TRUVO ADS

PRIVACY POLICY

1. INTRODUCTION

Welcome to Truvo Ads ("we," "us," "our," or "Truvo"). We are committed to protecting your privacy and handling your personal information with care and transparency.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you:

Visit our website at truvoads.com (the "Website")

Use our subscription-based advertising management services (the "Services")

Communicate with us via email, phone, or other channels

Interact with our marketing materials and advertisements

By using our Website or Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Website or Services.

This Privacy Policy should be read in conjunction with our Terms of Service available at truvoads.com/terms.

2. INFORMATION WE COLLECT

We collect several types of information from and about users of our Website and Services.

2.1 Information You Provide Directly

Account Registration and Profile Information:

Full name

Email address

Phone number

Company name

Job title or role

Business website URL

Mailing address (if provided)

Password (encrypted)

Campaign Discovery and Service Information:

Business and product descriptions

Target audience information

Campaign objectives and goals

Budget information

Geographic targeting preferences

Current advertising platform usage

Marketing goals and KPIs

Creative assets and brand guidelines

Competitor information

Any other information you provide in forms, surveys, or communications

Communication Information:

Content of emails, messages, and other communications you send to us

Customer support inquiries and correspondence

Feedback, testimonials, and reviews

Responses to surveys or questionnaires

2.2 Payment Information

Payment Processing (Handled by Stripe):

We use Stripe, a third-party payment processor, to process subscription payments and programmatic media invoices. We do NOT directly collect, store, or have access to your complete payment card details.

Information Stripe collects on our behalf:

Credit/debit card numbers (tokenized)

Card expiration dates

CVV/security codes (not stored)

Billing address

Cardholder name

Information we receive from Stripe:

Last four digits of card number

Card brand (Visa, Mastercard, etc.)

Expiration date

Transaction IDs and payment confirmations

Payment status and history

Billing address

Stripe's use of your payment information is governed by their Privacy Policy, available at stripe.com/privacy.

Additional Payment Information We Store:

Invoice history and billing records

Payment dates and amounts

Transaction records for programmatic media purchases

Bank account information (if you choose ACH/wire transfer for media invoices)

2.3 Advertising Account Data

With your explicit permission and authorization, we access and collect data from your advertising accounts to provide our Services:

Self-Serve Platform Accounts (You Own and Control):

For self-serve advertising platforms, you own and maintain your advertising accounts. We access them as authorized users/partners:

Account Access Information:

Account credentials or access tokens (encrypted)

Advertising account IDs

Business Manager/Ads Manager access

Campaign Performance Data:

Ad impressions, clicks, and conversions

Audience demographics and interests

Ad creative performance metrics

Budget spend and pacing information

Cost per result metrics (CPC, CPM, CPA, etc.)

Campaign structure and settings

Custom audience data

Pixel and tracking data

Attribution and conversion path data

Self-Serve Platforms Where You Own Accounts:

Meta Business Manager (Facebook & Instagram)

Google Ads and Google Analytics

TikTok Ads Manager

Snapchat Ads Manager

LinkedIn Campaign Manager

X Ads (Twitter)

Pinterest Ads

Your Ownership Rights for Self-Serve Platforms:

You retain full ownership and control of these advertising accounts

You can revoke our access at any time

You maintain administrative rights and account ownership

All audiences, pixels, and account assets belong to you

Account ownership transfers with you if you leave our service

Programmatic DSP Accounts (Truvo Owns and Manages):

For programmatic advertising channels, we own and manage the DSP (Demand-Side Platform) accounts where multiple advertiser campaigns are managed:

Programmatic Channels Using Truvo-Owned DSP Accounts:

Connected TV (CTV) Ads

Audio/Streaming Audio Ads

Display Ads

Native Ads

Online Video (OLV) Ads

How Programmatic Account Access Works:

We manage your campaigns within our proprietary DSP accounts

You do not have direct login access to DSP platforms

We cannot transfer DSP account ownership to you

Campaign performance data and reporting remain accessible to you through our dashboards

Campaign settings, targeting, and creative are configured on your behalf

Your Data Rights for Programmatic Channels:

You own all campaign performance data and results

You receive full reporting and analytics for your campaigns

You can export performance data at any time

Creative assets you provide remain your property

Audience data derived from your campaigns belongs to you

Important Data Ownership Clarification:

For Self-Serve Platforms (Meta, Google, TikTok, etc.):

You retain full ownership of all advertising account data and assets

We access this data solely to provide campaign management services

We will never sell or share your account data with third parties (except as required to provide Services or by law)

You can take your accounts with you if you cancel our services

For Programmatic DSP Platforms (CTV, Audio, Display, Native, OLV):

You own all campaign performance data, results, and creative assets

The DSP account infrastructure is owned and managed by Truvo Ads

We will never sell or share your campaign data with third parties (except as required to provide Services or by law)

Campaign performance data is portable through our reporting and can be exported

While you cannot transfer DSP account ownership, you retain all valuable campaign insights and learnings

2.4 Automatically Collected Information

Website Usage Data:

When you visit our Website, we automatically collect certain information about your device and browsing behavior:

Device Information: IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution

Usage Information: Pages visited, time and date of visits, time spent on pages, links clicked, referring/exit pages, search terms used on our Website

Location Data: General geographic location based on IP address (city, state, country)

Cookies and Similar Technologies:

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your use of our Website and Services. See Section 8 for detailed information about our cookie practices.

2.5 Information from Third-Party Sources

We may collect information about you from third-party sources, including:

Advertising Platforms:

Campaign performance data from Meta, Google, TikTok, and other platforms where we manage your campaigns

Platform analytics and insights

Business Intelligence Tools:

Industry benchmarking data

Competitive analysis information

Market research data

Public Sources:

Publicly available business information

Company websites and social media profiles

Industry databases and directories

Referral Partners:

Information from partners who refer clients to us

Co-marketing partner data

2.6 Analytics and Tracking

We use the following third-party analytics and tracking services on our Website:

Google Analytics:

Website traffic and user behavior analysis

Demographic and interest data

Conversion tracking

See Google's Privacy Policy at google.com/policies/privacy

Meta Pixel (Facebook Pixel):

Website visitor tracking for retargeting

Conversion tracking for Meta advertising

Custom audience building

See Meta's Privacy Policy at facebook.com/privacy/policy

GoHighLevel:

CRM and marketing automation

Form submissions and lead tracking

Email and SMS communication tracking

See GoHighLevel's Privacy Policy at gohighlevel.com/privacy-policy

ClickUp:

Internal project management

Task and workflow tracking

Team collaboration

See ClickUp's Privacy Policy at clickup.com/privacy

TapClicks:

Dashboard and reporting platform

Client performance data aggregation

See TapClicks's Privacy Policy at tapclicks.com/privacy-policy

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

3.1 To Provide and Improve Our Services

Campaign Management:

Set up and configure advertising campaigns across multiple platforms

Optimize campaign performance through A/B testing and data analysis

Monitor and adjust budgets, bids, and targeting parameters

Build and manage custom audiences

Track conversions and measure campaign ROI

Provide performance reporting and insights

Account Management:

Create and maintain your Truvo Ads account

Manage your subscription and billing

Provide customer support and respond to inquiries

Send service-related notifications and updates

Process payments and invoices

Service Improvement:

Analyze usage patterns to improve our Services

Develop new features and functionality

Identify and fix technical issues

Conduct quality assurance and testing

Create anonymized benchmarks and industry insights

3.2 Communication and Marketing

Client Communication:

Respond to your questions and support requests

Send account updates and service notifications

Provide campaign performance updates

Share best practices and optimization recommendations

Conduct satisfaction surveys and collect feedback

Marketing Communications (with your consent):

Send newsletters and promotional emails

Share case studies, blog posts, and educational content

Invite you to webinars, events, or training sessions

Inform you about new features or service offerings

You can opt out of marketing communications at any time by clicking the "unsubscribe" link in emails or contacting us at [email protected].

3.3 Legal and Security Purposes

Comply with legal obligations and respond to legal requests

Enforce our Terms of Service and other policies

Protect against fraud, abuse, and security threats

Defend our legal rights and interests

Conduct audits and maintain business records

Resolve disputes and prevent prohibited activities

3.4 Analytics and Research

Analyze Website traffic and user behavior

Conduct market research and competitive analysis

Create anonymized, aggregated data for industry benchmarking

Develop insights to improve advertising strategies

Test and optimize Website performance

Note: When we use data for research or benchmarking, we aggregate and anonymize it so that it cannot identify you or your business.

4. HOW WE SHARE YOUR INFORMATION

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the following circumstances:

4.1 With Your Consent or at Your Direction

When you explicitly authorize us to share information

When you direct us to integrate with third-party services

When you provide permission to share case studies or testimonials

4.2 Service Providers and Business Partners

We share information with trusted third-party service providers who help us operate our business and provide Services:

Technology and Infrastructure Providers:

Stripe: Payment processing

GoHighLevel: CRM, marketing automation, and website hosting

ClickUp: Internal project management

TapClicks: Client dashboard and reporting platform

Cloud hosting providers: Data storage and server infrastructure

Email service providers: Transactional and marketing email delivery

Advertising Platform Partners:

Meta, Google, TikTok, Snapchat, LinkedIn, X, Pinterest: For campaign management and access to your advertising accounts (with your permission)

Programmatic partners: For CTV, Audio, Display, Native, and OLV media buying

Professional Services:

Legal counsel and accountants

Business consultants and advisors

Auditors and compliance partners

Important: All service providers are contractually required to:

Use your information only for the specific services they provide to us

Maintain appropriate security measures

Comply with applicable privacy laws

Not sell or share your information for their own purposes

4.3 Business Transfers

If Truvo Ads is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our Website before your information is transferred and becomes subject to a different privacy policy.

4.4 Legal Requirements and Protection

We may disclose your information when we believe in good faith that disclosure is necessary to:

Comply with applicable laws, regulations, legal processes, or government requests

Enforce our Terms of Service or other agreements

Protect the rights, property, or safety of Truvo Ads, our clients, or the public

Detect, prevent, or address fraud, security, or technical issues

Respond to claims of illegal activity or violations of third-party rights

4.5 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you or your business. This includes:

Industry benchmarks and performance statistics

Market trends and insights

Research findings and case studies

Platform comparison data

5. DATA PROTECTION AND SECURITY MEASURES

We take the security of your information seriously and implement appropriate technical, administrative, and physical safeguards to protect it.

5.1 Technical Security Measures

Encryption:

All data transmitted between your browser and our servers is encrypted using SSL/TLS protocols (HTTPS)

Payment information is tokenized and encrypted by Stripe

Passwords are hashed using industry-standard algorithms

Sensitive data is encrypted at rest in our databases

Access Controls:

Multi-factor authentication (MFA) for team member accounts

Role-based access controls limiting data access to authorized personnel only

Regular access reviews and credential rotation

Secure credential storage and management systems

Network Security:

Firewalls and intrusion detection systems

Regular security monitoring and logging

DDoS protection and rate limiting

Secure API authentication and authorization

Software Security:

Regular security updates and patches

Vulnerability scanning and penetration testing

Secure coding practices and code reviews

Third-party security audits

5.2 Administrative Safeguards

Team Training:

Privacy and security training for all team members

Confidentiality agreements with employees and contractors

Clear policies on data handling and protection

Incident response training and procedures

Vendor Management:

Due diligence on all third-party service providers

Data processing agreements with security requirements

Regular vendor security assessments

Monitoring of vendor compliance

Data Governance:

Data classification and handling procedures

Regular privacy impact assessments

Data retention and deletion policies

Documentation of data processing activities

5.3 Physical Safeguards

Secure cloud infrastructure with physical access controls

Data center security certifications (SOC 2, ISO 27001)

Redundant backups and disaster recovery plans

Secure disposal of physical media containing data

5.4 Limitations

No Security is Perfect:

While we implement robust security measures, no system is completely secure. We cannot guarantee absolute security of your information. You acknowledge and accept this risk when using our Services.

Your Responsibility:

Keep your password secure and confidential

Use a strong, unique password for your account

Enable multi-factor authentication if available

Report any suspected security breaches immediately

Keep your devices and software updated

Be cautious of phishing attempts and suspicious communications

5.5 Data Breach Notification

In the event of a data breach that compromises your personal information, we will:

Investigate the incident promptly

Take steps to mitigate harm and prevent further unauthorized access

Notify affected users without unreasonable delay (typically within 72 hours)

Notify applicable regulatory authorities as required by law

Provide information about the breach and steps you can take to protect yourself

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

6.1 Retention Periods

Active Accounts:

Account and profile information: Retained for the duration of your subscription plus 30 days after cancellation

Campaign performance data: Retained for the duration of your subscription plus 3 years for historical analysis and reporting

Communication records: Retained for 7 years for customer service and legal purposes

Closed Accounts:

After account closure, most personal information is deleted within 90 days

Some information may be retained longer for legal, tax, or regulatory compliance (typically 7 years)

Anonymized, aggregated data may be retained indefinitely

Payment and Financial Records:

Transaction records: 7 years (required for tax and accounting purposes)

Invoice history: 7 years

Payment dispute records: Retained until resolved plus 7 years

Marketing Communications:

If you opt out of marketing emails, we retain your email address on a suppression list indefinitely to honor your opt-out preference

Marketing engagement data: 3 years

6.2 Factors Affecting Retention

We consider the following factors when determining retention periods:

Legal and regulatory requirements (tax laws, business records laws, etc.)

Industry standards and best practices

The nature and sensitivity of the information

The purposes for which we collected the information

Whether we can achieve those purposes through less invasive means

Potential risks from continued storage

6.3 Deletion and Anonymization

When we no longer need your information:

We securely delete or anonymize it using industry-standard methods

Backups containing deleted data are overwritten within 90 days

Anonymized data that cannot identify you may be retained indefinitely

7. YOUR PRIVACY RIGHTS

Depending on your location, you may have certain rights regarding your personal information.

7.1 Rights for All Users

Access and Portability:

Request a copy of the personal information we hold about you

Receive your information in a structured, commonly used, machine-readable format

Request transfer of your information to another service provider

Correction and Updates:

Update or correct inaccurate or incomplete personal information

Most account information can be updated directly in your account settings

Deletion:

Request deletion of your personal information (subject to legal retention requirements)

Close your account and request removal of associated data

Objection and Restriction:

Object to certain processing of your information

Request restriction of processing in specific circumstances

Opt-Out of Marketing:

Unsubscribe from marketing emails at any time

Opt out of SMS marketing communications

Control cookie preferences (see Section 8)

7.2 Additional Rights for California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know:

Request disclosure of personal information we collect, use, and share

Request specific pieces of information we've collected about you

Right to Delete:

Request deletion of personal information we collected from you (subject to exceptions)

Right to Opt-Out:

Opt out of "sale" or "sharing" of personal information (Note: We do not sell personal information)

Right to Correct:

Request correction of inaccurate personal information

Right to Limit Use:

Limit use and disclosure of sensitive personal information

Right to Non-Discrimination:

Not receive discriminatory treatment for exercising your privacy rights

California "Shine the Light" Law:

Request information about disclosure of personal information to third parties for their direct marketing purposes (Note: We do not disclose personal information for third-party marketing)

7.3 Additional Rights for European Users (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

Legal Basis for Processing:

We process your information based on:

Contract: To fulfill our contractual obligations to provide Services

Consent: When you've provided explicit consent (e.g., marketing communications)

Legitimate Interests: For business operations, fraud prevention, and service improvement

Legal Obligation: To comply with applicable laws and regulations

Additional GDPR Rights:

Right to withdraw consent at any time

Right to lodge a complaint with a supervisory authority

Right to data portability in machine-readable format

Right to object to processing based on legitimate interests

Right to not be subject to automated decision-making (Note: We do not use automated decision-making)

Data Transfers:

If we transfer your data outside the EEA, we ensure appropriate safeguards through:

Standard Contractual Clauses (SCCs) approved by the European Commission

Adequacy decisions by the European Commission

Other legally approved transfer mechanisms

7.4 How to Exercise Your Rights

To exercise any of these rights, contact us at:

Email: [email protected]

Subject Line: "Privacy Rights Request"

Please include:

Your full name and email address associated with your account

Description of the specific right you wish to exercise

Any additional information to help us locate your records

Verification Process:

To protect your privacy and security, we will verify your identity before processing requests. We may:

Request additional identifying information

Ask you to log in to your account

Require verification through your registered email address

Response Timeline:

We will respond to verified requests:

Within 30 days for most requests

Within 45 days for GDPR requests (with possible 45-day extension if complex)

We will notify you if we need additional time

No Fee:

We do not charge a fee to process privacy rights requests unless they are excessive, repetitive, or manifestly unfounded.

8. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, web beacons, pixels, and similar technologies to collect information and improve your experience on our Website.

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and recognize you on return visits.

Types of Cookies We Use:

Essential Cookies (Required):

Session management and authentication

Security and fraud prevention

Load balancing and performance

Required for the Website to function properly

Cannot be disabled without affecting Website functionality

Functionality Cookies (Optional):

Remember your preferences and settings

Auto-fill forms with saved information

Customize your experience based on previous interactions

Analytics Cookies (Optional):

Understand how visitors use our Website

Measure traffic sources and popular content

Identify technical issues and errors

Help us improve Website performance

Advertising/Marketing Cookies (Optional):

Track conversions from our advertising campaigns

Build audiences for retargeting

Measure effectiveness of our marketing

Deliver relevant ads on other websites

8.2 Specific Tracking Technologies We Use

Google Analytics:

Purpose: Website analytics and user behavior tracking

Data Collected: Pages viewed, session duration, device information, demographics

Retention: 26 months (configurable)

Opt-Out: Available at tools.google.com/dlpage/gaoptout

Meta Pixel (Facebook Pixel):

Purpose: Conversion tracking and audience building for Meta advertising

Data Collected: Website visits, page views, button clicks, form submissions

Retention: Varies by event type

Opt-Out: facebook.com/settings?tab=ads

GoHighLevel Tracking:

Purpose: Form submissions, lead tracking, CRM integration

Data Collected: Form data, page visits, email interactions

Retention: Duration of business relationship

Session Cookies:

Purpose: Maintain your logged-in session

Data Collected: Session ID, authentication token

Retention: Deleted when you close your browser

8.3 Third-Party Cookies

Some cookies on our Website are set by third-party services:

Advertising platforms (for campaign attribution)

Social media plugins (if you interact with share buttons)

Embedded content (videos, maps, etc.)

These third parties may use cookies subject to their own privacy policies.

8.4 Managing Your Cookie Preferences

Browser Settings:

You can control cookies through your browser settings:

Chrome: Settings > Privacy and Security > Cookies

Firefox: Settings > Privacy & Security > Cookies

Safari: Preferences > Privacy > Cookies

Edge: Settings > Cookies and site permissions

Options:

Block all cookies (may affect Website functionality)

Block third-party cookies only

Delete cookies after each session

Receive notification before cookies are set

Cookie Consent Manager:

When you first visit our Website, you'll see a cookie consent banner allowing you to:

Accept all cookies

Reject non-essential cookies

Customize your cookie preferences

You can change your cookie preferences at any time by clicking the "Cookie Settings" link in our Website footer.

Do Not Track:

Some browsers have "Do Not Track" (DNT) features. Currently, there is no universal standard for how websites should respond to DNT signals. We do not alter our tracking practices in response to DNT signals.

Industry Opt-Out Tools:

Network Advertising Initiative: optout.networkadvertising.org

Digital Advertising Alliance: optout.aboutads.info

European Interactive Digital Advertising Alliance (EU): youronlinechoices.eu

9. CHILDREN'S PRIVACY

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children.

If we discover we have collected information from a child under 18:

We will delete that information as quickly as possible

We will terminate any associated account

We will not use or share that information

If you believe we have collected information from a child under 18, please contact us immediately at [email protected].

Parental Rights:

Parents or guardians who believe their child has provided us with personal information may:

Request access to that information

Request deletion of that information

Refuse to permit further collection or use

Age Verification:

By using our Services, you represent that you are at least 18 years old or the age of majority in your jurisdiction.

10. INTERNATIONAL DATA TRANSFERS

Truvo Ads is based in the United States. If you access our Services from outside the United States, your information will be transferred to, stored, and processed in the United States.

10.1 Data Transfer Safeguards

For users outside the United States, we implement appropriate safeguards for international data transfers:

Standard Contractual Clauses (SCCs):

We use European Commission-approved SCCs for transfers from the EEA/UK

SCCs provide legal protection for your data when transferred to the US

Adequacy Decisions:

We rely on adequacy decisions where available (e.g., EU-US Data Privacy Framework if certified)

Other Safeguards:

Binding corporate rules for internal data transfers

Certification under recognized privacy frameworks

Encryption and security measures during transfer

10.2 Your Consent to Transfer

By using our Services, you consent to the transfer of your information to the United States and other countries where we or our service providers operate.

10.3 Data Protection Rights

Regardless of where your data is processed, you retain all privacy rights described in Section 7 of this Privacy Policy.

11. THIRD-PARTY LINKS AND SERVICES

Our Website and Services may contain links to third-party websites, applications, or services that are not operated by us.

We are not responsible for:

Privacy practices of third-party websites or services

Content or accuracy of third-party sites

Data collection by third parties

Security of third-party platforms

Examples of third-party links:

Advertising platform login pages (Meta, Google, TikTok, etc.)

Social media profiles and share buttons

Partner websites and resources

Payment processor (Stripe)

Blog articles and external resources

We encourage you to review the privacy policies of any third-party services you visit or use.

Advertising Platforms:

When you authorize us to access your advertising accounts (Meta, Google, TikTok, etc.), your use of those platforms is governed by their respective privacy policies and terms of service. We encourage you to review:

Meta Privacy Policy: facebook.com/privacy/policy

Google Privacy Policy: google.com/policies/privacy

TikTok Privacy Policy: tiktok.com/legal/privacy-policy

Snapchat Privacy Policy: snap.com/privacy/privacy-policy

12. CALIFORNIA CONSUMER PRIVACY DISCLOSURES

This section provides specific disclosures required under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

12.1 Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information:

Identifiers
Name, email, phone number, IP address, and account ID.
Collected: Yes

Personal Information (California Civil Code §1798.80)
Name, address, phone, and payment information.
Collected: Yes

Protected Classifications
Age and gender (only if voluntarily provided for targeting).
Collected: Limited

Commercial Information
Purchase history, payment records, and subscription details.
Collected: Yes

Internet / Network Activity
Browsing history, search history, and interactions with the Website.
Collected: Yes

Geolocation Data
General location based on IP address.
Collected: Yes

Professional / Employment Information
Job title, company name, and business role.
Collected: Yes

Education Information
Not collected.
Collected: No

Inferences
Preferences, characteristics, and behaviors derived from data.
Collected: Yes

Sensitive Personal Information
Account credentials (encrypted) and payment details (tokenized).
Collected: Limited

12.2 Sources of Personal Information

We collect information from:

Directly from you (forms, account creation, communications)

Automatically through Website usage (cookies, analytics)

From your advertising accounts (with permission)

From third-party partners and service providers

From public sources (business information)

12.3 Business and Commercial Purposes

We use personal information for:

Providing and improving Services

Campaign management and optimization

Account management and billing

Customer support and communication

Marketing (with consent)

Security and fraud prevention

Legal compliance

Business operations and analytics

12.4 Categories of Third Parties We Share Information With

We share personal information with:

Service providers (payment processors, hosting, CRM, analytics)

Advertising platforms (Meta, Google, TikTok, etc., with your permission)

Professional service providers (legal, accounting)

Business partners (programmatic media partners)

Government agencies and law enforcement (when required by law)

12.5 Sale and Sharing of Personal Information

We do NOT sell your personal information.

We do NOT "share" your personal information for cross-context behavioral advertising (as defined by CPRA).

We may share information with advertising platforms for campaign management purposes, but only with your explicit authorization and for the purpose of providing our Services to you.

12.6 Retention Period

See Section 6 (Data Retention) for detailed information about how long we retain each category of personal information.

12.7 Sensitive Personal Information

We collect limited sensitive personal information:

Account login credentials (encrypted)

Payment information (tokenized by Stripe)

We do NOT use or disclose sensitive personal information for purposes other than:

Providing Services you requested

Security and fraud prevention

Quality assurance

Legal compliance

12.8 Right to Limit Use of Sensitive Personal Information

Because we only use sensitive personal information for permitted purposes, the right to limit use does not apply. However, you may still exercise this right by contacting us at [email protected].

12.9 How to Exercise California Privacy Rights

See Section 7.2 for detailed information about California privacy rights and how to exercise them.

Contact Methods:

Email: [email protected]

Subject: "California Privacy Rights Request"

Authorized Agent:

You may designate an authorized agent to submit requests on your behalf. The agent must:

Provide written authorization signed by you

Verify their identity

Provide proof of their authority to act on your behalf

12.10 Non-Discrimination

We will not discriminate against you for exercising any of your California privacy rights. This means we will not:

Deny goods or services

Charge different prices or rates

Provide a different level or quality of service

Suggest you will receive a different price or quality of service

Financial Incentives:

We do not offer financial incentives or price differences related to collection, retention, or sale of personal information.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

13.1 How We Notify You of Changes

Material Changes:

If we make material changes that significantly affect your privacy rights, we will:

Update the "Last Updated" date at the top of this Privacy Policy

Send email notification to the address associated with your account

Display a prominent notice on our Website

Provide at least 30 days' notice before changes take effect

Non-Material Changes:

For minor changes (corrections, clarifications, formatting), we will:

Update the "Last Updated" date

Post the revised policy on our Website

Changes take effect immediately upon posting

13.2 Your Continued Use

Your continued use of our Services after the effective date of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with the revised policy, you should discontinue use of our Services and contact us to close your account.

13.3 Reviewing Previous Versions

We maintain an archive of previous Privacy Policy versions. To request access to previous versions, contact us at [email protected].

14. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Truvo Ads Privacy Team

Email: [email protected]

Support: [email protected]

Website:Truvoadstruvoads.com

Mail: 201 E Grand Ave Ste 2A, Escondido, CA, 92025

Response Time:

We strive to respond to all privacy inquiries within:

10 business days for general questions

30 days for privacy rights requests (or as required by applicable law)

Data Protection Officer (if applicable):

For GDPR-related inquiries, you may contact our Data Protection Officer at: [email protected]

Supervisory Authority (EU/UK Users):

If you are located in the EEA or UK and have concerns about our privacy practices, you have the right to lodge a complaint with your local data protection authority:

EU: Find your authority at edpb.europa.eu/about-edpb/board/members_en

UK: Information Commissioner's Office (ICO) at ico.org.uk

15. CALIFORNIA PRIVACY NOTICE AT COLLECTION

For California Residents:

At or before the point of collection, we provide notice about:

Categories of personal information collected (see Section 12.1)

Purposes for which we use personal information (see Section 12.3)

Whether we sell or share personal information (we do not)

Retention period (see Section 6)

This information is provided:

On our Website during account registration

In this Privacy Policy

In our forms and data collection points

Your Rights:

As a California resident, you have the right to:

Know what personal information we collect, use, and share

Request deletion of your personal information

Opt out of sale or sharing (we do not sell or share)

Not be discriminated against for exercising your rights

To exercise your rights, contact us at [email protected] with subject line "California Privacy Rights Request."

Last Updated: December 12, 2025

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