Privacy

Last modified: 9/3/2021

Introduction
American Secure Living Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect or that you may provide when you register with, access, visit, or use the products and services offered by us, the Company’s website located at https://truehold.com/ (the “Website”), including any content, functionality, and services offered on or through the Website (collectively the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information that:

- We collect on the Services.
- We collect in email, text messages, chat, and other electronic messages between you and the Services.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

This policy does NOT apply to information that:
We collect offline or on any other mobile applications, services, products, or websites you may access through the Services. 
You provide to or is collected by any third party (including but not limited to, social media providers and any third party we may refer or recommend on our Services.). These third parties may have their own privacy policies and practices regarding your information. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. Capitalized terms not defined herein shall have the meaning set forth in our Terms of Use.

Children Under the Age of 18
The Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on the Services or through any of its features, register on the Services, use the chat feature on the Services or provide any information about yourself to us, including your name, telephone number, or email address. If we learn we have collected or received personal information from a child under 18 we will delete that information. If you believe we might have any information from or about a child under 18, please email us at hello@truehold.com.

Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Services, including information:
- That you provide when registering or interacting with the Services by which you may be personally identified, such as name, e-mail address, phone number, address or by any other information the Services collect that is defined as personal or personally identifiable information under applicable law and any other identifier by which you may be contacted online or offline (“personal information”).
- That is about you but individually does not identify you, such as your financial information, including your income, savings, and debt. 
- That is about your home.
- About your internet connection, the equipment you use to access our Services, and usage details.

We collect information from and about users of our Services:
- Directly from you when you provide it to us.
- Automatically when you use the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. 
- From third party service providers and affiliates

.Information You Provide to Use
The information we collect on or through the Services may include:
- Information that you provide when you register with the Services.
- Information you provide to determine the value of your home and your eligibility as a potential customer.
- Information you provide relating to your finances, including but not limited to, your income, savings, and debt.
- Details of transactions you carry out through our Services. 
- Information that you provide when requesting a service.
- Records and copies of your correspondence (including email addresses, text messages, and messages sent through the chat feature), if you contact us. 
- Information when you report a problem with the Services. You also may provide information through the chat feature available on the Services.

Information We Collect Through Automatic Data Collection Technologies  
As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Services, including traffic data, logs, location data and other communication data and the resources that you access and use on the Services.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). 

The information we collect automatically does not include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Market future events based off your preferences.
- Store information about your preferences, allowing us to customize our Services according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services. 
- Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. 
- Web Beacons. Pages of the Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including links to our partner’s websites, on the Services are served by third-parties, including content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Services and its contents to you.
- To enable users and nonregistered users to communicate with us through the chat feature.
- To send you an information kit in the mail or through email if it is requested.To identify customers.
- To provide you with an estimate of the value of your home.
- To invest in your home.To determine future service offerings.
- To present the property management portal to you.
- To analyze your financial viability as a potential customer.
- To present to real estate investors to provide the capital for us to purchase your home.
- To refer you to third party affiliates who may provide their services to you.
- To respond to a service request.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account. 
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Services or any products or services we offer or provide though it.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please send us an email at hello@truehold.com.

Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 

We may disclose personal information that we collect or you provide as described in this privacy policy:
- To third parties who may provide their services to you.
- To our subsidiaries and affiliates.To credit reporting agencies.
- To contractors, service providers, investors and potential investors, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Services users is among the assets transferred.
- To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. 
- To fulfill the purpose for which you provide it. 
- For any other purpose disclosed by us when you provide the information.
- With your consent.

We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Services may then be inaccessible or not function properly.
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to hello@truehold.com.
- Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to hello@truehold.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a purchase, service experience or other transactions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email at. 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information
You can review and change your personal information by logging into the property management portal and visiting your account information.

You may also send us an email at hello@truehold.com to correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at hello@truehold.com.