Last Updated: June 15, 2023

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At Trusli, we are committed to protecting the privacy and security of our clients' and users' personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard the information provided to us through our contract automation and procurement automation software modules.

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Information We Collect & How We Use It

1.1 Personal Information:

We may collect personal information from our clients and users, such as names, contact details (including email addresses and phone numbers), job titles, and company information. This information is collected when users interact with our software, create accounts, submit purchase requests, or utilize our contract automation features.

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1.2 Usage Information:

We may collect usage information, including browser type and usage patterns when users access our software modules. This data helps us improve our products, provide personalized experiences, and ensure the security of our systems.

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We may display testimonials from satisfied customers. We will ask for your specific consent as part of the survey. If you wish to update or delete your testimonial, you can contact us at help@trusli.com. We may also display customer reviews. If you provide a review that we display and wish to update or delete it, you can also contact us at help@trusli.com.

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Use of Information

2.1 Provision of Services:

We use the collected information to deliver our cutting-edge contract automation and procurement automation services. Our modules are built on the secure Amazon Web Services (AWS) infrastructure. With our advanced technology, we aim to revolutionize the contract and procurement processes for our clients.

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2.2 Communication:

We may use personal information to communicate with clients and users, provide important updates, respond to inquiries, and deliver exceptional customer support. Our dedicated team is committed to ensuring a seamless and efficient experience for our valued clients.

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2.3 Security and Analytics:

We employ industry-leading security measures and comply with the rigorous SOC-2 (Service Organization Control 2) standards to protect the confidentiality, integrity, and availability of the information entrusted to us. We leverage AWS's secure infrastructure, which adheres to stringent security practices, to safeguard the data. Furthermore, we utilize advanced analytics to gain insights into system usage and performance, enabling continuous improvements to our products and services.

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Disclosure of Information

3.1 Service Providers:

We may engage trusted third-party service providers to assist in delivering our services. These providers undergo a thorough vetting process and are bound by strict confidentiality agreements. They are only authorized to use personal information for the specific purposes required to support our operations.

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3.2 Legal Compliance:

We may disclose personal information when required by law, regulation, or legal process, or to protect our rights, safety, or property, as well as the rights, safety, or property of our clients, users, or others. We are committed to cooperating with law enforcement agencies and authorities to ensure compliance with applicable regulations.

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Data Security

4.1 Security Measures:

We have implemented robust security measures to protect personal information from unauthorized access, alteration, disclosure, or destruction. These measures include but are not limited to encryption, multi-factor authentication, access controls, regular security audits, and vulnerability assessments. Our commitment to data security is an integral part of our company culture.

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4.2 Data Retention:

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We regularly review our data retention practices to ensure compliance with legal obligations and industry best practices.

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Your Rights

5.1 Access and Control:

Clients and users have the right to access, update, and correct their personal information. If you would like to exercise these rights or request the deletion of your information, please contact our Chief Technology Officer using the contact details provided at the end of this policy. We will promptly respond to your requests in accordance with applicable laws and regulations.

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5.2 Marketing Communications:

Clients and users have the option to opt out of receiving promotional emails, newsletters, or other marketing communications from us. You can exercise this right by following the instructions provided in such communications or by contacting us directly.

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Supplemental Privacy Notice for California Residents

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This Supplemental Privacy Notice supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Services and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to personal information we process as a service provider.

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Summary of Information We Collect

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If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” and "sensitive personal information" (as defined in the California Consumer Privacy Act (“CCPA”)).

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Throughout our Privacy Policy, we describe the personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the CCPA, we also have to provide you with the "categories" of personal information we collect and disclose for “business purposes” (as those terms are defined by applicable law). Those categories are identifiers (such as name, address, email address, phone number, other account information, and cookies); commercial information (such as transaction data); financial data (such as credit card and other financial account information); internet or other network or device activity (such as IP address or service usage); geolocation information (general location); inference data about you; sensory information (such as audio recordings if you call customer service); professional or employment related data; education data; insurance (including health insurance) information; medical information; physical characteristics or description; legally protected classifications (such as gender); other information that identifies or can be reasonably associated with you.The categories of sensitive personal information are account log-in, financial account information, and password or other credentials allowing access to your account.

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We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of our Website and Platform; (3) affiliates; and (4) third parties and other Trusli users.

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We or our service providers may collect and disclose the above categories of information for the purposes described in our Privacy Policy. This includes the following business or commercial purposes (as those terms are defined in applicable law):

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• Our operational purposes;
• Auditing consumer interactions on our Services;
• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
• Bug detection and error reporting;
• Customizing information that we or our service providers display on the Online Services;
• Providing our Services (e.g., intake requests, approval workflows, customer service, advertising and marketing, metrics and analytics, and communication about our Services);
• Improving our Services and developing new services (e.g., by conducting research to develop new products or features);
• Other uses that advance our commercial or economic interests, such as third party advertising and communicating with you about relevant offers from third party partners;
• Other uses about which we notify you.
• We may also use the above categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

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We describe our information disclosure practices in our Privacy Policy. We may disclose certain categories of personal information with third parties (as defined by the CCPA) for the business purposes described above. For example, we may disclose identifiers and other information that identifies or can reasonably be associated with you with counterparties to your agreements. We may disclose identifiers with our marketing partners, and we may also disclose any of the categories described above with our subsidiaries and affiliates. If you connect your account with social media services or interact with social media plugins or links on the Online Service, we may disclose identifiers, commercial information, internet or other network or device activity, or general location with those social media services.

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Consumer Rights

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If you are a California resident, you may have certain rights. California law may permit you to request that we:

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• Provide you the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for "collecting," "selling," or "sharing" your personal information; the categories of third parties to whom we disclose or "sell," or with whom we "share," personal information; and the categories of personal information we "sell."
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we have about you.
• Correct inaccurate personal information that we maintain about you.
• You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Online Services to you. If you ask us to delete it, you may no longer be able to access or use the Online Services.

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In instances where we process personal information on behalf of our customer, rights requests should be directed to the relevant customer. Any request sent directly to us that pertains to information collected on behalf of a customer will be forwarded on to that customer.

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If you would like to exercise any of these rights, you can submit a request at help@trusli.com. You will be required to verify your identity before we fulfill your request. To do so, you will need to provide information to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

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“Sale” of Personal Information

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California residents may opt out of the "sale" of their personal information. The CCPA broadly defines "sale" in a way that may include allowing third parties to receive certain information such as cookie identifiers, IP addresses and/or browsing behavior to add to a profile about your device, browser or you. Such profiles may enable delivery of interest-based advertising by such third parties within their platform or on other sites.

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Depending on how you use the Service, we may disclose the following categories of information for such interest-based advertising, which may be considered a “sale” as defined by the CCPA: identifiers (such as IP address, device identifiers, and cookies) and internet and device activity. To opt out of such "sales," please submit a request to legal@ironcladhq.com or submit the Consumer Rights Request Form.

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"Sharing" of Personal Information

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California residents may opt out of the "sharing" of their personal information. The CCPA defines "sharing" as the targeting of advertising to a consumer based on that consumer's personal information obtained from the consumer's activity across websites. We "share" information for these purposes to provide more relevant and tailored advertising to you regarding our Services. As part of this advertising, we may "share" identifiers (such as IP address, device identifiers, and cookies) and internet and device activity with advertising platforms and advertising networks. To opt out of such "sharing," please submit a request to legal@ironcladhq.com or submit the Consumer Rights Request Form.

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Global Privacy Control

Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.

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Children Under 16

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We do not knowingly "sell" or "share" the personal information of children under 16.

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Sensitive Personal Information

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The CCPA also allows you to limit the use or disclosure of your "sensitive personal information" (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

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Retention of Your Personal Information

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Please see the "Data Retention" section above.

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California Shine the Light

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We do not disclose personal information to third parties for their direct marketing purposes.

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Children’s Privacy

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The Online Services are not directed to children under the age of 13. We do not knowingly collect personal information (as that term is defined in the Children’s Online Privacy Protection Act (COPPA)) from children under 13. If we discover that an individual under 13 has provided us with personal information, we will delete the personal information to the extent required by COPPA.

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We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.

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Updates to the Privacy Policy

6.1 Policy Changes:

We may update, change, or replace any part of these Terms at any time. The most current version of the Terms will be posted on the Service. It is your responsibility to check the Service periodically for changes.

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If we make any material changes to the Terms that affect your rights or obligations, we will notify you of the changes in a reasonable manner. This may include notifying you through the Service or by sending you an email.

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Your continued use of the Service following the effective date of any changes to these Terms constitutes your acceptance of those changes. If you do not agree to the new Terms, you may not use the Service.

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Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal information, please contact our Chief Technology Officer at:

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Trusli Inc.

651 N Broad St, Suite 205 #3522

Middletown, Delaware 19709

help@trusli.com

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