True Organic Products, Inc and Data Controller

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data.Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact True Organic Products, Inc. (hereafter “True”)
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to True.

Mode and place of processing the Data

Methods of processing

True takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to True, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by True. The updated list of these parties may be requested from True at any time.

Legal basis of processing

True may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations True may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • Processing is necessary for compliance with a legal obligation to which True is subject;
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in True;
  • Processing is necessary for the purposes of the legitimate interests pursued by True or by a third party.

At all times, True will assist  and clarify the specific legal basis that applies to the processing, and in whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter a contract.

Place

The Data is processed at True's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by True to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with True using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:

  • Personal Data collected for purposes related to the performance of a contract between True and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of True’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by True within the relevant sections of this document or by contacting True.

True may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, True may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow True to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Interaction with external social networks and platforms and Analytics.For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

The rights of Users

Users may exercise certain rights regarding their Data processed by True.
In particular, Users have the right to do the following:

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in True or for the purposes of the legitimate interests pursued by True, Users may object to such processing by providing a ground related to their particular situation to justify the objection.Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether True is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to True through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by True as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by True in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that True may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from True at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

True reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to True. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, True shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: internet information.

True will not collect additional categories of personal information without notifying you.

How True collects information: what are the sources of the personal information it collects?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

How True uses the information it collects: sharing and disclosing of your personal information with third parties for a business purpose

True may disclose the personal information it collects about you to a third party for business purposes. In this case, True will enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

True may also disclose your personal information to third parties when you explicitly ask or authorize it to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For True  purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request True to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you would  like to know more or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact True for further information using the contact details provided in this document.

What are the purposes for which True uses your personal information?

True may also use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

True may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

True  will not use your personal information for different or  unrelated purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that True disclose:

The disclosure described above will be limited to the personal information collected or used over the past 12 months.If True delivers its response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – if this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that True delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, True will delete your personal information and use its best efforts to direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, please submit your verifiable request to True.

For True  to respond to your request, it’s necessary that True confirms your identity. Therefore, you can only exercise the above rights by making a verifiable request which must:

True will not respond to any request if it is unable to verify your identity and confirm the personal information in its possession relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request True  will typically confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

True will typically respond to your request within 45 days of its receipt. Should True require additional time to respond True will use best efforts to  explain why additional times is needed.

Our disclosure(s) will cover the preceding 12-month period.

Should True deny your request, it will explain as best it can its rationale.

True does NOT charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive.

In such cases, True  may charge a reasonable fee, or refuse to act on the request.

Stay Connected.

Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.

Join our community & receive tips on how to nourish your soil and planet and create a sustainable future!