Privacy Policy

Last updated November 21, 2021

This Global Privacy Policy describes the privacy practices of the Truli social platform that Hyperstellar Inc., offers as a mobile application (the “App”). Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. We also provide a supplementary privacy notice for California residents and a supplementary privacy notice for data subjects in the EEA, Switzerland and the UK (collectively, “Europe”) and Brazil.

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About Truli

Truli is a new type of social network based on sharing recommendations and asking questions— where people connect with their real friends and community to discover the next thing awesome thing, from the people they trust the most.

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Our Privacy Principles

If you decide not to read this entire Privacy Policy, we want you to walk away with a few key points about Truli’s privacy practices:

We use personal information to provide our services, to communicate about existing and new Truli features with you, and to comply with our terms and applicable laws.

We do not sell personal information.

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Personal Information We May Collect

Here’s a description of the categories of information we collect when you interact with our App, and examples of how we use the specific types of information. We may collect:

Account data, such as your first and last name, organization name, email addresses, phone number, profile picture, preferred language, user name, and other information you may choose to include in your profile/bio.
Contact information. If you authorize us to collect information about your contracts, we will store hash values derived from the telephone numbers in your contact list. To help users connect with people they know, we offer them the option to invite friends to join them on Truli. To take advantage of this feature, users can opt in to share phone numbers from their address book as noted above, or add phone numbers manually.
Names of friends you choose to invite to join you on the App.
Messages you send to and receive from other users on the App. We review the contents of these messages only if there are user reports or automated systems flags indicating a Trust and Safety violation.
Interests, usage, and connections, including information about your interests (if you choose to add them) and how you use the App, such as the types of Truli conversations you engage in, content you share, features you use, actions you take, people or accounts you interact and connect with, and the time, frequency, and duration of your use.
Communications that we exchange with users when they contact us with questions or feedback, including feedback about interacting with other users.
Information provided by social media companies, if you interact with our pages on their services or connect your social media accounts. Connecting your social media accounts allows the App to authenticate your identity and access limited information about those accounts, including the number of connections you have. The information that social networking accounts provide to Truli may depend on the privacy settings you have with each company, so please consult their privacy and data practices.
Device data, such as device IP address (and derived location), device name and operating system, browser type and settings, telecommunications provider, operating system, the date and time of App use, interactions with the App, and the time, frequency, and duration of the interactions. You may also opt-in to allow us to access your device's call log data to verify your phone number (as an alternative to text message-based verification) when you join Truli. We will access the call log data once – when you join Truli.

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How We Use Personal Information

We use personal information for the following purposes in the following ways.

Provide our services, including to:

Invite you to our App;
Operate the App and our business;
Maintain, improve, and develop the App and the App’s features;
Create and maintain your account;
Facilitate network connections;
Recommend recommendations, users to follow that might be of interest to you;
Notify you when one of your contacts has joined the App;
Communicate with you about the App by sending you push notifications with announcements, updates, security alerts, and support and administrative messages, if you have enabled that functionality;
Provide support for the App, and respond to your requests, questions and feedback

Direct marketing. We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of feature releases and special events. You may opt out of our email marketing communications as described in the “Opt out of marketing communications” section below. Please note that we may periodically send you service emails even after you opt out of direct marketing.

Research and development. We may create and use de-identified information for our business purposes, including to analyze the effectiveness of our App, to improve and add features to our App, and to analyze the general behavior and characteristics of users of our App.

Support and Maintenance. We use third party analytics services to automatically log certain information about your mobile device and how you interact with the App. The information collected is used to troubleshoot and prevent errors, perform data analysis, and develop new features.

Compliance and protection. We may use personal information to:

Protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims);
Enforce the Terms of Service that govern the App;
Audit our internal processes for compliance with legal and contractual requirements and internal policies;
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

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Personal Information We May Collect Relating to Non-Users

Users may upload their contact lists to Truli in order to help Truli connect them to existing users, and to people who join Truli later. Similarly, users may send people invitations either via the contact list, or by manually entering a telephone number. We do not share this information or make it available to others.

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How We Share Personal Information

We do not sell personal information. In the ordinary course of business, we may share personal information with:

Service providers. Companies and individuals that provide services on our behalf or help us operate the App or our business (such as hosting, analytics, customer support, email and SMS delivery).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties as we believe necessary to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the Terms of Service that govern the App; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

Subsidiaries and affiliates. If we were to engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy, we may share your information with a party involved in such a process (for example, a potential purchaser).

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How You Share Information on Truli

Public. When you establish an account on Truli, you share certain of your profile information with the Truli community on our App and on the web. This information includes your profile picture, bio, name, username, the handles of social media accounts you connect to Truli, the list of users you follow and those that follow you, the date you joined Truli, questions you asked or commented on, recommendations you created or commented on.

Truli users. Truli users with whom you have some affiliation on the App or other social media accounts may receive notifications about actions you take on the platform, such as sending a recommendation or answering a question.

Instagram, Twitter and other social media companies.

If you connect your social media accounts (e.g., Instagram or Twitter) with Truli, Truli will also inform those companies that you have authorized its access to your profile information and connections associated with your accounts with those companies. As mentioned above, the information that social media companies provide to us may depend on the privacy settings you have with them, so please ensure that you review and understand their privacy and data practices. You may choose to share recordings on other social media platforms. Such sharing will be carried out for your own purposes and not Truli's, and such recordings will be subject to the social media platform's policies.

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Your Choices

Update, correct, or delete. You can contact us to ask us to update or correct your information. You may also delete your account or request that we delete the contact phone numbers you previously shared with Truli. Please note that we will need to verify that you have the authority to update, correct, or delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.

Disconnect social media accounts. When you connect your social media accounts to Truli, we notify those platforms. You may disconnect your social media accounts directly on the App at any time.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions contained in the communications we send you.

Opt out of push notifications. If you opt-in to receive push notifications within the App, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the app, or deleting the App.

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Other Sites and Apps

The App may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

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Processing of Personal Information in the United States

Truli has users located across the globe. We are headquartered in the United States and Japan with services providers that operate in other countries. We may transfer your personal information to countries which may not have the same data protection laws as your home country or territory, but we will protect your personal information in accordance with this Privacy Policy, or as otherwise disclosed to you.

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International Transfers from Europe

We are headquartered in the United States and Japan with service providers that operate in the United States and in other countries. Where we transfer your personal information to a country that does not provide the same level of data protection as is provided in Europe, we will use standard contractual clauses to ensure that your personal information is protected.

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Data Security

You use the App at your own risk. We implement appropriate technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Internet. Please keep this in mind when disclosing any personal information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the App, or third party websites. Finally, we cannot control the actions of users on the platform, who may seek to use third party apps or devices to record, store, or share content or communication without other users' prior consent. Please keep this in mind when using the App.

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Children

The App is not intended for use by children under 13 years of age. If we learn that we have collected personal information through the App from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

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Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the App. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the App. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).

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How to Contact Us

You can reach us by submitting a support request here.

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Notice to California Residents

We are providing this supplemental privacy notice to Consumers in California, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).

We do not sell personal information.

The CCPA grants California residents the following rights:

Information. Our Privacy Policy describes how we use and share your personal information through the App, including during the past 12 months. The Policy describes:
The sources through which we collect California residents’ personal information and the types of personal information collected in the “Personal Information We May Collect” section above.
The purposes for which we use and share this information in the “How We Use Personal Information” section above and the “How We Share Personal Information” section above.
How users share information via Truli in the “How You Share Information on Truli” section of the Privacy Policy.
Access. You can request a copy of the personal information that we maintain about you.
Deletion. You can ask to delete the personal information that we maintain about you.

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The CCPA limits these rights. For example, companies may not provide users in response to access requests certain sensitive information and other consumers’ personal information, and may exclude information that would compromise the confidentiality of trade secrets. The CCPA also places limits on when companies must comply with a deletion request.

In accordance with the CCPA, Truli will not provide the following information in response to access requests for the reasons described:

Account data such as account passwords and identity verification codes, unmasked phone numbers, or email addresses, because of the sensitive nature of this information.
Other users’ and employees’ personal information, including the names and account information of individuals who may have invited you to the App, other users’ feedback, and employees’ comments because it is information that belongs to another natural person and disclosing it may impact their rights.
Internal proprietary attributes that enable us to provide various aspects of our App, including channel and room customization, suspension decisions, and content suggestions, because it is protected by federal and state trade secret law.
Server logs that are older than 30 days because we use these to ensure the security and integrity of our App.

You are entitled to exercise the rights described above free from discrimination.

Here is how you can submit requests:

To request access to or deletion of personal information collected, please email us here.
To verify your identity prior to responding to your requests, we may ask you to provide us with your phone number so we can send you a verification code, or with other details that we may need to verify your identity.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with the CCPA.

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Notice to European and Brazilian Data Subjects

We are providing this supplemental privacy notice to European data subjects, pursuant to European data protection laws (“GDPR”) and Brazilian data subjects, pursuant to Brazilian data protection laws (“LGPD”).

Controller and Representative. Truli is responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR. You can find our contact information in the “How to Contact Us” section above.

Personal Data We Collect From You and How We Use It. You can read about the personal data we collect from you in the “Personal Information We May Collect” section above, and how we use it in the “How We Use Personal Information” section above. Please note we do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Justification for Data Processing. European and Brazilian data protection law sets out a list of justifications on which companies may rely to process personal data, and requires companies to explain to consumers the specific justifications for the company’s data processing activities. Truli generally relies on one of the following justifications to process personal data:

Contractual Necessity, to provide you with the App in accordance with our Terms of Service.
Legitimate Interests, where it is necessary for our legitimate business purposes, your interest or the interests of a third party.
Consent, where required by law. Where we rely on your consent to process personal data about you, you have the right to later withdraw your consent in the manner indicated when you consent or by contacting us as described in this Privacy Policy.

Provision of some of this data is necessary to establish an account on Truli.

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Justification for Data Processing

Recipients of Data. We may disclose your personal data to the recipients described in the “How We Share Personal Information” section above.

Retention of Data. We keep your personal data for as long as you have a Truli account to fulfill the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To protect the safety and security of our users, your personal data will be retained for a reasonable period of time following account deletion, but no longer than necessary.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Storage. We are based in the United States and Japan and rely on cloud storage providers that store user data on our behalf in the United States. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in Europe. We have taken measures to protect the confidentiality and security of your personal data, and your rights as a data subject.

Your Rights. The GDPR and the LGPD grant European and Brazilian data subjects the following rights:

Access. You can request a copy of the personal data that we maintain about you. If you require additional copies, we may need to charge a reasonable fee.
Deletion and Correction. You can ask us to delete or correct the personal data that we hold about you.
Objection. You may have the right to object to how we use your personal data.
Restrict Processing. You may ask us to suspend our processing of your personal data, for example, if you want us to establish its accuracy or the reason for processing it.
Data Portability. If required to do so, we will give you your personal data in a structured, commonly used, and machine-readable format.
Withdrawal of consent. You can withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

To exercise these rights, please email info@hyperstellarinc.com. You also have the right to complain to a data protection authority in your country about our processing of your personal data.