Truebill is intended only for users in the United States, and its use is governed by US law.
Information We Collect
A. User-Provided Information
When you use the Service, you may provide and we collect information, such as your name, email address, mailing address, phone number, and other information. For example, you may provide us with information when you fill out forms or fields on our Site, when you participate in online surveys, when you use or redeem savings (e.g., discounts on partner products and services), when you apply for a job, when you contact us or request information about our Service (including by email or other means), when you submit User Content, and when you register for an account. The categories of information we collect include:
- Contact Data, including your name, email address, mailing address, and phone number.
- Identifiers, including your social security number.
- Account Credentials, including your password, password hints, and information for authentication and account access.
- Demographic Data, including your age, gender, and country.
- Commercial or Transactions Information, including records of products, services, and subscriptions purchased, obtained, or considered.
- Financial Information, including your current income level, current expenses, investable assets, and other financial information. You can also choose to provide your net worth through the Apps.
- Profile Data, including your interests, inferences, and preferences.
- Content, including content within any messages you send to us (such as when contacting customer support or asking a question).
In addition, if you submit a job application, we collect certain information in order to consider you for our open positions, such as your name, email address, city of residence, phone number, and your employment and education history.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
B. User-Provided Information Through Plaid and Other Third Party Integrations
Our Service may allow you to connect your third party accounts, including your financial accounts, to your Truebill account. We use Plaid and other third party integrations to provide this functionality to you. In order to connect your third party accounts to your Truebill account, you must expressly authorize such connection when first registering your Truebill account or at a later time through your account settings. You may terminate this connection at any time through your account settings.
When you connect your third party accounts to your Truebill account, you give Truebill and the third party integration the authority to act on your behalf to access and transmit your information from the relevant bank or other entity that provides your accounts. The information we receive from the entities that maintain your accounts varies depending on the information made available by those entities. Examples of the types of information we receive from financial accounts include financial account information, information about account balance, information about credit accounts, information about loan accounts, information about investment accounts, identifiers and information about account owners, information about account transactions, and employment information.
C. Automatically Collected Information
When you use the Service or open one of our HTML emails, we (or our service providers or vendors) automatically collect certain information from your web browser and through your device by using different types of technology, including “cookies,” “log files,” "pixels," and other tracking technologies. This automatically collected information includes:
- Device Data, including data about device identifiers such as IP address or other device address or ID, web browser and/or device type, your device’s operating software, your internet service provider, and your device’s regional and language settings.
- Service Use Data, including data about the web pages or sites that you visit just before or just after the Service, the pages you view on the Service, your actions on the Service, features you use, emails and advertisements you view, products and services you view and purchase, and the dates and times that you visit, access, or use the Service.
- Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).
The types of tracking technologies used include:
- Cookies. When you use the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service to personalize your experience, remember your preferences, and support security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies can be removed. Please review your web browser "Help" file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
- App Technologies. These technologies are included in our Apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our Apps may include SDKs (e.g., the Facebook SDK), which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring your advertising both on and off the Service, and provide you additional functionality, such as the ability to connect our Service with your Google account.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
E. Information from Other Sources
We also collect information from sources other than the Service, such as:
- Partners, Vendors, and Advertisers.
- Identity Verification and Fraud Prevention Services.
- Data brokers from which we purchase data to supplement the data we collect.
- Publicly-available sources, including data in the public domain.
How We Use Information
Your information is an integral part of our operations, and we use it in a variety of ways in providing the Service and operating our other business and commercial purposes. We use the information we collect about you for the following purposes:
- For purposes about which we notify you and with your consent.
- To operate, maintain, enhance and provide the features of the Service.
- To perform services requested by you, such as responding to your comments and questions.
- To understand and analyze the usages trends and preferences of our users, to improve the Service and other Truebill websites, apps, marketing efforts, products and services, and to create new features and functionality.
- To contact you for administrative purposes such as customer service, sending technical notices regarding updates, security alerts, information regarding our policies.
- To send you promotional materials, offers, messages related to the Service and the activities of partners, vendors, and advertisers we work with. Generally, you have the ability to opt-out of receiving any such communications, either through links provided in the messages, by updating your account preferences through the Service, or by contacting us directly at firstname.lastname@example.org.
- To address fraud, breach of policies or terms, and threats or harm.
- To personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service.
- To develop and provide advertisements, direct marketing, communications, content, and information about our and other entities’ products, offers, promotions, rewards, events, and services.
- To monitor and analyze the effectiveness of Service and our partners’ marketing activities.
- To monitor aggregate site usage metrics such as total number of visitors and pages/screens viewed.
- To track your entries, submissions, and status in any promotions or other activities, including verifying your eligibility and delivering prizes in connection with your entries.
- To fulfill any other purpose at your direction, such as when you direct us to negotiate a bill with another company on your behalf or you wish to integrate with a partner offering in order to save money on a particular bill through the Service.
- To conduct research, including focus groups and surveys.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
When We Disclose Information
- Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, fraud prevention, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
- Third Party Integrations. We share information with third parties (such as Plaid) and any relevant banks or other entities in connection with you connecting your third party accounts to your Truebill account. You may terminate this connection at any time through your account settings.
- Analytics and Advertising. We share information with vendors and other parties for our analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
- Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
- Partners, Vendors, and Advertisers. We share information in connection with offering co-branded services, selling or distributing our products, engaging in joint marketing activities, or providing advertising on our Service.
- Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
- Merger or Acquisition. In the event that all or a portion of Truebill or its assets are acquired by or merged with another entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users in connection with such merger, acquisition, sale, or other change of control.
- Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else. For example, we share information with identity verification services and fraud prevention services.
- Facilitating Requests. We share information at your request or direction.
- Consent. We share information with notice to you and your consent. For example, where we have received your consent, we will share your Service account with your spouse. Where we have received such consent, we are not responsible for the acts or omissions of your spouse on the Service. You can opt-out of such sharing at any time by disabling “Account Sharing” in the "Profile” section of the app.
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
Analytics and Advertising
We use analytics services, such as Amplitude, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Service (including our Site, Apps, and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel or SDK from another party into our own Service, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook SDK on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.
As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information.
For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
Your Rights and Choices
You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. Below is further information regarding your rights and choices for the Service:
- Account Information. If you have an account with us, you may update, correct, or delete your profile information and preferences you set within the account at any time by accessing your account preferences page through the Service. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- In-Service Offers. If you have a Truebill account, we may show you offers within your account or by email that are personalized to you based on information you have provided to us. For example, if we notice that you have a high utility bill, we may alert you to a better offer from one of our partners. We do not share your information with the partner unless you click on the offer and direct us to share information with them. We may get a commission from the partner if you purchase a product or service after clicking on the offer.
- Emails. If you do not wish to receive email offers or newsletters from us, you can opt-out of receiving email information from us (except for emails related to the completion of your registration, correction of user data, change of password and other similar communications essential to your transactions on the Service) by using the unsubscribe process at the bottom of the email. You can also unsubscribe or change your email preferences by updating your account preferences through the Service, or contacting us directly at email@example.com. Please note that while your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.
- Push Notifications. If you have opted-in to receive push notifications on your device, you can opt-out at any time by updating your account preferences through the Service, through your device settings, or by uninstalling the app.
- Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit https://www.allaboutdnt.com.
- App and Imprecise Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you.
- Google Analytics and Advertising. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb.
- Interest-based Advertising. The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
- Mobile Device. You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser, device, account, email address, and/or phone number from which you opt out. It will not affect subsequent subscriptions (where applicable). We are not responsible for any other entities’ effectiveness of, or compliance with, any opt out options or programs, or the accuracy of their statements regarding their opt out options or programs.
The Service may contain features or links to websites and services provided by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service. Some examples include:
- Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. We may get a commission if you purchase a product or service after clicking on a link to an affiliate partner’s website.
- Third Party Integrations as detailed in Section 2 above.
- Logging-In. We may embed a pixel or SDK on our Service that allows you to log-in to your Truebill account through your social media account. If you choose to log-in, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through your use.
Any information you provide on another party’s sites or services is provided directly to that party and is subject to that party’s policies and practices regarding privacy and security, even if accessed through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
The Service is intended for general audiences and is not directed at anyone under the age of 18. For that reason, we do not allow anyone under the age of 18 to use the Service or knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from anyone under the age of 18. If you are under 18 years of age, please do not use or access the Service at any time or in any manner. If we learn that personal information has been collected on the Service from children, we will take the appropriate steps to delete this information in accordance with COPPA. If you are a parent or guardian and discover that your child has obtained an account on the Service or provided us with personal information, you may alert us at firstname.lastname@example.org and request that we delete the personal information from our systems. We will remove the personal information in accordance with COPPA.
We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of your information. Nevertheless, transmission via the internet is not completely secure and we cannot ensure or warrant the security of any information you transmit to us or store on the Service and you do so at your own risk. We also cannot guarantee that such information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
Our Contact Information
Attn. Privacy Officer
8455 Colesville Rd. Suite 1645
Silver Spring, MD 20910
Additional Disclosures for Nevada Residents
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at email@example.com.
Additional Disclosures for California Residents
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
A. Notice of Collection
In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:
- Identifiers, including name, email address, mailing address, social security number, and online identifiers (such as IP address).
- Customer records, including phone number, billing address, and financial information.
- Characteristics of protected classifications under California or federal law, including gender.
- Commercial or transactions information, including records of products, services, and subscriptions purchased, obtained, or considered.
- Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
- Geolocation data.
- Employment and education information.
- Inferences drawn from the above information about your predicted characteristics and preferences.
For further details on information we collect, including the sources from which we receive information, review the “Information We Collect” section above. We collect and use these categories of personal information for the business purposes described in the “How We Use Information” section above, including to manage our Service.
B. Right to Know and Delete
You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
In addition, you have the right to delete the personal information we have collected from you.
To exercise any of these rights, please submit a request by emailing us at firstname.lastname@example.org. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
C. Right to Opt-Out.
To the extent Truebill sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information.
D. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
F. Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Our Contact Information” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.