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Privacy Policy

 

Last Updated: April 8, 2024

 

Privacy is important to us. At Psychological Capital, LLC, we care about your privacy and want you to feel comfortable and secure in your use of our website, services, mobile apps, and any other online or offline services and products we offer, all of which we collectively refer to herein as our “Website” for ease of reference. This policy explains how we collect, use, and disclose personal information collected from you. By using our Website (which refers to all of our websites, apps, products, and services), you are accepting this Privacy Policy with respect to the information that is collected, as well as the storing, processing, and transfer of information in and to the United States and other countries. Our policies may be modified at any time, and we will notify you of any changes to our policies by posting them on our Website or by sending an email to the address we have on file for you. Please check this page regularly for updates.

Collection of Personal Information

When you visit our Website, there are three general categories of information we collect.

Personal Information You Provide to Us: this is information that is identifiable to you as an individual or your household. Depending on what you do on our Website, this may include:

  • name, alias, date of birth;
  • email, home, and mailing addresses;
  • phone numbers, including mobile numbers;
  • account name and details for our Website and others you provide;
  • number and age of children;
  • hobbies, preferences, housing type, and other information requested through the tests and assessments on our Website;
  • credit card or other payment information;
  • psychometric and career interest information;
  • records of services and products purchased;
  • passwords and biometric data, including any form of digital identification;
  • photographs and videos;
  • personal characteristics and demographics, including some protected classification characteristics under California and federal law such as age, gender, marital status, ethnicity, and primary language;
  • forms of government identification such as driver’s license, and passport;
  • professional, employment-related and education information; and
  • other personal information you provide or we infer from information you provide.

Information Collected About Your Use of the Website: we also collect information about your use of our Website, which may include:

  • identifiers, such as computer, server, and IP addresses
  • internet or other electronic network activity information, such as browser versions, pages most visited, duration and time of visit, as well as standard fields from our web log reporting software; and
  • geolocation information.

Information Collected from Third Parties: we also collect personal information from you from third parties to perform certain functions such as customizing our marketing efforts.

You may choose not to provide any of the personal information we request from you, but we may not be able to complete the requested activity without the personal information and the full functionality of our Website may not be available to you without the requested personal information. If you communicate with us via email, or otherwise complete purchase orders, surveys, or any other online forms, tests, or assessments, any information you provide may be collected by us.

If you include personally identifying information in materials you contribute to the public areas of our Website via postings, chat rooms, comment areas, or otherwise, that personal information will be available to the public. We therefore strongly encourage you not to include personally identifying information in your interactions in public forums on our Website, including in your username.

How We Collect Personal Information

We collect personal information that you provide to us, for example the information you provide when you register for our Website, the information you provide when you respond to the assessments, and other information you provide like your resume and social media profile. Likewise, we collect personal information when you contact us requesting information, participate in or provide feedback on our Website, or forward information from our Website to internet addresses outside of our Website.

We also collect and use information automatically when you use our Website. We use common tracking tools such as cookies, clear GIFs (also referred to as web beacons or pixel tags), device identifiers or IP addresses to collect information about your use of our Website. We also use third-party analytics services, including Google Analytics, to analyze traffic and optimize performance; these services may also place cookies on your devices. In general, cookies are used to retain preferences, store information for things like shopping carts, and provide tracking data to third-party applications like Google Analytics. You may, however, disable certain cookies. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser or doing your own web research on how to disable cookies. Note that, if you choose not to accept cookies, some features and the personalization of our Website may no longer work for you. The information collected through these tools is primarily used for aggregate, statistical reporting and stored in log files. Log files are transaction records that web servers maintain and record information, such as: service provider IP addresses, browser versions, referring websites, search terms used, average number of pages requested, average duration of visit, and/or total visitor traffic.

Please note that linked third-party websites may also use cookies. We cannot control the use of cookies by these third-party websites. For example, when you link from our Website or app to a third-party website, that website may have the ability to recognize that you have come from our Website by using cookies. If you have any questions about how third-party websites use cookies, you should contact the third parties directly.

GIFs can tell us whether you have visited a Web page or received or opened a message we send to you.

An IP address is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet. In addition to logging your IP address, we may also record the referring page that linked you to us (e.g., another web site or a search engine); the pages you visit and how long you stay on our Website; and other usage activity and data.

Our Website also uses third-party analysis and tracking services to track the performance of our Website, understand how you use our Website, and offer you an improved and safer experience.

How We Collect Financial Information

If you are making a purchase, you will be asked to provide payment information. We use this information only in connection with your purchases and other financial transactions you authorize. You may be directed to a payment processing portal hosted by a third-party payment processor. Please read the privacy policy of the payment processor regarding the use, storage, and protection of your credit card information before submitting any credit card information. We retain financial information as permitted by and required by law.

Use of Information We Collect

We may use the information we collect from you in the following ways:

  • To set up your account with us.
  • To provide an analysis of your survey, test, and assessment responses, including using artificial intelligence to learn from our users, make our Website function better, and provide more accurate information and responses.
  • To perform transactions through our Website and third-party service providers.
  • To personalize your user experience and to allow us to deliver the type of content and offerings in which you are most interested, including sending you emails if you authorize us to do so.
  • To deliver service messages and other services and content you request and send information related to accounts and services, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages, and to enable user-to-user communication.
  • To conduct an aggregated analysis of the performance of our Website, including referral data if you arrive at our Website from an external source.

All the information we collect from you is necessary for us to deliver our Website. We use the ChatGPT application programming interface developed by OpenAI (commonly referred to as the ChatGPT API), to provide the services on our Website. By using our Website, you are acknowledging that you understand that OpenAI receives all of the information (like your resume and LinkedIn profile) that you provide to us because we use the ChatGPT API to process your information and to create the evaluations and documents you request. You should read the OpenAI terms and policies for the ChatGPT API to understand OpenAI’s data and privacy policies. Should you disagree with the collection and processing of your information, please stop using our Website and take steps to delete your account.

How We May Disclose Information We Collect

We may disclose personal information as follows:

  • We may disclose personal information with your consent. For example, you may let us disclose personal information with third parties for their own marketing uses. Those uses will be subject to the third-party privacy policies.
  • We may disclose personal information to third party service providers that perform services on our behalf, such as third-party researchers to perform data analysis, and with third-party payment platforms to fulfill an order.
  • We may disclose personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include, but are not limited to, any merger, financing, acquisition, or bankruptcy transaction or proceeding, and may involve the transfer of your personal information.
  • We may disclose information to respond to lawful requests and legal processes, and with banking partners as required by credit card association rules.
  • We may disclose information to protect the rights and property of our company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • We may disclose information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • We may disclose information with those who need it to do work for us.
  • We may disclose personal information to third parties like Facebook and Google for our marketing and advertising purposes. Those uses will be subject to the third-party privacy policies.
  • We may also share aggregated and/or anonymized data with others for their own uses.

Basis for Processing Personal Information

Our legal basis for collecting and using your personal information will depend on the personal information collected and the circumstances in which it is collected.  Generally, however, we collect personal information from you only (i) where we need the information to perform a contract with you or provide products or services to you; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so. We have a legitimate interest in operating our Website and communicating with you as necessary to provide products and services, for example when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Security of Your Personal Information & Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a product or service you have requested or to comply with legal, tax, or accounting requirements). When we have no ongoing legitimate business need to process personal information, we will either delete or anonymize it or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store personal information and isolate it from any further processing until deletion is possible.

The security of your personal information is important to us. When you enter sensitive information (such as credit card number) on our Website, we encrypt that information using secure socket layer technology (SSL). We take reasonable security measures to protect your personal information to prevent misuse, unauthorized access, disclosure, and alteration. Despite our reasonable efforts, no security measures are impenetrable. If you use a password on our Website, you are responsible for keeping it confidential. Do not share it with any other person. If you believe your password has been misused, please notify us immediately.

We share your information with OpenAI to provide you our services and we do not have control over the privacy practices of OpenAI. If you do not want your information shared with OpenAI, you should not use our services.

Your Rights Under the California Consumer Privacy Act (“CCPA”) and Other State Privacy Laws

The CCPA provides consumers in California with specific rights regarding their personal information. If you are a California resident, you have the right to:

  • request we disclose to you free of charge the following information covering the 12 months preceding your request: (a) the categories of personal information about you that we collected; (b) the categories of sources from which the personal information was collected; (c) the purpose for collecting personal information about you; (d) the categories of third parties to whom we disclosed personal information about you and the categories of personal information that were disclosed (if applicable) and the purpose for disclosing the personal information; and (e) the specific pieces of personal information we collected about you;
  • request we delete personal information we collected from you, unless the CCPA recognizes an exception; and
  • opt-out of the sale or sharing of your personal information

Consistent with California law, if you choose to exercise your applicable CCPA rights, we will not charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your personal information, we will not do so unless the benefits to you are reasonably related to the value of the personal information that you provide to us. If you wish to exercise your rights under the CCPA, please contact us at info@truepath.ai.

Several other states have enacted consumer privacy laws and the company will abide by all such laws. If you would to exercise any of your rights under a state law that applies to you, please contact us at info@truepath.ai.

Choices About Your Information

You may correct or update your information in your account. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account, request that we no longer use your information to provide you services, or delete your personal information, you may do so through your account settings, or contact us at info@truepath.ai. We will respond to your request to have your personal information updated as soon as practicable. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You can request that your account be deleted, however, certain financial record keeping information may be maintained in our systems because we have a legitimate legal and financial interest in maintaining such records. You may unsubscribe from receiving promotional emails from us. If you wish to do so, simply follow the instructions found in the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes, including messages about your current account and services.

Our Website may include links to other websites not controlled by us whose privacy practices may differ from ours. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any third-party websites you visit.

International Data Transfers

We may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.

Information of Children

Our Website is not directed to children and does not intentionally collect any information from children under the age of 18. Please contact us at info@truepath.ai if your child has provided personal information to us and we will delete the information.

Questions About This Policy

If you have any questions about this Policy, our practices related to our Website, or if you would like to have us remove your information from our database, please feel free to contact us at info@truepath.ai.

DSAR form

A Data Subject Access Request (DSAR) form allows individuals to request access to their personal data held by an organization, ensuring compliance with data protection regulations. It helps individuals understand how their data is used and verify its accuracy.

DSAR form