Privacy Policy

Last Updated: 7/7/2016


STATEMENT:

This Privacy Policy explains how TrueChoice Solutions, Inc. (“TCS”) collects Personal Data (defined below) via any and all Websites associated with TCS (a “Site” or collectively the “Sites”).  The Sites post or link directly to this Privacy Policy (or via offline means) and include both Websites created and/or maintained by TCS as well as Websites created, maintained and/or sponsored by TCS service providers.  This Privacy Policy also explains how TCS protects such data and the choices you have concerning TCS’ use of such data.

Please read this Privacy Policy carefully.  TCS may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. Please review the “LAST UPDATED” legend at the top of Site’s Privacy Policy Webpage to determine when this Privacy Policy was most recently revised.

For the purposes of this Privacy Policy, “TrueChoice Solutions”, “TCS”, "we", "us", and "our" means TrueChoice Solutions, Inc.

You do not have to provide us with any Personal Data to visit a Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of a Site.

Types of data collected:

We gather Personal Data and Other Data (as described below).

Personal Data definition:

Personal data is information that identifies you or can be used to identify or contact you; e.g., your name, email address, work or home address, or phone number ("Personal Data").

Other Data definition:

Other data is information that identifies the method by which you are connecting to the Site and information about your interaction with the Site ("Other Data").

Collection of Personal Data:

  • TrueChoice Solutions may collect Personal Data voluntarily provided by you, including in emails to a Site, online forms, online applications, surveys, promotion participation, or through offline means.
  • TrueChoice Solutions collects offline information through various means. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in a Site’s or Sites’ products and/or services. If we acquire such a list for use, we seek to obtain appropriate representations from the other party that the listed individuals have opted in to receiving promotional messages from any acquirer of such list.

Use of Personal Data collected:

We may use Personal Data for the following purposes:

  • Fulfillment of Requests. TrueChoice Solutions may use Personal Data about you to deliver products and services and/or provide you with information about products and services you’ve ordered.
  • Other Communications. From time to time, a Site may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If you would prefer that we not send electronic marketing messages to you, please see the "Your Choices" section below.
  • Promotions. We ask you for certain Personal Data when you enter and, if applicable, win a Promotion. You should carefully review the rules of each Promotion in which you participate, as they may contain additional important information about our use of Personal Data about you. To the extent that the terms and conditions of such rules concerning the treatment of Personal Data about you conflict with this Privacy Policy, the terms and conditions of such rules shall control.
  • Incentive Programs fulfillment. We ask you for certain Personal Data when you wish to claim an incentive for interacting with the Site. Such Personal Data is used to verify your eligibility to claim such an incentive and in order to fulfill the delivery of such an incentive.
  • Internal Business Purposes. We may also use Personal Data about you for our internal business purposes, such as data analysis, customer support, customizing and improving the content and layout of a Site, development of marketing and promotion plans and materials, statistical analysis of user behavior, product development, administering individual accounts, and meeting government regulatory requirements.
  • Administrative Communications. TrueChoice Solutions reserves the right to use Personal Data to send to you important information regarding a Site or Sites, your account status, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of a Site. Because this information may be important to your use of a Site, you may not opt-out of receiving such communications.

Collection and use of Other Data:

  • Monitoring Data: TrueChoice Solutions and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, location information, and other statistical data involving the use of a Site ("Monitoring Data"). We use Monitoring Data to help us understand who uses a Site and to improve and market it. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
  • Aggregated Data: Additionally, we may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site; for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.
  • TrueChoice Solutions uses cookies and Tool technologies (defined below) to understand how a Site is used and to customize and enhance the Internet experience of individual users. When you revisit a Site, TrueChoice Solutions may recognize you by a Tool and customize your experience. We believe cookies and Tool technologies add value to the user experience.
    • Cookies: To enhance the Internet experience on the Site, TrueChoice Solutions and our service providers may use ‘cookies’ on the Site. Cookies are data that a web server transfers to an individual's computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users' ongoing access to and use of a Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie or cookies from a particular web site to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about the procedure you are required to follow in order to disable cookies can be found on your Internet browser provider’s web site. We expect our service providers to honor any decision by you to block or disable cookies in connection with the Site.
    • Tools: We and our service providers may also use various common Internet tools such as “Flash,” “JavaScript,” or similar technologies (together, "Tools") in connection with Site pages and email messages in certain formats to among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened.
  • IP Addresses: When you visit and interact with the Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how the Site is used by our users and to improve the Site. Where required by applicable law, IP addresses will be treated as Personal Data.

Disclosure of Personal Data collected:

We may disclose Personal Data for the following purposes:

  • Third-Party Service Providers. We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, data analysis and services of an administrative nature.
  • Affiliate Communications. TrueChoice Solutions may transfer Personal Data among our affiliates to allow our affiliates to contact you regarding products, programs, services and promotions that they believe may be of interest to you, and such affiliates may otherwise use your Personal Data in accordance with this Privacy Policy. If you would prefer not to receive marketing communications from TrueChoice Solutions or our affiliates, please see the "Your Choices" section below. TrueChoice Solutions, Incorporated will be the party responsible for jointly used Personal Data.
  • Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with TrueChoice Solutions to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded web sites (“co-branded pages”). Any information, including Personal Data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners. By selecting an application or providing your information on these co-branded pages, or by signing up to receive information about or download a Jointly Offered Item, you also consent to our providing Personal Data about you to those third parties. You should check these third parties’ web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.
  • Promotions and Incentive Programs. We may share the Personal Data you provide in connection with Promotions and/or Incentive Programs with third-party sponsors of such Promotions and/or Incentive Programs (irrespective of whether such Promotions and/or Incentive Programs are hosted by us), or otherwise in accordance with the rules applicable to those Promotions and/or Incentive Programs.
  • Assignment. We may transfer any and all Personal Data that we collect to an affiliated entity or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
  • Law enforcement; emergencies; compliance. We may disclose Personal Data about you to others as we believe to be appropriate: (a) in compliance with laws, rules, or regulations in any country in which TrueChoice Solutions operates; (b) to comply with legal process; (c) to respond to requests from government or public authorities; (d) to protect our operations or those of any affiliated entities; (e) to protect the rights, privacy, safety or property of TrueChoice Solutions, its affiliated entities, you, or others; and (f) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.

Your choices:

We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. 

  • If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by sending an e-mail to unsubscribe@truechoicesolutions.com.
  • If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an e-mail to unsubscribe@truechoicesolutions.com.

We will comply with your request(s) as soon as reasonably practicable. Please note that if you exercise the second option as described above, we will not be able to remove your Personal Data from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Data (i.e., to which we have already provided your Personal Data as of the date that we implement your request). Further, please note that requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing-related emails from TrueChoice Solutions. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.

If we intend to use your Personal Data for a purpose that is incompatible with the purposes detailed in this Privacy Policy, or if we intend to disclose it to a type of third party not previously identified, we will notify you and offer you the opportunity to opt-out of such uses and/or disclosures.

How you can access, change or suppress your Personal Data:

Should you like to review, correct, update, suppress, delete, or otherwise limit our use of your Personal Data that has been previously provided to us, you may make a request by contacting us using the information provided in the “Contact Information” below. We will comply with your request as soon as reasonably practicable and consistent with applicable law.

Links:

A Site may contain links to other web sites, including social media sites. Linked sites are not under TrueChoice Solutions’ control and we are not responsible for the privacy practices or the contents of the linked site. We provide links only as a convenience, and TrueChoice Solutions does not endorse or control, and is not responsible for, the privacy practices or the content of these linked sites.

If you provide any Personal Data through any third-party web site, your transaction will occur on that third party's web site (not a Site) and the Personal Data you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES THAT DO NOT POST OR LINK DIRECTLY TO THIS PRIVACY POLICY.

Security measures:

TrueChoice Solutions has established reasonable organizational and technical measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. If you have reason to believe that your interaction with us is no longer secure, please notify us of the problem immediately by contacting us using the information provided below in "Contact Information.”

Data integrity:

TrueChoice Solutions will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Privacy Policy, or authorized by you. TrueChoice Solutions will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you). TrueChoice Solutions depends on you to update or correct your Personal Data whenever necessary.

Retention period:

We will retain Personal Data about you for the period reasonably necessary to fulfill the purposes outlined in this Privacy Policy and consistent with retention periods required or permitted by law.

Cross border transfer of Personal Data:

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using this Site or sharing Personal Data with us, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country.

Enforcement:

TrueChoice Solutions will periodically review its compliance with this Privacy Policy. TrueChoice Solutions will also review and respond to any formal written complaints that we receive from you. Please contact us at the address listed below in “Contact Information.”

Use of a site or sites by minors:

Sites are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through Sites.

Sensitive personal data:

We request that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, racial or ethnic origin, political views, religious beliefs) on or through this Site or otherwise to us.

Contact information:

Any questions or concerns regarding TrueChoice Solutions data security practices should be addressed to:

Security and Compliance Department
TrueChoice Solutions, Inc. 
150 East 52nd Street, Floor 11
New York, NY 10022
Phone: +1 (212) 660-0300 ext. 3922
E-mail: privacy@truechoicesolutions.com

If you choose e-mail the department, please mark the subject heading of your e-mail as “Privacy Policy Question” or, if applicable, “Personal Data update request”.