Privacy Policy and Notice

Truvantis Inc. (“Company,” “we,” “us’,” or “our”), takes privacy very seriously. We are committed to ensuring that the privacy rights of all individuals are afforded the highest levels of protection and fulfillment. This Privacy Policy details the types of personal information we collect, the purposes for that collection, disclosure details, data protection policies and practices, and the privacy rights and options you may have. This Privacy Policy applies to personal information collected through our website, services, and phone, face-to-face interaction, and any other methods of collection (collectively “Services”).

By using or accessing our website to obtain information or Services; by providing solicited or unsolicited personal information to us through any mechanism, or through otherwise using or accessing our Services, you are consenting to our use of such information, subject to applicable laws, and agreeing to the terms of this Privacy Policy. You also agree not to submit any information to us that would be subject to the private right of action for breach under the California Consumer Privacy Act, or any other sensitive or high-risk personal information.

Our Services are not directed to and we do not intend to, or knowingly, collect or solicit personal information online from children under the age of 16. In the preceding twelve months we have not sold any personal information or disclosed any personal information for a business purpose, as would be subject to the California Consumer Privacy Act.

Personal Information Collected by Truvantis

Categories of Personal Information Under California Law During the twelve months prior to the effective date of this Privacy Policy, dependent upon how you have interacted with us, we may have collected the following types of information from you, through our interactions with you and others, and from third parties:
Categories of Personal Information	Explanation
Identifiers, such as your name, address, phone number, zip code, IP address, and online identifiers (including categories of personal information described in §1798.180(e) and §1798.140(o)(1)(B) of the California Civil Code)	We may use this information to identify and communicate with you, to submit inquiries to us, and for marketing and other business purposes.
Commercial information, such as a record of your purchases and services you have obtained	We may use this information in order to provide our Sites in an individual and personalized way and for marketing and other business purposes.
Internet and electronic network activity information, such as information about your interactions with our Sites	We may use this information to better understand the visitors who come to our Sites, where they come from, and what content on our Sites is of interest to them, and for marketing and other business purposes.
Professional or employment-related information, such as your current employer and job title.	For job applicants, we may use this information to assess candidacies for potential employment with us.
Education information, such as the level of education you have achieved or the school you attend or attended.	For job applicants, we may use this information to assess candidacies for potential employment with us.
Broad geographic information, such as country or city-level location	We may use this information to improve the quality, security, and relevance of our Sites to our visitors and for other business purposes.
Other electronic information, such as information you provide to us through social media functions on our Sites	We may use this information to improve the quality, security, and relevance of our Sites to our visitors, and for marketing and other business purposes.
Inferences about you, including about your preferences and characteristics	We may use this information to provide our Sites to you in an individual and personalized way and to communicate with you regarding content and services we believe may interest you, and for marketing and other business purposes.

Categories of Business Uses of Personal Information Under California Law We use personal information we collect from you, through our interactions with you and others, and from third parties, in order to improve the products and services we provide, and for other business purposes. Below is a description of each category of business or commercial use of your personal information.
Categories of Business Uses of Personal Information	Explanation
Marketing	We may use any of the PI data we collect to market and sell our services. We may use the data we collect to personalize the marketing or sales communications that we send. These marketing communications may include advertising, and we may utilize personal information in conjunction with analyzing and managing tools for programmatic advertising campaigns to target these communications based on personal information.
Hiring	We may use any of the PI data we collect for processing and evaluating applications and related materials that are submitted by job applicants.
Legal	We may use any of the PI data we collect to detect and prevent fraud or other illegal activity, and to comply with regulations or other legal requirements.

How Your Personal Information is Collected.

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

• From publicly accessible sources (e.g., property records);
• Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
• From a third party with your consent (e.g., your bank);
• From cookies on our website; and
• Via our IT systems, including:
  • Door entry systems and reception logs; and
  • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

How To Contact Us

Truvantis Inc.

548 Market Street

San Francisco, CA 94104

privacy@truvantis.com

(855) 345-6298

California Consumer Privacy Rights

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information

You have the right to know:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information, if any; and
• The specific pieces of personal information we have collected about you.

Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
• Provide the personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose,

You have the right to know:

• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to us by your personal information.

Requests

To submit a request, contact us using the information in the How To Contact Us section above. For additional details on California consumer privacy rights see Cal Civil Code § 1798.80 et. seq.