Privacy Policy
Date of Last Revision: June 10, 2021
This Privacy Policy (“Privacy Policy”) is intended to inform you of the Truthbitpull Consulting, LLC, a Washington limited liability company ("TBP", “us”, “we”, or “our”), policies and practices regarding the collection, use, and disclosure of any Personal Information you submit to us through TRUTHBITPULL.com and all related URLS and subdomains related thereto (collectively, the "Services"). This Privacy Policy does not apply to the information practices of other companies and organizations, websites, applications, or services that display or link to different privacy statements by other companies or individuals.
"Personal Information" is information about you that is personally identifiable to you, like your name, address, email address or phone number, as well as other non-public information that is associated with any of the foregoing.
By submitting Personal Information through the Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Information according to this Privacy Policy.
The Data We Collect and How We Use it
1. Information You Choose to Give
● When you sign up for an account to use our Services (each, an “Account”), register for a “Live Event” with TBP, or sign up for content or offers, we may ask you to provide Personal Information, such as your email address, name and password.
● When purchasing any products through our services, such as a Season Pass (as defined in the TBP Terms of Service), you may be required to provide additional Personal Information including your name, phone number, postal address, and/or payment information, such as your bank account, credit, or debit card number. Please note we may only retain the last four digits of your credit card number or part of your bank account number. We do not retain your complete payment information within our systems, nor do we ever have access to it explicitly.
● When you register on the Services, we may collect your full name, email address, phone number, and your organization (if associated with an organization).
● When you contact us to submit comments, questions, or feedback using the forms on and/or in the Services or via email, we may collect your name, email address, and your comment, question, feedback, or any other information contained in the email you send us or any information attached to the email.
● If you provide feedback on any of our products or Services to us, we may use such feedback for any purpose on a royalty-free, worldwide, perpetual basis. TBP may collect any information contained in such communication and will treat the Personal Information in such communication in accordance with this Privacy Policy.
All Personal Information that you provide to us must be true, complete, and accurate and you must notify us of any changes to such Personal Information.
As otherwise detailed in this Privacy Policy, we will solely process this information to provide you with the Service you’ve signed up for.
2. Information Collected Automatically
When accessing the Services, interacting with our content, or using your Account, we may collect the below types of information.
Usage Data: We capture the name of your Internet Service Provider (“ISP”), the website from which you visited us from, the pages of the Website you visit, the date and duration of your visit, and information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) used during your visit (“Usage Data”). We only capture and store a truncated version of your IP address. Your full IP address never reaches our servers and we never have access to it.
We use Usage Data to facilitate and improve upon your access to the Services (e.g. to adjust the Services to the device you are using) and to recognize and stop any misuse. We also process Usage Data in an anonymized form for statistical purposes. Anonymized data is data that cannot be associated with any one individual. In addition, we use behavioral data that is automatically collected to improve and personalize the Services.
Cookies: We use cookies to process information, including standard Internet log information and details of visitor’s behavioral patterns upon accessing the Services. TBP stores this information in a pseudonymized User profile. Pseudonymized data is data that can no longer be attributed to a specific data subject. Cookies are small data files stored on your individual device and you have full control over their use. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well.
We use cookies to provide you with a better experience and to facilitate the use of certain functions. TBP does not process this information to identify individual Users or to match it with further data on an individual User.
You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time. Should you visit the Services with cookies deactivated, you may possibly not be able to use all of the functions on the Services to the full extent.
Log Files: Log files track actions occurring on the Services and collect data including your IP address, browser type, Internet Service Provider, referring/exit pages, and date/time stamps.
Web Beacons, Tags, and Pixels: Each of these items are electronic files used to record information about how you browse the Services. We use web beacons, tags, and pixels to deliver cookies and count visits.
Contact via Contact Form and Email: On the Services, you can contact us via the contact form. In that form, we ask for your contact information (e.g. name, email address etc.). If you choose to receive emails from us, we may use certain analytic tools to capture data, such as when you open our email or if you click on any links or banners in our email.
We may also occasionally send you notification emails about updates to our products, legal documents, or offer User Support or marketing emails.
We use this data solely to answer questions we receive or to help us improve on the effectiveness of our communications and marketing campaigns.
3. Use of Information We Collect
We use your Personal Information collected through the Services for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. For example, we may use your Personal Information to:
● provide and deliver products through the Services, such as one or more Live Events;
● secure, troubleshoot, and improve the Services;
● operate our business, such as improving our internal operations, securing our systems, detecting and preventing fraud, spam, abuse, security incidents, and other illegal or harmful activity;
● understand you and your preferences;
● enhance your experience and enjoyment using the Services;
● respond to your comments and questions and provide customer service;
● send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages, communicate with you about promotions and other news about products and Services offered by TBP;
● link or combine information about you with other Personal Information we get from third-parties;
● comply with our legal obligations;
● conduct security investigations and risk assessments;
● verify or authenticate information or identifications provided by you;
● resolve any disputes with any of our Users and enforce our agreements with third-parties; and
● enforce our Terms of Service.
We process this Personal Information for these purposes given our legitimate interest in protecting our business and Services, to measure the adequate performance of our contract with you and as necessary to comply with legal or regulatory obligations.
4. Sharing Personal Information with Third-Parties
Except as otherwise stated in this Privacy Policy, we do not trade, rent, sell, or share your Personal Information with third-parties. However, we may share your Personal Information with trusted third-parties to provide you with our products and Services.
Service Providers: We use a few trusted external service providers for data analysis, processing, and/or storage offerings. For example, if you provide payment data to purchase a product, we may share that data with other entities as appropriate for payment processing, fraud prevention, or other related financial services.
Affiliates: We may share some or all of your Personal Information with companies under common control, such as any subsidiaries or joint ventures (collectively, "Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy. We share Personal Information among our Affiliates to offer you certain products or services.
Vendors and Agents: With your permission we may also share Personal Information with vendors or agents working on our behalf for the purposes described in this Privacy Policy. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and Services may need access to Personal Information to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use Personal Information they receive from us for any other purpose.
Corporate Transactions: We may also disclose Personal Information as part of a corporate transaction, such as a merger, transfer, divestiture, or sale of all or a portion of our business or assets.
Law Enforcement or Legal Requests: We may access, transfer, disclose, and preserve your Personal Information when we have a good faith belief that doing so is necessary to:
● comply with applicable law or respond to valid legal process, including law enforcement or other government agencies;
● protect our Users, to prevent spam, or attempts to defraud Users of the Services;
● help prevent the loss of life or serious injury of anyone;
● operate and maintain the security of the Services, including to prevent or stop an attack on our computer systems or networks; or
● protect our rights or property, including enforcing the terms governing the use of the Services.
Analytical Companies: We may also share aggregated or de-identified information to companies that provide analytic reports to us, such as Google Analytics. Aggregated data refers to data that is collected from multiple Users and is compiled into data summaries, typically for the purposes of analysis. De-identified data refers to data from which all Personal Information has been removed to protect the individual identity and privacy.
These third-parties are required not to use your Personal Information other than to provide the products and Services requested by TBP and are bound by confidentiality agreements with regard to their use of such information. You expressly consent to the sharing of your Personal Information with our contractors and third party service providers for the sole purpose of providing products and Services to you.
5. Your Choices Regarding Your Personal Information
In accordance with applicable law, you have the right to be informed of your Personal Information processed by TBP, a right to rectification, correction, erasure, and restriction of processing. You also have the right to receive from TBP a structured, common, and machine-readable format of the Personal Information you provided to us.
When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the communication you receive or by contacting us directly at info@truthbitpull.com.
You may at any time change and/or withdraw your consent regarding any use or processing of your Personal Information, without affecting the lawfulness of the processing that was carried out prior to withdrawing it.
Whenever you withdraw your consent, you acknowledge and agree that this may have a negative influence on the quality of the Services we provide. You further acknowledge and agree that TBP shall not be held liable or responsible with respect to any loss and/or damage to your Personal Information if you choose to withdraw consent.
6. Do Not Track
Do Not Track (“DNT”) is a privacy preference that Users can set in certain web browsers. When you visit a website in any browser, you automatically share information with that website, such as cookies, your IP address, and other standard PC information. Please note the tracking we do is minimal and is used to make the Services work. If you choose to turn on your DNT signal, we will honor it.
7. Your European Privacy Rights (GDPR)
TBP is committed to processing data in accordance with its responsibility under the European General Data Protection Regulation (“GDPR”). If the processing of Personal Information about you is subject to the GDPR, you have certain rights with respect to that data including,
● The Right to Access: You have the right to request from TBP copies of your Personal Information.
● The Right to Rectification: You have the right to request that TBP correct or complete any information you believe is inaccurate.
● The Right to Erasure: You have the right to request that TBP erase your Personal Information, under certain conditions.
● The Right to Restrict Processing: You have the right to request that TBP restrict the processing of your Personal Information, under certain conditions.
● The Right to Object to Processing: You have the right to object to TBP’s processing of your Personal Information, under certain conditions.
● The Right to Data Portability: You have the right to request that TBP transfer the data that we have collected to another organization or directly to you, under certain conditions.
To make such requests, contact us at info@truthbitpull.com. You also have the right to lodge a complaint with a supervisory authority, but we encourage you first to contact us with any questions or concerns.
8. Your California Privacy Rights and Nevada Privacy Rights
California:
TBP is committed to processing data in accordance with its responsibility under the California Consumer Privacy Act (“CCPA”), to the extent CCPA applies to TBP’s business and to your Account. If you are a California resident, you have the following rights free of charge:
● Right to Know: You have the right to request that we disclose to you the Personal Information we collect, use, or disclose and informational about our data practices.
● Right to Notice: You have the right at or before the point of collection of your Personal Information to know what categories of Personal Information will be collected and the purposes for which these categories will be used.
● Right to Access: You have the right to request access to your Personal Information twice per year, free of charge.
● Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you.
● Right to Non-Discrimination: You have the right to not be discriminated against for exercising any of these rights.
In particular, TBP has collected the following categories of Personal Information from its Users within the last twelve (12) months:
Category
Examples
A. Identifiers
Name, email address, postal address, unique personal identifiers, truncated version of your IP address, and cookies.
B. Commercial Information
Products or services purchased.
C. Usage Data
Information on the User’s interaction with the Services, ISP, the website from which you visited us from, the pages of the Website you visit, the date and duration of your visit, device type, operating system, screen resolution, language, country you are located in, and web browser type.
D. Purchasing Details
User-provided last four digits of credit card and User-provided partial bank account information.
We use your Personal Information in accordance with the reasons described within this Privacy Policy. Additionally, we may share your Personal Information with the parties described within this Privacy Policy for a business purpose. In the proceeding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
● Usage Data;
● Purchasing Details; and
● Identifiers.
Lastly, we receive the Personal Information in the above categories from sources that are described within this Privacy Policy.
If you would like to exercise your above rights, please submit your request to User Support at info@truthbitpull.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. The verifiable consumer request must:
● provide sufficient information that allows us to reasonably verify you as the person about whom we collect Personal Information or an authorized representative; and
● describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Nevada:
Under Nevada law, certain Nevada consumers may opt out of the sale of "personally identifiable information" for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased Services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us at info@truthbitpull.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
9. Regarding Children
The Services are not intended for children or minors under the age of 16. We do not knowingly collect Personal Information from children or minors under the age of 16. If you are under the age of 16, please do not provide any information to us. By accessing the Services, you represent and warrant that you are over the age of 16. If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to TBP, please contact us using the 'Contact Us' information below, and you may request exercise of your applicable rights detailed in Your Choices Regarding Your Personal Information, above.
If we learn that we have collected the personal data of a child under the age of 16 years, we will take reasonable steps to delete the personal data. This may require us to delete the Account for that child.
10. Other Sites
Please note that the Services may include references or links to external websites for your convenience. This does not signify our endorsement of such other website or its contents. We have no control over, do not review, and cannot be responsible for these outside websites or their content. If you provide Personal Information to any of those third-parties or consent to our sharing Personal Information with them, that data is governed by their privacy statements and the terms of our Privacy Policy do not apply to these outside sites. We recommend that you consult the privacy statements of all third-party websites you visit.
11. Security of Personal Information
TBP is committed to protecting the security of your Personal Information.
Please remember no Internet transmission is every fully secure or error-free. Please keep this in mind when disclosing any Personal Information to TBP via the Internet. Although TBP makes efforts to ensure that your Personal Information is not intercepted, accessed, used, or disclosed by unauthorized persons, you should know that TBP cannot fully eliminate security risks associated with Personal Information and any transmission is at your sole and exclusive risk.
In case of a data breach, TBP will notify affected individuals within three (3) days. Additionally, we may communicate any additional steps we take to make sure a data breach does not occur in the future.
12. Retention of Personal Information
We may store your Usage Data and other Personal Information until such time when you withdraw your consent for us to do so or for as long as necessary for the purpose(s) for which we originally collected it, unless otherwise required by law. Because these needs can vary for different data types, actual retention periods can vary significantly based upon User expectations, consent, sensitivity of data, and the availability of automated controls that enable the deletion of data.
When we have no ongoing legitimate business need to process your Personal Information or if you withdraw your consent for us to store your Usage Data or other Personal Information, we may either delete or anonymize it after one year, or if this is not possible (for example, because your Personal Information has been stored in backup archives), then we may securely store your Personal Information and isolate it from any further processing until deletion is possible.
Additionally, your Personal Information may be stored on certain third-party databases from time to time, such as Highrise, wufoo, HubSpot, Squarespace, Member Stack, and other databases determined by us from time to time. Please contact us at info@truthbitpull.com if you would like to understand which databases we currently use to store your information. Such storage and use on these databases will be subject to the applicable database’s privacy policy and terms and conditions, which we do not control.
13. Transfer of Personal Information
Your Personal Information may be processed, stored, or transferred by TBP in the country where it was collected, as well as transferred to, stored in, and processed in other countries (including the United States) where laws regarding processing of Personal Information may be less stringent than the laws in your country. When we transfer your data from other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements, providing adequate protection for the transfer of data to countries outside the European Economic Area (“EEA”) and outside the United Kingdom.
If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:
● the country to which the personal data will be transferred has been granted a European Commission adequacy decision; or
● we have put in place appropriate safeguards in respect of the transfer, such as if we have entered into EU standard contractual clauses with the recipient, or the recipient is a party to binding corporate rules.
14. Dispute Resolution
If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will do our best to investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of Personal Information in accordance with this Privacy Policy. If a dispute is escalated in any fashion, you represent, warrant, acknowledge, and agree that such dispute shall be resolved in accordance with the dispute resolution Terms of Service included on the Site, which are incorporated herein by reference.
15. Privacy Policy Updates
As part of the TBP Terms of Service, this Privacy Policy is subject to occasional amendment, in accordance with the terms of the Terms of Service. If we make any changes to this Privacy Policy, we will change the “last updated” date and post a notice of our material changes on our Services. As of the effective date of the revised Privacy Policy, you will be considered to have consented to all changes in the Privacy Policy. If you disagree with the terms of this Privacy Policy you may choose not to use the Services at any time.
16. Contact Us
Should you have any questions or concerns regarding this Privacy Policy or would like to issue a complaint, please contact us info@truthbitpull.com or:
Truthbitpull Consulting, LLC
13000 Beverly Park Rd. Suite A
Mukilteo, Washington 98275