Privacy Policy

1. Introduction

Welcome to TrueInfo, a platform operated by Consultancy Services, LLC ("TrueInfo," "Company," "we," "us," or "our") that connects clients seeking professional insight ("Clients") with subject-matter experts, survey respondents, and research participants ("Participants") (collectively, the "Service"). This Privacy Policy describes how we collect, use, share, and safeguard personal information when you access or use the Service, including our website, applications, tools, and related features.

By accessing or using the Service, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you may not access or use the Service.

2. Scope of This Policy

This Privacy Policy applies to all users of the Service, including Clients, Participants, and website visitors, and governs personal information that we collect and process as a controller.

When we process personal information on behalf of a Client in connection with a Client's research project (for example, survey or interview responses collected through the Service at a Client's direction), we act as a service provider or processor on behalf of that Client. The Client's own privacy policy governs the Client's collection and use of such information, and questions about a Client's handling of your information should be directed to that Client.

Where required by applicable law, or where requested by a Client, we will enter into a data processing agreement governing our processing of personal information on that Client's behalf. Copies of any such data processing agreements will be available upon request.

3. Personal Information We Collect

3.1 Information You Provide

We collect information that you provide directly to us, including:

• Account Information: name, email address, telephone number, postal address, and other contact information provided when you create an account or update your profile.
• Profile Information: professional background, demographic information, employment history, areas of expertise, LinkedIn or other professional-network profile information, and other information provided to facilitate participation in projects.
• Project and Research Information: information provided in connection with research studies or consulting engagements, including survey responses, interview content, and communications with Clients through the Service.
• Payment Information: billing and payment details, to the extent processed by us or our third-party payment service providers.
• Communications: information provided when you contact us for support, submit feedback, or otherwise communicate with us.

3.2 SMS and Text Messaging Opt-In Information

If you opt in to receive text messages from us (including through project- or study-specific recruitment pages), we may collect:

• Your first and last name and mobile phone number;
• Your SMS consent preference (whether, when, and how you agreed to receive messages);
• Your mobile carrier's name and the date, time, and content of messages sent to or received from us;
• Other information provided on opt-in or related forms, such as project invitation tokens or tracking parameters; and
• Participant identifiers linked to your opt-in so that we can connect your registration to your participation in a project.

We use this information to send informational and transactional messages, including project invitations, reminders, qualification steps, scheduling notices, and payment or account notifications. Message frequency may vary depending on your level of activity with the Service.

3.3 Information Collected Automatically

When you access or use the Service, we automatically collect certain information about your device and usage, including:

• Device Information: device type, operating system, web browser, unique device identifiers, IP address, and time zone.
• Usage Information: pages and features accessed, links clicked, referring or exit pages, search terms, time spent on the Service, and other interactions with the Service.
• Location Information: approximate geographic location derived from your IP address.

We collect this information using cookies, log files, web beacons, tracking pixels, and similar technologies. See Section 8 (Cookies and Tracking Technologies) below.

3.4 Information from Third Parties

We may receive information about you from third parties, including identity verification services, fraud-prevention services, and publicly available sources, to the extent permitted by applicable law.

3.5 Sensitive Personal Information

You are not obligated to provide us with personal information; however, if you choose not to provide certain information, your ability to access some features of the Service may be limited. You must not submit sensitive personal information through the Service — for example, Social Security numbers, racial or ethnic origin, political opinions, religious beliefs, health information, biometric or genetic data, criminal history, or trade union membership — unless we have specifically requested it in connection with a particular project and explained how it will be used and protected.

4. How We Use Your Information

We use the information we collect for the following purposes:

• Providing the Service: operating, maintaining, and delivering the Service, including matching Participants with projects, facilitating communications between Clients and Participants, processing payments, and administering accounts.
• Improving the Service: analyzing usage patterns, diagnosing technical issues, developing new features, and improving the quality and performance of the Service.
• Quality Assurance and Fraud Prevention: detecting, preventing, and addressing fraud, data-quality issues, security threats, and violations of our Terms of Service.
• Managing Contractual Relationships: fulfilling contracts with Clients and Participants and pursuing our legitimate business interests.
• AI and Automated Processing: operating artificial intelligence and automated tools used in connection with the Service, as described in Section 5.
• De-Identification and Aggregation: creating de-identified, aggregated, and derived data, as described in Section 6.
• Communications: sending service-related notices (including by SMS or similar messaging where you have opted in), responding to inquiries, and, where permitted, sending promotional communications, which you may opt out of as described in Section 13.
• Analytics and Advertising: analyzing trends, administering the Service, tracking user activity, gathering demographic information, and delivering relevant advertising.
• Legal Compliance: complying with applicable laws, regulations, and legal process, and enforcing our agreements and policies.

5. AI and Automated Processing

We use artificial intelligence, machine learning, and other automated tools in connection with the Service, including for data collection and interview or survey moderation, quality assurance and fraud detection, data analysis and pattern recognition, platform optimization and feature development, and the creation of de-identified, aggregated, and derived data.

Where AI or automated tools are used in a manner that could reasonably be perceived as human interaction — for example, AI-moderated interviews or AI-generated communications with Participants — we will disclose that use to affected individuals prior to, or at the start of, the interaction.

To the extent we use third-party AI or machine-learning providers in connection with the Service, we require by contract that such providers not retain or use personal information to train their own models, or for any purpose other than providing services to us.

6. De-Identified, Aggregated, and Derived Data

We may create de-identified data, aggregated data, and derived data from information processed through the Service. Once information has been de-identified or aggregated such that it can no longer reasonably identify any individual, household, or Client, it is no longer considered personal information under this Privacy Policy, and we may use it for any lawful business purpose, including service improvement, product development, analytics, benchmarking, industry reporting, and the creation of commercial data products.

We will not attempt to re-identify de-identified or aggregated data except as required by law or with the express consent of the applicable party.

7. How We Share Your Information

We may share your personal information in the following circumstances:

• With Clients: If you are a Participant, we may share your personal information (including profile information, application details, and professional-network profile information) with applicable Clients to facilitate your participation in a project.
• With Service Providers: We share information with third-party service providers who perform services on our behalf, including hosting, analytics, payment processing, fraud detection, and customer support. These providers are contractually required to use personal information only to provide services to us and to maintain appropriate security measures.
• With Affiliates: We may share information with our corporate affiliates — including any parent company, subsidiary, or company under common control — for purposes consistent with this Privacy Policy. Affiliates are required to honor this Privacy Policy.
• For Legal Reasons: We may disclose information where required by applicable law, regulation, subpoena, search warrant, court order, or other lawful request, or where we believe disclosure is necessary to protect the rights, property, or safety of the Company, our users, or others.
• Business Transfers: In connection with a reorganization, merger, acquisition, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. In bankruptcy, personal information may be treated as a business asset, and the receiving party may not be bound by the commitments in this Privacy Policy unless required by law. We will notify you of any such transfer to the extent required by applicable law.
• With Your Consent: We may share your information with third parties when you have given us consent to do so.
• Anonymized and Aggregated Data: We may share de-identified or aggregated information with third-party partners, such as advertisers and analytics providers, for relevant advertising and Service improvement, consistent with Section 6.

7.1 What We Do Not Do

We do not sell personal information to third parties for their own direct marketing purposes, and we do not share personal information for cross-context behavioral advertising except through the cookie and advertising mechanisms described in Section 8, which you may control through your browser or our cookie preferences. We do not share your telephone number or other personal information collected through your communications with us with third-party lead-generation services. SMS and text-messaging opt-in data, consent records, and related personal information will not be sold or shared with any third party or affiliate for their own marketing purposes, except as required by law or as needed to provide the Service itself (for example, an SMS delivery vendor operating under contract on our behalf).

8. Cookies and Tracking Technologies

We use cookies, log files, web beacons, tags, pixels, tracking pixels, and similar technologies to collect information about your interactions with the Service over time and across websites or online services. These technologies help us:

• remember your preferences and settings;
• authenticate your identity and maintain your session;
• analyze how the Service is used, track actions, and measure performance;
• screen for potential fraud and risk (for example, using IP address); and
• deliver relevant advertising and marketing communications based on your interests.

You can learn more about cookies generally at allaboutcookies.org and can control the use of cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when a cookie is being set; if you disable cookies, some features of the Service may not function properly. We may also use third-party analytics services, such as Google Analytics, to help us understand how the Service is used; you can opt out of Google Analytics at tools.google.com/dlpage/gaoptout.

9. SMS and Text Messaging Program

Where you have provided your mobile number and opted in, we may send SMS or similar text messages related to project invitations, screening and scheduling, account and transactional notifications, and customer support. Message frequency varies and may increase during active projects (for example, up to several messages per month). Message and data rates may apply depending on your mobile carrier and plan.

You may opt out of our text messages at any time by replying STOP to any message we send you. For help, reply HELP or contact us at the email address in Section 18. Opting out of SMS messages does not affect email communications you have separately agreed to receive, or information we must retain for legal, security, or research-integrity purposes.

10. Do Not Track

Most web browsers and some mobile operating systems include a Do-Not-Track ('DNT') feature that signals a preference not to have your online activity monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. We currently do not respond to DNT browser signals or other automatic tracking-choice mechanisms. We will revise this Privacy Policy if and when a legally required standard for online tracking is adopted.

11. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements and policies. The specific retention period depends on the nature of the information and the purpose for which it was collected.

Usage data collected automatically is generally retained for a shorter period, except where it is used to strengthen the security or functionality of the Service or where we are legally obligated to retain it longer.

When a Client's engagement with the Service ends, we will delete or anonymize the Client's project data from our active systems in accordance with our agreement with that Client, except that de-identified, aggregated, or derived data may be retained and used indefinitely as described in Section 6. When a Participant's account is terminated or deleted, we will deactivate or delete the Participant's personal information from active databases, except to the extent retention is necessary to comply with applicable law, prevent fraud or enforce our Terms of Service, resolve disputes, or maintain de-identified, aggregated, or derived data that no longer identifies the Participant.

12. Data Security

We implement administrative, technical, and physical security measures designed to protect personal information from unauthorized access, disclosure, alteration, and destruction, and we restrict access to personal information to personnel who require it to perform their job functions. While we take reasonable steps to protect your information, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your personal information.

In the event of a breach of personal information that triggers notification obligations under applicable law, we will notify affected individuals and any applicable regulatory authorities within the timeframes required by law.

13. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information under applicable privacy laws, including the right to:

• Know or Access the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes of collection, and the categories of third parties with whom we share it;
• Correct inaccurate or incomplete personal information;
• Delete personal information we hold about you, subject to certain legal exceptions;
• Port your personal information to another service, where technically feasible;
• Opt Out of the sale or sharing of personal information, targeted advertising, or certain profiling activities (we do not sell or share personal information for cross-context behavioral advertising, as defined under the CCPA);
• Restrict or Object to certain processing of your personal information; and
• Withdraw Consent where our processing is based on your consent.

We will not discriminate against you for exercising any of these rights. To exercise any of these rights, please contact us using the information in Section 18. We will verify your identity before processing your request and will respond within the timeframes required by applicable law. If you are unsatisfied with our response, you may have the right to appeal our decision or to lodge a complaint with your local data protection authority.

If you are a California resident, the rights described above are provided consistent with the California Consumer Privacy Act, as amended ("CCPA"). Our Privacy Preference Center, where available on the Service, provides information on managing "Do Not Track" and similar preferences.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases, as applicable: (a) your consent; (b) performance of a contract with you; (c) compliance with a legal obligation; or (d) our legitimate interests (such as operating and improving the Service, fraud prevention, and security), provided those interests are not overridden by your data protection rights. You have the right to lodge a complaint with your local supervisory authority if you believe your rights have been violated.

14. International Data Transfers

Your personal information may be stored and processed in any country where we maintain facilities or engage service providers, including the United States. By using the Service, you consent to the transfer of your information to countries outside your country of residence, which may have data protection laws that differ from those of your jurisdiction. Where required by applicable law, we will implement appropriate safeguards for cross-border transfers of personal information, such as standard contractual clauses or other legally recognized transfer mechanisms.

15. Children's Privacy

The Service is not directed to, and is not intended for use by, individuals under the age of 18 ("Children"). We do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us using the information in Section 18. If we become aware that we have collected personal information from a child without verified parental consent, we will take steps to remove that information from our systems.

16. Third-Party Websites and Services

The Service may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you visit.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. We will post the updated Privacy Policy on this page and update the "Effective Date" above. For material changes, we will provide notice before the change takes effect, which may include email notice, an in-product notification, or another conspicuous method. We encourage you to review this Privacy Policy periodically. Your continued use of the Service after the effective date of an updated Privacy Policy constitutes your acceptance of the updated policy.

18. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:

Consultancy Services, LLC (TrueInfo.com)
PO Box 6563
Denver, CO 80206
Email: support@trueinfo.com