Privacy Policy

‍

This Privacy Policy describes how The True Life Companies and its affiliates (“TTLC”, “we,” “our,” or “us”) collects and uses your personal information (as defined below) through your interactions with us and when you visit this website (“Website”); how we protect and share this personal information; and the rights you may have in relation to this personal information.

For users who are located in the European Union (EU) or European Economic Area (EEA) and Switzerland and subject to the General Data Protection Regulation (GDPR), please review this Privacy Policy and see the below Section 12 for a description of your rights and other information related to the GDPR.

If you are a California Resident (as defined below), please review the below Section 14 for additional disclosures and for a description of your rights under the California Consumer Privacy Act (with any implementing regulations, as amended by the California Privacy Rights Act (“CPRA”), and as may be amended from time to time, “CCPA”).

1. How to Contact Us

If you have any questions about this Privacy Policy or how we treat your personal information, please use the following email address: info@thetruelifecompanies.com.

2. Third-Party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

3. What Personal Information Do We Collect?

When we use the term personal information (“Personal Information”) we mean any information that can help us directly or indirectly identify you. We collect some of this information when it is provided by you directly, and other information when it is collected automatically when you visit our site.

Depending on how you interact with us through the Website, we may collect the following categories of Personal Information from or about you:

  • Identifiers and similar information such as, name, address, date and place of birth, email address, telephone number, social security number or other unique identifier number, tax identification number, driver’s license number, passport and other national identity details, internet protocol (“IP”) address, username, password, online identifiers or other similar identifiers;
  • Certain financial information protected under federal or state laws, like a signature, bank account, or other financial information;
  • Personal details, including characteristics of protected classifications under certain federal or state laws, such as gender or marital status, or information that might be considered special category data or otherwise sensitive under applicable law, including, racial or ethnic origin;
  • Commercial information, including purchasing histories or tendencies, funds invested, investments considered, or sources of wealth;
  • Education information, including information that is not publicly available, and personally identifiable information as defined in the Family Educational Rights and Privacy Act;
  • Internet or other electronic network activity information, including certain technological information like interactions with our Site or use of certain online tools; and
  • Professional or employment-related information, including occupation, compensation, employer, title, certifications, professional license numbers.

Please note that some of this information may be considered special category data, or sensitive data under applicable law.

You may also be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to gain access to certain information and services on the Website, which rely on such information (for example, you will not be able to register for e-mail updates if you do not provide us with an e-mail address, and if you choose not to provide a username and password, we will not be able to provide you with services available through an online account).

4. How is Your Personal Information Collected?

We use different methods to collect information from and about you:

  • You, directly in person, by telephone, text, or email
  • Third party with your consent (e.g., your bank)
  • Advertising networks
  • Internet service providers
  • Data analytics providers
  • Government entities
  • Operating systems and platforms
  • Social networks
  • Data brokers
  • Publicly accessible sources (e.g., property records)
  • Cookies on our website
  • Our IT and security systems

If you are in the European Union or European Economic Area you can find out more about your rights in relation to your Personal Information that we handle by consulting Section 12, below, or by consulting the Guide to the GDPR published by the Information Commissioner’s Office.

5. How Do We Use Your Personal Information?

We may use the personally identifiable information that you submit to us to provide products, services or information that you request, or to otherwise respond to your inquiry. We may also use any personally identifiable information that you submit, separately or in combination with pre-existing information to:

  • Provide or allow our affiliates or service providers to provide you with information, products or services;
  • To fulfill any other purpose for which you provide it;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • Enforce our Terms of Use - info@thetruelifecompanies.com;
  • To notify you about changes to our Site or any products or services we offer or provide though it; or
  • Contact you with more information about our services and those of our affiliates or others with whom we may have a business relationship.

6. Cookies

When you visit our Website, you will not have the opportunity to reject our use of strictly necessary cookies, which are necessary for the Website to function. You may set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies, or install certain plugins.

We use cookies only for administering the Website and ensuring website security.  If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.

7. How Do We Share Your Personal Information?

We may also disclose your personally identifiable information to our affiliates and to third parties whom we occasionally hire to provide services on our behalf, such as our web hosting service. In addition, in the event that we are involved in a transaction that involves a transfer of stock or assets, your personally identifiable information may be transferred to the other party in the transaction. We reserve the right to disclose your personally identifiable information if required to do so by law or legal process or otherwise requested by any law enforcement or agency acting under color of law.

We respect your privacy. We will not sell your personally identifiable information to any third party other than in connection with a sale of all or a significant portion of our business. We will not use or share your personally identifiable information other than as described above without prior notice and an opportunity to opt-out pursuant to this Privacy Policy.

8. How Long Do We Retain Your Personal Information?

We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  

If you are in the European Union or European Economic Area you can find out more about your rights in relation to our retention of your personal information consulting Section 12, below, or by consulting the Guide to the GDPR published by the Information Commissioner’s Office.

9. How Do We Secure Your Personal Information?

We use reasonable technical, administrative and physical security measures to protect your Personal Information.  We of course cannot guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be safe from unauthorized access or use (e.g., by hackers).  We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties while or after you transmit your information to us.

10. Children’s Privacy

Our services are not directed at individuals under the age of 18.  We do not knowingly collect information from children under the age of 18.  If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

As a parent or guardian, if you become aware that your child has provided us with Personal Information, you should contact us at the email address provided in Section 1 above.

11. Changes to this Privacy Policy

We may change this Privacy Policy from time to time.  When we do, we will update you by posting the changed Privacy Policy on this page with a new “Last Updated” date. In some cases, we may also inform you of changes by additional means, such as by sending an email to your email address in our records.

12. Information Collected from Individuals in the European Union and European Economic Area

Your Legal Rights

You have various rights under the EU GDPR in relation to the Personal Information we hold about you. These include:

  • The right to request access to your Personal Information and obtain a copy of the information we hold about you;
  • The right to correct your Personal Information that we hold where it is incomplete or inaccurate;
  • The right to have your Personal Information erased where there is no good reason for us continuing to use or retain it;
  • The right to request that your personal information is used only for restricted purposes;
  • If the lawful basis for processing your Personal Information is either our or a third party’s legitimate interests, the right to object to your Personal Information being processed;
  • The right to require certain of your Personal Information to be transferred to you or a third party; and
  • The right to lodge a complaint with the relevant data protection authority in your jurisdiction (for example, the Information Commissioner’s Office in the United Kingdom).

If you wish to exercise any of these rights, please contact us at the following email address: info@truelifecapital.com.

13. International Transfers

This Website is hosted in the United States. If you access this Website from the EEA, you are voluntarily transferring your Personal Information to the United States, a jurisdiction which does not offer the same type of protection to the Personal Information of individuals as countries within the EEA.

14. Additional Information for California Residents

The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) regarding “Personal Information.”  If you are a California Resident, please review the following information about your potential rights regarding your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”

Notice at Collection and Use of Personal Information

Information We Collect

Depending on how you interact with us, and which Site you are visiting, we may collect the categories of personal information listed above in Section 3.

Our Use and Collection of Information

We may collect and use personal information from you for the purposes described above in Section 5.

Sale or Sharing of Personal Information

We do not “sell” your personal information under the CCPA, meaning we do not rent, release, disclose, transfer, make available, or otherwise communicate personal information to another business or third party for monetary or other valuable consideration. We also do not “share” your personal information, as defined under the CCPA to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

How Long We Keep Information‍

We retain your personal information as described above in Section 8.

For more information about our privacy practices, please review our entire Privacy Policy.

Our Collection, Use, and Disclosure of Personal Information and Sensitive Personal Information

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

In the preceding 12 months, depending on how you interact with us and which Site you are visiting, we may have collected the categories of personal information from the categories of sources listed above in Section 3 and Section 4. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in Section 5.

Our Disclosure of Personal Information

We do not sell or share your personal information (as those terms are defined under the CCPA).  We do not knowingly sell or share the personal information of California Residents under 16 years old. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information (described in more detail in Section 3 and Section 4 above) to the following categories of third parties, as described below:

Category of Third Parties: Our affiliates

Categories of Personal Information

Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Internet or Electronic Network Activity Information; Audio (e.g., voicemail), electronic, visual or similar information; Professional or Employment Related Information; Inferences

Business or Commercial Purpose for Disclosure

Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); Internal research for technological development and demonstration; Activities to verify, maintain, or improve the quality of our services; Business development and marketing initiatives.

Category of Third Parties: Counterparties and intermediaries (e.g., broker-dealers)

Categories of Personal Information

Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Professional or Employment Related Information; Inferences

Business or Commercial Purpose for Disclosure

Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); and Activities to verify, maintain, or improve the quality of our services.

Category of Third Parties: Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund

Categories of Personal Information

Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Professional or Employment Related Information; Inferences

Business or Commercial Purpose for Disclosure

Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); and Activities to verify, maintain, or improve the quality of our services.

Category of Third Parties: Professional services organizations, such as auditors and law firms

Categories of Personal Information

Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Internet or Electronic Network Activity Information; Audio (e.g., voicemail), electronic, visual or similar information; Professional or Employment Related Information; Inferences

Business or Commercial Purpose for Disclosure

Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); Internal research for technological development and demonstration; and Activities to verify, maintain, or improve the quality of our services.

Category of Third Parties: Prospective lenders to or creditors of a fund or portfolio company in which we have or are considering investing

Categories of Personal Information

Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Commercial information; Education information; Professional or Employment Related Information; Inferences

Business or Commercial Purpose for Disclosure

Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); and Activities to verify, maintain, or improve the quality of our services

Category of Third Parties: Our portfolio companies

Categories of Personal Information

Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Commercial information; Education information; Professional or Employment Related Information; Inferences

Business or Commercial Purpose for Disclosure

Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); Activities to verify, maintain, or improve the quality of our services; and Business development and marketing initiatives.

***

In addition, we may disclose and in the preceding 12 months, may have disclosed for all of the categories of personal information identified in Section 3 and Section 4 above to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose the categories of personal information identified in Section 3 and Section 4 for the business or commercial purposes identified above in Section 5. Additionally, we may disclose your personal information to third parties upon your request, at your direction, or with your consent.

We may also disclose your personal information or otherwise make it available to our service providers such as our IT and/or CRM providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.

Use and Disclosure of Sensitive Personal Information

As noted in Section 3 and Section 4, we may collect certain special category data or sensitive personal data under certain laws. We do not currently collect “sensitive personal information” (as defined under the CCPA) from our website visitors. We may collect “sensitive personal information” from our investors or job applicants, as explained in separate notices such as our subscription materials or candidate privacy notice.

California Residents’ Rights Under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected, and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit); (vii) correct inaccurate personal information (“Request to Correct”); and (viii) request that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months (“Request to Know”).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations.  In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the GLBA.  We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

How to Submit a Request Under the CCPA

You may submit a Request to Know, Request to Correct, or Request to Delete through the following email: info@truelifecapital.com.

When you submit a Consumer Rights Request may ask that you provide clarifying or identifying information to verify your request.  Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address.  Any information gathered as part of the verification process will be used for verification purposes only.

If you would like to use an authorized agent to submit a request, we may request proof that that they are authorized to act on your behalf, or have a power of attorney.  We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

Privacy Notice to Nevada Residents

Pursuant to Nevada state law, we must inform you that if you would like more information regarding this notice or Nevada's law regarding corporate do-not-call registries, you can contact us as described above, or via the Bureau of Consumer Protection, Office of the Nevada Attorney General at 555 E. Washington Street, Suite 3900, Las Vegas, Nevada 89101. Phone: (702) 486-3132 / Email: BCPINFO@ag.state.nv.us. However, please know we do not currently sell data triggering this state’s opt-out requirements.

Privacy Notice to Vermont and North Dakota Residents

We will not disclose information about you to affiliates or non-affiliated, third-party companies, other than as described in this Privacy Policy or as permitted by law, without your express permission.

***

We may change this Privacy Policy from time to time.  Should we do so, we will post the changes to this page.  We suggest that you periodically consult this Privacy Policy to review any changes.  Your continued use of the Website after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.