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”).
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.
3. WE COLLECT, USE, SHARE AND OTHERWISE PROCESS INFORMATION
4. OUR LEGITIMATE INTERESTS
The legitimate interests of Trunkd Corp. and our third-party service providers and partners include:
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:
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.
Information automatically collected when you use the Services
We collect certain information automatically whenever you use the Services:
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
How we use your Non-Personally Identifiable Information
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:
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.
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 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: email@example.com. 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 firstname.lastname@example.org. 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.
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.