NOTICE: PRIVACY POLICY UPDATED, EFFECTIVE 1/15/2008

TrueNow, LLC Respects Your Privacy

This Privacy Policy details TrueNow LLC’s treatment of personally identifiable information (PII) that it collects when you provide PII directly to us through this website.

TrueNow LLC reserves the right to modify this privacy policy from time to time. Changes to the privacy policy will be posted on this website and the effective date of the policy will be modified to reflect the effective date of the most recent version. If a material change to our PII practices occurs in the future, we will only use PII collected from the time of the policy change forward for these new purposes unless we have your consent.

Types of Information We Collect or Maintain About Consumers

Personally Identifiable Information

PII is information that allows TrueNow LLC to identify and communicate with an individual consumer. Through the use of this, TrueNow LLC may collect or maintain the following PII about consumers:

• First and Last Name
• Physical Address
• Email Address
• Phone Number
• Fax Number
• SSN
• Annual Income
• Any other PII the user submits during the course of normal correspondence with TrueNow LLC or its third-party companies

Non-Personally Identifiable Information

Non-personally identifiable information is information collected by TrueNow LLC in the normal course of operating its business that does not reveal the specific identity of the consumer. This data records a consumer’s activity either on the TrueNow LLC website or within a TrueNow LLC -initiated email. Types of non-personally identifiable information collected include:

• IP Address
• Consumer click-stream data;
• Consumer email-open data;
• Aggregate click-stream data provided to TrueNow LLC by third-party companies.

Children’s Privacy

TrueNow LLC places the highest value on the privacy of children. TrueNow LLC does not knowingly accept PII from children under the age of 13.

How We Use Consumer PII

Consumer PII collected on this site.

TrueNow LLC will not sell, rent, or lease PII collected on this site to unaffiliated companies. Affiliated companies are companies under common ownership.

TrueNow LLC will use consumer PII collected on this site to contact the consumer in response to consumer-initiated inquiries, to provide services requested by the consumer, to inform consumers of other companies’ products or services, to alert consumers to changes in services or features, and to provide consumers with requested information regarding TrueNow LLC or our services. TrueNow LLC may share this PII with service providers who assist us with our marketing efforts, but those service providers will not use this PII for their own marketing purposes and are prohibited by contract from sharing this PII with any party other than TrueNow LLC or its parent company.

TrueNow LLC may use data-enhancement providers to augment data provided to us by consumers on this site. Data-enhancement providers will not use the data for any purpose other than to provide the enhancement information to TrueNow LLC, and are prohibited by contract from sharing that PII with any party other than TrueNow LLC. TrueNow LLC may, in order to provide the highest level of service, use data collected through affiliated organizations to enhance the data we collect on this site.

TrueNow LLC may share data with any company that is under common ownership or is legally affiliated with TrueNow LLC. These companies will adhere to the terms of this privacy policy and will not share your information with any unaffiliated third party, except in the limited circumstances detailed in this policy.

TrueNow LLC may also share PII in the following limited circumstances: (1) upon receipt of a properly authorized and authenticated governmental request for information; (2) in response to a subpoena or a court order, (3) to comply with relevant laws; (4) in response to an investigation of fraud regarding a specific consumer, or (5) in an effort to safeguard the person or property of a TrueNow LLC employee or a third party.

Finally, TrueNow LLC may, in the future, decide to sell, merge or otherwise reorganize its business. TrueNow LLC reserves the right to transfer and disclose PII in this circumstance, but data collected by TrueNow LLC will be governed by the same privacy policy that existed prior to any change in business conditions unless you consent to the new privacy policy.

European Union Residents

For PII collected from consumers inside the European Union, TrueNow LLC will not manage that consumer data unless that consumer first requested, pursuant to clear and conspicuous notice, to receive such types of marketing communications. Moreover, the EU recipient must be given clear and conspicuous notice that the data is going to be shared with third parties for marketing purposes, and that notice must be given prior to receipt of the recipient’s permission.

Cookies

TrueNow LLC may employ “cookies” to help customize your access to the website, and for the delivery of targeted advertisements. A cookie is a piece of data stored on your hard drive containing information about you. Cookies have many benefits to enhance your experience at our website and to facilitate the receipt of targeted advertisements.

We use cookies to track, monitor and target the interests of our users to further enhance the experience on our website, and for subsequent advertising and/or delivery purposes. To find out more about cookies, please visit http://www.cookiecentral.com/. To disable and reject cookies generally, click here.

In addition, for the purpose of formatting and delivering future campaigns, TrueNow LLC may employ pixel tags (also known as clear gifs) to track: 1) the pages that our users visit on affiliate and/or partner websites; and 2) user opens of, and clicks on, our targeted email advertising. We reserve the right to employ user source information, including applicable category and interest(s), for the marketing of targeted e-mail messages. This source information may be shared with our third party marketing partners. TrueNow LLC reserves the right to retain cookie and pixel tag data indefinitely.

Group and Aggregate Data

TrueNow LLC reserves the right to provide aggregate or group data about TrueNow LLC users for lawful purposes. Aggregate or group data is data that describes the demographics, usage, or characteristics of TrueNow LLC participants as a group, without disclosing PII.

Right to Contact Via Telephone

In addition, by registering at the website, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”). Notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, we reserve the right to contact you via telemarketing in accordance with the Rule.

Security

We endeavor to safeguard and protect our users' information. When users submit information at the website, such information is protected both online and offline. The servers in which we store PII are kept in a secure physical environment. TrueNow LLC has security measures in place to protect against the loss, misuse, and alteration of personal information under our control. Please be advised that, although we take reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, TrueNow LLC cannot warrant that your information will be absolutely secure. Any transmission of data at or through our website is at your own risk. However, access to your information is strictly limited, and not accessible to the public.

Access:

Consumers wishing to review PII collected by TrueNow LLC on this site should write to TrueNow LLC Privacy Department, 212-978-4185. TrueNow LLC may take reasonable steps to confirm the identity of the consumer in an effort to prevent identity theft.

Consumers wishing to review PII list managed by TrueNow LLC but collected on a third-party site pursuant to the third-party’s privacy policy should contact the third-party company responsible for the collection of the consumer’s PII.

Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents who have provided PII to TrueNow LLC to request certain information regarding TrueNow LLC’s disclosure of PII to third parties for their direct marketing purposes. Within thirty days of receiving such a request, we will provide a list of the categories of PII disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this section.

If you have any questions about this Privacy Policy, please contact us at privacy@creditimprovement.org or in writing at: If you have any questions about this Privacy Policy, please contact us at privacy@truenow.com or in writing at:

True Now LLC
1461 First Avenue #171
New York, NY 10021