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Privacy Policy

Last modified: Mar 12 2019
Effective: Mar 12 2019

TruZen Inc. ("TruZen", "we", or "us") provides an online marketplace for spa services via TruZen's website (the "Site"), the TruZen application (the "App") and related internet services (collectively, the "Service(s)"). The Service is operated by TruZen for users of the Service ("you"). This Privacy Policy sets forth our policy with respect to information that is collected from visitors to the Site and users of the App and/or the Services. Under applicable law, TruZen is the "data controller" of personal data collected through the Services.

I. GENERAL TERMS

1. Notification of Copyright Infringement

TruZen respects the intellectual property rights of others and expects its users to do the same. It is TruZen's policy, in appropriate circumstances and at its discretion, to disable and/or terminate the account or access of users who repeatedly infringe or are repeatedly charged with infringing the copyrights or other intellectual property rights of others.

In accordance with the Digital Millennium Copyright Act of 1998, the text of which may be found on the U.S. Copyright Office website at http://www.copyright.gov/legislation/dmca.pdf, TruZen will respond expeditiously to claims of copyright infringement committed using the Services that are reported to TruZen at legal@truzen.com and identified as in the sample notice below.

If you are a copyright owner, or are authorized to act on behalf of one, or authorized to act under any exclusive right under copyright, please report alleged copyright infringements taking place on or through the Services by completing the following DMCA Notice of Alleged Infringement notice and delivering it to TruZen at legal@truzen.com. Upon receipt of the Notice as described below, TruZen will take whatever action, in its sole discretion, it deems appropriate, including removal of the challenged material from the Services.

2. DMCA Notice of Alleged Infringement ("Notice")

Identify the copyrighted work that you claim has been infringed, or - if multiple copyrighted works are covered by this Notice - you will provide a comprehensive list of the copyrighted works that you claim have been infringed.

Identify the material that you claim is infringing (or to be the subject of infringing activity) and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material, including at a minimum, if applicable, the URL of the link shown on the Site and App where such material may be found.

Provide your mailing address, telephone number, and, if available, email address.

Include both of the following statements in the body of the Notice:

I hereby state that I have a good faith belief that the disputed use of the copyrighted material is not authorized by the copyright owner, its agent, or the law (e.g., as a fair use).

I hereby state that the information in this Notice is accurate and, under penalty of perjury, that I am the owner, or authorized to act on behalf of the owner, of the copyright or of an exclusive right under the copyright that is allegedly infringed.

Provide your full legal name and your electronic or physical signature.

Deliver this Notice, with all items completed, to TruZen at either:

legal@truzen.com

OR

TruZen Inc.
c/o The Apex Law Group, LLP
Attn: Peter J. Smith
200 1st Ave. W. Suite 104
Seattle, WA 98119

II. Health Insurance Portability and Accountability Act ("HIPPA")

Please note that TruZen is not intended for the medical industry or any industry that requires strict compliance with the protection of special categories of personal data including but not limited to medical information. TruZen is a marketplace facilitator and is not intended to store, transmit, or communicate sensitive health data.

If you and your information requires HIPPA compliance you should not use the Service to transmit the information.

III. INFORMATION WE COLLECT

When you interact with us through the Services, we may collect information from you, as further described below.

1. INFORMATION YOU PROVIDE:

We collect information from you when you voluntarily provide such information, such as when you register for access to the Services or use certain Services. Information we collect may include but is not limited to name, phone, zip code, date of birth, username, email address, payment information such as credit card information, and any messages, images, transient VOIP data (to enable communication delivery only) or other content you send via the chat feature.

You may choose to provide additional information as part of your TruZen profile (such as gender, city, and a personal description). Some of this information as indicated in your settings is part of your public profile page and will be publicly visible to others.

You may otherwise choose to provide us information when you fill in a form, update or add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us, or use other features of the Services.

2. OTHER INFORMATION:

a. Data We Collect Automatically: When you interact with us through the Services, we receive and store certain information such as an IP address, device ID, geo-location, and your activities within the Services. We may store such information or such information may be included in databases owned and maintained by affiliates, agents, or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of messages users have sent, as well as the sites which refer visitors to TruZen.

b. Aggregated Information: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our customer demographics, interests, and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

c. Info through other Services: You may give us permission to collect your information in other services. For example, you may connect a social networking service ("SNS") such as Facebook or Twitter to your TruZen account. When you do this, it allows us to obtain information from those accounts (for example, your friends or contacts).

d. Cookies: We employ cookies and similar technologies to keep track of your local computer's settings such as which account you have logged into and notification settings. Cookies are pieces of data that websites and services can set on your browser or device that can be read on future visits. We may expand our use of cookies to save additional data as new features are added to the Service. In addition, we use technologies such as web beacons and single-pixel gifs to record log data such as open rates for emails sent by the system.

We may use third party web site analytic tools such as Google Analytics on our website that employ cookies to collect certain information concerning your use of our Services. However, you can disable cookies by changing your browser settings.

e. Advertisements: You may see our Service advertised in other applications or websites. After clicking on one of these advertisements and installing our Service, you will become a user of the Service. Advertising platforms, which include Twitter and Facebook (and whose SDKs are integrated within our Service), may collect information for optimizing advertising campaigns outside of the Service.

If you do not wish to receive personalized advertising that is delivered by third parties outside of TruZen's Service, you may be able to exercise that choice through opt-out programs that are administered by third parties, including the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA).

Our Services currently do not respond to "Do Not Track" (DNT) signals and operate as described in this Privacy Policy whether or not a DNT signal is received, as there is no consistent industry standard for compliance.

IV. WHERE INFORMATION IS PROCESSED

TruZen is based in the United States. No matter where you are located, you consent to the processing and transferring of your information in and to the U.S. and other countries. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

V. OUR USE OF YOUR INFORMATION

We use the information you provide in a manner that is consistent with this Privacy Policy. If you provide information for a certain reason, we may use the information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem. Also, if you provide information in order to obtain access to the Services, we will use your information to provide you with access to such services and to monitor your use of such services. TruZen and its subsidiaries and affiliates (the "Related Companies") may also use your information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. TruZen and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

VI. OUR LEGAL BASIS FOR HANDLING OF YOUR PERSONAL DATA

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:

1. To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users' request in anticipation of entering into a contract with them. For example, we handle personal data on this basis to create your account and provide our Services.

2. Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes:

  • Providing a safe and enjoyable user experience;
  • Customer service;
  • Marketing, e.g. sending emails or other communications to let you know about new features;
  • Protecting our users, personnel, and property;
  • Analyzing and improving our business, e.g. collecting information about how you use our Services to optimize the design and placement of certain features;
  • Processing job applications; and
  • Managing legal issues.

3. Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

4. To protect the vital interests of the individual or others: For example, we may collect or share personal data to help resolve an urgent safety situation.

5. Consent: Where required by law, and in some other cases, we handle personal data based on your implied or express consent.

VII. OUR DISCLOSURE OF YOUR INFORMATION

TruZen is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information with certain third parties, as set forth below:

1. Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, bankruptcy, dissolution, or similar event, your information may be part of the transferred assets.

2. Consent: We may transfer your information with your consent.

3. Related Companies: We may also share your information with our Related Companies for purposes consistent with this Privacy Policy.

4. Agents, Consultants, and Related Third Parties: Like many businesses, we sometimes hire other companies or individuals to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments.

5. Legal Requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of TruZen or Related Companies, (iii) protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

6. Aggregated or Non-identifiable Data: We may also share aggregated or non-personally identifiable information with our partners or others for business purposes.

VIII. UNSOLICITED INFORMATION

You may provide us with ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

IX. CHILDREN UNDER THE AGE OF 18

The Services are not directed to children under the age of 18, unless permitted by the child's parent and or guardian. We do not knowingly collect information, including personal data from children or other individuals who are not legally able to use our Services. If we obtain actual knowledge that we have collected personal data from a child under the age of 18 without proper parental consent, we will promptly delete it, unless we are legally obligated to retain such data. Contact us via the information below if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.

X. LINKS TO OTHER WEB SITES

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by us (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

XI. DATA RETENTION

We generally retain personal data for so long as it may be relevant to the purposes identified herein. To dispose of personal data, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:

  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Login ID for fraud or safety reasons, we may retain certain information from that Login ID to prevent that Member from opening a new Login ID in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, TruZen may keep some of your information for tax, legal reporting, and auditing obligations.
  • Information you have shared with others (e.g., reviews) may continue to be publicly visible on the Platform, even after your Login ID is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
  • Because we maintain the Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

XII. SECURITY

We take reasonable steps to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information via the Internet.

XIII. YOUR DATA RIGHTS AND CHOICES

We believe that users should be treated equally no matter where they are, and so we are making the following options to control your data available to all users, regardless of their location.

You can update certain information by accessing your profile via "Settings." You can also unsubscribe from certain emails by clicking the "unsubscribe" link they contain. You can opt out from certain cookie-related processing by managing your browser settings.

Individuals in the European Economic Area, Canada, Costa Rica, and some other jurisdictions outside the United States have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment, or deletion in appropriate circumstances. They may also object to our uses or disclosures of personal data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways.

1. How can I access the personal data you have about me?

If you would like to submit a data access request, you can do so by emailing legal@truzen.com.

2. How do I correct, update, amend, or delete the personal data you have about me?

If you would like to correct, update, amend, or delete certain personal data, you can also request modifications from us directly. Please write us at legal@truzen.com with the words "Personal Data Request" in the subject or body of your message, along with an explanation of what data subject right you are seeking to exercise. For your protection, we may take steps to verify identity before responding to your request.

3. How do I object or restrict the way TruZen processes my personal data?

You have a right to ask us to stop using or limit our use of your personal data in certain circumstances—for example, if we have no lawful basis to keep using your data, or if you think your personal data is inaccurate.

TruZen offers you the ability to restrict the processing of your data for specific uses. You can request such restrictions by emailing legal@truzen.com. Individuals in the European Economic Area have the right to opt out of all of our processing of their personal data for direct marketing purposes. To exercise this right, please see email TruZen at legal@truzen.com.

The rights and options described above are subject to limitations and exceptions under applicable law. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

XIV. CALIFORNIA RESIDENTS

For California residents, TruZen will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state's law.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. Please write us at legal@truzen.com to request this information. TruZen does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.

XV. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

XVI. CONTACTING US

Please also feel free to contact us if you have any questions about this Privacy Policy or the information practices of the Services. You may contact Adam Duren, CEO, as follows: legal@truzen.com.