Privacy Policy

Truly’s Privacy Notice

Last Modified Date: August 20, 2020

PLEASE READ THIS PRIVACY NOTICE CAREFULLY.

Scope

This Privacy Notice details how Truly’s (“we” “us” “Truly’s” or the “Company”) will collect, use, disclose and protect personal information (“Personal Information”) obtained from: (a) visitors to our website and to our store; and, (b) customers who order our products online or via telephone.  This Notice also describes the rights that you have with respect to such Personal Information. 

IMPORTANT:  At this time, Truly’s offers its products at its store in Wellesley, Massachusetts.  Online orders are available for in-store pick-up only.    Thus, this Privacy Notice applies only to the Company’s practices with respect to Personal Information collected from individuals doing business with Truly’s in Massachusetts. 

What Is Personal Information 

Personal Information is defined differently by different laws.  However, generally speaking, it is a category of information that can be used to identify a person or a household or that can be reasonably associated with a person or household.  The specific data that qualify as Personal Information vary slightly depending on the state and country to which a law applies.  The following categories are examples of Personal Information in many (though not necessarily all) jurisdictions:

Categories of Personal Information and Examples of Data Elements

Personal Identifier:  Name, alias, postal address, unique personal identifier, online identifier, account name, social security number, driver’s license number, passport number, financial account number, or credit or debit card number

Personal Identifier:  Name, alias, postal address, unique personal identifier, online identifier, account name, social security number, driver’s license number, passport number, financial account number, or credit or debit card number

Internet or other electronic network activity information: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement

Geolocation information:  To disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection.

Truly’s Collection of and Purpose for Collecting Personal Information

Truly’s collects various categories of Personal Information.  Listed below are the sources from which the Company obtains Personal Information and the specific categories of Personal Information collected from each along with the purpose for collection.

The individual him/her/theirself:

Source of Personal Information

Website:  When you browse Truly’s website, we collect Personal Information about you if: (a) you choose to establish an online account; (b) you submit information in our “Contact Us” web form, and (c) you order our products online. Category and elements of personal information collected: Personal Identifiers such as: First name, last name, billing address, user name, email address, online password, credit card number, telephone number.

Telephone:  If you contact Truly’s via telephone, we may collect Personal Information about you in the course of our conversation.  Category and elements of personal information collected: Personal Identifiers such as:  First name, last name, billing address, credit card number, telephone number, email address.

In-Person:  If you visit our Wellesley storefront, we may collect Personal Information about you during your visit. Category and elements of personal information collected: Personal Identifiers such as:  First name, last name, billing address, credit card number, telephone number, email address.

Purpose for Collection: We collect Personal Information via our website, over the telephone and in-person in order to:

establish a personal account that enables you to do business with us, to fulfill your orders and process payment transactions, to communicate with you regarding promotions or events we offer, to respond to questions or concerns you may have, and/or for security purposes.

Operating systems and platforms:

Truly’s website collects certain Personal Information automatically when you visit the site, and stores it in log files.  See the Section below about “Cookies and Other Technology.” 

Details of how you used our Service from the personal information collected; Internet protocol (IP) addresses; Web pages viewed; Date and time; Domain type; Device event information such as crashes; System activity; Hardware; Settings; Browser type or version; Browser language; Referral URL; Region or general location from which your computer or device is accessing the internet.

Data Collection Through Cookies 

In addition to the above, we use “cookies” to collect Personal Information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.  

What Cookies Do We Use and Why

Truly’s website uses “first-party cookies”. These are cookies set and controlled by Truly’s and are used to:  store the preferences of our website visitors, to make our website function properly, and to authenticate you when you return to our website.

How You Can Manage Cookies

The cookies used on our website can be enabled or disabled through your browser. To disable cookies through your browser, follow the instructions usually located within the “Help,” “Tools” or “Edit” menus in your browser. Please note that disabling a cookie or category of cookies does not delete the cookie from your browser unless manually completed through your browser function.  Disabling cookies may impact your ability to use certain  

Truly’s Disclosure and Sale of Personal Information

Truly’s does not sell Personal Information.  Truly’s may disclose Personal Information as necessary or appropriate in connection with any of the purposes for which we use Personal Information.   

For our business purposes: We use third-party service providers (e.g., Clover Business Solutions) to process payment transactions.  That provider must comply with the principles set out in this Privacy Notice, and may only use the Personal Information received for the purposes for which it was provided to them.  Those third party service providers may use transaction data for the purpose of providing additional products and services to Truly’s, other merchants, or third parties. This includes using your cardholder information, dates, transaction details, and other transaction data to provide Truly’s with analytics products and services as well as collecting and using transaction data aggregated with other merchants’ transaction data to provide Truly’s, other merchants, and third parties with analytic products and services. We use a third party service provider, WPEngine, Inc., to design and facilitate the hosting of our website.  

For legal purposes: For instance, (i) to investigate, prevent or take action regarding actual or suspected illegal activities or fraud, situations involving potential threats to the physical safety of any person, or violations of our terms of use; (ii) to respond to or defend against subpoenas, court orders, or other legal process; (iii) to establish or exercise our legal rights; or (iv) to otherwise comply with applicable law.

As part of a corporate transaction: Truly’s may acquire other businesses, and other businesses may acquire us. If that occurs, the information, we collect would likely be one of the assets examined or transferred as part of the transaction. Truly’s will not permit another business to examine the information we have collected without a confidentiality agreement and only to the extent permitted by law. We will not transfer the information we have collected in this acquisition context unless the recipient agrees to provide privacy protections equal to or exceeding those established by this Privacy Notice.

Advertisers and Marketing

Your Choices and Controls

Marketing communications and sharing with third parties. If you want to opt out of receiving marketing communications from us, you may send us an email at manager@Trulys.com and request such. To opt out of receiving our email marketing communications, you can utilize the “unsubscribe” instructions provided in any marketing email you receive from us.  

Third-Party Links and Websites

Our website may contain links to third-party websites and services. While we endeavor to work with third parties that share our respect for user privacy, we are not responsible for the websites or privacy practices of such third-parties. You are responsible for knowing when you are leaving our website to visit a third party website, and for reading and understanding the terms of use and privacy policy statements for each such third party.

Children Under 13

Truly’s website is not directed to persons under 13. We do not knowingly collect Personal Information from children under 13. If you become aware that your child is accessing the website and providing Personal Information without your consent, please contact us via email or phone:

We will take steps to remove Personal Information from the Company’s servers and terminate the account should the Company determine that a child under 13 has provided Personal Information via the website.

Social Media and Community Platforms

Any information, communications, or material of any type or nature that you submit to the website (including, but not limited to any Company-specific pages on a social media platform such as Facebook, Instagram, or Twitter) by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy.  We cannot control the actions of other users of any third party social media platform or website.  By visiting our pages contained on a social media platform, you are representing and warranting to us that you have reviewed the applicable Privacy Notice and terms of use of such platform or website and that you will abide by all such provisions contained therein. We do not control who reads postings on our pages, or how they may use or disclose such information. If you choose to voluntarily disclose information, that information will be publicly available and can be collected and used by others. For example, if you post your e-mail address, you may receive unsolicited messages. 

Access to and Ability to Correct Your Information and to Opt Out

If the Personal Information that we maintain about you is incorrect, you may contact us via email or phone and request a correction.  By providing your Personal Information to us, you agree that we can communicate with you electronically regarding any security, privacy, business or administrative issues relating to your use of the website.  If, at any time after registering your Personal Information or after electing to register for an online account, you change your mind about receiving information from us, send us a request specifying your new choice via email or phone:

Privacy Choices

Choice to Opt-Out

If you would like to opt out of receiving periodic email communication from us (regarding company news, product and service information, etc.), you may do so by clicking the ‘Unsubscribe’ link provided at the bottom of those emails, or send an unsubscribe request to manager@trulys.com

“Do Not Track” and Targeted Ads

We do not respond to web browser “Do Not Track” signals. We do not serve targeted advertisements on our Site at this time. To learn more about browser tracking signals and “Do Not Track”, visit http://www.allaboutdnt.com.

How We Protect Your Information

Truly’s works hard to protect the Personal Information we process from unauthorized access, alteration, disclosure, or destruction, including by:

  1. maintaining a secure firewall configuration to protect data 
  2. encrypting the transmission of data sent across open/public networks, using methods indicated in the Payment Card Industry Data Security Standard (PCI DSS) 
  3. regularly updating anti-virus software and keeping security patches up-to-date 
  4. restricting access to data to those with a “need to know”
  5. regularly testing security systems and processes 
  6. maintaining a policy that addresses information security for employees and contractors
  7. restricting physical access to Personal Information
  8. securely destroying or purging all media containing Personal Information

Changes or Updates to this Privacy Notice

We reserve the right to revise or update this Privacy Notice at any time, and each update to the Privacy Notice will reflect the “Last Modified” Date.  Your interaction with the Company through the methods discussed in this Privacy Notice constitutes your assent to the terms contained herein.  You should periodically revisit the Privacy Notice to learn of any revisions or updates. 

In the event we materially change the way in which we use Personal Information, the Company will provide you with at least 30 days’ notice thereof.

If you have specific questions about this Privacy Notice, please e-mail us at Manager@Trulys.com

Contact Us

If you have questions or complaints about this Privacy Notice, or if you wish to exercise any of your rights in relation to your personal information, please email us at manager@trulys.com or write to us at:

Truly’s

Attn: Manager

35 Grove Street

Wellesley, MA  02482

Phone:    781-239-1356

We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.