Privacy Policy
Last Updated: November 1, 2018
We are committed to protecting the privacy of your data. This Privacy Policy explains more specifically what information TrueKonnect and its Group Companies (together, “TrueKonnect,” “we” or “us”) collect from Account Holders and End Users (“you”) through TrueKonnect’s websites and applications, which we refer to collectively as “the Service.” The Service includes the TrueKonnect App and Software. 
 
Please note, if you use TrueKonnect Free, Basic, or Premium, you are both the Account Holder and End User of an TrueKonnect service account. 
 
Although significant changes are rare, this policy may be amended as new features, technology, or legal requirements arise, so please check back from time to time. We’ll notify you if we make a significant change and, where required, seek your consent. 
 
What information does TrueKonnect collect? 
We built TrueKonnect to help you make personal, custom connections based on your profile and preferences. That means you can input, upload, or store in TrueKonnect any text, images, and other data that you choose—we refer to that information as “Content”. We also collect and receive the following types of information: 
 
Basic account information: To open your account and process payments, we collect and receive basic information like your email address, phone number and, depending on how you purchase a subscription to TrueKonnect Plus, TrueKonnect Premium or TrueKonnect Business (each a “Paid Service”), your billing address and other payment information.   
 
Usage data: We collect and log data on how you and others access and use TrueKonnect, for example, the act of selecting profile preferences. Usage data may be collected through cookies, and similar technologies. For more information, including how to opt-out, contact hello@truekonnect.com.   
  
Location information: When you use certain features of the Platform or App, including if you opt-in to use our Location Sharing feature, we may collect information about your location (e.g., IP address, GeoLocation) or more specific location information (e.g., more precise location information from your mobile device). Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device’s settings menu. We collect the IP address you use to connect to the Service, and — if you choose to share it — your location information from a mobile device. Device information. We collect information about the number and type of devices you use to connect to the Service, as well as information about the operating systems on those devices (e.g., iOS, Android, Windows). 
 
We also may link your account information with data we receive from our partners and other third parties to help understand your needs and provide you with a better experience.  For example, if you create or log into an TrueKonnect account using your Facebook credentials via single sign-on, we will have access to certain information such as your, profile photo name and email address as authorized in your Facebook profile settings. 
 
How does TrueKonnect use my information? 
We have specific rules for how and when we use the information we collect and receive. We describe these below.  
  
How do we use what we collect? 
We use, store and process your information to provide and improve our Services and ensure a secure, safe and trusted experience. For example, we may use your information to: 
  
• Provide and improve our services and enable you to access and use the TrueKonnect Services 
• Provide customer support 
• Send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you and contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorized by our Terms of Service 
• Enable the processing of transactions and send notices about your transactions 
• Improve the Services, including by personalizing or customizing your user experience 
• Measure the performance of the Services and improve our content and layout 
• Enable you to communicate with other TrueKonnect users, including by sending them messages or other information  
• If you provide us or our service providers any information relating to other people in connection with the Services, we may use and store this information to facilitate your referral invitations; send your requests for reviews, for fraud detection and prevention and for any purpose you authorize at the time of collection 
  
What does TrueKonnect do with my information? 
We are committed to protecting the privacy of your information. Below, we describe the ways in which we use the information we collect and receive to provide, maintain, and improve the Service; to provide troubleshooting and customer support; to protect the Service for all our users; to contact you; and to administer TrueKonnect paid accounts. 
 
We use a number of technologies to help you get the most out of the Service. Our systems automatically analyze your data to power TrueKonnect features and to continually improve the Service for you in a way that does not require anyone to look at your Content. This may include, for example: 
Making sure you find what you’re looking for when you search for service providers. 
Showing you information most relevant to how you are or could be using the Service at a specific time or location. 
Suggesting actions for you to take based on information you’ve stored. 
Suggesting TrueKonnect service features or products to you that we think will help you get the most out of our Service. 
Recommending people for you to follow and connect with. 
To provide troubleshooting and customer support, our Customer Support team may need to access your information, such as your account email address and information about the TrueKonnect application you are using, subject to the protections described below.   
As part of our efforts to protect your account and the functionality of the Service, our systems may analyze the emails you send to and from your TrueKonnect account and the messages you share to detect spam, malware, or other potential security concerns. If we determine that such material constitutes a Terms of Service or User Guidelines violation, we may block delivery of or remove the problematic material, much like a spam filter works for your email inbox. 
Learn more about steps you can take to protect your account, such as using strong passwords, two-step verification, and encryption. 
In accordance with your communication preferences, we’ll occasionally contact you to announce new products and features we build for you, share tips for using TrueKonnect to get more done, make special offers, and provide information about how TrueKonnect works with products and services from our business partners. 
 
Would someone at TrueKonnect ever view my Content? 
 
You have control over who sees your Content. We limit the use of your Content to make sure that no one at TrueKonnect can view it unless you expressly give us permission or it’s necessary to comply with our legal obligations. Specifically: 
 
To help refine or improve the technology, we may ask you for permission to review portions of your Content. For example, if a new feature suggests new connections relevant to your profile preferences, we may give you an opportunity to provide us feedback on how well the feature is performing along with a sample of the Content in question, so we can make sure this feature provides appropriately tailored suggestions. Such access to your Content is done only with your express permission and is subject to strict confidentiality rules and data access controls. Choosing to give us such permission is completely voluntary. 
If you contact our Customer Support team for help with specific pieces of Content in your account (for example, if you can’t find a contact you believe should match to your profile), we may ask for your temporary permission to look at your Content. This permission terminates when the issue is resolved. 
  
If we become aware of a potential violation of our Terms of Service or User Guidelines, we may suspend or close your account until the problematic material is removed. Under such a circumstance, we would only look at the Content in your account if you give us consent or if necessary to comply with our legal obligations, including to protect the safety of you or any other person. 
 
To test and improve our product offerings for our users, we use aggregated data that does not contain any personal information, does not identify any person, and cannot be connected to any specific user. This policy is not intended to apply to such anonymized/de-identified data. 
 
How does TrueKonnect share or disclose my information? 
TrueKonnect is not in the business of selling or renting your information. Here are instances when we may disclose your information — and then only the minimum information necessary: 
 
We share your information with Service Providers who process data on our behalf, such as credit card processors and customer management systems. For example, these Service Providers help us: 
Operate, develop, and improve the features and functionality of the Service 
Complete your payment transactions 
Fulfill your sales and support requests 
Communicate with you as described elsewhere in this policy 
We require these providers to agree to strict data protection requirements in keeping with our privacy policy standards, the European Union's General Data Protection Regulation ("GDPR"), and our commitments under our EU-US Privacy Shield and Swiss-US Privacy Shield certifications as discussed below.  
 
We do not share your information with any third parties for their own advertising purposes. 
 
Your Content is private unless you decide you want to share it. You may choose to share using public links or through any of the Service’s features that allow you to share or collaborate on Content (“Collaboration Features”). If you choose to share, we may need to take steps to facilitate your collaboration.   
  
In the event of a merger, sale, or reorganization of all or part of our business, information covered by this policy may be transferred in connection with that deal.   
As described on our Cookie Information page, we contract with third-party advertising networks in order to deliver relevant TrueKonnect advertisements to you across the Internet and to manage our communications with you. We do not use your Content for these purposes. In addition, we may share with partners or Service Providers a hashed identifier to serve you relevant TrueKonnect ads when you visit partners’ and providers’ websites, applications or platforms. We may, for instance, participate in the Google Adwords Remarketing, Twitter Tailored Audience and Facebook Custom Audience services. To learn more about the privacy controls that Google, Twitter and Facebook offer and honor for those respective services, please visit here for Google, here for Twitter, and here for Facebook. You may opt out of certain ad targeting and retargeting services by visiting the Digital Advertising Alliance’s opt-out page, or the Network Advertising Initiative opt-out page. 
We also may share information about you with third parties whenever you consent to or direct such sharing. This includes, for example, if you connect your TrueKonnect account with a third-party app in our App Center. 
 
How does TrueKonnect respond to legal requests for my information? 
We vigilantly protect the privacy of your account. We will not disclose your information to law enforcement or other governmental authorities unless we believe it is required to comply with warrants, court orders, subpoenas, or other lawful government requests. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards of due process. 
 
We narrowly interpret all information requests, and we only disclose Content in your account that is specifically responsive to a government warrant or where you have provided your explicit consent. In accordance with our user notice policy, we will notify you if we believe we are compelled to comply with a third party’s legal demand for your information, and we routinely push back on government orders to delay user notice that we view as overly broad.  
 
In addition, in rare cases, we may share your information as necessary to investigate or take action regarding illegal activities, suspected fraud, or potential threats against persons, property or the systems on which we operate the Service, or as otherwise necessary to comply with our legal obligations. 
 
How can I manage my information stored in TrueKonnect? 
Consistent with our first law of data protection—your data is yours—in most cases, you can manage your information simply by logging into your account and editing your information directly within the TrueKonnect service. 
 
However, if you prefer, you can contact us at to ask us to provide access to, correct, update, or delete your personal information. Please note that we may ask you for proof of account ownership and/or identity before fulfilling your request. We will comply with such requests to the extent required by applicable law or the US-Swiss Privacy Shield and US-EU Privacy Shield. 
 
A Note for our European Users about our Data Processing Grounds and Data Access Rights 
 
The European Union's GDPR requires that we provide notice in a specific way to our European users about their privacy rights. We process Account Holder or End User personal information on one of three grounds, depending on the circumstances: (i) your affirmative consent, in which case you will have the right to withdraw consent at any time; (ii) contractual necessity; or (iii) our legitimate interest in providing the Service. In addition, we are required to list the data access right available to all users in a specific way. 
 
How long does TrueKonnect store my information? 
 
TrueKonnect's mission is to make personal, focused connections between clients and beauty professionals. In order to do that, we make the Content you store in TrueKonnect readily accessible to you, until you make the decision to delete it. 
 
If you delete your Content and then sync, it will no longer be accessible to you or others who may access the Service. The TrueKonnect service’s back-up systems may retain residual copies of your deleted Content for up to one year due to the nature of those systems’ operations. 
 
TrueKonnect provides you with features that allow you to communicate and connect with other users. Please note that deleting your copy of these communications (such as messages) won't delete copies existing in the accounts of people you were interacting with. 
 
For users who are inactive for extended periods of time, we may close your account to satisfy our obligations under applicable law, and in accordance with our data retention policy. If that happens, we will try to notify you before taking any action. 
 
What happens if I want to stop using TrueKonnect? 
 
As described above, you can delete your Content at any time, and you can stop using the TrueKonnect service at any time. And as we promise in our third law of data protection, your data is portable. You can export your notes at any time, as explained here. 
 
What happens if TrueKonnect closes my account? 
 
If TrueKonnect deactivates your account due to a TOS violation, then you may contact us to request deletion of your Content, and we will evaluate such requests on a case by case basis, pursuant to our legal obligations. 
 
Where does TrueKonnect store my information? 
When you use TrueKonnect Software on your computing device, such as by using our downloadable application, some of your data will be stored locally on that device. 
 
When you sync your computing device with the Service, that data will be replicated on servers maintained in the United States. This means that if you store information in or submit data to the TrueKonnect website or TrueKonnect Software and sync such TrueKonnect Software with the TrueKonnect service, you acknowledge your personal information will be transmitted to, hosted, and accessed in the United States. 
 
Data privacy laws or regulations in your home country may differ from, or be more protective than, those in the United States. We will collect, store, and use your personal information in accordance with this Privacy Policy and applicable laws, wherever it is processed. 
 
Which TrueKonnect company is my data controller? 
 
If you live in the United States and Canada, your data controller is TrueKonnect (headquartered in Arizona). 
 
How does TrueKonnect comply with data transfer rules? 
If you are a resident of the European Economic Area (“EEA”) or Switzerland, please note that we use standard contractual clauses approved by the European Commission to transfer your personal Information from the EEA or Switzerland to the United States and other countries. 
 
In addition, TrueKonnect follows compliance with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from EU member countries and Switzerland. 
 
How can I contact TrueKonnect? 
 
TrueKonnect welcomes your feedback regarding this Privacy Policy. If you have questions, comments or concerns about this Policy, please contact us by email at hello@truekonnect.com.  
  
GLOSSARY 
Account Holder means the person or entity who has contracted with TrueKonnect as either an individual Basic, or Premium user or as a Customer as defined in our TrueKonnect Business Agreement. 
Collaboration Features means any of the Service’s features that allow you to share or collaborate on Content. 
Content means the text, images, and other data you choose to input, upload, and store in TrueKonnect. 
End User means the individual who uses an account on the TrueKonnect service. 
 

Teresa Young
Founder of True Konnect
Copyright 2019 - Teresa Young, TrueKonnect - All Rights Reserved
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