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”)
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.
True may process Personal Data relating to Users if one of the following applies:
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.
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.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
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 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”.
Personal Data is collected for the following purposes and using the following services:
Users may exercise certain rights regarding their Data processed by True.
In particular, Users have the right to do the following:
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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