry-standard administrative, technical, and physical safeguards designed to prevent unauthorized access to Personal Data.
However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and maintaining the security of your devices.
V. International Data Transfers
Your Personal Data may be collected, transferred to, and stored by us in the United States, and by our affiliates and third parties that are based in other countries. The addresses of our offices where Trusona, Inc. and its affiliates are located can be found online at https://www.trusona.com/contact.
Your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area. We ensure that the recipient of your Personal Data offers an adequate level of data protection, for example, by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (as described in Article 46 of the General Data Protection Regulation), or we will ask you for your prior consent to such international data transfers.
VI. How Long Does Trusona Keep Your Data?
We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We determine the appropriate retention period for Personal Data by considering the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
VII. Your Information Choices
Your Privacy Choices
In the above sections, we describe how we may collect, use and share your Personal Data for providing relevant content and advertising. Below, we describe how you may unsubscribe, opt-out, or otherwise modify settings related to our processing of your Personal Data.
Direct Email Marketing. If you wish to withdraw from direct email marketing communications from Trusona, you may click the “unsubscribe” button included in our emails. Please note, you cannot unsubscribe from critical transactional emails that are related to our provision of our online Service (such as those related to security and your Trusona account).
Direct Marketing – Phone or Postal Mailings. If you wish to withdraw from phone call or postal mail marketing communications from Trusona, please request to do so through our form.
Your European Privacy Rights
Under the General Data Protection Regulation, if you are a European Union data subject, you have rights to understand and request how we collect, use, and disclose Personal Data in our capacity as a data controller, to the extent permitted by applicable law.
Right to Access. You have the right to access your Personal Data held by us.
Right to Rectification. You have the right to rectify inaccurate Personal Data and, taking into account the purpose of processing, to ensure it is complete.
Right to Erasure (or “Right to be Forgotten”). You have the right to have your Personal Data erased or deleted.
Right to Restrict Processing. You have the right to restrict our processing of your Personal Data.
Right to Data Portability. You have right to transfer your Personal Data, when possible.
Right to Object. You have the right to object to the processing of your Personal Data that is carried out on the basis of legitimate interests, such as direct marketing.
Right Not to be Subject to Automated Decision-Making. You have the right not to be subject to automated decision-making, including profiling, which produces legal effects. Trusona does not currently engage in the foregoing on our websites or in our products and services.
If you would like to make a request and exercise your rights described above, please complete our online form.
Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (“CCPA”), effective January 1, 2020, if you are a California resident, you have rights to understand and request that we disclose how we collect, use, disclose, and sell your Personal Data to the extent permitted by applicable law. If you would like to learn about our verification process, including the details that you must provide to us to verify your request, click here.
Right to Know About Personal Data Collected, Disclosed, or Sold. You have the right to request that we disclose what Personal Data we collect, use, disclose, and sell.
Right to Request Deletion of Personal Data. You have the right to request the deletion of your Personal Data collected or maintained by us as a business.
Right to Opt-Out of the Sale of Personal Data. You have the right to opt-out of the sale of your Personal Data by us as a business, in the event we sell Personal Data.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.
Authorized Agent. You may designate an authorized agent to make a request under the CCPA on your behalf by us with a copy of your power-of-attorney document granting that right.
Financial Incentives. We do not provide any financial incentives tied to the collection, sale, or deletion of your Personal Data.
XI. How to Contact Trusona
If you would like to contact us with questions or concerns about our privacy policies and practices, you may contact us via any of the following methods:
Online Form: Click here.
Email: privacyrequests@Trusona.com
Toll-free Number (USA): 1-888-TRUSONA
Mailing Address:
Trusona, Inc.
8776 E Shea Blvd., Suite 106, #603
Scottsdale, AZ 85260
Last Reviewed 09/09/2024
