Last Updated: November 30, 2020
Hello there! We’re glad to see that you're concerned about your privacy, because we are, too. ♥
- our website http://truluv.ai (our "Website");
- our mobile application BreatheLUV (our "BreatheLUV App");
- our mobile application #SelfCare (our "#SelfCare App"); and
- any exchange you may have with us, including by e-mails, social media or otherwise.
When you use our Services, you may have access to websites, applications or services that are offered by other entities. Prior to accessing these third-party services, please make sure that you review their privacy policies and terms and conditions, as unfortunately we don’t control how they handle personal data. This includes our social media accounts, such as Soundcloud, Instagram or Facebook. It’s always important you protect yourself and take a few minutes to understand their practices. ♥
At TRU LUV, we refer to our Users as “Tenders” and will do so throughout this document.
1. How can you contact us?
If you have any questions, comments, or concerns regarding this Policy, how we handle your personal data, or if you want to exercise your privacy rights, you can contact us by e-mail at: firstname.lastname@example.org, or by mail:
Data Protection Officer
Tru Luv Media Inc.
186-720 King Street West
Toronto, Ontario, Canada
2. Do we process personal data about children?
While we believe wellness is important for people of all ages, we do collect sensitive health data through your devices to offer you with our Services, and therefore, we do not allow individuals under the age of 16 to use our services, with or without parental consent. If you are under 16 years old, don’t worry – we’ll be happy to get to know you when you reach 16 years old! In the meantime, we prefer that you use services that are tailored for your age group. If we find out that you’ve been using our Services and you are not 16 years old, we will delete your personal data to protect your privacy.
3. What do we mean by personal data?
The word data means stored information signs or indications, and the word personal means that the identification of an individual is possible based on the available data. Data is personal if it allows us to identify you, directly or indirectly.
￼Personal data includes online identifiers, such as your IP addresses, location data, and identification data such as your name, mobile phone numbers and e-mail address. This Policy provides you with more information on how we process your personal data.
4. What do we mean by cookies?
Cookies are little data files installed on your device (a computer tablet or mobile phone for instance) to fulfil several purposes. In this Policy, when we use the term cookies, we also imply similar tracking technologies such as tracking pixels (or pixels tags), web beacons and browser fingerprinting.
Cookies can be installed by us, in which case, they are called “first party cookies.” They can also be installed by third parties. These are called “third party cookies” and result in the sharing of your personal data, such as IP addresses, with these third parties.
5. What personal data do we collect about you and why?
We collect your personal data to offer you with our Services, including to allow you to use the BreatheLUV App and #SelfCare App, to conduct surveys, for our artificial intelligence algorithms to personalize our #SelfCare App experience based on your in-game actions, to manage our communities, to provide you with specific functionalities such as syncing with your heart rate, to manage our social media accounts, to subscribe you to our newsletters, to provide you with support and to understand and improve our Services. The personal data that we collect may include electronic data, health data, identification data and any information you share with us from time to time.
We collect personal data directly from you, or from our service providers who collect it directly from you. We do not buy any personal data from third parties and neither do we sell any. We do not use your personal data within the BreatheLUV App and the #SelfCare App to conduct interest-based marketing based on your behavior, and we do not allow third parties to do so either.
If you allow us to, the BreatheLUV App can read your heart rate from the Apple Health App. We do not input your heart rate as a data source, so we only need read permission. You can provide us with this permission through your Apple devices by opting-in, and you can opt-out at any time. If you opt-out, then we will not be able to read to read your health data, in which case, the functionality which allow us to sync the animations with your heart rate will not be available to you, but you can still use the BreatheLUV App without this functionality. You can consult this page from Apple for more information on how to manage your preferences regarding Apple Health data such as heart rates.
The BreatheLUV App is also available on Apple Watch. Our Tenders generally use the Apple Watch to input their heart rate into the Apple Health app, which allows us to read your heartbeat if you opted-in to let us do so.
We do not sell or use your health data for any other purposes, including for advertising or marketing purposes. If you are in the European Union, the lawful basis applicable for us to collect health data is your explicit and specific consent.
At TRU LUV, we love #SelfCare, and this also means having support from and interacting with other kind humans. This is why we are creating communities on third-party platforms such as Discord and Mighty Networks. When you interact with us or others in this community, any content you share will be available to others (unless sent in private), along with your pseudonym. You have no obligation to participate in our communities.
If you are in the European Union, the lawful basis applicable to the collection of community data is your explicit and specific consent.
Our Services may offer in-app purchases through Apple Pay or Google Pay. We don’t see or access the payment data you provide to Apple Pay or Google Pay - they collect your payments on our behalf.
If you are in the European Union, we only process payment data pursuant to the performance of a contract, or in some cases for functionalities that are not necessary for the BreatheLUV and #SelfCare Apps, with your explicit and specific consent.
In-App Game Data #SelfCare App
Our #SelfCare App uses artificial intelligence to adapt the game to your choices. Our artificial intelligence uses scores that we generate as data inputs. These scores are based on the aggregation of your actions within the game, and through our artificial intelligence algorithms, this generates instructions on how the game interacts with you. This processing of your personal data is done entirely on your device, and not on our servers.
Performance and Usage Data
When you use the #SelfCare App, we use third parties such as Unity Analytics to gather information about how our app is used. We don’t use such data for advertising or to send you notifications. We only use it to understand how our Tenders like to use our App, to improve and to understand any security or performance issue. We don’t actually see your actions as an individual, as we are provided with aggregated data on performance which do not allow us to identify you individually. Instead, our service providers use an IP address, a token associated with your device or a similar indirect identifier to associate these aggregated data with your use of the #SelfCare App.
If you are located in the European Union, we collect analytics data based on the performance of a contract whenever this is necessary to the #SelfCare App, and based on our legitimate interests when the processing of performance and usage data is not necessary for the performance of a contract. Our legitimate interests are to improve our Services, such as by detecting bugs, and we ensure that our interests are compelling and aligned with yours. ♥
Support and Communication Data (Social Media, E-mails, etc.)
If you inquire about our Services, if you fill a contact form on our Website, interact with us on social media or whenever you exchange with us, we collect the personal data that you share with us. On social media, we will have access to your publicly available information when you interact with us. Except in the case of subscribing to our newsletters, when you interact with us, we use your data only to answer your lovely questions and to connect with you, and not for marketing purposes.
When we respond to your inquiries, if you are located in the European Union, we do so based on your explicit consent.
Automatically Collected Electronic Data
Our Services automatically collect electronic data about you on our Website, such as your IP address, browser type, the types of devices that you’re using and your language preferences. Your use of our BreatheLUV App and #SelfCare App may also generate electronic data, such as whether you are using an iOS version of the apps, or an Android version.
If you are located in the European Union, the legal basis for our processing of such personal data on our Website is our legitimate interests, such as to provide you with the Services. Within our apps, the performance of a contract is the applicable lawful basis for collecting electronic data as we would not be able to provide you with our BreatheLUV App and #SelfCare App.
Business Communication; Consent Preferences
We collect electronic information to remember your consent preferences, including for privacy purposes.
Marketing Communications; Newsletters
With your explicit consent, we will use your e-mail address to provide you with promotional content, such as newsletters.
You can unsubscribe at any time from marketing communications using the unsubscribe option within our communications.
Surveys about our Services
We love to hear from you! ♥
For this reason, and with your explicit consent, we may collect personal data about you as part of our surveys. We use Microsoft Forms to prepare our surveys and collect your personal data. The personal data that we collect may include your answers to the questions and your identification data, such as name, e-mail, age range, location, personal habits and preferences when using the Services, depending on the type and nature of the survey. Only a few members of the TRU LUV team will access your personal data. We collect this information to improve our Services, make sure you’re satisfied and get feedback from you.
If you are in the European Union, we collect these data based on your explicit consent.
6. What cookies do we collect and why?
We do not use essential, performance, functional or targeting cookies on our Website.
7. What kinds of analytics do we use?
8. To whom do we disclose your personal data?
We care about you, and we’re not in the business of selling your personal data to anyone. ♥
We share your personal data to provide you with our Services, to respond to your inquiries and to obtain performance data about our Services. We do not share health data with third parties.
We may have to share your data in exceptional circumstances, such as if we are forced to do so under the law, if we sell our assets to a third party, or in the course of corporate reorganization.
Within our organization, we apply access on a need-to-know basis as a principle.
Service providers are used to provide you with the Services, and include:
IT Service Providers
We also use performance partners such as Unity Analytics to collect data about your use of our Services and the performance of our Services, such as which pages or functionality is most popular, or whether there are bugs in our Services.
Law Enforcement and Other Authorities
We may receive requests by the authorities to access your personal information. We will validate that the request is licit before responding. When possible, we will advise you. We will only share what is strictly required.
In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of TRU LUV, in whole or in part, your personal data may be transferred as part of the transaction.
When using #SelfCare app on an Apple iPhone or iPad, your data will be saved in Apple iCloud. Backup to Apple iCloud may be turned off in the iCloud Setting menu. For more information, please consult the Apple iCloud Security overview.
9. Where will my personal data be processed?
When you use our BreatheLUV and #SelfCare Apps, these apps are hosted using edge computing. This means that your data is always processed at the edge of your network, where you are located, so it is not centrally located in any database.
We use third party service providers in various countries. For instance, MailChimp, our e-mail provider, is located in the United States and the Microsoft Forms data that we collect for surveys are stored on servers in the United States. In the case of third-party services, your data are hosted by them.
If you are in the European Union, we are required to ensure that appropriate safeguards are in place prior to transferring your personal data out of the European Union. We do so through standard contractual clauses or through other safeguards when they are available.
10. How do you ensure my personal data is safe?
TRU LUV has implemented various reasonable physical, administrative and technical safeguards designed to protect the confidentiality and security of personal data under our control. For instance, when we developed our Website, we took into consideration HTML & CSS security best practices. Internally, we only allow access to your personal data on a need-to-know basis and with two factors authentication enabled. However, please be careful when using the Internet – it’s not entirely safe, and no security control can guarantee the security of your personal data. Make sure that you use safe network connections, and that you develop good practices when using your mobile device, such as enabling two-factor authentication. We believe #SelfCare also means developing safe practices for your data. ♥
11. How long do you keep my personal data?
We keep your personal data as long as necessary (a) for the purposes of the collection or (b) as required under applicable laws, whichever is ￼longer. For instance, we keep your personal data that you transmit to us through surveys for a maximum period of one (1) year, which is how long we believe that the personal data can be useful to us. If we want to keep the data longer, we will de-identify prior to doing so.
12. Do I have any rights regarding my personal data?
You do. Your rights differ depending on where you are located in the world.
In most locations, you can access and rectify your personal data. In the European Union, you may also benefit from these additional rights:
- The right to revoke your consent when processing is based on consent;
- The right to object to the processing of your personal data;
- The right to restrict the processing of your personal data;
- The right to data portability, which means that your personal data is provided to you or a third party in normal format to allow you to re-use them, including with another provider;
- The right to have automated decisions being reviewed by a human in some cases, and some rights over profiling.
If you would like to learn more about these rights, click here for a more detailed explanation.
All of these rights are subject to limitations in the law, so if we cannot comply, we will respond to you and let you know why. We will respond to any of your requests within 30 days. In some cases, we may need additional information to validate your identity, in which case, we will use it only for this reason and delete it after. We do not charge any fees for you to exercise your rights.
You always have the right to lodge a complaint to the local authorities if you disagree with how we handle your personal data.
13. Can I opt out of marketing communications and push notifications?
Yes, you can do so directly in the e-mails you receive by clicking the “unsubscribe” link. You can also contact us directly or manage your preferences within our Services where available.
You can opt-out of push notifications through your mobile device, and you can also control our right to read heart data through your mobile device by opting out at any time.
14. Can we change this policy?