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Website Privacy Policy

Last Updated: November 2023

This Website Privacy Policy (“Privacy Policy”) sets out the privacy practices related to the use by Trulioo Information Services Inc. and our affiliates (“Trulioo“, “we“, “our“, “us“) of the personal information of our customers, potential customers, employment applicants, and visitors to our website at www.trulioo.com.

Trulioo provides identity verification and related online services to our customers (such as banks, online marketplaces and payment providers). In doing so, we process the personal information of our customers’ end users on behalf of our customers. For more information about how we process personal information in connection with our online services, please refer to our Services Privacy Policy.

If you are a California resident, you may have certain additional privacy rights and you should visit our California Privacy Notice for more information.

1.  How does Trulioo collect and use my personal information?

When you subscribe to our newsletter

We collect your name, company email address, company name, and industry directly from you in order to be able to provide you with important product and industry news via email.

Our legal basis for using this personal information is your consent, which we obtain when you subscribe online. You may unsubscribe at any time via the link in the footer of our emails.

When you download a white paper, register for a webinar, request a demo, or request a conversation

We collect your name, company email address, phone number, company name, industry, and job title directly from you when you complete a form on our website.

In some cases we provide you with a free text field so that you can submit comments to us. We ask that you do not provide additional personal information in these fields.

We use your name and contact information to send the white paper, register you for the webinar, or reach out to you to discuss our products and services or demos. We use information about your role and company to better understand our customers and potential customers and their interests in our services. Our legal basis for processing your personal information for these purposes is our legitimate interest which includes promotion of our business, industry and services in response to requests from our existing or potential customers.

If you have indicated that you wish to receive marketing communications when you submit a form online, we will also use your personal information to provide you with additional information about products, services, events and resources. Our legal basis for such outreach is your consent and you may unsubscribe at any time via the link in the footer of our emails.

When you apply for a job

If you chose to apply for a job at Trulioo using Trulioo’s online application forms, we will request the following information from you:

  • your name, email address, and phone number (so that we can contact you about the role, request more information or invite you to an interview)
  • a copy of your CV / resume, a cover letter and (if applicable) a link to your website or LinkedIn profile (so that we can assess your qualifications and suitability for the role)
  • your location / ability to relocate for the position and whether you require visa sponsorship in connection with the role (so that we can assess your eligibility for the role and timescale for onboarding)
  • your salary expectations (in order to assess whether we can adequately meet your expectations)
  • any special accommodations that may need to be made for you in connection with the interview process (to ensure that we can meet and welcome you in a manner that is suitable for your needs)
  • your preferred pronouns (so that we ensure to address you per your preferences)

You may also chose to apply for a role using the “Apply with LinkedIn” button, in which case your application will be pre-populated with the information published on your LinkedIn profile. As noted above, we will use this information to determine your qualifications and suitability for the role. 

We may also obtain your personal information from third parties such as recruiting firms.

Our legal basis for processing this information is our legitimate interests, which include the identification of suitable candidates for our job openings and providing equal opportunities to job applicants or, where applicable, our legal obligations, for example providing a safe place of work and avoiding unlawful discrimination.

As a general rule, during the recruitment process, we try not to collect or process any personal information that is categorized as “sensitive” under data protection laws (also known as “special categories” of personal information). However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some sensitive personal information for legitimate recruitment-related purposes: for example, information about your health or disability status in order to provide appropriate accommodations for you during the interview process. We process such information where authorized by law or where necessary to comply with applicable law.

When you submit questions and feedback

If you contact us with questions or feedback, we will use your contact information (name and business email address) to respond to you. We may record and store logs and transcripts of the communication to keep track of what we discussed and for quality and training purposes.

Our legal basis for using your contact information and storing our communication with you is our legitimate interests, which include maintaining and improving customer relationships, ensuring a high level of customer support and promoting our business and services.

For website analytics and advertising

When you visit our website, we automatically collect certain information such as IP address, geographic region, type of web browser, and information on what pages you visit. This information is used to help us analyze visitor traffic, perform statistical analysis, improve the site to provide a better experience for you, to improve our products and services and inform our business strategy. We collect this information using various types of technology including cookies and similar technologies. A cookie is a small text file sent to your device when you visit our website.

More information on the types of cookies used on our website and their purposes can be found in our Cookie Policy.

2. How does Trulioo share my personal information?

Trulioo uses some tools, apps and third party services to help us manage our business: things like managing customer interactions, communicating with you, and storing data (including personal information). If these tools are provided by third party vendors, we perform due diligence and use contractual measures to safeguard your data. Categories of third party vendors with whom we share your personal information, include:

  • information technology infrastructure providers (to host, provide and support our online services);
  • data analytics providers (to analyze market trends and deliver insights that inform our business strategy) ;
  • customer service support providers (to provide efficient and user friendly support options);
  • providers of professional services, including legal, accounting, auditing, advisory (where necessary in order to support our business administration).

Additionally, in the course of operating our business, we may need to provide personal information to:

  • members of the Trulioo group of companies, only for the purposes outlined in this Privacy Policy;
  • any competent law enforcement body, regulatory, government agency, court or other third party (e.g., our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • a buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy; or
  • any other person with your consent to the disclosure (obtained separately from any contract between us).

3.  How does Trulioo protect my personal information?

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures are designed to provide a level of security appropriate to the risk of processing your personal information. For example: (i) we only work with trusted technologies and vendors who are bound by contractual obligations to protect your personal information and who are assessed for information security risk prior to onboarding, (ii) we limit the number of people who can access your information to people who need to know as part of their job, (iii) we provide training to our employees on data privacy and information security; and (iv) we have in place reasonable security defenses, including malware protections, vulnerability management and recovery resilience measures. 

4. Does Trulioo transfer my personal data internationally?

Trulioo is headquartered in Canada, with offices in the United States, Ireland and Denmark, as well as employees globally. Our third party vendors operate in a number countries around the world including the United States. This means that we may process your personal information in and transfer your personal information to countries outside of the country in which you are based. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Where we transfer your personal information to countries and territories outside of the European Economic Area, Switzerland and the UK, which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission or Swiss authorities, or the “adequacy regulations” (data bridges) from the Secretary of State in the UK. In 2001, the European Commission recognized Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) as providing adequate protection for European personal data. The decision is available here. Accordingly, for transfers of European personal information to Trulioo in Canada, Trulioo and its customers can rely on the European Commission’s adequacy decision. 

Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy and applicable laws. The safeguards we use to transfer personal information are the European Commission’s Standard Contractual Clauses (and similar measures in the UK and Switzerland).

5. For how long is my personal information retained by Trulioo?

We retain the personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested, as part of an ongoing recruitment process, or to comply with applicable legal, tax or accounting requirements). 

In certain circumstances, we may need to keep your information for legal reasons after our contractual relationship has ended. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement.

For example, we will retain your information:

  • Where we are made subject to a legal obligation to do so (e.g., where we are subject to a court order or legal hold);
  • Where we require access to your information in order to effectively deal with and resolve requests or complaints (e.g., where there is an ongoing complaint with respect to a service we have provided);
  • To evidence compliance (e.g., we may be required to retain information about a data subject access request after the request is dealt with in case there is a subsequent complaint and the information is needed to demonstrate how the request was handled);
  • In connection with litigation or regulatory matters (e.g., we would retain your information if there was an ongoing legal claim and the information was relevant to the claim; this information would be retained until the legal claim had been concluded); or
  • Following the conclusion of your recruitment process, (i) in case of a successful application, in which case your personal information may be retained as part of your employment file, or (ii) in case of an unsuccessful application, in which case your personal information may be retained so that we can make you aware of other opportunities which may be of interest to you (where you have indicated that you would like to hear from us in this way).

When we have no ongoing legitimate business need or legal reason to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6.  Your email marketing and cookie choices

E-mail

You can opt out of marketing communications from Trulioo at any time by clicking “unsubscribe” at the bottom of the e-mail or sending us a note at [email protected]. We will stop sending you marketing and promotional emails, but we will still respond to questions or requests and communicate with you about your account.

Tracking and cookies

Trulioo’s website incorporates a few commonly used tools for user experience and advertising purposes. These tools are often referred to as “cookies”, but may also include similar technologies (herein, we refer to cookies to describe technologies that collect or store information about you based on your browsing patterns and information you provide). Cookies record language preferences, for example, or let users avoid logging in each time they visit a site. Cookies can be very useful because without them, you would have to enter certain bits of your personal information each time you visit your favourite site.

Trulioo uses cookies that are necessary to make our website function, to improve performance, and to understand how you interact with our site. Some of our vendors use third party cookies or other digital markers to help us maintain and improve our websites and deliver interest-based advertising. 

For more information please review our Cookie Policy.

7.  Your rights

Depending on where you are located and subject to applicable privacy laws, your rights regarding your personal information (which you may exercise by sending us an email at [email protected]) may include the following:

The right to access information we hold about you

We will provide you with a copy of your personal information that we hold in an understandable format.

You also have the right to ask us about:

  • the categories of personal information we’re processing
  • the purposes of personal information processing
  • the categories of third parties to whom the personal information may be disclosed
  • how long the personal information will be stored (or the criteria used to determine that period)
  • your other rights regarding our use of your personal information

The right to request we correct any inaccurate personal information about you

We will correct your personal information and where your personal information is processed by a third party on our behalf to manage our business, we will notify them of your request.

The right to request we transfer your personal information to another entity

We will transfer your personal information to another organization, provided that we process the personal information with your consent or we have a contract with you, and where our processing is automated.  We will tell you if we are unable to meet your request.

The right to be “forgotten” by us

Depending on the circumstances, you may have a right to request that we delete your personal information from our systems and we will make commercially reasonable efforts to have your information deleted from our partners’ systems.

Where your right to deletion has arisen, there may still be some circumstances in which we are unable to comply (including where our retention of the information in question is subject to any mandatory retention specified under financial or other legislation or is needed to complete the transaction for which it was collected). If we cannot comply with a deletion request, we will provide the reason why.

The right to object to processing and require the restriction of processing

In certain circumstances, you may have the right to object to Trulioo’s processing of your personal information, or request that Trulioo restrict that processing. These rights may be limited where Trulioo is permitted or required by applicable law to continue processing the data, in which case we will inform you of the basis for our continued processing. 

Please note that all requests under the rights listed above may require verification procedures in order to validate your identity as required by applicable law. Any such additional information requested will be used only to validate your identity. We will endeavor to respond to your request within 30 days. Where an exemption applies (for example, where complying with a request would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights), we will tell you if we can’t meet your request for that reason. We will also inform you if we require additional time to fulfil your request, for example where the request is complex, and additional time is permitted under applicable law.

If we have collected and processed personal information with your consent, you may withdraw that consent at any time using the contact information provided below, under the heading “How to contact us“. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to the date you withdraw consent, nor will it affect any processing based on lawful grounds other than consent.

The right to lodge a complaint regarding our use of your personal information

You have the right at any time to make a complaint about our use of your personal information and we will do our very best to resolve any concerns you may have. You may also lodge a complaint with your local data protection authority or regulator.

8.  Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, regulatory, technical or business developments.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

9.  How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details:

Email: [email protected]

You may also write to us at the following address:

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

Or, if you are located in Europe:

FAO Privacy Office
Trulioo (Ireland) Limited
1st Floor, 40 Molesworth Pl.
Dublin 2 D02 K023
Ireland

You may contact our Data Protection Officer by email at [email protected].