Privacy Notice

Introduction

This privacy notice (this "Notice") describes how Truly Free, Inc., a Delaware corporation, and our affiliates ("Company", "Our", "Us", and/or "We"), collect and process your personal information through https://trulyfree.com and Our other websites (Our "Website") or through other applications or services that reference this Notice (together with Our Website, Our "Services").

By accessing or using our Website or other Services, you are consenting to the practices described in this Notice.

We respect your privacy and are committed to protecting it through Our compliance with this Notice. This Notice applies to information We collect:

  • On Our Website or through other Services;
  • Via email, text, and other electronic messages between you and Our Website or other Services;
  • Through mobile and desktop applications you download from Our Website or other Services; and
  • When you interact with Our advertising and applications on third-party websites and services, if those applications or advertising include links to our Website, Our other Services, or this Notice.

This Notice does not apply to information collected by third parties (other than Our affiliates and subsidiaries), such as through any application or content (including advertising) that may link to or be accessible from or through the Website or other Services.

Our Website is currently hosted through CloudFare, which has its own privacy policy to which you also agree by accessing or using our Website which may be accessed here: https://www.cloudflare.com/privacypolicy.

Please read this Notice carefully to understand Our guidelines and practices regarding your information and how We will treat it. Note that the information We collect may also be collected by CloudFare or other third parties. If you do not agree with Our guidelines and practices, nor CloudFare's, your choice is not to use Our Website or other Services offered by us.

By accessing or using Our Website or other Services, you agree to this Notice and CloudFare's privacy policy.

This Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of this Website or other Services after We make changes is deemed to be acceptance of those changes, so please check this Notice periodically for updates.

Children Under the Age of 16

Our Website and other Services is not intended for children under 16 years of age. No one under age 16 may provide any information, personal or otherwise, to or on the Website or through our other Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, do any of the foregoing with respect to Our other Services, or provide any information about yourself to Us, including your name, address, telephone number, email address, or any screen name or user name you may use. If We learn We have collected or received personal information from a child under the age of 16 without verification of parental consent, We will delete that information. If you believe We might have any information from or about a child under 16, please contact Us at Our designated contact information (see Contact Information).

Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding the collection, sale, and use of their personal information. Please see Your State Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of Our Website and other Services, including information:

  • By which you may be personally identified, such as name, user name, date of birth, postal address, email address, telephone number, bank account information, credit & debit card information, and any other identifier by which you may be contacted online or offline ("personal information");
  • That is about you but individually does not identify you, such as your Website or other Service interaction data and aggregated statistics, and/or
  • About your internet connection, the equipment you use to access Our Website or other Services, and usage details.

We collect this information:

  • Directly from you when you provide it to Us;
  • Automatically as you navigate through the Website or other Service, which may include usage details, internet protocol ("IP") addresses, and information collected through cookies, web beacons, and other tracking technologies; and/or
  • From third parties, including Our business partners.

Information You Provide to Us

The information We collect on or through Our Website or other Services may include:

  • Information that you provide by filling in forms, including information provided at the time of registering to use Our Website or other Services, subscribing to any of Our Services, selling or purchasing products through our Website or other Services, posting material, or requesting support;
  • Information that you provide when you enter a contest or promotion sponsored by Us;
  • Information that you provide when you report a problem with Our Website to Us;
  • Records and copies of your correspondence (including email addresses), if you contact Us;
  • Your responses to surveys that We might ask you to complete for research purposes;
  • Details of transactions you carry out through Our Website or other Services and of the fulfillment of your orders, including financial information; and
  • Your search queries on the Website or other Services.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website or other Services, or transmitted to other users of the Website or Services or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although We limit access to certain pages and/or you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, We cannot control the actions of other users of the Website or Services with whom you may choose to share your User Contributions. Therefore, We cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with Our Website and other Services, We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to Our Website and Services, including traffic data, location data, logs, and other communication data & the resources that you access and use on the Website or other Services; and
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information We collect automatically does not include personal information, but We may maintain it or associate it with personal information We collect in other ways or receive from third parties. It helps Us to improve Our Website and other Services to deliver a better and more personalized service, including by enabling Us to:

  • Estimate Our audience size and usage patterns;
  • Store information about your preferences, allowing Us to customize Our Website and other Services according to your individual interests;
  • Speed up your searches; and
  • Recognize you when you return to Our Website or other Services.

The technologies We use for this automatic data collection includes the following:

Cookies (or browser cookies)

A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts or functions of Our Website or other Services. Unless you have adjusted your browser setting so that it will refuse cookies, Our system will issue cookies when you direct your browser to Our Website or access other Services.

Below is a current list of cookies that We use:

  • "_session_id", which allows CloudFare to store information about your session (e.g., referrer, landing page, etc.). This is a unique, sessional token.
  • "_CloudFare_visit", which does not hold your data but is persistent for thirty minutes from your last visit. This cookie is utilized by CloudFare to serve as an internal stats tracker and record the number of visits to Our Website.
  • "_CloudFare_uniq," which does not hold your data and expires at midnight (relative to the time zone of the visitor) of the next day. This cookie counts the number of visits to Our Website's store by a single customer. It also contains a unique token that persists for two weeks that stores information about the contents of your online shopping cart connected to Our Website.
  • "_secure_session_id", which is a unique, sessional token.
  • "storefront_digest", is a unique, indefinite token that is used to determine if the current visitor to Our Website has access to that particular landing page. This cookie is relevant if the particular webpage requires a password to access it.

For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.

  • Web Beacons. Pages of Our Website and Our emails and other Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages or opened an email, and for other related website statistics (e.g., recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website or other Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use Our website or other Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that We collect about you or that you provide to Us, including any personal information:

  • To present Our Website and its contents or other Services to you;
  • To provide you with information, products, or services that you request from Us;
  • To fulfill any other purpose for which you provide it;
  • To provide you with notices about your account and/or your subscription services, including expiration and renewal notices;
  • To carry out Our obligations and enforce Our rights arising from any contracts entered into between you and Us, including for billing and collection;
  • To notify you about changes to Our Website or other Services We offer or provide though them;
  • To allow you to participate in interactive features on Our Website or other Services;
  • In any other way We may describe when you provide the information; and
  • For any other purpose with your consent.

We may also use your information to contact you about Our own and third-parties' goods and services that may be of interest to you. If you do not want Us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information We have collected from you to enable Us to display advertisements to Our advertisers' target audiences. Even though We do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about Our users, and information that does not identify any individual, without restriction.

We may disclose personal information that We collect or you provide as described in this Notice:

  • To Our subsidiaries and affiliates;
  • To contractors, service providers, and other third parties We use to support Our business, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which We disclose it to them;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about Our Website or other Service users is among the assets transferred;
  • To third parties to market their products or services to you if you have not opted out of these disclosures, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which We disclose it to them; (for more information, see Choices About How We Use and Disclose Your Information);
  • To fulfill the purpose for which you provide it;
  • For any other purpose disclosed by Us when you provide the information; and
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To enforce or apply Our Member Terms of Service, Partner Terms of Service, Seller Terms of Service, and other agreements, including for billing and collection purposes;
  • If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, Our customers, or others, which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to Us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website or other Services may then be inaccessible or not function properly.

  • Disclosure of Your Information for Third-Party Advertising. If you do not want Us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by contacting us via email at the address provided in the Contact Information section below.

  • Promotional Offers from Company. If you do not wish to have your contact information used by Company to promote Our own or third parties' products or services, you can opt-out by contacting us via email at the address provided in the Contact Information section below. Please note this opt-out does not apply to information provided to Company as a result of a product purchase, warranty registration, product service experience, or other transactions.

  • Targeted Advertising. If you do not want Us to use information that We collect or that you provide to Us to deliver advertisements according to Our advertisers' target-audience preferences, you can opt-out by contacting us via email at the address provided in the Contact Information section below.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website or other Services and visiting your account profile page or its equivalent for the relevant Service.

You may also send Us an email at the address provided in the Contact Information section below to request access to, correct, or delete any personal information that you have provided to Us. Please note, however, We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if We believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website or other Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website or Service users. Proper access and use of information provided on the Website and other Services, including User Contributions, is governed by Our Member Terms of Service, Partner Terms of Service, and Seller Terms of Service.

Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding Our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

  • Confirm whether We process their personal information;
  • Access and delete certain personal information;
  • Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah);
  • Data portability;
  • Opt-out of personal data processing for: targeted advertising (excluding Iowa), sales, or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah); and
  • Either limit (e.g., opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please send Us an email at the address provided in the Contact Information section below. Additionally, to appeal a decision regarding a consumer rights request, please email Us at the address provided in the Contact Information section below.

Company does have an Additional Privacy Notice for California Residents ("CA Privacy Notice") accessible via this link. The CA Privacy Notice aims to comply with the California Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020. To learn more about California residents' privacy rights, visit the link above. Please note, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of Our Website or other Services that are California residents to request certain information regarding Our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send Us an email or write to us at the addresses provided in the Contact Information section below.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to the email address designated in the Contact Information section below. However, please know We do not currently sell data triggering that statute's opt-out requirements.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to Us is stored on Our secure servers behind firewalls. Your payment information is also encrypted using secure socket layer technology and stored with an AES-256 encryption. Additionally, CloudFare stores information you provide through the Website or other services on a secure server behind a firewall. All payment transactions will be encrypted, as well. All direct payment gateways adhere to the standards set by the Payment Card Industry Data Security Standard to ensure the secure handling of financial information by our Website and other Services.

The safety and security of your information also depends on you. Where We have given you (or where you have chosen) a password for access to certain parts of Our Website or other Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website and other Services. The information you share in public areas may be viewed by any user of the Website or other Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although We do Our best to protect your personal information, We cannot guarantee the security of your personal information transmitted to Our Website or other Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or other Services.

Changes to Our Privacy Policy

It is Our policy to post any changes We make to Our Notice on this page. If We make material changes to how We treat Our users' personal information, We will notify you by email to the email address specified in your account and/or through a notice on Our Website or other Service. The date the Notice was last revised is identified at the top of the page. You are responsible for ensuring We have an up-to-date active and deliverable email address for you, and for periodically visiting Our Website and this Notice to check for any changes.

Contact Information

To ask questions, opt-out of any features, comment about this Notice and Our privacy practices, register a complaint, or otherwise connect with Company related to this Notice, contact Us at [email protected]. You may also reach us via mail, as provided in this Notice, at the following address:

Truly Free Market, Inc.
345 West South Airport Road
Traverse City, Michigan 49686
United States

Please be sure to send us an email at the address listed above if you need to access this Notice in an alternative format due to having a disability.

38889:00002:201199525-2