We at Truly Wireless, Inc. (“Truly Wireless”), are committed to protecting the privacy of customers and users of our Truly Wireless services, users of our website, trulywireless.com and users of our mobile application. We have therefore created this policy statement (the “Policy”) to explain our privacy practices and procedures, including:
We believe that you should know what information we collect from you, as well as understand how we use, disclose, and protect that information. We believe that you should be able to communicate with us easily to limit the disclosure of any of your personally identifiable information, where practicable, and to address any questions or concerns that you may have. And we will not disclose information to unaffiliated third parties without your consent or as otherwise provided in this Policy.
By purchasing, subscribing to, or using Truly Wireless’s services or using Truly Wireless’s website, you agree to the terms and conditions set forth in this Policy. For other terms and conditions that govern your use of Truly Wireless’s services and its webSite, please review the Truly Wireless website.
We collect a variety of personally identifiable information (also referred to as “personal data”) about users of our services and visitors to our website in order to ensure an enjoyable user experience and seamless communications. When we use the term “personally identifiable information,” we mean information that is directly associated with, or could be used to identify, a specific person. Such information includes a name telephone number, e-mail address, or information about activities directly linked to that person which would permit the physical or online contacting of that person.
Our definition of personally identifiable information does not include “aggregate information”— data we collect about a group or category of services or users or customers and from which individual user or customer identities have been removed. Aggregate information—for example, a report that indicates that a certain number of our customers reside in a particular state or region of the United States, or a report on how many of our customers visited particular pages of our website—aids us in understanding trends and customer needs. For example, aggregate information allows us to consider new services or tailor existing services to customer preferences, and to provide aggregate statistics to customers, potential customers, and business partners.
Our definition of personally identifiable information also does not include your Internet protocol (“IP”) address, unless you have registered with us in the “Preferences” section of our website, in which case your IP address is linked to your personally identifiable information.
We collect the following types of personally identifiable information through use of our website and telephone calls to Truly Wireless customer service:
Truly Wireless does not knowingly collect—either actively or passively—any information, including personal information as defined by the Children’s Online Privacy Protection Act, from children under the age of 13.
To see how we use, disclose, and protect the personally identifiable information that we collect, please review the rest of this Policy.
Our Internal Use: In general, we use personally identifiable information to serve our existing and prospective customers and to enhance and extend our customer relationships. By understanding how you use our services and our website, we are able to customize and personalize our interactions with you. More specifically:
While you may choose not to receive marketing information from us, you will continue to receive bills, customer service-related notifications, and other similar information from us electronically or otherwise. You will also continue to receive communications directly related to each service you purchase or subscribe to.
Our Customer Surveys: Periodically, you may be able to participate in our surveys to help us improve our services. Any personally identifiable information that we may collect from you in a survey will ONLY be used internally by Truly Wireless. And unless otherwise explained in the instructions for a particular customer survey, any personally identifiable information you provide to us for purposes of that survey will be used in accordance with this Policy.
Third-Party Use: To understand when and how Truly Wireless may disclose personally identifiable information to unaffiliated third parties, please read the Disclosure of Your Personally Identifiable Information section below
Because information about our existing and prospective customers is one of our most important business assets, we seek to protect it and keep it confidential. We do not share personally identifiable information with unaffiliated third parties, nor do we sell it to third parties, unless permitted to do so in accordance with this Policy.
Your Consent: Truly Wireless may disclose your personally identifiable information if you consent to the disclosure in advance. Depending on the service, we may obtain your consent in a number of ways, including:
In general, we may release personally identifiable information without your consent when we believe release is appropriate to do one of the following:
Disclosure to Affiliates: We may share your personal data between our Truly Wireless group companies and business affiliates where it is necessary to support the services provided to you.
In order to verify payment methods and prevent fraud, Truly Wireless verifies personally identifiable information, including payment information, with payment providers and fraud prevention services. If at any time you apply for a credit line with Truly Wireless, Truly Wireless may perform a credit inquiry with credit reporting agencies, and such inquiry may be noted on your credit record. We may use automated decision making systems to verify payment methods, assess creditworthiness, or prevent fraud, and we may contact you requesting additional information when needed.
For European Economic Area (“EEA”) customers, this may mean that the personally identifiable information (i.e., personal data) you provide us may be transferred to countries outside the EEA. By way of example, this may happen if any of our group servers or companies are located in a country outside the EEA, such as Truly Wireless, Inc., which is located in the United States. These countries may not have similar data protection laws to the EEA. Nonetheless, if we transfer information outside the EEA in this way, we will take steps to ensure your privacy rights continue to be respected.
Disclosure to Unaffiliated Third Parties: We may share personally identifiable information with unaffiliated third parties only as necessary to complete a transaction or perform a service that you have requested, or to support the technical operation and maintenance of our services and of our website. We may also share personally identifiable information with or to our agents, outside vendors or service providers to perform functions on our behalf. For example, we use third party service providers to perform functions such as analyzing data, providing marketing assistance, providing customer service and processing orders. When the unaffiliated third party acts solely on our behalf, Truly Wireless requires that party to follow our privacy practices. Truly Wireless does not sell its customer lists or any personally identifiable information associated with its customers to third parties.
Business Transfers: Information about our users and customers, including personally identifiable information, may be disclosed as part of any merger, acquisition, or sale of company assets. It may also be disclosed in the unlikely event of an insolvency, bankruptcy, or receivership in which personally identifiable information would be transferred as one of the business assets of Truly Wireless.
In the normal course of providing telecommunications and interconnected voice-over-Internet-protocol (“interconnected VoIP”) services to its users and customers, Truly Wireless collects and maintains certain customer proprietary network information (“CPNI”). Your CPNI includes the types of telecommunications and interconnected VoIP services you currently purchase or subscribe to, how you use those services (for example, your calling records), and billing information related to those services. Your Truly Wireless telephone number, name, and address do not constitute CPNI.
Truly Wireless would like to share your CPNI within our company and with our affiliates and authorized agents in order to offer you additional products and services that may fit your needs. Truly Wireless does not sell, trade, or otherwise share your CPNI with anyone outside of Truly Wireless or with anyone who is not authorized to represent us to offer our services or to perform functions on our behalf, except as the law may require or you may authorize.
Protecting your CPNI is important to us. In the United States, Federal law permits us to use this information to provide the telecommunications and interconnected VoIP services you purchase or subscribe to, and to bill and collect for those services. We may also use or disclose your CPNI for legal or regulatory reasons such as to respond to a court order, to investigate fraud, to protect our rights or property, to protect against the unlawful use of our services, or to protect other users. You have a right and we have a duty under federal law to protect the confidentiality of your CPNI.
In order to opt-out and restrict access to your CPNI for our own marketing purposes, please email email@example.com within 30 days of this notice. Restricting our use of your CPNI will not affect our provision of any service or product to which you currently subscribe, nor will you necessarily eliminate all types of Truly Wireless marketing.
We maintain a variety of physical, electronic, and procedural safeguards to guard your personally identifiable information and CPNI. Specifically, we use commercially accepted procedures and systems to protect against unauthorized access to our systems. We restrict access to your personally identifiable information and CPNI to those employees and contractors—all of whom are covered by this Policy—who need to know that information to provide services to you or otherwise assist you. We protect the security of your personally identifiable information during transmission via the Truly Wireless website by using Secure Sockets Layer (“SSL”) software, which encrypts information you input, so that no one else can read it as it is transmitted over the Internet.
You can take additional steps on your own to safeguard your personally identifiable information. For example, you should be sure to sign off when finished using a shared computer. And you should always log out of any website, including the Truly Wireless website, after viewing personal account information, such as the “Settings” section of our website.
Please be advised that Truly Wireless has no control over or responsibility for the security or privacy policies or practices of other sites on the Internet you might visit, interact with, or from which you might buy products or services, even if you visit them using links from the Truly Wireless website.
Cookies allow us to do the following:
We also use a session-based cookie to maintain continuity of navigation for you when viewing our website during a particular online session. After closing the browser, the session cookie simply terminates; it is not stored on your computer’s hard drive thereafter.
Truly Wireless does not use technology that recognizes “Do Not Track”’ signals from your browser. You can block cookies from your computer through your web browser’s settings (see below).:
Truly Wireless uses web beacons on its website. A web beacon (sometimes called a “web bug” or “clear GIF”) is a tiny graphic image (usually a 1-by-1 pixel) displayed in a webpage, web-based document, or e-mail message, but it is usually invisible, as it is usually the same color as the background of the webpage, document, or e-mail message. When the user’s web browser reads the HTML code for the web beacon to retrieve the image, it can pass along the IP address of the user’s computer, the time the web beacon was viewed and for how long, and the type of browser used. Web beacons can also be linked to a user’s cookies and any personally identifiable information that may be stored in them.
Truly Wireless uses web beacons to gather aggregate information, as described above in Information We Collect. Truly Wireless does not use web beacons that link to cookies or to personally identifiable information on unaffiliated third-party websites. And it does not permit unaffiliated third parties to place such web beacons in advertisements on Truly Wireless’s website.
Truly Wireless customers can review or change the information in the “Settings” section of our website, or by telephoning or writing to Customer Service. As noted in the Information We Collect About You section above, we may also use updated address information obtained from other sources to update our records. We will respond to your requests to access your records within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services contact us.
If you choose to use our referral programs to refer someone to our site, we will ask you for the intended recipient’s name, email address, and phone number. Truly Wireless will store and use this information to send emails inviting him or her to visit the site. Truly Wireless stores this information for the sole purpose of sending the emails and tracking the success of our referral program. Your referral may contact us at firstname.lastname@example.org to request that we remove this information from our database.
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
With your input and your consent, we may post a customer testimonial by you on our website, which may include your name, industry, company, title, or other identifying information. If you want your testimonial removed please contact us at firstname.lastname@example.org.
Truly Wireless will revise or update this Policy if our practices change or as we change existing services, add new services, or develop better ways to inform you of services we think will interest you. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. You should refer back to this page for the latest information and the effective date of any changes.
If you have any questions, comments or concerns about this Policy, please e-mail us at
Truly Wireless is committed to the policies set forth in this Policy.