PRIVACY POLICY

Last Updated: June 28, 2019

1. OUR SERVICE

Hi there, we are Trunkd Corp. (“Trunkd Corp. “we”,“us”, or “our”), the creators of Trunkd, which is a virtual smart phone system that helps you manage, handle and route incoming calls and SMS messages, amongst other things (“Trunkd”, the “Platform”, the “Trunkd Platform” or the “Service”).

2. ABOUT OUR PRIVACY POLICY

This Privacy Policy applies to your access and use of Trunkd. We take great care to protect your private and personal information under applicable legislation. Before you start using Trunkd, please take a moment to carefully read and understand our Privacy Policy, which tells you what personal information we collect about you, how we use that personal information, how this information may be shared, and what choices and rights you have with respect to this information.

We are headquartered in Toronto, Canada and our Platform is provided to you by Trunkd Corp. If you are a resident of the European Union (“EU”), Trunkd Corp. is the controller of your personal data for the purposes of the EU data protection legislation.

This policy was originally written in English. To the extent a translated version conflicts with the English version, the English version governs. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through our Platform.

If you have questions or comments about this Privacy Policy, please contact us at: support@trunkd.co

3. WE COLLECT, USE, SHARE AND OTHERWISE PROCESS INFORMATION

We rely on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

as necessary to provide the Service and fulfill what we promised in our Terms of Service. For example, we cannot route a call to your personal mobile phone number, if we do not collect and use your personal information and disclose it to our third-party call routing provider;
where you have consented to the processing of your information;
where necessary to comply with a legal obligation, such as a court order or to exercise or defend legal claims;
to protect your vital interests, or those of others, such as in the case of emergencies;
where you have made the information public;
where necessary in the public interest; and
where necessary for the purposes of our or a third party’s legitimate interests, such as those of our service providers and partners.

4. OUR LEGITIMATE INTERESTS

The legitimate interests of Trunkd Corp. and our third-party service providers and partners include:

providing and improving the Platform. We do so as it is necessary to provide the Platform to you, and to keep developing and improving our Service.
Keeping the Platform safe and secure. We do so as it is necessary to ensure the Platform is secure, and to protect against fraud, spam and abuse, etc.

5. INFORMATION WE COLLECT ABOUT YOU

When you use Trunkd, we collect various types of information about you. Some of this information like email address, can be used to identify you (“Personally Identifying Information” or “PII”), and some of this information, like activity and log data, cannot be used to identify you (“Non-Personally Identifying Information” or “Non-PII”).

The amount and type of personal information we ask for depends on the nature of the interaction. We will only collect such information as is necessary or appropriate to fulfill the purpose of your requested interaction with Trunkd.

We collect information in a few different ways, including information that you entered when you sign up for an Account and configure or customize Trunkd, from third parties (for example, and if applicable, if you choose to log in with a third-party single-sign-on such as Google), and automatically when you use the Platform (for example, when you navigate within Trunkd).

Information you provide us

We collect information that you provide us, including:

Account and profile information:We collect information you provide us to sign up for an account, such as your name, email, username and password, physical address, phone number, etc.
Content you submit: We collect information and content that you submit to the Platform, such as when you create and customize an Interactive Voice Response greeting.
Payment source information:We collect certain information in order to process your Subscription payment, such as billing address and payment details (credit card, Paypal information, etc).
Communications:When you communicate with us (via email, etc.), we store a copy of your communications.

Such information is generally considered to be personally identifying information.

Information from third parties

We collect information that third parties provide us, including information from other platforms, publicly available information, and information from our service providers. The information we receive from these other platforms for log in or sign up purposes will generally be considered Personally Identifiable Information.

Other Platforms: If available, Trunkd may allow you to sign up and log in to the Platform using accounts that you have created with third-party platforms, such as Google. If you access Trunkd with a third-party account, we will collect information that you have agreed to make available, such as your name, email address, public profile information, etc. This information is collected by the third-party account provider and is provided to us under their privacy policies. You can generally control the information that we receive from these sources using the privacy settings in your third-party account.
Publicly available information: We may collect information that you make available to the public, such as when you make an Instagram post about Trunkd on your public Instagram page.
Service Providers: We may receive information about you from our service providers. For example, Twilio may provide us with information on the duration of your phone call, or Stripe may provide us with your updated creditworthiness or ability to pay.

Information automatically collected when you use the Services

We collect certain information automatically whenever you use the Services:

Website activity: We collect information about your use of the Platform, including your addition of registered phone numbers or emails, the frequency of incoming calls, incoming call numbers, the duration of calls, etc.
Device information: We also collect information that your device provides us in connection with your use of the Platform, such as your desktop device type, system language, mobile carrier, browser type, IP address, etc.

Cookies and similar technology:We use cookies in connection with your use of the Platform to collect information related to what you see and interact with. Cookies are small files placed on your hard drive that assist us in providing our services. We may use cookies to collect usage information, determine our total audience size and traffic and determining which areas of the Platform are of greatest interest to users.

Web Beacons/Pixel Tags. These are invisible tags placed on certain pages of our Website. When you access our Website, pixel tags generate a notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous website visit. We may use web beacons to recognize users and access traffic patterns.

6. USE OF INFORMATION

In general, we use both Personally Identifiable Information and Non-Personally Identifiable Information in order to administer, operate and provide Trunkd to you.

Here are some of the ways that we use your information:

How we use your Personally Identifiable Information

troubleshooting technical issues that you encounter;
to analyze, evaluate and improve the functionality and experience of our Platform. For example, we use crash reporting to be able to fix issues promptly.
to respond to customer service inquiries when you contact us;
to prevent fraud and to maintain a quality experience for our business purposes or legal reasons;
to enforce our Terms of Service and Privacy Policy;
to provide you with system or administrative messages relating to the Platform;
to let you know about new features or updates to our Terms of Service or Privacy Policy;
to send you information about your relationship or transactions with us;
to send you marketing communications (where you have opted-in to receive such messages);
to administer surveys, contents or promotions (to the extent that you have opted-in to participate in these).

How we use your Non-Personally Identifiable Information

to analyze, evaluate and improve our Platform functionality and experience. For example, we may use crash reporting to be able to fix issues promptly and analytics to gain insight into what actions you are taking within Trunkd
to personalise your Trunkd experience

Aggregated Statistics. We may also de-identify or aggregate the information collected in connection with the Platform, in ways that do not personally identify you. From time to time, we may use this non-identifying aggregated information to perform statistical analyses of user behavior and demographics in order to measure the interest in and use of Trunkd, or to publish trends such as number of downloads, number of active users, etc.

Any use of your information that is incompatible with these uses will be disclosed to you in advance so that you may opt out of such uses at your discretion.

7. SHARING YOUR INFORMATION

We will not rent or sell your information to anyone. If any of your information is shared or disclosed to third parties, it will only be so that we can provide you with the full suite of our Services.

We share your information in the following ways:

Service Providers. We may share your information with third parties who provide services to us, such as AWS for database hosting, application hosting, text-to-speech for interactive voice response, email delivery, and file hosting, Google Cloud for speech-to-text transcription, maps and directions generation, Twilio for phone number acquisition, call handling and routing, and SMS handling and routing, payment processing solutions by Stripe, analytics and reporting by Google Analytics, etc. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. Except as otherwise stated in this Privacy Policy, these third party service providers are required not to use your information other than to provide the services requested by us.

Legal Requests. We cooperate with law enforcement inquiries and demands for information that are made under force of law. Therefore, we may disclose your information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), in accordance with the applicable law (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, in accordance with the applicable law (c) as otherwise required under any applicable law.

We may also disclose your information if we determine in good faith that disclosure is reasonably necessary or appropriate to protect the property rights of Trunkd Corp., third parties, yourself or the public at large.

Related Business Affiliates. We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regards to your information.

Sale of Business. If we become involved in a business merger, acquisition, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction. If we do this, such disclosure will be subject to confidentiality arrangements that are typical of such transactions.

We do not share your information with third parties for promotional purposes unless you have opted-in to such disclosure. If you have opted-in to have your information shared, you may choose to opt-out from receiving further communications from any third party that is not our agent or service provider at any time by contacting the marketing partner/affiliate directly.

FAQ.If you send us a request for information or support in relation to our Services, we reserve the right to publish the content of your request (with any PII removed) for the purposes of clarifying our Service for other users (e.g. in a “FAQs” section).

8. PROTECTING YOUR INFORMATION

We strive to protect your information. We use commercially reasonable administrative, technical, and physical measures to safeguard your information in our possession against loss, theft and unauthorized use, disclosure or modification. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. For data transmission security, we use standard encryption protocols (TLS/HTTPS) for transmission of information. The encryption process protects your information by scrambling it before it is sent to us from the Platform. Our hosting service providers for our database and application are reputable third-party hosting service providers whose privacy, security, transparency and industry-specific standards are best-in-class. Our systems and databases are backed up regularly to help protect your information in case of an incontrollable catastrophe.

Unfortunately, no data transmission over Trunkd and the internet and no storage of data can be guaranteed to be 100% secure. Therefore, while we strive to make all reasonable efforts to use commercially acceptable means to protect your information, we cannot warrant the security of any information you transmit to us, and you acknowledge that there is always some risk when transmitting information to us through the Services.

9. DATA RETENTION

Information associated with your account will generally be kept until it is no longer necessary to provide the Service or until you ask us to delete it or your account is deleted, whichever comes first. We may however retain information from deleted accounts to comply with the law, to prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will, of course, be subject to this Privacy Policy.

Information about you that is no longer necessary and relevant to provide our Services to you may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to us, such as statistics related to the use of the Services.

10. MANAGING YOUR SETTINGS

Notification and Email Preferences. If you originally subscribed or opted-in to receive newsletter communications from us, you may unsubscribe by following the instructions contained at the bottom of each type of email. All other notification settings, if applicable, may be found in the “My Account” section of Trunkd.

Updating Account Information. You may correct, amend or update User account information that is inaccurate at any time by adjusting that information in the “My Account” section of Trunkd.

11. EU MEMBER RIGHTS

If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

Access and Porting. You can access much of your information by logging into your account and accessing the “My Account” screen. If you require additional access or to download a copy of your data, please contact us at: support@trunkd.co. We will generally respond to your request within 10-14 business days.

Correcting and Deleting.You can also rectify, restrict, limit or delete much of your information by logging into your account and accessing the “My Account” screen. If you are unable to do this please contact us at support@trunkd.co. We will generally respond to your request within 10-14 business days.

Object. Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Revoke Consent. Where you have previously provided your consent, you have the right to withdraw your consent to the processing of your information at any time. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

Complain. Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

Response. We will respond to all requests that we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identify in order to help us respond efficiently to your request.

12. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Trunkd is hosted and operated from within Canada and the United States. If you are located outside of Canada or the United States and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in Canada or the United States and other jurisdictions of our third-party service providers, as it is necessary to provide the Services and our obligations to you under the Terms of Service.

13. CHILDREN

The Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18 years of age. In the event that we learn that we have collected personal information from a child under 18 years of age, we will take appropriate steps to delete that information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in the “Questions” section.

14. ADDITIONAL DETAILS

Feedback.We welcome any feedback you may have as a potential or current member of the Trunkd community, subject to our Terms of Service. Please feel free to send us comments, register a complaint, or ask questions about our Services. We may store your communications, including any personal information you include in them, so that we can effectively respond to you.

Links To Other Websites.Trunkd may contain links to other websites on the internet maintained by third parties. Clicking on a link to a third-party site will make you leave the Platform and go to the site you requested. We cannot control the activities of third parties. Therefore, we cannot accept responsibility for any use of your information by such third parties, and we cannot guarantee that these third parties will adhere to the same privacy practices as ours. We encourage you to carefully review the privacy policies of any other service provider from whom you request services.

15. CHANGES IN THIS PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy at any time and in our sole discretion, so please check back frequently. If we decide to change our privacy practices, we will post the changes to this Privacy Policy on the home page or dashboard of Trunkd, as an update alert, or message in the notification section of Trunkd, or by sending you an e-mail update, and/or any other places we deem appropriate so that you can be made aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

16. QUESTIONS

If you have questions about this Privacy Policy, please contact us at support@trunkd.co.