We at TruFit (“TruFit,” “We,” “Us,” “Our”) know that You care about how information You (“You” or “Your”) provide to Us is used and shared, and We take Your privacy very seriously. This Privacy Policy relates to the information collection and use practices of TruFit in connection with the use of Our website, online platform, and services (together, the “Platform”).
We strive to educate You about how to appropriately safeguard Your privacy when using Our Platform. We are committed to complying with the EU General Data Protection Regulation (“EU GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), and any other local privacy acts to which We may be subject to.
By visiting or using Our Platform, You acknowledge that You have read and understood this Privacy Policy and the accompanying Terms of Use. If You do not agree with this Privacy Policy, you must discontinue use of Our Platform. Capitalized terms not defined in this Privacy Policy will have the meaning stated in Our Terms of Use.
1. Key Terms
It is helpful to start by explaining some key terms used in this policy:
Biometric Information
An individual’s physiological, biological, or behavioral characteristics, including information about an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric Information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information
Personal Information
Any information relating to an identified or identifiable individual
Sensitive Personal Information
Personal Information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, Personal Information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, Biometric Information, or citizenship and immigration status
Special category Personal Information
Personal Information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
TruFit, We, Us, Our
Includes TruFit Talent, TruYu Profile, TruYu Growth Report, TruTalent Match Score, TruTalent Matching, and TruTeam Insight Matrix, and any affiliated brands, products, or services we may introduce in the future.
2. Personal Information We Collect About You
The following table provides a comprehensive overview of the types of Personal Information We may collect, including Sensitive Personal Information, that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We update this information at least annually and more frequently if our data collection practices change substantially. Where We do not collect certain types of information, this is clearly indicated:
Identifiers
(e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
We DO collect the following types of information in this category:
- Real name
- Unique personal identifier in the form of a Username
- Email address
- Account name
- IP Address
We DO NOT collect the following types of information in this category:
- Alias
- Postal address
- Online identifier
- Social Security Number
Personal Identifiable Information
(Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information)
We DO actively request the following types of information in this category:
- Name
We DO NOT actively request the following types of information in this category, but this information may be within documents that You voluntarily upload to Our Platform (such as resumes):
- Signature
- Social Security Number
- Physical characteristics or description
- Address
- Telephone number
- Passport number
- Driver’s license or state identification card number
- Insurance policy number
- Bank account number
- Credit or Debit card number
- Any financial, medical, or health information
Account Credentials
(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)
We DO NOT collect any types of information in this category.
Protected Classifications
(Characteristics of protected classifications under applicable law)
We DO NOT collect any information in this category.
Commercial Information
(e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
We DO collect the following types of information in this category:
- Your purchase history with TruFit
- Products or services You may have considered based on Your IP address and the web pages You visited on Our website
We DO NOT collect the following types of information in this category:
- Records of personal property
- Products or services that You have purchased, obtained, or considered, or other tendencies related to third-party products
Biometric Information
We DO NOT collect any information in this category.
Internet or Other Electronic Network Activity Information
(e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement)
We DO collect the following types of information in this category:
- Browsing history, search history, and information regarding Your interaction with Our website, Our Platform, and/or advertisements
We DO NOT collect the following types of information in this category:
- Browsing history, search history, or information regarding Your interaction with any third-party websites, applications, or advertisements
Geolocation Data
We DO collect the following types of information in this category:
- Geographical location of the IP address used to access Our Platform
We DO NOT collect the following types of information in this category:
- Precise GPS coordinates from mobile devices
- Real-time location tracking
- Bluetooth or WiFi-based location tracking
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
We DO collect the following types of information in this category:
- Video, Audio and Text-based responses and communications (including speech-to-text functionality, if applicable)
We DO NOT collect the following types of information in this category:
- Photographs or images
- Thermal data
- Olfactory data
- Visual biometric data
Professional or Employment-Related Information
We DO collect the following types of information in this category:
- Job titles and work experience
- Skills and competencies
- Professional certifications and qualifications
- Career objectives and preferences
- Performance assessment results
- Professional references
- Industry experience and background
- Work-related preferences and requirements
We DO NOT collect the following types of information in this category:
- Salary or wage information from previous employers
- Disciplinary records or personnel files
- Performance reviews from previous employers
- Union membership status
- Workers’ compensation claims
Education Information
(defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA))
We DO collect the following types of information in this category:
- Educational degrees and certifications attained
- Schools and educational institutions attended
- Fields of study and academic majors
- Graduation dates and academic achievements
We DO NOT collect the following types of information in this category:
- Transcripts or detailed academic records
- Student identification numbers
- Disciplinary records from educational institutions
- Financial aid or tuition information
- Educational records obtained directly from schools or institutions without Your consent
Inferences
(Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)
We DO collect the following types of information in this category:
- Assessments of professional skills and competencies based on Your responses
- Evaluations of job fit and compatibility with potential positions
- Analysis of career preferences and work style indicators
- Professional aptitude assessments derived from Your provided information
- Job matching recommendations based on Your profile data
- Professional styles across style polarities
We DO NOT collect the following types of information in this category:
- Psychological profiling for non-employment purposes
- Personal lifestyle or behavioral predictions outside of work context
- Intelligence assessments unrelated to job performance
- Personality analyses for marketing or advertising purposes
- Predictive inferences about personal relationships or private life
Racial or Ethnic Origin, Religious or Philosophical Beliefs, Union Membership, or Citizenship or Immigration Status
We DO collect the following types of information in this category:
- Citizenship or immigration status (when required for employment eligibility verification)*
- Racial or ethnic origin
We DO NOT collect the following types of information in this category:
- Religious or philosophical beliefs
- Union membership status
* We may collect citizenship or immigration status information solely for the purpose of verifying employment eligibility and to match candidates with positions that align with their work authorization status.
Contents of Communications
(Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication)
We DO collect the following types of information in this category:
- Communications sent directly to Us through Our Platform (messages, emails, and other communications where TruFit is the intended recipient)
We DO NOT collect the following types of information in this category:
- Contents of Your personal emails with third parties
- Text messages between You and other parties
- Mail or communications where TruFit is not the intended recipient
- Private communications that do not involve TruFit
Genetic Data
We DO NOT collect any information in this category.
Processing of Biometric Information to Uniquely Identify a Consumer
We DO collect the following types of information in this category:
- Voice patterns from speech-to-text functionality (processed temporarily for conversion purposes, with data deleted within 24 hours after conversion)
- Fingerprint or facial recognition data for mobile app authentication (stored locally on Your device)
- Profile photographs when voluntarily uploaded
We DO NOT collect the following types of information in this category:
- Biometric templates for permanent identification purposes
- DNA or genetic biometric data
- Iris or retina scans
- Palm print or hand geometry data
- Gait pattern analysis for identification
Health Information
We DO NOT collect any information in this category.
Sex Life or Sexual Orientation
We DO NOT collect any information in this category.
* Potential employers (the “Hosts”) will require this information in order to determine whether You may be eligible for a visa in the Host’s country. Therefore, failing to provide this Personal Information may delay or prevent Us from providing services to You.
3. How Your Personal Information is Collected
We collect Personal Information from the following categories of sources:
- You, directly in person, by telephone, text, email, and via Our website
- Third party with Your consent (e.g., The Global Recruitment Collaborative)
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Cookies on Our website
4. How and Why We Use Your Personal Information
Under data protection laws, We can only use Your Personal Information if We have a proper reason for doing so, for example:
- To comply with Our legal and regulatory obligations;
- For the performance of Our contract with You or to take steps at Your request before entering into a contract;
- For Our legitimate interests or those of a third party; or
- Where You have given consent;
A legitimate interest is when We have a business or commercial reason to use Your information, so long as this is not overridden by Your own rights and interests.
The table below explains what We use Your Personal Information for and Our reasons for doing so:
To provide services to You
For the performance of Our contract with You or to take steps at Your request before entering into a contract
To prevent and detect fraud against You or TruFit
For Our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for Us and for You
Verifying the accuracy of user credentials and professional qualifications
For Our legitimate interests of ensuring the integrity of Our assessment platform and provide accurate results to You and potential employers
Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies
To comply with Our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use
For Our legitimate interests or those of a third party, i.e., to make sure We are following Our own internal procedures so We can deliver the best service to You
Operational reasons, such as improving efficiency, training, and quality control
For Our legitimate interests or those of a third party, i.e., to be as efficient as We can so We can deliver the best service for You at the best price
Ensuring the confidentiality of commercially sensitive information
For Our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information. To comply with Our legal and regulatory obligations
Statistical analysis to help Us manage Our business, e.g., in relation to Our financial performance, customer base, product range or other efficiency measures
For Our legitimate interests or those of a third party, i.e., to be as efficient as We can so We can deliver the best service for You at the best price
Preventing unauthorized access and modifications to systems
For Our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for Us and for You. To comply with Our legal and regulatory obligations
Updating and enhancing customer records
For the performance of Our contract with You or to take steps at Your request before entering into a contract. To comply with Our legal and regulatory obligations. For Our legitimate interests or those of a third party, e.g., making sure that We can keep in touch with Our customers about existing orders and new products
Statutory returns
To comply with Our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
To comply with Our legal and regulatory obligations. For Our legitimate interests or those of a third party, e.g., to make sure We are following Our own internal procedures and working efficiently so We can deliver the best service to You
Marketing Our services and those of selected third parties to: Existing and former customers; Third parties who have previously expressed an interest in Our services; Third parties with whom We have had no previous dealings
For Our legitimate interests or those of a third party, i.e., to promote Our business to former, existing, and prospective customers
5. Automated Decision-Making and AI Systems
We use artificial intelligence and automated decision-making technology (ADMT) to enhance Our Platform. This includes:
- AI-powered assessment scoring and analysis;
- Performance prediction models;
- Skills assessment automation;
- Behavioral pattern analysis during assessments.
The reports generated by Our ADMT, including skills assessments and compatibility scoring, may significantly affect Your employment opportunities.
We may use aggregated and anonymized data derived from user interactions to:
- Improve Our Platform and algorithms;
- Enhance the accuracy of Our Platform’s outputs;
- Develop new AI-powered features; and
- Train machine learning models.
We do NOT use Your Personal Information to train AI models that would be made available to third parties without Your explicit consent.
For Our ADMT systems, We provide:
- A plain language explanation of the logic used in Our AI processes;
- Information about how AI influences decision-making and the role humans play;
- Details about accuracy testing and bias mitigation measures We implement; and
- Information about the benefits and potential consequences of AI-driven decisions.
We regularly assess Our AI systems for potential discriminatory impacts, accuracy across different demographic groups, fairness in employment-related outputs, and Our technical safeguards against bias.
You have the following rights regarding Our ADMT and AI systems:
- Right to Opt Out. You have the right to opt out of certain automated decision-making processes and request human review of decisions that significantly affect You.
- Right to Explanation. You can request information about how Our AI systems work and how they reached decisions affecting You.
- Right to Human Review. You can request human review of automated decisions when reasonably feasible.
- Right to Opt Out of Profiling. You can opt out of automated profiling that produces legal or similarly significant effects.
- Right to AI Disclosure. We will clearly disclose when You are interacting with an AI system rather than a human.
6. EEA Data Subjects: Promotional Communications
We may use Your Personal Information to send You updates (by email, text message, telephone, or post) about Our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing Your Personal Information for promotional purposes (see above “How and why We use Your Personal Information”). This means We do not usually need Your consent to send You promotional communications. However, where consent is needed, We will ask for this consent separately and clearly.
We will always treat Your Personal Information with the utmost respect and never sell it to third parties for their marketing purposes. Any sharing of Personal Information with organizations outside the TruFit group will be done only as described in this Privacy Policy and in compliance with applicable laws.
You have the right to opt-out of receiving promotional communications at any time by:
- Contacting Us at connect@trufittalent.com or
- Using the “unsubscribe” link in emails or “STOP” number in texts
We may ask You to confirm or update Your marketing preferences if You instruct Us to provide further services in the future, or if there are changes in the law, regulation, or the structure of Our business.
7. Who We Share Your Personal Information With
We routinely share Personal Information with:
- Our affiliates, including companies within the TruFit group;
- Service providers We use to help deliver Our services to You, such as job posting platforms and employment forums, third-party software providers integrated into Our Platform, and technology service providers;
- Other third parties We use to help Us run Our business, such as marketing agencies or website hosts;
- Third parties approved by You, including social media sites You choose to link Your account to or third-party payment providers;
- Credit reporting agencies;
- Our insurers and brokers; and
- Our bank.
We only allow Our service providers to handle Your Personal Information if We are satisfied they take appropriate measures to protect Your Personal Information. We also impose contractual obligations on service providers to ensure they can only use Your Personal Information to provide services to Us and to You. We may also share Personal Information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with Our legal and regulatory obligations.
We may also need to share some Personal Information with other parties, such as potential buyers of some or all of Our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
8. Personal Information We Sold or Shared
In the preceding 12 months, We have sold or shared the following categories of Personal Information:
- Identifiers (e.g., a real name, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers);
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, education, employment or employment history, email, postal address, and signature;
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Biometric Information;
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement);
- Geolocation data;
- Audio, electronic, visual, thermal, olfactory, or similar information;
- Professional or employment-related information;
- Education information, defined as information that is not publicly available personally identifiable information as defined in the FERPA; and
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
9. Categories of Personal Information We Disclosed for a Business Purpose
In the preceding 12 months, We have disclosed the following categories of Personal Information for a business purpose:
- Identifiers (e.g., a real name, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers);
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, education, employment, or employment history;
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Biometric Information (if sharing assessment results that include this);
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement);
- Geolocation data;
- Audio, electronic, visual, thermal, olfactory, or similar information;
- Professional or employment-related information;
- Education information, defined as information that is not publicly available personally identifiable information as defined in the FERPA;
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
- Sensitive Personal Information.
10. How Long Your Personal Information Will Be Kept
We will keep Your Personal Information while You have an account with Us or while We are providing services to You. Thereafter, We will keep Your Personal Information for as long as is necessary:
- To respond to any questions, complaints or claims made by You or on Your behalf;
- To show that We treated You fairly; or
- To keep records required by law.
We will not retain Your Personal Information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of Personal Information.
When it is no longer necessary to retain Your Personal Information, We will delete or anonymize it.
11. California Consumers: Your Rights Under the CCPA/CPRA
You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know, and request disclosure of:
- The categories of Personal Information We have collected about You, including Sensitive Personal Information;
- The categories of sources from which the Personal Information is collected;
- The categories of third parties to whom We disclose Personal Information, if any; and
- The specific pieces of Personal Information We have collected about You.
Please note that We are not required to:
- Retain any Personal Information about You that was collected for a single one-time transaction if, in the ordinary course of business, that information about You is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
- Provide the Personal Information to You more than twice in a 12-month period.
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose
In connection with any Personal Information We may sell, share, or disclose to a third party for a business purpose, You have the right to know:
- The categories of Personal Information about You that We sold or shared and the categories of third parties to whom the Personal Information was sold or shared; and
- The categories of Personal Information that We disclosed about You for a business purpose and the categories of persons to whom the Personal Information was disclosed for a business purpose
You have the right to opt-out of the sale of Your Personal Information or sharing of Your Personal Information for the purpose of targeted behavioral advertising. If You exercise Your right to opt-out of the sale or sharing of Your Personal Information, We will refrain from selling or sharing Your Personal Information, unless You subsequently provide express authorization for the sale or sharing of Your Personal Information.
To opt-out of the sale or sharing of Your Personal Information, send email to connect@trufittalent.com requesting Do Not Sell or Share My Personal Information.
Right to Limit Use of Sensitive Personal Information
You have the right to limit the use and disclosure of Your Sensitive Personal Information to the use which is necessary to:
- Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
- To perform the following services: (1) Helping to ensure security and integrity to the extent the use of Your Personal Information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of Your current interaction with the business, if the Your Personal Information is not disclosed to another third party and is not used to build a profile about You or otherwise alter Your experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and
- As authorized by further regulations.
You have a right to know if Your Sensitive Personal Information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
To limit the use of Your Sensitive Personal Information, send an email to connect@trufittalent.com.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from You, We will:
- Delete Your Personal Information from Our records; and
- Direct third parties to whom the business has sold or shared Your Personal Information to delete Your Personal Information unless this proves impossible or involves disproportionate effort
Please note that We may not delete Your Personal Information if it is reasonably necessary to:
- Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by You, or reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform a contract between You and Us;
- Help to ensure security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for those purposes;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided We have obtained Your informed consent;
- Enable solely internal uses that are reasonably aligned with Your expectations based on Your relationship with Us;
- Comply with an existing legal obligation; or
- Otherwise use Your Personal Information, internally, in a lawful manner that is compatible with the context in which You provided the information
Right of Correction
If We maintain inaccurate Personal Information about You, You have the right to request Us to correct that inaccurate Personal Information. Upon receipt of a verifiable request from You, We will use commercially reasonable efforts to correct the inaccurate Personal Information.
Protection Against Retaliation
You have the right to not be retaliated against by Us because You exercised any of Your rights under the CCPA/CPRA. This means We cannot, among other things:
- Deny goods or services to You;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to You; or
- Suggest that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Please note that We may charge a different price or rate or provide a different level or quality of services to You, if that difference is reasonably related to the value provided to Our business by Your Personal Information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of Personal Information, the sale of Personal Information, or the retention of Personal Information.
12. EEA Data Subjects: Your Rights Under the EU GDPR
Right to Be Informed
You have the right to know or be notified about the collection and use of Your Personal Information
Right to Access
You have the right to be provided with a copy of Your Personal Information (the right of access)
Right to Rectification
You have the right to require Us to correct any mistakes in Your Personal Information
Right to be Forgotten
You have the right to require Us to delete Your Personal Information—in certain situations
Right to Restriction of Processing
You have the right to require Us to restrict processing of Your Personal Information—in certain circumstances, e.g., if You contest the accuracy of the data
Right to Data Portability
You have the right to receive the Personal Information You provided to Us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object
You have the right to object:
- At any time to Your Personal Information being processed for direct marketing (including profiling); and
- In certain other situations to Our continued processing of Your Personal Information, e.g., processing carried out for Our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making
You have the right to opt out of certain automated decision-making processes that produce legal or similarly significant effects, and to request human review of decisions that significantly affect You. You also have the right to receive meaningful information about the logic involved in automated decision-making, including AI systems, and the significance and consequences of such processing.
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the European Data Protection Board (EDPB) on individual rights under the EU General Data Protection Regulation.
13. How to Exercise Your Rights
If You would like to exercise any of Your rights as described in this Privacy Policy, You can do so by email at connect@trufittalent.com.
- Please note that You may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
- If You choose to contact Us directly via the URL provided above or by email, You will need to provide Us with:
- Enough information to identify You (e.g., Your full name, address and customer reference number (if applicable), any the organization with whom you engaged with (if applicable));
- Proof of Your identity and address (e.g., a copy of Your driving license or passport and a recent utility or credit card bill);
- A description of what right You want to exercise and the information to which Your request relates.
- We are not obligated to make a data access or data portability disclosure if We cannot verify that the person making the request is the person about whom We collected information or is someone authorized to act on such person’s behalf.
- Any Personal Information We collect from You to verify Your identity in connection with Your request will be used solely for the purposes of verification.
14. EEA Data Subjects: Where Your Personal Information is Held
Information may be held at Our offices in the United States and at third-party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some of these third parties may be based outside the EEA. For more information, including on how We safeguard Your Personal Information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”
15. EEA Data Subjects: Transferring Your Personal Information Out of the EEA
To deliver services to You, it is necessary for Us to share Your Personal Information outside the EEA, e.g.:
- With Our offices outside the EEA;
- With Your and Our service providers located outside the EEA;
- If You are based outside the EEA; or
- Where sharing the information outside the EEA is necessary to provide the services that You have requested.
These transfers are subject to special rules under European and UK data protection law.
If You would like further information, please contact Us Our Data Protection Officer (see “How To Contact Us” below).
16. Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. We limit access to Your Personal Information to those who have a genuine business need to access it. Those processing Your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify You and any applicable regulator of a suspected data security breach where We are legally required to do so.
17. EEA Data Subjects: How to File a GDPR Complaint
We hope that We can resolve any query or concern You raise about Our use of Your information.
The GDPR also gives You the right to lodge a complaint with a supervisory authority in the European Union member state where You work, normally live, or where any alleged infringement of data protection laws occurred. You can find information about Your local supervisory authority at: edpb.europa.eu/edpb_en.
18. Changes to This Privacy Notice
This privacy notice was published on 9.24.25 and last updated on [10.1.25].
We may change this privacy notice from time to time. When We make material changes to this Privacy Policy, We will inform You via a pop-up notification and request Your acknowledgement before You continue using Our services. The updated privacy notice will be effective upon Your acknowledgement or continued use of Our Platform after notification, whichever occurs first.
19. How to Contact Us
Please contact Us by mail, email, or telephone if You have any questions about this privacy policy or the information We hold about You.
Our contact details are shown below:
Mailing Address: 3722 N. Washington, Tacoma, WA 98407
Email: connect@trufittalent.com
Phone: +1 (253) 349-7766
20. Do You Need Extra Help?
If You would like this notice in another format (for example: audio, large print, braille) please contact Us (see “How to contact Us” above).