Privacy & Security

Online Consumer Privacy and Security Policy

Last Revision Date: 07/09/2024

Welcome to the Truvion Consumer Privacy Notice, an essential guide to understanding how we handle your personal information while maintaining your privacy and security. We are committed to safeguarding your data and ensuring transparent practices. Below, we provide insights into the ways we collect, use, and share your information, along with the rights you possess in relation to your data.

1. Changes and Amendments to the Privacy Policy

Changes to our Privacy policy may occur routinely. We will notify you of these updates by posting the last revision date at the header of this policy. This notice will serve as the most recent revision.

2. Information Collection: What we Collect.  

Truvion takes pride in disclosing our information collection practices, which are designed to serve you better. We collect information in various scenarios. By engaging with Truvion and all/any of its subsidiaries, Affiliates and Non-Affiliates, you are providing consent for Truvion to obtain your information.

Information you have authorized Truvion to Collect.

• Personal Information: Full Name, Date of Birth, Social Security Number, Marital Status, and number of dependents, passport, and other government identification numbers.
• Profile Identifiers Data: Full name, alias, unique personal identifier, online identifier, and IP address, Username and Password, Social Media Profiles, Blogs, photos, videos, feedback, and any surveys.
• Contact and Mailing Information: Telephone Numbers, Email address, and Postal Address.
• Geographical Location: Street, City, County, State, and County with your IP Address.
• Demographic Details: Race, ethnicity, age, gender, and more, as per federal or state requirements.
• Property Insights: Home ownership status, property location, value, and images.
• Financial Information: Income, assets, liabilities, savings, investments, and bank account details.
• Employment and Education History: Professional background, education, and employment details.
• Insurance and Profile Data: Interests, preferences, and additional information you choose to provide.
• Communication engagement data, which may include conversations, messages, questions, social media post, blogs, and metadata.
• Your Contact information: With your consent, we access the information of your contacts by linking into our system. Upon your request, we can unlink the information provided.
• Your Business information: Upon obtaining information for your individual profile, Truvion may collect information about your business, which may include, but limited to, the business name, address, phone number, field of business, financials, employee count, and vendors relationships.

3. Information Collection: How We Collect.

A. Information provided by third party sources.

• When referred to us by our affiliates, joint ventures, or partners.
• Through interactions on third-party platforms, contests, promotions, or surveys.
• Inquiries for customer support or information about our offerings.
• Public Sources, Government agencies, Social Media Platforms, and any Public Record Resources.
• Non-Affiliates – Credit reporting Agencies, Public Sources, Data Providers, and Marketing Partners
• Communication through job applications, current employees, and former employees.

B. Automated Data Collection and Cookies

• Online and Mobile Activity: Data regarding your online actions, encompassing the pages or screens you observed, the duration of time spent on each page or screen, the site you accessed prior to visiting our website, the routes taken while navigating between pages or screens, particulars about your engagement on specific pages or screens, timestamps indicating access instances and the duration of such access, as well as insights into whether you have interacted with our email communications by opening them or clicking on embedded links.
• Location: We obtain location information of your device through your IP address
• Device Information: Information related to your device, including the operating system version and type, manufacturer, model, browser details, screen resolution, memory and storage capacity, CPU utilization, device categorization (like phone or tablet), IP address, distinctive identifiers (including those utilized for advertising aims), language configurations, mobile carrier details, radio and network specifics (such as Wi-Fi, LTE, 5G), and broad geographic indicators like city, state, or region.
• Cookies: compact textual files that are stored on users' devices, enabling web servers to capture users' browsing actions and retain their inputs, preferences, and login status during their site exploration. Our websites utilize various types of cookies, including "session cookies" which are erased at the end of a browsing session, "persistent cookies" with a longer lifespan, "first party" cookies implemented by us, and "third party" cookies provided by our external business associates and service providers.
• Pixel Tags: Are used to demonstrate that certain pages or emails are accessed and to confirm if content has been engaged in.
• Data Storage Systems: Our digital systems and strategies are designed to manage and organize data in a structured and efficient manner. These technologies encompass a range of methods, such as file systems, databases, and virtual storage, that enable the logical organization, retrieval, and manipulation of data on various computing platforms.
• Replay Technologies: Encompasses various tools for recording and analyzing user interactions on our digital platforms. They are employed solely to enhance user experience and identify areas for improvement. These technologies help us analyze user behavior, track navigation patterns, and troubleshoot technical issues.

4. Information Collection: Who we Share and Disclose it to.

• Amongst the Truvion Companies and Subsidiaries: Truvion Holdings, the central entity in our corporate structure, collaborates seamlessly with its diverse subsidiaries, including Truvion dba Truvion Capital, Truvion Insurance, Truvion Sentry, Truvion Tax, Truvion Partners, Truvion Technologies, Truvion Communications, Truvion Investments, Truvion Flow, and Truvion Initiative. This cooperative approach ensures that our operations remain aligned and consistent with the principles outlined in the Truvion Holdings Privacy Policy. By fostering this unity among the Truvion entities, we optimize the ability to provide you a comprehensive spectrum of services that cater to your evolving personal and financial requirements throughout various stages of your journey.
• Sharing with Affiliates: Sharing in a collaborative manner extends to our Affiliates within the Truvion network who engage as vendors, service providers, and consultants, utilizing personal information to execute services on our behalf. This encompasses endeavors such as call center and directory services. Moreover, our Affiliates within the Truvion network engage in the exchange of information for their distinct services and marketing endeavors. Regulatory reporting mandates and the tracking of performance metrics also prompt the interaction with our Affiliates. In instances where circumstances indicate the necessity, we may disclose information to our Affiliates under these circumstances: (1) if your actions deviate from our user agreements or policies, (2) in the event of a legal violation, or (3) for the safeguarding of Truvion's rights, property, user base, the general public, or others. Lastly, the sharing of information with Affiliates within the Truvion network finds its context in cases where your consent or directives guide the decision. To maintain privacy while fostering transparency, we also distribute aggregated or de-identified information, which inherently precludes the reasonable identification of individuals.
• Sharing with Third Parties and Non-Affiliates: Personal information communicated among Truvion's network of vendors, service providers, and consultants, encompassing those who access such information to carry out tasks on our behalf. These entities provide services such as, Web Hosting, Delivery Services, Payment Solutions, Fraud Prevention, Customer Support, Data Insights, Property Services, Technical Assistance, and Marketing Strategies, play a vital role in facilitating our operations. Should you contribute a product review or post content in another publicly accessible section of our Services, the dissemination of this information becomes a part of our public engagement. If you opt to engage with our integrations, such as the Google Maps feature, relevant data might be shared with the integration collaborators. Moreover, personal information is extended to third parties for their proprietary services, marketing initiatives, and analytics pursuits, at times combining efforts to present joint products and services. Requests for information regarding offerings from other companies might lead to the sharing of your information with these entities, enabling us or them to apprise you of suitable products or services. In alignment with legal obligations or mandates, we may disclose personal information, complying with lawful requests from public authorities in matters of national security or law enforcement. We also exercise discretion in sharing personal information, particularly (1) in response to actions inconsistent with our user agreements or policies, (2) to address potential legal violations, or (3) to uphold the well-being of Truvion, our user community, the general public, or any other stakeholders. Collaboration with legal representatives and professional advisors is another avenue through which personal information is shared when necessary to ensure sound advice and the protection of our business interests. Your explicit consent or directives, including third-party integrations of your choice, can prompt the sharing of personal information. Lastly, aggregated or de-identified information that doesn't reasonably identify individuals is also a facet of our information distribution. If you are part of an SMS short code offers program, your opt-in details and participation consent are not disseminated to external parties.
• We do not share or sell your personal information to third parties without your consent, except when legally required to do so. Personal information is shared within the Truvion family of companies and subsidiaries, as well as with our network of vendors, service providers, and consultants who perform tasks on our behalf, such as web hosting, delivery services, payment solutions, fraud prevention, customer support, data insights, property services, technical assistance, and marketing strategies. These entities are integral to our operations.
• If you contribute a product review or post content in publicly accessible sections of our services, this information will be publicly visible. Engagements with integrations, like Google Maps, may result in sharing relevant data with the integration partners.
• We do not share mobile information with third parties or affiliates for marketing or promotional purposes. This includes text messaging originator opt-in data and consent, which will not be shared with any third parties.
• In alignment with legal obligations, we may disclose personal information to comply with lawful requests from public authorities for national security or law enforcement purposes. Additionally, personal information may be shared to respond to actions inconsistent with our user agreements or policies, address potential legal violations, or uphold the well-being of Truvion, our user community, the general public, or other stakeholders. We also share personal information with legal representatives and professional advisors as necessary to obtain sound advice and protect our business interests. With your explicit consent or at your direction, including through third-party integrations you choose, your personal information may be shared.
• If you opt out of any solicitation or communication, please contact us at 877-778-5887.
• Lastly, aggregated or de-identified information that does not reasonably identify individuals is also a facet of our information distribution.

5. Usage of Your Information

Truvion employs the information we collect to enhance your experience and streamline various processes. Your data is used to:

• Determine your creditworthiness by pulling credit reports from credit bureaus.
• Assist underwriters in assessing loan requests within your financial context.
• Execute activities and transactions during lending, title, escrow, loan settlement, real estate transactions, Insurance, and other product and service processes.
• Maintain regular communication throughout application and stipulation processes.
• Enable affiliates and partners to communicate about loan settlement processes, real estate transactions, title insurance, and related services.
• Address any transaction-related issues or concerns.
• Inform you about available products and services.
• Facilitate automatic payments and fund transfers.
• Implement necessary collection activities.
• Meet with local state and federal regulatory obligations.
• Marketing and Solicitation
• Technology and application delivery
• Research and development

We also analyze your information to enhance our performance, increase user experience, and develop opportunity logs. Additionally, we may gather names and email addresses from those inquiring through our website, solely for the purpose of responding to inquiries.

6. Preservation of your information

Truvion upholds the confidentiality of your data, revealing it solely when mandated to do so by our essential partnership within lending, insurance, real estate, tax, legal, investments technology, or the provisioning of products and services. These partnerships encompass facets and services required to conduct operations of our entity.

Our retention of collected information aligns with the principles outlined in this Privacy Policy, persisting for the duration of your service use or as required to fulfill its initial purpose. This includes the resolution of disputes, the establishment of legal defenses, audit procedures, pursuit of legitimate business interests, agreement enforcement, compliance with prevailing laws, and the execution of other legal obligations.

Your data remains in our care for as long as your active account demands or until service requirements are met. We will utilize this data appropriately to fulfill our legal commitments, resolve disputes, and uphold the terms of our agreements.

Upholding the security of personally identifiable data is a paramount commitment. Our policies and processes are engineered to safeguard this information from unauthorized disclosure or misuse. Our security protocols encompass an intricate framework of physical, digital, and procedural measures to uphold the sanctity and confidentiality of your personal information. These measures include controlled access to your files, comprehensive building security programs, and advanced information technology security practices like password encryption, firewalls, virus prevention, and intrusion detection software. We consistently evaluate emerging technologies and adapt our physical and digital security systems to align with the latest advancements.

Employee access to your personal data is governed by a clear-cut policy, permitting access exclusively for business purposes such as administration, provision, or development of our products and services. Our company-wide code of conduct mandates all employees to prioritize the safeguarding of personally identifiable information concerning our consumers and customers, both present and past.

7. Security

Truvion employs rigorous measures to ensure the protection of your personal and sensitive data, employing industry-standard physical, digital, and procedural protocols. Data classified as highly confidential can solely be accessed or modified through designated service access points, which are safeguarded with password-based security. Our data's physical integrity is fortified through a fusion of network firewalls and servers equipped with rigorously tested operating systems, securely housed within a fortified facility. A tiered system of authorization, underpinned by a senior manager's oversight, regulates and grants access to both the physical and digital realms of our systems.

8. Information of Children

Truvion's offerings are designed for individuals aged 18 and above. We are committed to not intentionally gathering personal data from individuals under the age of 18. Should you be under 18, we kindly request that you refrain from providing any personal information via our Website, app, or services. If, by any chance, you suspect that we might have inadvertently obtained personal information from someone under 18, please reach out to us promptly at (877) 778-5887.

Furthermore, it's important to emphasize that we do not knowingly amass, distribute, or trade the personal information of minors under the age of 18.

9. Customer Complaints

At Truvion, your privacy is a matter of utmost importance, and we have established a dedicated protocol to address any apprehensions you may have concerning breaches of this Policy. If you suspect that we have not adhered to this policy regarding your personal information or if you have inquiries pertaining to your privacy with us, please don't hesitate to reach out to us at (877) 778-5887. Should you wish to report any instances of non-compliance with this Privacy Policy, kindly provide a comprehensive description of the matter, ensuring not to divulge sensitive details about yourself or any third parties involved. Your concerns will be handled with the utmost care and attention.

10. State-Specific Privacy Requirements

Truvion complies with state-specific privacy requirements to ensure your privacy is upheld as per local laws. Below are specific provisions for certain states:

California Residents:

We do not sell personal information under California law. Your data is shared only with your consent or as authorized by law. Additional choices for California residents to delete your personal information can be initiative through "Request to Delete information".

Vermont Residents:

We share information only as permitted by Vermont law, including transactions and experiences within our corporate family.

Nevada Residents:

You have the option to be placed on our internal Do-Not-Call List.

Your rights and privacy are of utmost importance to Truvion. For further details and to exercise your rights, kindly refer to the State-Specific Privacy Requirements section.

Truvion Holding and/or its subsidiaries.

Compliance Department

150 Paularino Avenue

Suite D-290

Costa Mesa, CA 92626

Nevada Law requires the following to be presented to obtain additional information

Office of Attorney General

100 North Carson St.

Carson City, NV 89701

Telephone: 775-684-1100

Email: AgInfo@ag.state.nev.us

Alaska, Illinois, Maryland, and North Dakota Residents:

Truvion will not share any personal / private information to nonaffiliates for the purposes of marketing without your prior consent and authorization.

Massachusetts, Mississippi, and New Jersey Residents:

Truvion will not share any person / private information share relationships with nonaffiliates for the purposes of marketing without your prior consent and authorization.

For any inquiries regarding your privacy or this Consumer Privacy Notice, please don't hesitate to contact us at (877) 778-5887 or privacy@truvion.com . We appreciate your trust in Truvion, and we are dedicated to preserving the security and privacy of your personal information.