TruRating Global Privacy Notice

At TruRating we are passionate about consumer privacy and we are fully committed to protecting the anonymity and privacy of every consumer that uses our services.

This policy details the data we collect, how we collect it, what we do with it and what controls you have.

This Global Privacy Notice (together with our website terms of use and any other documents referred to in it) sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your data and how we treat it.

This Global Privacy Notice may be amended from time to time if our practices change. Any changes we may make to this Global Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Global Privacy Notice.

1. Who are we?

TruRating Limited is a company registered in England and Wales which together with its subsidiaries is part of the TruRating group of companies (collectively referred to as “TruRating” or “we” or “us” in this policy).

2. What do we do?

We use the point of payment – in–store, online and however customers pay, now and in the future – to ask each customer a single question. We use the responses to those questions to help both consumers and businesses to make better, data driven, decisions.

The data we collect is only useful and valuable if it can be trusted – if there is no way in which consumers could have been influenced to answer the questions in a certain way. The anonymity of consumers is therefore both fundamental to the value of the data we collect as well as our belief in the rights of the consumer to privacy over their own data.

3. What data do we collect when you rate?

When you enter a rating or answer a single question in store or online we store the question we asked and the response that you gave. We link this to the details of the transaction that you made which may include the date and time, the total amount that you spent, the items that you purchased and your method of payment. If you made the transaction in store then we also collect the name and location of the store and the till where you were served. If you made the transaction online then we collect the website that you came from and the broad location (city or county level) derived from the IP address. If you choose to add additional comments to your rating when or after you rate then we will also hold those comments.

We receive the detailed transaction data that we link to the rating from the merchants that make use of the TruRating service. They share this data with us in accordance with their own privacy policies and lawful reasons for processing and sharing the data

We do not collect or accept any data that would allow us to identify you (e.g. name, address, email, social log ins, phone number, date of birth etc) and we never share your data at an individual level that would allow anyone else to identify you using other data that they might hold about you. Nobody will ever be able to contact you or treat you differently because of a rating that you gave.

We use the responses that you and other consumers give to provide aggregated and anonymous consumer insights. Businesses use this insight to measure and improve areas such as customer service, store operations, product display and marketing effectiveness.

We also use the aggregated insight to provide an online service to consumers who can search for and find feedback on businesses that they are considering using.

We do not ask or allow our clients to ask questions of consumers that we believe they would be uncomfortable answering or that would reveal sensitive data about them.

GDPR – Lawful Processing – Legitimate Interest

Under GDPR definitions the data we collect is pseudonymous. This means we must still consider the data you provide as personal data and we must ensure that the way in which we process it is lawful as defined by GDPR.

We process the data that you provide to us under the lawful reason of legitimate interest.

This means we have a genuine and legitimate reason to process your data and that we can show we are not harming any of your rights and interests when we process your data in this way.

When we process your data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Sharing your information

We will only disclose your data to third parties or individuals when obliged to by law, for purposes of national security, taxation and criminal investigations.

We will never share your individual rating or transaction data with anyone else for any other reason. This means that while we will use your data with responses from other consumers for analytics and market research we will never use it or share it for the purposes of direct marketing to you or the differentiation of any services you might receive from any merchant.

Retaining your information

We hold the rating that you provide for only as long as is necessary for each purpose we use it. This period will normally be for seven years after you provided the rating, unless we have a good reason to keep your information for a longer period. This is based on any legal, regulatory or business reasons we may have to retain your information.

4. What data do we collect in other cases?

If you interact with TruRating in ways other than providing us with a rating and in a role other than as a consumer (e.g. as a supplier, a representative of a merchant that uses our service, as a prospective employee etc) then we may collect your personal data. This section sets out how we collect it, how we hold it, how we use it and to whom we may disclose it. It also sets out how you may access and seek correction of your personal information or complain about a breach of your privacy.

On our website, you may find links to other websites not operated by us, including our partners’ websites. This Global Privacy Notice doesn’t apply to them – always check the privacy policy of any other website you enter.

The situations in which we may collect your personal data are as follows:

  • if you are a representative of a TruRating merchant registering for or accessing your TruRating dashboard;

  • if you contact us by any channel and provide your personal details for follow up communications;

  • if you provide personal data when you complete a customer satisfaction survey we have produced for a third party;

  • in connection with an actual or potential business or employment relationship with TruRating;

This information is only collected so we can provide the nominated TruRating service to you and for the purposes set out below. This information may include your name, company name and registration details, contact details, IP address, browser information, and other information relevant to the provision of your TruRating service. The information we collect includes the information you give us, the information we acquire from third parties and that which is generated by you – including your use of our website and how you arrived at our website in the first place (please see our Cookie Policy on TruRating.com for more detail). We will not collect any information about you without your consent; however, where you have given us or generated the information, your doing so will constitute your consent to our collection of that information.

Why do we collect the information and how do we use or disclose it?

We collect, hold, use and disclose your information:

  • to provide and contact you about, your nominated TruRating service;

  • to develop and enhance our products and services;

  • to detect and prevent fraudulent activity;

  • to conduct research and to plan and develop our product and marketing strategies;

  • to operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of and optimising our advertising; analysing our products, services, websites, mobile applications and any other digital assets; facilitating the functionality of our websites, mobile applications and any other digital assets) and performing accounting, auditing, billing, reconciliation and collection activities;

  • evaluate your interest in employment and contact you regarding possible employment with TruRating;

  • enforce our Website Terms of Use or other legal rights;

  • as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over TruRating or its affiliates;

  • comply with industry standards and our policies;

  • to promote and market products and services of ours and our TruRating partners; and

  • to comply with our legal obligations.

How can you withdraw your consent or request not to receive direct marketing?

You can withdraw your consent to our collection, use and disclosure of your personal information at any time by sending us an email at privacy@trurating.com. We will action your request as soon as we reasonably can. However, we may not be able to continue to provide the nominated TruRating service to you.

If you’ve previously indicated to us that you’d like to hear about TruRating, we may contact you by post, telephone, email or SMS. You can change your preferences / unsubscribe at any time – just send us an email – privacy@trurating.com. We’ll action your request as soon as we reasonably can.

When might we disclose your personal information?

We share your personal information with:

  • companies who work on our behalf to provide your nominated TruRating service;

  • companies within the TruRating group;

  • government, law enforcement agencies, the courts and regulatory bodies when legally obliged to; and

  • if you have given TruRating feedback to pass to a third party such as through TruRating Online’s feedback tool or via customer satisfaction survey, we will give your feedback and any personal data you have provided to that third party. They may contact you or use your personal data in accordance with their privacy policy.

5. International Data Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information was originally collected, including the United States of America.

We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area ("EEA") or Switzerland.

6. How do we protect your information?

We hold your personal information in a combination of electronic and hard copy files. We may store your personal information with a third party data storage provider.

We take all reasonable steps to ensure that the information we hold is protected from misuse, interference and loss, and unauthorised access, modification or disclosure by the use of various methods, including secure storage. Where we store your information with a third party data storage provider, we require them to keep it secure and only use or disclose it for the purpose for which it was provided.

Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information that we hold.

We will only keep information about you for as long as we need for the purpose for which it was collected and we take steps to ensure that any third party to which we have disclosed your information does the same.

7. How to contact us

If you have any questions or comments about this Global Privacy Notice, TruRating’s privacy practices or if you would like us to update information or preferences you provided to us, please email us at: privacy@trurating.com ; or write to us at:

Privacy Officer
TruRating Limited
107 Leadenhall Street
London EC3A 4AF

You can ask for access to your personal information that we have about you. We ask that you put your request in writing and provide proof of identity. It may take up to 40 days for us to respond and sometimes we will not be able to provide you with the information, in which case we will give you a written notice explaining why.

If you think that any personal information we hold about you is inaccurate, incomplete, out–of–date or irrelevant, you may ask us to correct it. We will take reasonable steps to correct it unless we disagree with your reasons. If we refuse to correct your personal information we will give you a written explanation why.

If you are a California resident, California Civil Code Section § 1798.83 permits users of our website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@trurating.com.

8. Who should use TruRating?

TruRating is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or through our website. We do not knowingly collect personal information from children under 13.

If you are under 13, do not use or provide any information on our website or on or through any of its features/register on the website, use any of the interactive or public comment features of our website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@trurating.com.

With thanks,

The TruRating Team

Last Updated: October 2018