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TruRating Global Privacy Notice

 

FOR CONSUMERS

At TruRating we are passionate about consumer privacy and we are fully committed to protecting the anonymity and privacy of every consumer that uses our services.

This policy details the data we collect, how we collect it, what we do with it and what controls you have.

This Global Privacy Notice (together with our website terms of use and any other documents referred to in it) sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your data and how we treat it.

This Global Privacy Notice may be amended from time to time if our practices change. Any changes we may make to this Global Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Global Privacy Notice.

We adhere to the UK General Data Protection Regulation (UK GDPR), the European Union General Data Protection Regulation (EU GDPR), the Australian Privacy Act 1988 and relevant United States privacy legislation.

1. WHO ARE WE?

TruRating Limited is a company registered in England and Wales which together with its subsidiaries is part of the TruRating group of companies (collectively referred to as “TruRating” or “we” or “us” in this policy).

2. WHAT DO WE DO?

We use the point of purchase – however customers buy, in-store and/or online – and/or through followup emails and texts after interacting with a retailer – to ask each customer a single question out of a rotated set. We use the responses to those questions to help both consumers and businesses to make better, data driven, decisions.

The data we collect is only useful and valuable if it can be trusted – if there is no way in which consumers could have been influenced to answer the questions in a certain way. The anonymity of consumers is therefore both fundamental to the value of the data we collect as well as our belief in the rights of the consumer to privacy over their own data.

3. DATA COLLECTION AND USE

3.1 IF YOU USE OUR WEBSITE

We collect and process personal data through our website and services, including but not limited to:

  • session information (IP address, browser, device etc.).

The information we collect includes the use of our website and how you arrived at our website in the first place (please see our Cookie Policy on TruRating.com for more detail). We will not collect any information about you without your consent.

3.2 IF YOU ANSWER ONE OF OUR QUESTIONS ONLINE OR INSTORE

When you enter a rating or answer a single question in store or online we store the question we asked and the response that you gave. We link this to the details of the transaction that you made which may include the date and time, the total amount that you spent, the items that you purchased and your method of payment. If you made the transaction in store then we also collect the name and location of the store and the till where you were served. If you made the transaction online then we collect the website that you came from and the broad location (city or county level) derived from the IP address. If you choose to add additional comments to your rating when or after you rate then we will also hold those comments.

We receive the detailed transaction data that we link to the rating from the merchants that make use of the TruRating service. They share this data with us in accordance with their own privacy policies and lawful reasons for processing and sharing the data.

We do not knowingly collect or accept any data that would allow us to identify you (e.g. name, address, email, social log ins, phone number, date of birth etc) and we never share your data at an individual level that would allow anyone else to identify you using other data that they might hold about you. Nobody will ever be able to contact you or treat you differently because of a rating that you gave.

We use the responses that you and other consumers give to provide aggregated and anonymous consumer insights. Businesses use this insight to measure and improve areas such as customer service, store operations, product display and marketing effectiveness.

We also use the aggregated insight to provide an online service to consumers who can search for and find feedback on businesses that they are considering using.

In certain situations, we may ask questions that are relevant to products you are purchasing or other aspects of your transaction such as your loyalty membership. In all such cases, we maintain the privacy of each individual and the anonymity of your response.

We do not ask or allow our clients to ask questions of consumers that we believe they would be uncomfortable answering or that would reveal sensitive data about them.

4. GDPR, LAWFUL PROCESSING AND LEGITIMATE INTEREST

Under GDPR definitions the data we collect is pseudonymous. This means we must still consider the data you provide as personal data and we must ensure that the way in which we process it is lawful as defined by GDPR.

We process the data that you provide to us under the lawful reason of legitimate interest.

This means we have a genuine and legitimate reason to process your data and that we can show we are not harming any of your rights and interests when we process your data in this way.

When we process your data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

5. OTHER MARKETS – PRIVACY LEGISLATION

For markets where privacy legislation other than GDPR applies, all data we process is deidentified and therefore outside of the purview of these privacy regulations.

6. SHARING YOUR INFORMATION

We will only disclose any information you’ve shared with us to third parties or individuals when obliged to by law, for purposes of national security, taxation and criminal investigations.

We will never share your individual rating or transaction data with anyone else for any other reason. This means that while we will use your data with responses from other consumers for analytics and market research we will never use it or share it for the purposes of direct marketing to you or the differentiation of any services you might receive from any merchant.

7. RETAINING YOUR INFORMATION

We hold the rating that you provide for only as long as is necessary for each purpose we use it. This period will normally be for seven years after you provided the rating, unless we have a good reason to keep your information for a longer period. This is based on any legal, regulatory or business reasons we may have to retain your information.

8. INTERNATIONAL DATA TRANSFERS

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information was originally collected, including the United States of America.

We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area (“EEA”) or Switzerland.

9. HOW DO WE PROTECT YOUR INFORMATION?

We hold your personal information in a combination of electronic and hard copy files. We may store your personal information with a third party data storage provider.

We take all reasonable steps to ensure that the information we hold is protected from misuse, interference and loss, and unauthorised access, modification or disclosure by the use of various methods, including secure storage. Where we store your information with a third party data storage provider, we require them to keep it secure and only use or disclose it for the purpose for which it was provided.

Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information that we hold.

We will only keep information about you for as long as we need for the purpose for which it was collected and we take steps to ensure that any third party to which we have disclosed your information does the same.

10. HOW TO CONTACT US

If you have any questions or comments about this Global Privacy Notice, TruRating’s privacy practices or if you would like us to update information or preferences you provided to us, please email us at: [email protected] ; or write to us at:

Privacy Officer
TruRating Limited
Pendragon House
65 London Road
St. Albans AL1 1LJ UK

You can ask for access to your personal information that we have about you. We ask that you put your request in writing and provide proof of identity. It may take up to 40 days for us to respond and sometimes we will not be able to provide you with the information, in which case we will give you a written notice explaining why.

If you think that any personal information we hold about you is inaccurate, incomplete, out–of–date or irrelevant, you may ask us to correct it. We will take reasonable steps to correct it unless we disagree with your reasons. If we refuse to correct your personal information we will give you a written explanation why.

If you are a California resident, California Civil Code Section § 1798.83 permits users of our website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

11. WHO SHOULD USE TRURATING?

TruRating is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or through our website. We do not knowingly collect personal information from children under 13.

If you are under 13, do not use or provide any information on our website or on or through any of its features/register on the website, use any of the interactive or public comment features of our website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

With thanks,

The TruRating Team

 

FOR BUSINESS

At TruRating, we are passionate about data privacy, and we are committed to protecting your privacy and ensuring you have a positive experience on our website and while using our services.

This policy details the data we collect, how we collect it, what we do with it and what controls you have.

This Global Privacy Notice (together with our website terms of use and any other documents referred to in it) sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your data and how we treat it.

This Global Privacy Notice may be amended from time to time if our practices change. Any changes we may make to this Global Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Global Privacy Notice.

We adhere to the UK General Data Protection Regulation (UK GDPR), the European Union General Data Protection Regulation (EU GDPR), the Australian Privacy Act 1988 and relevant United States privacy legislation.

1. WHO ARE WE?

TruRating Limited is a company registered in England and Wales which together with its subsidiaries is part of the TruRating group of companies (collectively referred to as “TruRating” or “we” or “us” in this policy).

2. WHAT WE DO

We use the point of purchase – however customers buy, in-store and/or online – and/or through followup emails and texts after interacting with a retailer – to ask each customer a single question out of a rotated set. We use the responses to those questions to help both consumers and businesses to make better, data driven, decisions.

The data we collect is only useful and valuable if it can be trusted – if there is no way in which consumers could have been influenced to answer the questions in a certain way. The anonymity of consumers is therefore both fundamental to the value of the data we collect as well as our belief in the rights of the consumer to privacy over their own data. You can find out more about our services here.

3. DATA COLLECTION AND USE

We collect and process personal data through our website and services, including but not limited to:

  • personal identification information (name, email address, phone number, etc.);
  • business information (company name, address, etc.);
  • session information (IP address, browser, device etc.);
  • transaction information (purchase details, feedback, etc.);
  • other information relevant to the provision of your TruRating service.

The information we collect includes the information you give us, the information we acquire from third parties and that which is generated by you – including your use of our website and how you arrived at our website in the first place (please see our Cookie Policy on TruRating.com for more detail). We will not collect any information about you without your consent; however, where you have given us or generated the information, your doing so will constitute your consent to our collection of that information.

3.1 WHY DO WE COLLECT THE INFORMATION AND HOW DO WE USE OR DISCLOSE IT?

We collect, hold, use and disclose your information:

  • to provide and contact you about, your nominated TruRating service;
  • to develop and enhance our products and services;
  • to detect and prevent fraudulent activity;
  • to conduct research and to plan and develop our product and marketing strategies;
  • to operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of and optimising our advertising; analysing our products, services, websites, mobile applications and any other digital assets; facilitating the functionality of our websites, mobile applications and any other digital assets) and performing accounting, auditing, billing, reconciliation and collection activities;
  • evaluate your interest in employment and contact you regarding possible employment with TruRating;
  • enforce our Website Terms of Use or other legal rights;
  • as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over TruRating or its affiliates;
  • comply with industry standards and our policies;
  • to promote and market products and services of ours and our TruRating partners; and
  • to comply with our legal obligations.

3.2 HOW CAN YOU WITHDRAW YOUR CONSENT OR REQUEST NOT TO RECEIVE DIRECT MARKETING?

If the above conditions apply, you can withdraw your consent to our collection, use and disclosure of your personal information at any time by sending us an email at [email protected]. We will action your request as soon as we reasonably can. However, we may not be able to continue to provide the nominated TruRating service to you.

If you’ve previously indicated to us that you’d like to hear about TruRating, we may contact you by post, telephone, email or SMS. You can change your preferences / unsubscribe at any time – just send us an email – [email protected]. We’ll action your request as soon as we reasonably can.

3.3 WHEN MIGHT WE DISCLOSE YOUR PERSONAL INFORMATION?

We share your personal information with:

  • companies who work on our behalf to provide your nominated TruRating service;
  • companies within the TruRating group;
  • government, law enforcement agencies, the courts and regulatory bodies when legally obliged to; and
  • if you have given TruRating feedback to pass to a third party such as via a feedback or followup form created by TruRating for a third party and controlled by that third party, or by agreeing to follow a link to a third-party customer feedback form, we will give your feedback and any personal data you have provided to that third party. In such cases, the third-party’s privacy policy shall apply, and they may contact you or use your personal data in accordance with their policies.

4. OUR TECHNOLOGY PARTNERS

We utilize HubSpot, Salesforce and Outreach as our Customer Relationship Management (CRM) tools to collect, store, and process data. These tools assist us in managing our interactions with you and improving our services. The privacy policies for these services can be found at:

6. DATA PROCESSING THROUGH OUR TECHNOLOGY PARTNERS

We also process data in accordance with the terms and conditions of our technology platforms. These platforms include, but are not limited to, HubSpot, Salesforce, Outreach, and any other technology partners we may work with to deliver our services. For detailed information on the terms and policies of our technology platforms, please refer to the following:

8. DATA SECURITY

We hold your personal information in a combination of electronic and hard copy files. We may store your personal information with a third party data storage provider.

We take all reasonable steps to ensure that the information we hold is protected from misuse, interference and loss, and unauthorised access, modification or disclosure by the use of various methods, including secure storage. Where we store your information with a third party data storage provider, we require them to keep it secure and only use or disclose it for the purpose for which it was provided.

Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information that we hold.

9. DATA RETENTION

We will only keep information about you for as long as we need for the purpose for which it was collected and we take steps to ensure that any third party to which we have disclosed your information does the same.

We retain to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements.

10. INTERNATIONAL DATA TRANSFER

TruRating operates globally. As such, your information may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different from the laws of your country. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area (“EEA”) or Switzerland.

11. YOUR DATA PROTECTION RIGHTS

Depending on your location, you may have the following rights regarding your personal data:

  • The right to access – You have the right to request copies of your personal data.
  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you be
  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • The right to erasure – You have the right to request that we erase your personal data, under certain conditions where it is no longer necessary for the purposes for which it was collected, or you have withdrawn your consent and there are no other legal grounds for processing.
  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions such as contesting the accuracy of the data or when processing is unlawful.
  • The right to data portability – You have the right to request a copy of your personal data in a structured, machine-readable format and to transmit that data to another controller where technically feasible.
  • The right to object – You have the right to object to the processing of your personal data, under certain conditions such as direct marketing or where processing is based on legitimate interests.
  • Rights related to automated decision making and profiling – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you, unless it is necessary for entering into or performing a contract between you and us, or you provide explicit consent for this.

12. COMPLAINTS

If you believe that we have not complied with your data protection rights, you have the right to lodge a complaint with a supervisory authority, which may be the Information Commissioner’s Office (ICO) in the UK, the Data Protection Authority in your country of residence within the EU, or the relevant authority in the US or AUS.

13. HOW TO CONTACT US

If you have any questions or comments about this Global Privacy Notice, TruRating’s privacy practices or if you would like us to update information or preferences you provided to us, please email us at: [email protected] ; or write to us at:

Privacy Officer
TruRating Limited
Pendragon House
65 London Road
St. Albans AL1 1LJ UK

You can ask for access to your personal information that we have about you. We ask that you put your request in writing and provide proof of identity. It may take up to 40 days for us to respond and sometimes we will not be able to provide you with the information, in which case we will give you a written notice explaining why.

If you think that any personal information we hold about you is inaccurate, incomplete, out–of–date or irrelevant, you may ask us to correct it. We will take reasonable steps to correct it unless we disagree with your reasons. If we refuse to correct your personal information we will give you a written explanation why.

If you are a California resident, California Civil Code Section § 1798.83 permits users of our website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

14. WHO SHOULD USE TRURATING?

TruRating is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or through our website. We do not knowingly collect personal information from children under 13.

If you are under 13, do not use or provide any information on our website or on or through any of its features/register on the website, use any of the interactive or public comment features of our website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

With thanks,

The TruRating Team

LAST UPDATED: JULY 2024

Cookie Privacy Policy

We’re quite excited by our new website and will be making continual revisions to it to try and better it as we go. We want to see how many people have found us and where they’ve come from, and so Google Analytics can help us do that with their cookie technology. We use Google Analytics to better understand how our customers navigate to and through our websites, how long people spend visiting our content items, how often they return to visit our websites and what demographic categories (age, gender, interests) they fall into.

Google Analytics uses cookies to collect this information and this information helps us to improve our websites. If you would rather not be part of Google Analytics – you can always download their Google Analytics Opt-out Browser Add-on from here or check out Google’s privacy policy for further info.

Cookies are small data files that are sent to your browser from a website you visit. They are stored on the device (such as your computer’s hard drive, your mobile phone or your tablet) that you are using to access the Internet.

We use a variety of cookies, as they perform different functions, from remembering that you are logged in during visits to what your screen name is. They also help us to identify which of our web pages are the most popular and what type of journey a visitor has through our site. They help us to arrange the content and layout of our site, and recognise computers that have been to our site before. They therefore play an important role in helping us to enhance your experience when browsing our website.

We also use web beacons to help us understand how you engage with our emails, and to tailor their content so that it is relevant to you. We use a company called SendGrid to help us with our emails. They use web beacons – tiny transparent images in an email – to see if an email has been opened. We use web beacons together with cookies to help us understand how you interact with our websites and the emails we send you. This is to help us improve your browsing experience, to ensure that content is relevant to you and to better manage our website and email content. You can find SendGrid’s privacy policy here.

If you are a registered TruRating merchant or TruRating partner, we may link information about your website activity or usage with your account information. This information provides us with statistics that we can use to analyse and improve our websites and our products and services. We do this with the use of session cookies.

You can control your cookies and delete them. How to do it will depend on the browser you use. We like this website – http://www.aboutcookies.org/ – which is run by the lawfirm Pinsent Masons which will help you better understand the cookies on your device. What’s more, they have the World’s Best Cookie Recipe!

Please remember, if you do delete all your cookies, some features of our websites, such as remembering your login details, will not work and your experience on our websites may be affected.

As always, let us know if you have any questions and we’re always happy to help – [email protected].