Welcome to the TruTake Privacy Policy

1. Data Controller

For purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR), TruTake is operated by Alt House, Corp., a corporation organized under the laws of the United States.

Alt House, Corp. is the data controller responsible for determining the purposes and means of processing personal information described in this Privacy Policy.

2. Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

2.1 Log Data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include standard technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

2.2 Device Data

When you visit our website or interact with our services, we may automatically collect data about your device, such as:

	•	Device type
	•	Operating system
	•	Device settings
	•	Coarse geo-location data (such as city, state, and country). We do not retain precise geographic coordinates.

Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

2.3 Personal Information

We may ask for personal information — for example, when you submit content to us or when you contact us — which may include one or more of the following:

	•	Email
	•	Username (selected by you)
	•	Age range or age band (exact birth date is not retained or stored)
	•	Phone/mobile number

If age-related information is collected, it is used solely to determine age range or minor-status flags. Exact dates of birth are not retained or stored.

2.4 Sensitive Information

“Sensitive information” or “special categories of data” is a subset of personal information that is given a higher level of protection under applicable law. Examples include information relating to racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, health information, sexual orientation, criminal records, biometric data, or other information classified as sensitive under applicable data protection laws.

Sensitive information may be provided by you directly through optional demographic fields or may arise from your responses to questions submitted on the platform.

The types of sensitive information that may be processed in connection with your use of TruTake include:

• Racial or ethnic origin
• Political opinions
• Religion or philosophical beliefs
• Trade union or professional association / membership
• Health-related information
• Sexual orientation
• Criminal history information

We will not collect or process sensitive information about you without your explicit consent where required by law. Sensitive information is used solely for anonymized and aggregated analysis in accordance with this Privacy Policy and is not used to make individual-level decisions about you.

We will only use or disclose sensitive information as permitted, required, or authorized by law.

2.5 User-Generated Content

We consider “user-generated content” to include materials voluntarily supplied by users of the platform, including (i) posts and comments submitted for publication and (ii) answers submitted in response to questions on the platform.

2.5.1 Public Posts and Comments

Posts and comments submitted for publication on the platform are associated with the account used to submit the content and may be publicly displayed, including your username and profile avatar.

Content submitted for publication may be included in curated threads, trails, insight reports, or media experiences generated by TruTake. Once published, such content may be accessible to other users and, depending on platform functionality, to the public. Once publicly available, content may be viewed, shared, or referenced by third parties not covered under this Privacy Policy.

You should not submit content for publication that you do not wish to be publicly available.

2.5.2 Answer Submissions

Answers submitted in response to questions on the platform are treated differently from posts and comments.

Individual answer data is not publicly displayed under your username, is not disclosed at the individual level, and is not attributable to your username or profile. Instead, answer data is combined with responses from other users and used for anonymized and aggregated statistical analysis and, where applicable, to support platform functionality such as personalization within your account.

Aggregated results may be reflected in composite contributor models (“Crowd Personas”), insight reports, and related media experiences. These aggregated outputs do not identify individual users or disclose individual-level answer data.

3. How TruTake Generates Revenue

TruTake does not sell individual-level personal data and does not sell data to advertisers.

TruTake generates revenue by selling anonymized and aggregated insight reports and related media outputs derived from statistical modeling of grouped user responses. These reports are built from analysis of answer data at the group level and do not reveal or expose individual user data.

Individual responses are never sold, disclosed, or made accessible to third parties.

4. Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. We only collect personal information that is reasonably necessary to provide our services to you.

4.1 Collection and Use of Information

We may collect personal information from you when you do any of the following on our website:

	•	Register for an account
	•	Sign up to receive updates from us via email or social media channels
	•	Use a mobile device or web browser to access our content
	•	Contact us via email, social media, or on any similar technologies
	•	When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

	•	To provide you with our platform's core features and services
	•	To enable you to customize or personalize your experience of our website
	•	To contact and communicate with you
	•	To enable you to access and use our website and associated applications
	•	For internal record keeping and administrative purposes
	•	To comply with our legal obligations and resolve any disputes that we may have
	•	For security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use
	•	For technical assessment, including to operate and improve our app, associated applications, and associated social media platforms

4.2 Lawful Basis for Processing (GDPR)

If you are in the European Economic Area (EEA), United Kingdom, or Switzerland, TruTake processes personal data under the following lawful bases:

4.2.1 Contractual Necessity - Article 6(1)(b) GDPR

We process certain personal data as necessary to provide the TruTake platform and fulfill our contractual obligations to you. This includes:

• Creating and maintaining your account
• Storing and displaying your profile information
• Recording your answers and participation in platform features
• Generating user-facing reports and exports

Without this processing, we would be unable to provide the core functionality of the platform.

4.2.2 Legitimate Interests - Article 6(1)(f) GDPR

We process certain data as necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms. These interests include:

• Maintaining platform security and preventing fraud or abuse
• Improving platform performance and reliability
• Enforcing our Terms of Service
• Analyzing system-level usage patterns in aggregated form

Where we rely on legitimate interests, we assess and balance those interests against your data protection rights.

4.2.3 Consent - Article 6(1)(a) GDPR

We process optional demographic information based on your freely given consent. You may choose whether to provide such information, and you may withdraw consent at any time.

If you withdraw consent, we will stop using that data for future demographic modeling and aggregated insight generation.

4.2.4 Explicit Consent for Special Categories of Data - Article 9(2)(a) GDPR

If you voluntarily provide special categories of personal data (such as information relating to race, ethnicity, political opinions, religion, or sexual orientation), we process that information only with your explicit consent.

Such data is used for anonymized and aggregated analysis and statistical modeling in accordance with this Privacy Policy and is not used to personalize content, affect individual visibility, or make individual-level decisions about you.

We will only use or disclose sensitive information as permitted, required, or authorized by law.

You may withdraw this consent at any time.

4.2.5 Withdrawal of Consent

Where processing is based on consent, you may withdraw your consent at any time through your account settings. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

4.3 Automated Analysis and Profiling

TruTake uses automated statistical modeling to analyze aggregated user contributions and generate structured insight reports. These processes include clustering techniques that group anonymized responses into composite contributor models (“Crowd Personas”) to identify patterns, trends, and consensus dynamics across groups.

These processes are designed to:

• Operate on anonymized and aggregated data
• Prevent identification of individual users
• Generate statistical insights rather than individualized evaluations

Certain platform features may use automated processing to personalize content or organize information within your account. Such processing does not produce legal effects or similarly significant impacts on you.

TruTake does not use automated decision-making to make legal, financial, employment, credit, or similarly significant decisions about individual users.

No automated process on the platform produces legal effects or similarly significant impacts on individuals within the meaning of Article 22 of the GDPR.

Users may withdraw consent for demographic processing at any time, and such withdrawal will prevent future inclusion of that data in aggregated modeling.

4.4 Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.

You are responsible for ensuring any passwords and email accounts associated with accessing TruTake are secure and confidential.

All access to personal data is restricted to personnel and service providers who require such access to perform their duties.

4.5 Data Retention (How Long We Keep Your Personal Information)

We retain personal data while your account remains active.

If you delete your account, personal data associated with your account is permanently deleted from our active systems.

Anonymized statistical aggregates derived from user contributions may be retained indefinitely, provided they no longer identify individuals and cannot reasonably be linked back to individual users.

We retain limited records of privacy-related actions (such as consent changes or deletion confirmations) for compliance and auditing purposes.

4.6 Age Requirement

TruTake is intended only for individuals 18 years of age or older. We do not knowingly collect or process personal information from individuals under 18.

5. Disclosure of Personal Information to Third Parties

We may disclose personal information to the following categories of third parties where necessary to operate our services and comply with legal obligations:

• Our employees, contractors, and affiliated entities who require access to perform their duties
• Service providers who assist in operating the platform, including hosting providers, cloud infrastructure providers, database and authentication providers, payment processors, and technical support providers
• Professional advisors, including legal, accounting, or compliance advisors
• Courts, regulatory authorities, or law enforcement agencies where required by law or to establish, exercise, or defend legal rights
• An entity that acquires all or substantially all of our assets in connection with a merger, acquisition, or corporate restructuring

We do not sell personal information to advertisers or third-party advertising networks.

Third-party service providers we currently use in connection with the platform include:

• Stripe (payment processing)
• Supabase (database and authentication services)
• Google Cloud Platform (cloud hosting and infrastructure)
• MailChimp (email and SMS notifications)

6. International Transfers of Personal Information

TruTake stores and processes personal data in the United States.

If you access the platform from outside the United States, you understand that your information will be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.

Where required, we implement appropriate safeguards such as Standard Contractual Clauses or other legally recognized transfer mechanisms consistent with applicable data protection laws.

7. Your Rights and Controlling Your Personal Information

Depending on your location and applicable law, you may have certain rights regarding your personal information. These rights may include:

7.1 Access

You may request confirmation of whether we process your personal information and request access to the personal information we hold about you.

7.2 Correction

You may request correction of inaccurate or incomplete personal information.

7.3 Deletion

You may request deletion of your personal information, subject to applicable legal limitations, including retention obligations.

7.4 Restriction of Processing

You may request that we restrict the processing of your personal information in certain circumstances permitted by law.

7.5 Objection

You may object to certain types of processing where permitted by law.

7.6 Data Portability

You may request a copy of your personal information in a structured, commonly used, and machine-readable format where technically feasible.

7.7 Withdrawal of Consent

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

You may exercise these rights by contacting us using the details provided below. We may request information necessary to verify your identity before responding to your request.

You are not required to provide personal information to us. However, certain information may be necessary to access core features of the platform.

7.8 Europe

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you also have the right to lodge a complaint with your local data protection authority if you believe our processing of your personal information violates applicable law.

7.9 Unsubscribe

If you wish to opt out of receiving promotional or update emails, you may do so using the unsubscribe link included in the communication or by contacting us directly.

7.10 Data Breach

We will comply with applicable data protection laws in the event of a data breach and will notify affected users where required.

8. Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of the transaction, subject to applicable legal requirements. Any successor entity will be required to honor the commitments set forth in this Privacy Policy or provide notice of any material changes in accordance with applicable law.

9. Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other operational needs.

When we make material changes, we will update the “Effective” date at the top of this policy and provide appropriate notice, which may include posting a prominent notice on our website or notifying registered users through account communications.

Where required by applicable law, we will obtain your consent before implementing changes that materially affect how we process your personal information.

We encourage you to review this Privacy Policy periodically to remain informed about how we protect your information.

11. Additional Disclosures for U.S. States Privacy Law Compliance

The following section includes provisions that comply with the privacy laws of these states (California, Colorado, Delaware, Florida, Virginia, and Utah) and is applicable only to the residents of those states. Specific references to a particular state (in a heading or in the text) are only a reference to that state's law and applies only to that state's residents. Non-state specific language applies to all of the states listed above.

11.1 Do Not Track

Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser "Do Not Track" signals.

11.2 California Privacy Laws - CPPA

Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents have certain rights regarding their personal information, including the rights described in the “Right to Know, Access, and Delete” section above.

TruTake does not sell personal information and does not share personal information for cross-context behavioral advertising.

We do not offer financial incentive programs in exchange for personal information.

11.3 California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

• Identifiers, such as email address, username, IP address, phone number (if provided), and an ID or number assigned to your account.
• Payment information processed via third-party payment processors (we do not store full credit card numbers or billing addresses on our servers).
• Demographic information, such as age range or gender, voluntarily provided by users. This category may include data that qualifies as protected classifications under California or federal law.
• User-generated content, such as posts, comments, and other materials you submit for publication on the platform.
• Coarse geolocation data, such as city, state, and country.
• Inferences, derived from aggregated participation patterns for statistical analysis. These inferences do not result in individualized behavioral profiles.

For more information on the sources of personal information we collect and the purposes for which we use it, please review the “Information We Collect” and “Collection and Use of Information” sections of this Privacy Policy.

We do not sell personal information or share personal information for cross-context behavioral advertising.

11.4 Right to Know and Delete

Subject to applicable law, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the preceding 12 months. You may request:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The business or commercial purposes for collecting the personal information;
• The categories of third parties to whom we disclosed personal information for a business purpose;
• The specific pieces of personal information we have collected about you.

You also have the right to request deletion of your personal information, subject to certain legal exceptions, including where retention is required to comply with legal obligations or to maintain anonymized and aggregated statistical data that cannot reasonably be linked back to you.

To exercise any of these rights, please contact us using the details provided in this Privacy Policy. We may request information necessary to verify your identity before responding to your request.

11.5 Shine the Light

Under California Civil Code Section 1798.83, California residents may request information regarding the disclosure of personal information to third parties for their own direct marketing purposes.

TruTake does not share personal information with third parties for their own direct marketing purposes.

12. Contact Us

If you have questions about this Privacy Policy or our data practices, you may contact us at: