Privacy Policy | Bleeker

True Advance Privacy Policy

Effective April 4, 2024

Scope of This Policy
Agreement to Terms
Information We Collect
Cookies
Children’s Privacy
Our Use of Personal Information
Our Disclosure of Personal Information
Your Privacy Choices
Security
Notice to Residents of Canada
Notice to European Users
Notice to California Users
Links to Other Websites
Effective Date and Changes to This Privacy Policy
How to Contact Us

1. Scope of This Policy

True Leadership Solutions LLC (“True Advance,” “we,” “us,” “our”) respects your privacy and values your trust. The purpose of this Privacy Policy is to inform you of the treatment and handling of information that we may learn about you from using our websites, including our corporate site at trueadvance.com and the My True Advance site at mytrueadvance.com (the “Sites”) and related subdomains, our True Advance Collective mobile application (the “App”), and/or by use of any of our services (collectively, with the Sites and the App, the “Service”). If you have any questions regarding this information or our privacy practices, please see the section entitled How to Contact Us at the end of this Privacy Policy.

To comply with privacy requirements in Europe and California, we have provided additional details about our privacy practices to users in the European Union, European Economic Area, United Kingdom (collectively “Europe” or “European”) and California.

2. Agreement to Terms

If you do not agree with the terms of this Privacy Policy or our Terms of Use, then you should immediately discontinue use of the Service without providing us any personally identifiable information.

3. Information We Collect

We may collect the following categories of personal information (a) directly from you (such as when you sign-up for an account or complete assessments), (b) from third-party social networking sites (e.g., LinkedIn), (c) from the device and browser that you use to access our Service, or (d) from cookies.

Identifiers

We may collect your name, email address, account username and password, and phone number.

User-generated Content

We collect the information and content you post or otherwise share through the Sites and App. This may include your profile picture, status updates, responses to assessments, interests or hobbies, comments, and communications between you and other users of the Service. In addition, if you send a message to us (such as through email or social media), we collect any personal information you choose to share with us through those messages.

Audio-visual Information

If you participate in an event (live or virtual) held by True Advance, we may record the event and capture your image, photograph, audio recording, and/or video recording. We may also collect your profile picture as indicated in User-generated Content, above.

Inferences

We may also draw inferences from the information we collect from you that reflect your preferences, characteristics, abilities, and aptitudes.

Device Information

We may collect device information when you visit our Sites or App. Device information may include your device type, browser type, online identifiers, IP address, access times, and geolocation information.

Internet Activity

We may collect information concerning your interaction with our Sites and App, including when you access our Sites or App and your browsing activity on our Sites or App (such as which pages you visit, in what order, and for how long). This may include “traffic data” or tracking information provided by the Site’s host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving our Sites.

You are not required to provide all personal information identified in this Privacy Policy to use our Service or to interact with us, but certain functionality will not be available if you do not provide certain personal information. For example, if you do not provide certain personal information, we may not be able to respond to your requests, allow you to register an account, or provide you with promotional notices that we believe you may find valuable

4. Cookies

We store certain information that gets collected automatically at our end through cookies and other similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for marketing purposes, including targeted advertising (as discussed in more detail below). Cookies on our websites are generally divided into the following categories:

Strictly Necessary Cookies. These are required for the operation of our Sites. They include, for example, cookies that enable you to log into password-protected portions of the Sites. These cookies are session cookies that are erased when you close your browser.
Analytical/Performance Cookies. These allow us to recognize and count the number of users to our Sites and understand how such users navigate through our Sites (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located).

We also use Google Analytics for part of this process. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. Google provides users with the ability to prevent their data from being used by Google Analytics—learn more by going to https://tools.google.com/dlpage/gaoptout.

Functional Cookies. These improve the functional performance of our Sites and make them easier for you to use. For example, cookies are used to remember that you have previously visited a Site and asked to remain logged into it (e.g., this saves your username). These cookies qualify as persistent cookies because they remain on your device for use during your next visit to the Site. You can delete these cookies as detailed below.
Targeting Cookies. These record your visit to our Sites and the pages you have visited and the links you have followed, to recognize you as a previous visitor, and to track your activity on the Sites and other websites you visit. These cookies are used to display our ads on other websites based on your visits to our Site and other online activity. These cookies qualify as persistent cookies because they remain on your device. You can delete these cookies as detailed below

You can prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help,” “Internet Options,” or “Settings.” If you disable or delete certain cookies in your Internet browser settings, you may still access our Sites, however, you might not be able to access or use important functions or features of our Sites, and you may, for example, be required to re-enter your log-in details.

Do-Not-Track Signals

At this time, we do not recognize automated browser signals regarding tracking mechanisms, which include “do-not-track” instructions.

5. Children’s Privacy

The Service is not intended for users under the age of 16 and True Advance does not knowingly collect personal information from individuals under the age of 16. If you are aware of, or suspect that, someone under the age of 16 is using the Service without permission, please notify us immediately by contacting us as detailed below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.

6. Our Use of Personal Information

We collect and use your personal information for the following purposes

Providing the Service to you and providing products or services requested by, or reasonably anticipated within the context of our relationship with, you;
Managing our relationship with you, and if you decide to establish an account, creating and managing your account;
Responding to your inquiries or requests, and requesting feedback;
Evaluating your eligibility for career and job opportunities with us or our business clients that have engaged us for our executive recruiting services;
Developing an understanding of our community and providing programming that meets their needs;
Tracking use of your username and password to access our Sites and App;
Personalizing our Sites and App (e.g., displaying your name after you log in);
Analyzing use of our Sites;
Providing promotional material or other marketing materials that we believe will be of interest to you;
Tailoring advertisements to what we believe will be of interest to you (including working with our advertising partners to display advertisements on third-party websites that you may visit);
Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible; and
Complying with legal and regulatory obligations.

7. Assessments

We may share your personal information with the following third parties:

Service providers, including hosting providers and IT outsourcing, web analytics providers, and companies that provide marketing assistance. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
Our business clients, as part of our leadership development services and executive recruiting services.
Other users, such as when you post or share content through our Sites or App or when you interact with users on our Sites or App. In some cases, you may be able to opt-out or limit the sharing of your information with other users.
Advertising networks, to tailor advertisements to you.
Advisers and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
With third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counter-parties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant or other lawful request for information we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable

8. Your Privacy Choices

a. True Advance has adopted a policy that provides for the suspension and/or termination of any user who is found to have infringed on the rights of True Advance or of a third party, or otherwise violated any intellectual property laws or regulations.If you no longer want to receive our newsletter, emails, or other marketing communications, you may unsubscribe at any time selecting the “unsubscribe” option in the communication itself. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account. True Advance’s policy is to investigate any allegations of copyright infringement brought to its attention.

By logging into your account, you may update your password and view and update certain elements of your profile (e.g., your avatar, career vibe, biographical information, Mind Patterns, and Thinking Talents). If you wish to delete your account, please contact us at the contact information in the How to Contact Us section below or submit a request at privacy.trueplatform.com

9. Security

We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alternation, or unintentional destruction. We have implemented various security measures to protect both the personal information and the general information that we receive from you through the Service. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.

You play an important role in keeping your information secure. You should not share your username or password with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately at the information in the How to Contact Us section below

10. Notice to Residents of Canada

This section contains additional disclosures for residents of Canada. As noted above, you may update your password and certain elements of your profile (e.g., your avatar, career vibe, biographical information, Mind Patterns, and Thinking Talents) by logging into your account. If you wish to request access to or correction of other personal information, or to opt-out of the processing of your personal information or request that we delete your personal information, you may contact us at privacy@trueplatform.com with the subject line “Canada Privacy” so that we can get your email to the right team or you may submit a request at privacy.trueplatform.com. You may also contact us for information about how foreign-based service providers process your personal information or if you have any questions or complaints about the manner in which we treat your personal information.

We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise permitted by law

11. Notice to European Users

Controller

True Advance is the controller of your personal information covered by this Privacy Policy. See the How to Contact Us section below to contact our Privacy Officer.

Legal Bases for Processing

The legal bases for our processing of your personal information are described below.

To provide our products and services. Where we have an agreement governing this purpose, processing is necessary to perform the contract governing our provision of services or to take steps that you request prior to signing up for our services. When we collect sensitive information, we process such information as necessary to carry out obligations in the field of employment or rely on the individual’s consent. In all other cases, these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

The following processing activities constitute our legitimate interests:

Providing the Service to you and providing products or services requested by, or reasonably anticipated within the context of our relationship with, you;
Managing our relationship with you, and if you decide to establish an account, creating and managing your account;
Responding to your inquiries or requests, and requesting feedback;
Evaluating your eligibility for career and job opportunities with us or our business clients that have engaged us for our executive recruiting services;
Developing an understanding of our community and providing programming that meets their needs;
Tracking use of your username and password to access our Sites and App;
Personalizing our Sites and App (e.g., displaying your name after you log in);
Analyzing use of our Sites;
Providing promotional material or other marketing materials that we believe will be of interest to you;
Tailoring advertisements to what we believe will be of interest to you (including working with our advertising partners to display advertisements on third-party websites that you may visit);
Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible
Complying with legal and regulatory obligations
To identify you when you visit our websites.
To respond to your inquiries.
To send marketing and promotional materials.
To conduct analytics.
For internal administrative purposes.
To, in an aggregated or anonymized form, generate industry reports about trends.
To assess whether you may become a potential client in the future.
For compliance, fraud prevention and safety.

To comply with law. Processing is necessary to comply with our legal obligations.
Other uses. Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when we requested the consent or by contacting us.

Cross-border Data Transfer

Whenever we transfer your personal information out of Europe to countries not deemed by the European Commission to provide an adequate level of personal information protection, we will transfer the information:

Pursuant to the recipient’s compliance with Standard Contractual Clauses, EU-US Privacy Shield, or Binding Corporate Rules,
Pursuant to the consent of the individual to whom the personal information pertains, or
As otherwise permitted by applicable European requirements

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

12. Notice to California Users

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of their personal information.

This notice and the privacy rights it describes do not apply to information related to our business contacts.

Personal Information that We Collect, Use and Share
The information below describes how we currently collect, use and share personal information, and how we have collected used and shared personal information over the past 12 months. The below information may not cover information you volunteer to us, such as in correspondence.

We do not sell personal information. We engage in:

Online tracking. As we explain above, we use cookies and other tracking technologies to analyze website traffic and facilitate advertising. If you would like to learn how you may opt out of our (and third-party tracking companies’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide.
Directed disclosures. In addition, when you use our services to submit a resume or inquire about job openings, you direct us to engage with an ecosystem that will help you find your next opportunity, including by sharing your information with companies seeking job candidates, job leads, and business partners that assist with employment searches.

We may collect, use and share personal information in the following ways:

Potential Candidates’ Information and Mailing List Information
- Sources of personal information: Potential candidates, clients, and publicly available sources (e.g., social media platforms)
- CCPA categories of personal information collected: Identifiers, commercial information, professional information, education information, and protected classification characteristics
- Business/commercial purposes for which we may collect and use personal information:
  - To provide our products and services.
  - To contact potential candidates who may be interested in an employment opportunity with one of our clients.
  - For internal administrative purposes.
  - To conduct analytics.
  - To send marketing and promotional materials.
  - To, in an aggregated or anonymized form, generate industry reports about trends.
- Data sharing: By using our service, you direct us to disclose this information with companies seeking candidates and business partners that assist with employment searches.
Email Interconnectivity, Mobile Devices, Web Logs, and Online Activity
- Sources of personal information: Automatically collected
- CCPA categories of personal information collected: Online identifiers, internet or network information, and geolocation data
- Business/commercial purposes for which we may collect and use personal information:
  - To identify you when you visit our websites.
  - To conduct analytics.
  - For internal administrative purposes.
- Data sharing: This information is collected directly by third-party tracking companies.
Surveys and Feedback/Support
- Sources of personal information: Potential candidates
- CCPA categories of personal information collected: Identifiers, commercial information, and professional information
- Business/commercial purposes for which we may collect and use personal information:
  - To provide our products and services.
  - To respond to your inquiries.
  - To conduct analytics.
  - For internal administrative purposes.
  - To, in an aggregated or anonymized form, generate industry reports about trends.
Data sharing: We do not share this information.

Please note that we may also disclose personal information with service providers, and in connection with corporate transactions or compliance.

California Residents’ Privacy Rights

The CPRA grants California residents the following rights:

Information. You can request information about how we have collected, used and shared your personal information during the past 12 months. We have made this information available to California residents without having to request it by including it in the above chart.
Access. You can request a copy of the personal information that we have collected about you.
List of Third-Party Marketers. Under California’s Shine the Light law, True Search users who are California residents may request a notice identifying the categories of personal information that we share with third parties for their own direct marketing purposes, and such third parties’ contact information.
Deletion. You can ask us to delete the personal information that we maintain about you.

Please note that the CPRA limits these rights by, for example, prohibiting us from providing certain information we maintain for compliance in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. You are entitled to exercise the rights described above free from discrimination, as prohibited by the CPRA.

How to Submit a Request

To request access to or deletion of personal information:
- call (888) 677-8471
- visit privacy.trueplatform.com
- email privacy@trueplatform.com
Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

13. Links to Other Websites

For your convenience, we may link to third-party sites and services, provide functionality for users to post links to third-party sites and services, or otherwise display third-party content through the Service to provide increased value to our visitors. We have no control over these linked sites, each of which has separate privacy and data collection policies and practices independent from us. As such we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to users, collect data, or solicit personal information, and we encourage you to review their policies before engaging with these third-party sites.

14. Effective Date and Changes to This Privacy Policy

This Privacy Policy is effective as of the date at the top of this policy. True Advance has the discretion to update this Privacy Policy at any time. When we do, we will revise the effective date at the top of this page. We encourage users to frequently check this page for any changes and to stay informed about how we are helping to protect the personal information we collect, especially before you provide information, and particularly personal information, directly to us through the Service. In the event of a material change to this Privacy Policy, we will provide a message through our website or via email informing you of the change.

15. How to Contact Us

If you have any questions about this Privacy Policy or our Service, please contact us at

True Leadership Solutions LLC
56 N. Haddon Avenue, 1st Floor
Haddonfield, NJ 08033
ATTN: Privacy Officer

Or at privacy@trueplatform.com.