• in order to provide the services and fulfill our obligations pursuant to our Terms of Service.  For example, we cannot provide our services without an email address to sign into your account, conduct customer support, or send educational materials; we cannot provide the service without users providing financial information on which the TrueView system is based;

• where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
• to protect your vital interests, or those of others, such as in the case of emergencies;
• where you have made the information public;
• where necessary in the public interest;
• where necessary for the purposes of TrueView's or a third party’s legitimate interests, such as those of visitors, members or partners;
• where you provide consent (for example, to join email mailing lists).​

We also process your data based on our legitimate interest in:

• providing quality service and in improving that service;

• ensuring the services are secure;

• protection against fraud, spam, and abuse, etc.;

• understanding of how clients and visitors interact with our websites and services so that we can continuously improve the experience and effectiveness of doing so.

Categories of the data we collect

We collect information about you, including information that directly or indirectly identifies you, through your use of TrueView. We do so:

• when you provide the information, through filling out forms or otherwise providing information on our websites and apps;

• when we connect to your financial institutions in order to retrieve transaction data on your behalf through Plaid our API service ("Plaid");

• when you correspond with us to receive customer support via email or chat.

This includes:

• The email address that you provide to us as a username.

• The phone number you enter during the onboarding process for account creation, authentication and text communication services.

• Your credit card information to process monthly or yearly payments as decided by you.

• Your IP address when you interact with our website and apps.

• When you chose to directly link financial accounts to TrueView, Fincity stores your login credentials (including usernames and passwords) for the accounts you link to our services, account security and/or challenge questions for those accounts, and other information from the financial accounts that you link to our service (including account balances, transactions, and holdings).  See Plaid's security policy at plaid.com/en-eu/security/.

• Records and copies of your correspondence (including e-mail addresses different than that used to establish your account), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out with TrueView and of the fulfillment of your orders.

• Information that you provide by filling in forms on our website or app. This includes information provided at the time of registering to use our app, subscribing to our app, or requesting further services. We may also ask you for information when you report a problem with our Website or app.

• To provide you with customer support or service offerings, including responding to and resolving your inquiries and requests via email or text-based chat. When you request assistance from our customer support team with respect to importing third-party financial account data, to allow a customer support representative to review a limited amount of data from recent transactions for the sole purpose of facilitating technical implementation of the account aggregation services. When asked to do so by you, our customer support representative may utilize that transaction data on your behalf in interactions with third-party financial account providers intended to facilitate implementation of requested account aggregation within our services.

Plaid (our API service)

TrueView provides notice that use of the TrueView app gives any consent required for Plaid to process end user information in accordance with Plaid's privacy policy. 

Cookies and technical data

TrueView may collect information as visitors and clients browse and interact with the website and/or apps.

Site visitors

When you visit our website, we may place a cookie on your browser so that our system can recognize you when you make a return visit. Third parties may also place cookies on your browser for targeted advertising purposes. That cookie allows us to recognize your browser on a return visit. We do not otherwise collect or process data when you are a visitor.

Signed-in Users

To help analyze how you and other visitors navigate the TrueView website and app, and compile aggregate statistics about site usage and response rates, we, with assistance from third-party analytics service providers (described below), collect certain information when you visit our site. This information includes IP address, geographic location of the device, browser type, browser language, date and time of your request, time(s) of your visit(s), page views and page elements (e.g., links) that you click, and other similar data. We may use cookies, pixel tags, and tracking scripts on our site or in our email messages to assist us in collecting and analyzing such information. We use this information to provide better, more relevant content on our site, to measure the effectiveness of advertisements, to identify and fix problems, and to improve your overall experience on our site.

Recipients of personal data

We do not sell users’ data.  We share data to fulfill the purposes for which you provide it; to enforce or apply our Terms of Service, including billing. We may disclose or transfer personal information that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our business, in particular providing infrastructure and analytics services, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• With respect to aggregating your banking and other financial accounts, we will transmit your account credentials to third-party aggregation partners, who will use them to gather and maintain your account balances, transactions, and holdings used to provide our services.

• 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 our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

• To fulfill the purpose for which you provide it.

• In aggregated form, and/or information that does not identify any individual.

• For any other purpose disclosed by us when you provide the information.

• 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 our Terms of Service or terms of sale and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TrueView, LLC, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Categories of third-party providers

Categories of services used to process data include:

Infrastructure & Fulfillment 

TrueView partners with third-parties to provide storage and server access that acts as infrastructure for our website and apps. In addition, we partner with third-parties to fulfill payments and transactions in fulfillment of our terms.

Aggregation

TrueView partners with third-parties to aggregate financial information from your financial institutions when you request it.

Analytics

TrueView partners with third-parties to help us monitor and analyze website traffic and can be used to keep track of user behavior, helping us to improve the services and experience of using them.

Customer Support

TrueView partners with third-parties to help us receive, process, and respond to customer support requests, as customer support and education are a core part of the services offered.

Performance and Logging

TrueView partners with third-parties that assist us in monitoring the stability of the website and applications and resolving issues or errors with the service.

Marketing

TrueView partners with third-parties to manage receipt of consent to send marketing emails and sending those same emails.

Data retention

We retain account data for a period of time after an account expires, whether through trial expiration or subscription expiration.

Automated data processing

In conjunction with a third-party payment processor, we use automated analysis to screen for suspicious or fraudulent transactions.

When we make solely automated decisions that affect you in a legal or a significant way, you have the right to provide your point of view and have those decisions reviewed by a member of our staff.

Children under the age of 13

TrueView is not intended for children under 13 years of age.  No one under this age may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on TrueView or on or through any of its features, register on TrueView, make any purchases through TrueView, use any of the interactive or public comment features of TrueView or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 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.

Your rights

We have established a number of procedures to help you manage your personal data.

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Deletion

Requests to delete personal data will be subject to any applicable legal and ethical reporting or document filing or retention obligations with which TrueView must comply. In all other cases, TrueView will keep personal data only as long as is reasonably required for the processing of the purpose for which the personal data were collected and in accordance with any applicable legal or ethical reporting or documentation retention requirements. TrueView reserves the right to delete unsubscribed accounts after 120 days of inactivity.

Adjust notification and email preferences

TrueView offers various ways to manage the communications you receive. You can choose to unsubscribe from emails and lists by following the instructions contained at the bottom of each type of email. Any administrative or service-related emails (to confirm a purchase, or an update to this Privacy Policy or the Terms of Service, etc.) generally do not offer an option to unsubscribe as they are necessary to provide services you requested.

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Updating account information

You may correct, amend, or update your email and/or password at any time by adjusting that information in your account setting.  You may cease aggregation of transactions from your financial institutions at any time through the individual account settings in the TrueView app.

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California Privacy Rights

California Civil Code Section § 1798.83 permits users of TrueView that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

TrueView has not and does not transfer information to third parties for direct marketing purposes.

Transfers

TrueView is operated from the United States. If you are located outside of the United States and choose to use TrueView or provide information to us, you acknowledge and understand that your information will be transferred, processed, and stored in the United States, as it is necessary.

TrueView LLC, Security Policy (last modified 8/7/2023)

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Security and protection of your data are a top priority for us.  We use the highest industry standards and spare no expense in ensuring your data is safe.

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Our development office and API service are all managed, supervised and operated here in the USA.

Network Encryption

All information transferred over the web can be read like a children's book unless we scramble it using encryption. We enforce a strict level of encryption, similar to banks (SSL /TLS1.2), on all requests to our apps as well as all data requested or sent by the apps.

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Data Encryption

All data stored with us is encrypted using an advanced standard (AES-256) or better. The encryption is done with symmetric keys and we also encrypt the keys and change them regularly.

In addition, we double encrypt extra sensitive data like names and passwords.

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Server and Database Access

We limit the number of people who have access to production data and we protect that access using two factor authentication.

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Server Firewall

Any server on the web can try to connect to any other server on the web. A firewall allows us to prevent connections for all servers except our own. All TrueView servers are protected by separate firewall layers.

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Server Updates

The internet and all software on it is undergoing a constant stream of updates. These updates often include bug fixes and security fixes. Keeping up with these changes is something that is built into our process, in fact, every time we deploy code changes, our servers are re-built from scratch to include many of these fixes automatically.

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Code Management

As we add new features or edit existing ones, we're constantly making changes to the code. After these changes are tested, they are also reviewed by senior level developers. Once approved, these changes are never directly transferred from a developer's computer to a live server, but they're submitted to a code repository where they're reviewed again and built from scratch before they're pulled from there to a production environment.

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Plaid

We use Plaid a leading API service in the United States as the bridge between our app and our clients financial institutions.  For information on the security practices of Plaid please visit plaid.com/en-eu/security/.