Our Commitment to Privacy

Your privacy is important to us. This website, www.True North.com (the “Site“), is owned and operated by True North Software, Inc. (“True North“). This True North Privacy Policy (“Privacy Policy“) describes how True North and its affiliates collect, use and disclose personally identifiable information or personal data (“Personal Information“) that we may obtain about you (“You“) through the Site. When You provide Personal Information to us via our Site, we protect it according to this Privacy Policy. By using any True North Site, You acknowledge that You have reviewed, understood and agree to, the terms of this Privacy Policy. If You do not agree to this Privacy Policy, do not use this Site.

For California residents, additional disclosures required by California law may be found in our California Privacy Notice.

True North adheres to its Controller and Processor Data Protection Binding Corporate Rules (“BCR Policy”) approved by European data protection authorities with respect to compliance with European data protection laws and specifically to transfers of Personal Information of employees, customers, resellers, suppliers, service providers and other third parties wherever it is collected and used in conjunction with True North business activities and the administration of employment between members of the True North Group or to external service providers. Information about True North’s BCR Policy can be found in the section set out below: “BCR Framework“.

True North operates in the business-to-business (B2B) software industry. Unlike many companies and websites, we do not focus on consumer users or the collection of consumer data. To the extent we collect information online, our purpose is to better serve our business customers.

BCR Framework

True North has established the Controller and Processor Binding Corporate Rules Policy when acting as a Data Controller and/or a Data Processor which have been reviewed and approved by European data protection authorities (“BCR Policy”). The BCR Policy is incorporated into a True North corporate wide policy, requiring all True North entities, employees and third party providers to comply with and respect the BCR Policy governing the collection, use, access, storage and transfer of Personal Information among True North entities and third parties. To learn more about the BCR framework and to view True North’s BCR Certification, please visit the European Commission’s website.

The Personal Information We Collect

We may collect the following types of information when You browse this Site, any other True North website, or any site of a True North affiliate (“True North Website”), as part of True North’s legitimate interests as it is described below:

Personal Information You provide directly when You register on a True North Website, make an online order, join an online community or other group, inquire about True North products, or request True North support or services at any True North interactive message board or via any e-mail messages You send True North, including Your name, contact information (phone and fax numbers, address, and email address), ordering information, and payment data.

Personal Information You provide directly, including information You submit through a True North Website as part of the online job application process, registering for a True North-sponsored training, event, user group, or conference, creating an online account with True North, or requesting customer support, education services or information about True North products.

Passively collected information, including through the use of “cookies” as described below, such as IP addresses, web browser and operating system information, date and time of visits, and the web pages Your Internet browser visits when browsing any True North Website; click-through information related to True North emails and related marketing activities; and aggregate, non-Personal Information, such as the number of hits per week or per web page.

Cookies

True North Software uses cookies to distinguish you from other users of a True North Website. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our sites. For detailed information on the type of cookies we use and the purposes for which we use them and how you can control them, read our Cookie Notice. By using this Site, www.True North.com, or any other True North Website, you accept the use of cookies in accordance with the Cookie Notice. If you do not accept the use of cookies, please disable them following the instructions in the Cookie Notice, by using the Cookie Consent Tool provided by True North on this Website, or by changing your browser settings so that cookies cannot be placed on your computer or mobile device.

Web Beacons

True North may use “web beacon” technology to gather metrics from anonymous web users and email recipients for the purpose of operating and improving True North websites and email communications. A web beacon is an electronic image that is imbedded in a web page or email which allows True North to track web page views/hits or the opening of an email containing a beacon. True North may use web beacon in conjunction with cookies to track web site activity on this Site, www.True North.com, and other True North websites. Web beacon tracking by True North does not identify the name or email address of the web user or mail recipient.

The Way We Use Personal Information

True North uses Personal Information You have provided directly or information we collect indirectly online about You in the following ways, as part of True North’s legitimate interests:

For Personal Information You provide directly online, or through email messages, relating to inquiries about products, ordering products, requests for support or services, or downloading products, we use the information to engage in and process transactions with You, to respond to Your inquiries and requests, to provide information on True North products and services, to provide information on True North’s partners offering True North’s services and products, and to provide customer support activities. Before we use Your Personal Information, we will give You the opportunity to choose whether or not You allow True North to use Your Personal Information in such ways described in this Privacy Policy. You may at any time choose to stop receiving True North’s emails relating to our marketing materials by following the unsubscribing instructions contained in the emails we send to Your attention. You can also unsubscribe by sending an email to privacy@True North.com and requesting the removal of Your name from True North marketing lists.

Some True North products and services may be advertised by third parties. In the U.S. and other jurisdictions with similar laws, we will only share Your Personal Information if You have not expressed Your preference by opting out of having Your information shared. In countries that are members of the European Union and all other jurisdictions with similar laws, we will only share Your Personal Information if You have agreed to allow us to share Your information with third parties. You have the opportunity to choose to not receive such marketing materials from third parties by updating Your subscription preferences here.

True North informs You that when You agree for Your information to be shared and used by third parties, then these third parties are responsible for handling Your information. Personal Information You provide online on others’ sites may be provided to third parties working on True North’s behalf, such as True North partners, data processors, and advertisers. Therefore, we recommend that You familiarize yourself with their online privacy policies so you understand how True North partners will use, collect, and handle your information.

For Personal Information You provide online, including cookies, actions, or clicks from hyperlinks and subscriptions, we may use such information to customize future communications and True North web pages in accordance with communication preferences You have established with True North.

For some registration, email and data You provide, we may direct You to particular web pages, customize the web pages You see, or otherwise increase the relevance of the information You receive. True North may use Analytic Cookies as described in our Cookie Notice accordingly to collect Your Personal Information about web pages visited, page hits per week, and the like, and True North will use this information internally to improve the design of our web pages.

For Personal Information submitted using the online job application process, we may use and disseminate this information internally and among our affiliates as necessary to consider Your application and to contact You regarding our decision.

For Personal Information submitted online for scheduling training or registering to attend a True North-sponsored conference or event, we may use and disseminate this information internally and among our affiliates to communicate with You and to facilitate Your registration and participation.

When We Share Your Personal Information

As a global company, True North shares information for business and marketing purposes only on a need-to-know basis and only with: (a) its own employees and contingent workers (b) the customer from which True North received the information; (c) True North distributors, resellers, third parties software vendors, subcontractors, consultants, and third-party service-provider companies, that have agreed to safeguard such information in a like manner to the way that True North safeguards such information and that have agreed to confidentiality terms with True North or that have entered into arrangements with True North to provide the services described in this Privacy Policy; and (d) other entities authorized to have access to such information under applicable law or regulation.

True North may only disclose Personal Information in accordance with the BCR Policy, as necessary in connection with the sale or transfer of all or part of its business, to protect our rights or property, or to enforce our terms of use and legal notices. True North may disclose Your Personal Information as required or permitted by law, or at the request of government regulators or other law enforcement officials and the courts (including the issuance of a valid subpoena) only in accordance with our BCR Policy.

True North will not use or share Your Personal Information in ways unrelated to those described above without first notifying You and offering You a choice as to whether or not we may use Your Personal Information in a different manner.

Data Security, Integrity and Access

True North is committed to protecting Your privacy. True North processes Your Personal Information only in ways compatible with the purpose for which it was collected and in accordance with the BCR Policy. To the extent necessary for such purposes, we take reasonable steps to make sure that the information is accurate, complete, current and otherwise reliable with regard to its intended use. True North provides data subjects with the opportunity to access, review and correct their own Personal Information, and otherwise provides such individual access to Personal Information in accordance with the BCR Policy. However, True North expects that You will update your Personal Information with True North as necessary as described in the section below “How You Can Access or Correct Your Personal Information”.

True North takes reasonable and appropriate measures to maintain the confidentiality and integrity, prevent the unauthorized use or disclosure, of Personal Information and to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. This includes maintaining a system of appropriate administrative, physical and technical safeguards to secure such information.

Links to Unaffiliated Third Party Websites

This Site may contain links to unaffiliated third party websites. If You link to or otherwise visit any other websites managed by third parties, True North encourages You to review the privacy policies available on such websites. You understand that True North has no control over those websites and is not responsible or liable for the policies and practices followed by such third parties.

How You Can Access or Correct Your Personal Information

If You have created an online profile with True North, You can update Your profile by logging on and following the prompts. Other online registration profiles You may have established at True North relating to sales, marketing, customer support, training, and event registrations can be updated by following the instructions provided within each profile/account.

You can also request access to Your Personal information that we collect online and maintain, and update or correct that information, through e-mailing privacy@True North.com with the subject line heading of “Privacy Policy Request.” To protect Your privacy and security, we will take reasonable steps to verify Your identity before granting access or making corrections.

You can also request erasure, restrict or object to the processing of Your Personal information.

We may keep information in an off-line form, for archival purposes or as otherwise required by law. Please note that if Your information is removed from our databases, You may no longer be able to access certain areas of a True North website requiring registration or a subscription.

Users may request to be removed from a True North e-mail list, by following the “unsubscribe” instructions on e-mails from True North or by sending a request to privacy@True North.com.

We keep information for as long as is necessary for the purposes for which it is collected and further processed, in accordance with the True North’s record retention policies and procedures.

Revisions and Contact Information

We periodically update the features of True North Websites. We reserve the right to change this Privacy Policy without advance notice and any modifications are effective when they are posted here. The date of the newest version will be posted below. Please check back frequently, especially before You submit any Personal information at this Site, to see if the Privacy Policy has changed. If You have any questions, please contact us by sending an e-mail message to privacy@True North.com with the subject line heading of “Privacy Policy Request.”

Cooperation Procedure with Data Protection Authorities and Dispute Resolution

True North agrees to cooperate and comply with EU and Switzerland data protection authorities in the investigation and resolution of complaints brought under the BCR Policy, in accordance with the Cooperation Procedure set forth in the BCR Policy. Additionally, you have the right to lodge a complaint with a data protection authority.

Questions, Complaints and Inquiries

Questions or complaints regarding this Privacy Policy, True North’s BCR Policy or requests for access to Personal Information should be directed to the True North Global Privacy Office, privacy@True North.com

True North Privacy Policy Rev. 2020-01-08