Effective Date: January 1, 2023
Zethos, Inc. dba Truework (collectively, “Truework”, “we”, “us” and/or “our”) provides our employment and income verification services (the “Service”) to requesters (each, a “Requester”) and consumers (each, a “Consumer”) through its website located at www.truework.com or via API (the website and the API collectively referred to as the “Site”). Your access to and use of this Site is subject to the Terms and Conditions for Consumers and Terms and Conditions for Requesters.
Information Truework Collects
When you interact with us through the Site, Truework may collect and store personal Data and other information from you, as further described below.
Information You Give Us
Your Personal Data: When you use the Site as a Requester, you will be asked to provide certain personally identifiable information (“Personal Data”) about yourself, including your name, work email, phone number, payment information, company name and company address as well as Personal Data about the employee about which you seek Service, including the employee’s name and their employer’s name. The Service will also have additional optional data collection fields. When you use the Site as a Consumer, you will be asked to provide certain Personal Data about yourself to Truework so that Truework may verify your identity and process your request.
Device Information: When you use the Site via a mobile device, Truework may collect and store certain information about the device you are using, including, without limitation, the applicable device identifier. Truework may collect and use this information to help us manage and improve the Service and deliver a more customized experience to you.
Location Information: The requests you make to Truework contain your IP address. Truework may use such IP addresses for various purposes, including to: analyze and report upon the usage of our Site and any content, comply with applicable laws, features and services made available through the Site; diagnose and prevent service or technology problems affecting our Site; determine the geographic location you are accessing our Site from; and monitor and prevent fraud and abuse.
Cookies and Similar Technologies
Automatically Collected Data: In addition to the Personal Data that Truework collects, when you interact with Truework through the Site, Truework automatically receives and stores certain information about your visit and use of the Site (“Automatically Collected Data”). Automatically Collected Data is collected passively using various technologies such as web beacons that access or set cookies (see Cookies below) and may be used to track usage of the Site. Truework may store such Automatically Collected Data itself or the Automatically Collected Data may be included in databases owned and maintained by Truework or its service providers. The Site may use and share such Automatically Collected Data and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. Truework may share Automatically Collected Data with our current or prospective business partners, but does not share Automatically Collected Data that can be used to identify you.
How Truework Uses and Shares Information Truework Collects
Your Personal Data: Truework uses the Personal Data that you provide to the Site in order to provide the Service. If you contact us by email, Truework will use the Personal Data you provide to answer your question or resolve your problem. Truework may use email addresses to send transactional emails Sending, receiving and responding to transactional email communications is inherent in the use of our Site. Receiving marketing messages from Truework, such as by email or post, is optional and subject to your specific preferences. All marketing communications sent by Truework will contain instructions permitting you to determine communications you want to receive from Truework including: unsubscribe from all future marketing emails or some part thereof.
Site Analytics: Truework may also use your Personal Data and other information collected through the Site for analytics for the internal purpose of improving our Site and the Service including content and functionality, and to better understand our users.
When and to Whom Truework Discloses Data: As further sets forth below, Truework may at time disclose Personal Data and other information to third parties.
Aggregated Data: In an effort to understand and serve the needs of the users of the Site, Truework analyzes user demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis (the “Aggregated Data”), and Truework may share this Aggregated Data with its agents and business partners. Truework may also disclose Aggregate Data in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes. Notwithstanding the foregoing, Aggregate Data does not include information Truework collects about employees from their employers.
Agents, Consultants and Related Third Parties: Truework, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include delivering our communications, maintaining databases, analyzing data, marketing, and processing payments. When Truework does retain another company, Truework only provides them with the information that they need to perform their specific function, and they may only use such information for our benefit and the purposes for which they were engaged.
Business Transfers: If Truework is involved in a merger, acquisition, due diligence, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, your information, including Personal Data, may be sold or transferred as part of such a transaction as permitted by law and/or contract.
For Legal Reasons: Truework may disclose your Personal Data 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 or a government request, (ii) verify compliance with or enforce our legal terms or protect and defend the rights or property of Truework, users of the Site or others (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
Consent: Truework may disclose to a Requestor Personal Data and other information (including information collected from employers) relating to a Consumer where the Consumer explicitly consents to such disclosure.
Truework takes reasonable steps (including physical, electronic and procedural measures) to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
All Personal Data is transmitted over secure HTTPS using TLS 1.2. This is the same data transmission encryption used by banks and other financial institutions. Stored Personal Data is encrypted using AES-256 - for maximum protection. Please note however, that Truework cannot guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. No Internet or email transmission or electronic storage of information is ever fully secure or error free. In particular, information sent to or from this Site via email may not be secure. Therefore, you should take special care in deciding what information you send via the Site. Please keep this in mind when disclosing any Personal Data to Truework via the Internet.
Links to other Websites
Access to Your Personal Data
As outlined in Section 4 of our Terms and Conditions for Consumers, employees have the right to request the correction of incorrect information in one’s employment record. Please see the Terms and Conditions for Consumers for further details on the process for requesting data correction.
Truework has collected the following categories of California Personal Information within the last 12 months from the sources listed below:
- Identifiers, such as a real name, physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This category of information is collected from you, your devices, and third parties, and public databases.
- Personal information described in subdivision (e) of Section 1798.80 (California customer records statute), such as a name, address, telephone number, credit card number, debit card number, or other payment information. This category of information is collected from you directly.
- Characteristics of protected classifications under California or federal law such as age, gender, race, ethnicity or national origin. This category of information is collected from you when you choose to provide it to us directly or indirectly through our service providers and business partners as part of our surveys and market research.
- Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category of information is collected from you and your devices.
- Internet or other similar network activity, including, but not limited to, browsing history, search history, browser settings like language preference, and information regarding a California Party’s interaction with a website, application, or advertisement. This category of information is collected from you and your devices.
- Geolocation data, including physical location or movements. This category of information is collected from you and your devices.
- Inferences, such as a profile about a California Party’s preferences, characteristics, and behavior, drawn from information Truework collects and insights Truework receives from third parties such as our marketing and advertising partners and data analytics providers.
- Sensitive personal information, such as account login information allowing access to an account, precise geolocation data, race, and ethnicity, in each case as further described above in the relevant categories. If you win a promotional prize or sweepstakes, Truework may also collect your W9 information, including FEIN or SSN for legal compliance. Please note Truework does not collect sensitive personal information for the purpose of inferring characteristics about you.
For each of the above categories, Truework uses the California Personal Information for a variety of business purposes such as:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Helping to ensure security and integrity to the extent the use of a Consumer's personal information is reasonably necessary and proportionate for these purposes;
- Debugging to identify and repair errors in our systems;
- Short-term, transient use including contextual non-personalized advertising shown as part of a California Party’s current interaction with us;
- Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
- Conducting internal research to develop and demonstrate technology;
- Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which Truework may own, control, or provide; and
- Other business purposes described in the “How Truework Uses and Shares Information” Section.
Truework may also use the information Truework collects for our own or our service providers’ other operational purposes, purposes for which Truework provides you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.
Within the last 12 months, Truework has disclosed California Personal Information for our business purposes. To learn more about the categories of third parties with whom Truework shares such information, please see the “When and to Whom Truework Discloses Data” Section.
Your California Privacy Rights
If you are a California Party, you have certain rights related to your California Personal Information, including:
- The right to know what California Personal Information Truework has collected about you, including the categories of personal information, the categories of California Personal Information, the categories of sources from which the California Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing California Personal Information, the categories of third parties to whom Truework discloses California Personal Information, and the specific pieces of California Personal Information Truework hase collected about you.
- The right to correct inaccurate California Personal Information that Truework has collected about you.
- The right to delete California Personal Information that Truework has collected from you, subject to certain exceptions. For example, Truework may not be able to delete your information if such information is subject to the Fair Credit Reporting Act.
- The right to opt out of the sale or the sharing of California Personal Information.
- Truework does not sell California Personal Information, but if you wish to opt out of the sharing of California Personal Information in the future, please contact us via one of the methods outlined under the “Contacting Us” section below.
- The right to limit the use or disclosure of your sensitive personal information. Truework does not use or disclose sensitive personal information for purposes that, under applicable law, require us to support the right to limit the use or disclosure of sensitive personal information.
- The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by applicable law, including the right not to be retaliated against for the exercise of your rights.
As required under applicable law, Truework will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. Truework may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. Truework may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, Truework will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. Truework will require the agent to provide proof of that written permission. To the extent permitted by law, Truework may require you to verify your own identity in response to a request, even if you choose to use an agent.
If you are an authorized agent submitting a request on behalf of a California Party, please make a request as outlined below under “Contacting Us”.
If you are a resident of a state in which state-level privacy law is enacted (e.g., Colorado, Connecticut, Utah or Virginia), additional rights described in this Section may apply to you as applicable law comes into effect. You may have the following rights, in each case to the extent set out in applicable law:
- The right to confirm whether Truework processes personal information about you and requests access to such personal information (including, if applicable, in a portable and readily usable format).
- The right to correct inaccuracies in certain personal information Truework may hold about you; and
- The right to request that Truework delete personal information collected from or about you.
You may request to exercise these rights by contacting Truework via the methods noted under “Contacting Us” below. If your rights request is denied, you may lodge an appeal with us. The response to your rights request will inform you of any appeal rights you may have and how you may exercise them.
Truework do not sell personal information, but if you wish to opt out of the sharing of personal information in the future, please contact us via one of the methods outlined under the “Contacting Us” section below.
As required under applicable law, Truework will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. Truework may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. Truework may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights described above, Truework will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.
Under applicable law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. Truework will require the agent to provide proof of that written permission. To the extent permitted by law, Truework may require you to verify your own identity in response to a request, even if you choose to use an agent. If you are an authorized agent submitting a request on behalf of a consumer, please make a request as outlined below under “Contacting Us”.