Last modified: October 22, 2019

Introduction

Truly Nolen of America, Inc., and its affiliates and subsidiaries (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (the “Privacy Policy”).

Our Privacy Policy describes the types of information we may collect from you (or that you may provide), including when you access or use www.trulynolen.com, including any content, functionality, and services offered on any of its pages or affiliated sites (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Our Privacy Policy applies to information we collect:

• On, through, or from our Website;
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy;
• When you request, order, or purchase any information, products, or services from the Company (not on, through, or from our Website); and
• In email, text, other electronic messages, and other communications between you and the Company.

It does not apply to information collected by:

• By any other means, including on, through, or from any other website operated by any third-party or offline; and
• Any third-party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible on, through, or from our Website.

Please read our Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with anything in our Privacy Policy, you must not access or use our Website. By accessing or using our Website, you agree to our Privacy Policy. Our Privacy Policy may change from time to time (see the Changes to Our Privacy Policy section). Your continued access or use of our Website after we make changes is deemed to be acceptance of those changes, so please regularly check our Privacy Policy for any changes.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Website. We do not knowingly collect personal information from children under age 13. If you are under age 13, do not use or provide any information on our Website, use any features of our Website, register to use any part of our Website, make any purchases through our Website, or provide any information at all about yourself, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received personal information from a child under age 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@trulymail.net or 432 South Williams Boulevard, Tucson, Arizona 85711.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, or any other information our Website collects that is defined as personal or personally identifiable information under any applicable law, and any other identifier by which you may be contacted online or offline;
• That is about you but individually does not identify you, such as any inquiries or requests for information that are submitted through our website, including but not limited to inquiries regarding the types and quantities of services we provide; and
• About your internet connection, the equipment you use to access our Website, and other usage details.

We collect this information:

• Directly from you when you provide it to us; and
• Automatically as you navigate through our Website, including usage details, IP addresses, and information collected through cookies and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide in your access and use of our Website, including but not limited to information provided at the time of registering to use our Website, requesting further services, when you report a problem with our Website, or when you request, order, or purchase any information, products, or services from the Company;
• Records and copies of your correspondence (including email addresses), if you contact us;
• Your responses to surveys that we might ask you to complete for research purposes;
• Details of any transactions you carry out through our Website and of the fulfillment of your orders, which may include financial information; and/or
• Your search queries on our Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns including:

• Details of your visits to our Website and the resources that you access and use on our Website, including traffic data, location data, logs, and other communication data; and/or
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third-parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Website according to your individual interests;
• Recognize you when you return to our Website; and
• Otherwise enhance your access and use of our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website;
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings, see the Choices About How We Use and Disclose Your Information section; and
• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on our Website are provided, served, and managed by third-parties. These third-parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third-parties’ tracking technologies or how they may be used. If you have any questions, please contact us at info@trulymail.net or 432 South Williams Boulevard, Tucson, Arizona 85711.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you;
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• To notify you about changes to our Website or any products or services we offer or provide though it;
• To provide you with notices about your account;
• To notify you of promotions and sales;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. For more information, see the Choices About How We Use and Disclose Your Information section.

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in our Privacy Policy:

• To any subsidiaries and affiliates of the Company;
• To contractors, service providers, and other third-parties we use to support our business and who are bound by contractual or other legal obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information; and
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply the Terms of Use and any other agreements, including for billing and collection purposes; and
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information including:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly;
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our products or services, you can opt-out at any time by sending us an email stating your request to info@trulymail.net. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

Google Maps

Our Website includes Google Maps features and content and the use of Google Maps features and content is subject to the current versions of the: Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html and Google Privacy Policy at https://www.google.com/policies/privacy/.

Accessing and Correcting Your Information

You may also send us an email at info@trulymail.net to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

California Civil Code sections §§ 1798.83-1798.84 permit users of our Website that are California residents to request certain information regarding our disclosure of personal information to third-parties in certain situations. To make such a request, please send an email to info@trulymail.net or write us at 432 South Williams Boulevard, Tucson, Arizona 85711.

For Users in the European Union

Under EU Regulation 2016/679 of the European Parliament and the Council; the General Data Protection Regulation (“GDPR”), if you are a user interacting with our Website as a resident of the EU, you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country of residence within the EU. You can exercise any of these rights by contacting us through our help center or the details in the contact us section below:

The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.

The right of access. You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law. You can do this by writing us on the email address below.

The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in personal information that we hold by writing us on the email address below.

The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing. You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

The right to data portability. You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however and there are exceptions.

The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other services we provide which we think may be of interest to you or being contacted with varying potential opportunities). You may change your preferences regarding email communications by sending us an email stating your request to info@trulymail.net.

The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

The right to withdraw consent. If you have given your consent to anything we do with your personal data (i.e we rely on consent as a legal basis for processing your personal information), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal information at any time.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

Users from the European Economic Area (“EEA”) or the EU

If you are based in a country in the EEA or EU and we hold personal information about you as a data controller, the controller of your personal information is Truly Nolen of America, Inc., a(n) Arizona corporation, whose principal place of business is located at 432 South Williams Boulevard, Tucson, AZ, 85711, U.S.A.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account. The date our Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about our Privacy Policy, please send an email to info@trulymail.net or write us at 432 South Williams Boulevard, Tucson, Arizona 85711.