Privacy Statement for California Residents

This Privacy Statement for California Residents (“Privacy Statement” or “Statement”) supplements the information contained in the TrueRank Privacy Policy. TrueRank has adopted this statement to comply with the California Privacy Rights Act of 2020 (the “CPRA”) and other California privacy laws, and it applies solely to “consumers” as that term is defined in the CPRA. Any terms defined in the CPRA have the same meaning when used in this Privacy Statement.

Information TrueRank Collects

In the last twelve (12) months, we may have collected the following categories of personal information:

• Identifiers, such as name, Internet Protocol address, email address, including business and/or other email addresses , job title and employer, and social networking URLs.
• Personal Information Categories Listed in the California Customer Records Statute, such as name, , education, employment, and employment history.
• Internet or Other Similar Network Activity, such as Internet Protocol address and information on a consumer’s interaction with a website, application, or advertisement.
• Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address.
• Professional or Employment-Related Information, such as email address, including business and/or other email addresses, current or past job history, and title.
• Inferences, which may be drawn from the information identified above to produce quantitative metrics about professional and education history.
• Sensitive Information, such as your TrueRank account login and password (if you are a TrueRank customer or user). TrueRank only uses sensitive information for the purposes specified in the CPRA and does not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing prior notice.

Categories of Sources from which Personal Information is Collected

TrueRank collects personal information from the following categories of sources:

• Publicly available information
• First-hand research
• Submissions from TrueRank’s customers or product users
• Third-party data vendors
• Directly and indirectly from activity or submissions on TrueRank’s website
• Directly and indirectly from our customers or their representatives
• Directly from vendors and other contractual counterparties

Purposes for Collection, Disclosure, Sharing, and Sale of Personal Information

TrueRank collects, discloses, shares, and sells personal information for the following business and commercial purposes:

• Provide, maintain, and improve the Site
• Verify, cleanse, update, and maintain professional Information and other information provided through the Site
• Provide and deliver the Services, process transactions, and send related information, including communications and invoices
• Send technical notices, updates, security alerts, and support and administrative messages
• Respond to comments, questions, and requests, and provide customer support
• Create TrueRank account(s) and identify users signing in to their account
• Communicate about products, services, offers, promotions, rewards, and events offered by TrueRank and others, and provide news and information
• Monitor and analyze trends, usage, and activities in connection with the Site
• Detect, investigate, and prevent fraud and other illegal activities
• Protect the rights and property of TrueRank, our customers, and others
• Personalize and improve the Site
• Provide notice of important changes to the Site, including changes or updates to this Privacy Policy
• Consider persons for possible employment with TrueRank, and communicate about employment opportunities or submitted employment applications
• Create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners or customers may use to provide and improve our respective services
• Comply with our contractual and legal obligations, resolve disputes with users, and enforce our agreements
• Carry out any other purpose described at the time the information was collected or as otherwise set forth in the CPRA

Third-Party Recipients

TrueRank may disclose personal information to the following third-party recipients for the business and commercial purposes identified above:

• TrueRank affiliates
• Service providers
• TrueRank customers
• TrueRank users
• TrueRank partners

Sale, Sharing, and Disclosure of Personal Information

We sell personal information collected for our database to our customers. This database may contain information about consumers’ business personas including name, employer, job title, email address, social media or professional profile link, and work or educational history. This information is sold to TrueRank’s customers for the purpose of recruiting and is provided subject to license agreements that limit its use to those purposes.

In the preceding twelve (12) months, we have sold or shared the following categories of personal information to TrueRank customers, partners, or affiliates:

• Identifiers
• Personal information categories listed in the California Customer Records statute
• Internet or other similar network activity
• Professional or employment-related information
• Inferences

TrueRank may also disclose personal information to its service providers for business purposes necessary for providing functions related to our operation of our business and provision of our products and services. In the preceding twelve (12) months, we have disclosed for a business purpose the following categories of personal information to our service providers:

• Identifiers
• Personal information categories listed in the California Customer Records statute
• Internet or other similar network activity
• Professional or employment-related information
• Inferences

We do not sell or share the personal information of minors under 16 years of age.

A Consumer’s Right to Opt-Out of the Sale or Sharing of Personal Information

A consumer has the right to opt-out of the sale or sharing of that consumer’s personal information by TrueRank. Consumers may opt-out of the sale of their information by sending an email to [email protected]. In order to submit a request, a consumer or an Authorized Agent will be required to demonstrate that such person has control of an email inbox associated with the profile in question. If such person cannot, then we may be contacted regarding other means of verifying such person’s identity or the authorization of a third party to exercise a consumer’s rights on that consumer’s behalf.

A Consumer’s Other CPRA Rights and Choices

The CPRA provides consumers with specific rights regarding their personal information. This section describes a consumer’s CPRA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

A consumer has the right to request that we disclose certain information to that consumer about TrueRank’s collection and use of that consumer’s personal information over the past twelve (12) months. Once we receive and confirm a consumer’s verifiable consumer request, we will disclose:

• The categories of personal information we collected about that consumer.
• The categories of sources from which the personal information was collected.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about that consumer (also called a data portability request).

Correction Request Rights

A consumer has the right to request that we correct personal information that we maintain about the consumer if it is inaccurate, taking into account the nature of the personal information and the purposes for which it is processed. Once we receive and confirm a consumer’s verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information. We may require documentation if necessary to confirm the accuracy of the requested correction. We may deny the request if:

• We determine, based on the totality of the circumstances, that the contested personal information is more likely than not accurate as maintained.
• We determine that the requested correction would be impossible or would involve disproportionate effort.
• The requested correction is in conflict with federal or state law.
• We denied the same request to correct within the past six months and the consumer has not provided additional documentation in support of the request.
• We have a good-faith, reasonable, and documented belief that the request to correct is fraudulent or abusive.

In any case, we will inform you of the action we take and, where the request has been denied, the reasons for the denial. Subject to the exceptions given below, a consumer whose request to correct has been denied may be able to exercise a right to delete the contested data.

Deletion Request Rights

A consumer has the right to request that TrueRank delete any of his or her personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete (and direct our service providers and/or customers to delete) that consumer’s personal information from our records, unless an exception applies.

We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to:

• Complete the transaction for which we collected the personal information, fulfill the terms of a product warranty or product recall conducted in accordance with federal law, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.
• Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the ability to complete such research, if a consumer provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s relationship with us and compatible with the context in which the consumer provided the information.
• Comply with a legal obligation.

Exercising Access, Correction, Data Portability, and Deletion Rights

To exercise the access, correction, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us at [email protected]

Only a consumer, or a natural person or business entity that a consumer authorizes to act on a consumer’s behalf (an “Authorized Agent”), may make a verifiable consumer request related to a consumer’s personal information. A consumer may also make a verifiable consumer request on behalf of that consumer’s minor child.

A consumer or the consumer’s Authorized Agent may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows TrueRank to reasonably verify a consumer is the person about whom we collected personal information.
• If an Authorized Agent is being used, provide sufficient proof that the consumer has provided the Authorized Agent with permission to submit the request on the consumer’s behalf, such as signed permission or a power of attorney executed pursuant to California Probate Code Sections 4121 to 4130.
• Describe a consumer’s request with sufficient detail that allows TrueRank to properly understand, evaluate, and respond to it.

We cannot respond to a consumer’s or an Authorized Agent’s request or provide a consumer or Authorized Agent with personal information if we cannot verify the consumer’s or Authorized Agent’s identity and/or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use personal information provided to us in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform the consumer of the reason and extension period in writing. We will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will choose a format to provide a consumer’s personal information that is readily usable and should allow a consumer to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to a consumer’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide the consumer with a cost estimate before completing that consumer’s request.

Non-Discrimination

Consumers have the right to not receive discriminatory treatment by a business for exercising their rights under the CPRA. We will not discriminate against a consumer for exercising any CPRA rights.

Deidentified Data

To the extent TrueRank may collect or process deidentified data, we will maintain and use the information in deidentified form and will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy applicable requirements.

Data Retention

For all categories of personal information we collect, we will retain personal information for a period of time consistent with and not longer than is reasonably necessary for the original purpose(s) for which we collected it, as described in this Privacy Policy, including, as applicable, (i) for as long as we have an ongoing relationship with the individual to whom the information pertains; (ii) as long as needed to provide users, our customers, or our partners the Services; (iii) as necessary to comply with our legal obligation(s); (iv) as necessary to resolve disputes or to protect ourselves from potential future disputes; or (v) as necessary to enforce our agreements. Retention periods will be determined taking into account the amount, nature, and sensitivity of the personal information and the purpose(s) for which it was collected. After the retention period ends, we will delete the personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of such information.

Changes to Our Privacy Statement

We reserve the right to amend this privacy statement at our discretion and at any time. When we make material changes to this privacy statement, we will provide notification by email or through a notice on our website homepage.

Consumer Rights Requests Metrics

During the previous calendar year, TrueRank received the following number of requests from residents of California:

Contact Information

If there are any questions or comments about this Statement, our Privacy Policy, the ways in which we collect and use a consumer’s personal information, how to receive a copy of the Privacy Policy and/or this Statement in an alternative format (for consumers with a disability), a consumer’s choices and rights regarding such use, or to exercise consumer rights under California law, please do not hesitate to contact us at:

TrueRank

Attn: Privacy

6430 Sunset Blvd, Suite 708

Los Angeles, CA 90028

Email: [email protected]

This Privacy Statement was last updated on July 27, 2023.