California Privacy Notice

Last Updated: April 2023

This California Privacy Notice (“Notice”) supplements the Website Privacy Policy and Services Privacy Policy of Trulioo Information Services Inc. and our affiliates (“Trulioo“, “we“, “our“, “us“) with information required by applicable California laws. This Notice describes our privacy practices with respect to the personal information we may collect or receive from California residents who are our customers, potential customers, employment applicants, and visitors to our website at www.trulioo.com, or whose personal information we may use for certain limited purposes in connection with our identity verification and related online services (our “Services”).

As mentioned in our Services Privacy Policy, Trulioo makes our Services available to our customers for integration into our customers’ websites and mobile applications. This Notice does not apply to the services offered by our customers who use our Services. Please consult the privacy policy of our customer that is using our Services with you for more information about their processing of your personal information.

California’s “Shine the Light Law”: You may request a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties, once per calendar year. Contact us at [email protected] to make such a request.
“Do Not Track” Signals and Third Party Tracking: Your browser may offer a “Do Not Track” (DNT) option, which generally signals to operators of websites that you do not wish your online activities to be tracked over time and across different websites. Since not all browsers offer DNT and currently there is no industry consensus as to what constitutes a DNT signal, Trulioo does not respond to DNT requests at this time. Click here to learn more about DNT signals.
The California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”) provides specific rights to California residents regarding their personal information. The remainder of this Notice describes such rights and Trulioo’s collection, use, disclosure, sale, and sharing of the personal information of California residents as described above. We use certain terms in this Notice as defined by the CCPA and CPRA and its implementing regulations.

1. Personal Information We Collect

The following table details the categories of personal information that we collect or receive (and have collected or received during the 12-month period prior to the “Last Updated” date of this Notice). Note that we may not collect or receive all categories for every individual who interacts with us.

Category	Examples	Collected (YES/NO)
A. Identifiers	A real name, IP address, email address, or other similar identifiers.	Yes
B. Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))	A name, signature, Social Security Number, address, telephone number, passport number, driver’s license number, insurance policy number, education, employment history, bank account number, credit card number, financial information, medical information, or health insurance information.	Yes
C. Protected classification characteristics under California or Federal law.	Age, race, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy, childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information.	No
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes
F. Internet or similar network activity	Browsing history, search history, information on interaction with a website, application, or advertisement.	Yes
G. Geolocation Data	Physical location or movements.	No
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 CFR Part 99).	Education records directly related to a student maintained by an educational intuition or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from any of the information identified in the categories above	Information generated that could be used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No
L. Sensitive personal information	Personal information that reveals: – A consumer’s social security, driver’s license, state identification card, or passport number; – A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; – A consumer’s precise geolocation; – A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; – A consumer’s genetic data; – The processing of biometric information for the purpose of uniquely identifying a consumer; – Personal information collected and analyzed concerning a consumer’s health. – Personal information collected; and analyzed concerning a consumer’s sex life or sexual orientation.	Yes

Trulioo does not collect sensitive personal information for the purpose of inferring characteristics about consumers. You can refer to the How does Trulioo collect and use my personal information? section of the Website Privacy Policy and What types of personal information do we use? section of the Services Privacy Policy for more information.

2. Sources of Personal Information

We may collect or receive personal information from a number of sources, including:

Directly from you (e.g., forms you complete on this website)
Indirectly from you (e.g., from observing your actions on our website, including by the use of cookies – review our Cookies Policy for more information)
From our customers (where permitted by our customers and applicable law) in connection with our Services – see our Services Privacy Policy for more information.

3. Purposes for Collecting Personal Information

When you visit our website or interact with us, we may collect your personal information during the activities, and for the purposes, described below:

When you subscribe to our newsletter
When you download a white paper, register for a webinar, request a demo, or request a conversation
When you apply for a job
When you submit questions and feedback
For website analytics and advertising

You can refer to the How does Trulioo collect and use my personal information? section of the Website Privacy Policy for more information.

In relation to our Services, where permitted by our customers and applicable law, we may use certain information collected in connection with our document verification services for our own internal purposes in order to develop and improve that service and our proprietary technology. For these limited product improvement purposes, Trulioo will be the “controller” of your personal information. You can refer to the Product development and improvement section of the Services Privacy Policy for more information.

We do not sell or share your personal information for monetary or other valuable consideration. However, some uses of cookies and similar tracking technologies via our website may be considered “selling” or “sharing” (for cross-context behavioral advertising) under California law. To exercise your right to opt-out of the “selling” or “sharing” of your personal information, visit our Cookies Policy, click “Cookie Settings,” then select your cookie preferences. We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of anyone under 16 years of age.

Categories of personal information disclosed that may be considered “sale” / “sharing”: Identifiers, Internet or similar network activity, Geolocation Data.
Categories of third parties to whom personal information was disclosed that may be considered “sale”/ “sharing”: advertisers and marketing partners, data analytics providers, and social media networks.

You may also opt-out by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC) (if your browser/browser extension supports such a signal). For more information on the GPC and to download a compatible browser, visit https://globalprivacycontrol.org/orgs.

5. Disclosing Personal Information for Business Purposes

During the 12-month period prior to the “Last Updated” date of this Notice, we may have disclosed your personal information with third parties for specific business purposes. You can refer to the To whom does Trulioo disclose my personal information? section of the Website Privacy Policy and Services Privacy Policy for more information.

6. Retention of Personal Information

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Notice, but no longer than as required or permitted under applicable law or internal Trulioo policy.

7. Your Rights and Choices

You can make certain requests regarding your personal information, and we will honor requests received to the extent required by applicable law. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.

Right to Know. You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you.
Right to Deletion. You have the right to request that we delete personal information that we have collected about you. Note if you have requested a service that requires the use of your personal information, we may not be able to provide that service if you choose to delete your personal information.
Right to Correct. You have the right to request that we correct inaccurate personal information that we have collected about you.
Right to Opt-Out. You have the right to opt-out of the “sale” of personal information about you for monetary or other valuable consideration, and the “sharing” of personal information about you for cross-context behavioral advertising. See the Sale and Sharing of Personal Information section of this Notice for more information.

To exercise the rights described above, send us an email at [email protected].

Once you have submitted your request, we will respond within the time frame permitted by the applicable law. Please note that we may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.

We do not discriminate against California residents who exercise any of their rights described in this Notice.

8. Verifying Your Identity

We take steps to verify your request before we can provide personal information to you, correct or delete personal information, or otherwise process your request. To verify your request, we may require you to provide your name, physical address, email address, contact information, and information about your account or previous transactions with us.

9. Using an Authorized Agent

You may designate an authorized agent to submit a request on your behalf and to exercise your rights for you. Your agent may contact us at [email protected] to make a request on your behalf. Even if you choose to use an agent, we will require documentation demonstrating your agent’s authority to submit requests on your behalf (e.g., a valid power of attorney or other documentation, including a letter, signed by you (the California resident) authorizing the agent to submit your requests).

10. Notice of Financial Incentive

If we provide a financial incentive, your participation is entirely optional, and we will provide you with the additional details, including how the incentive is related to your personal information before you participate. You will always be able to withdraw from participation and we will provide you with directions on how to withdraw.

11. How to contact us

You can contact us at [email protected] with any questions or comments about this Notice or about how we handle your personal information. Our mailing address is:

FAO Privacy Office
Trulioo Information Services Inc.
400 – 114 E 4th Ave
Vancouver, BC V5T 1G2
Canada