Effective date: Jan 13, 2026
We at TruCentive, Inc. (“TruCentive” or “we”) know you care about how your personal information is used and shared, and we take your privacy seriously. This Privacy Policy (the “Privacy Policy”) covers our treatment of personally identifiable information that we gather when you are accessing or using our website or Services. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you consent that we will collect, use, and share your information in the ways described below. Remember that your use of the Services is at all times subject to the TruCentive Terms of Use, which incorporate this Privacy Policy; any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
This Privacy Policy also incorporates our obligations under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the UK GDPR, where applicable. If you are a resident of the European Economic Area (EEA) or the United Kingdom, the additional GDPR provisions in this Policy apply to you. TruCentive acts as a data controller with respect to personal data collected through our Services.
“Personal Information” as used in the policy means any information relating to an identified or identifiable natural person or a combination of information that can be used to identify, contact or locate a specific person. This Privacy Policy does not apply to the practices of companies we do not own or control, or people that we do not manage (including Merchants and our licensees who are the Purchasers of the Instruments we deliver); you should look to the privacy policies of those people or entities to learn how they process their Personal Information.
We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile and to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties as described below.
As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13, or under the age of 16 where required by applicable law including the GDPR. If you are under the applicable age threshold, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child below the applicable age threshold, we will delete that information as quickly as possible. If you believe that a child may have provided us personal information, please contact us at support@trucentive.com.
For users in the EEA and UK, we process your personal data under one or more of the following lawful bases as required by the GDPR:
We will indicate the specific legal basis relied upon for each category of processing in our register of systems, which is reviewed at least annually.
We receive and store any information you knowingly provide to us. This can occur when you fill out applications, create accounts, complete a purchase, add money to your account, take surveys, click links or fill in various online fields on our website. For example, through the registration process and/or through your account settings, we may collect Personal Information such as your name, e-mail address, billing and payment details, phone number and third-party account credentials (for example, your log-in credentials for social networking or other third-party sites).
You do not have to provide us with your Personal Information, but if you choose not to disclose certain information we might not be able to provide you with certain services or features. If you provide your third-party account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts (“Third-party Account Information”) may be transmitted into your account with us, and that Third-party Account Information transmitted to our Services is covered by this Privacy Policy.
We may communicate with you if you have provided us the means to do so. For example, if you have given us your e-mail address, we may send you promotional e-mail offers on behalf of our business or other businesses, or e-mail you about your use of the Services. We may also deliver Instruments via other communication methods, including text messages, subject to the terms of the TruCentive SMS Terms and Conditions.
Where we rely on your consent to send marketing communications, you have the right to withdraw that consent at any time. If you do not want to receive communications from us via e-mail, please contact us at support@trucentive.com or click “unsubscribe” at the bottom of any e-mail. To opt out of marketing text messages, please follow the directions in the applicable text message or respond “STOP.”
We may receive information about you from licensees, Merchants and other users of TruCentive via the Services (“Friend-Provided Information”). For example, your employer or friend may provide us with your name and e-mail address and/or text number in order for us to deliver an envelope with an Instrument, e-mail and/or text to you. We use Friend-Provided Information in accordance with this Privacy Policy in the same manner we use Personal Information that a user provides us about himself or herself.
If you provide information to TruCentive about your friend or another third party, you represent and warrant that you have all rights to do so and to permit us to contact that friend as set forth in this Privacy Policy. Where required by applicable law, including the GDPR, you are responsible for ensuring a valid lawful basis exists for sharing that individual’s personal data with us.
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, device identification, location information, “cookie” information, the type of browser and/or device you are using to access our Services, the capabilities of the browser and/or device, and the page or feature you requested.
“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. Where required by applicable law, including under the GDPR and the ePrivacy Directive, we will obtain your prior consent before placing non-essential cookies on your device. You may withdraw that consent at any time by adjusting your cookie preferences through our cookie consent tool or your browser settings.
You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services.
We may de-identify your Personal Information so that you are not identified as an individual and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services. We never disclose aggregate usage or de-identified information to a partner in a manner that would identify you as an individual person.
We may allow advertisers and/or merchant partners and licensees (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers. We may provide any of the information we have collected from you in personally identifiable form to our licensees, and to other Advertisers in non-personally identifiable form, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers.
We may provide certain Personal Information to our licensees and/or Merchants in connection with redemption of our Instruments and to otherwise allow the Licensees or Merchants to contact you regarding their service offerings. By using the Services, you consent to our sharing such information with our Licensees and Merchants.
Where we share your personal data with third-party Advertisers or Merchants who act as independent data controllers, those parties are responsible for their own compliance with applicable data protection laws, including the GDPR. We will, to the extent required by law, enter into appropriate data processing agreements with such parties.
To the extent permitted by law, we may provide information about your transactions or use of our Services to other affiliated entities, whose use and disclosure of your Personal Information is subject to this Privacy Policy. By using the Services, you consent to our sharing such information with affiliated businesses. Where such sharing involves transfers of personal data subject to the GDPR, we will ensure appropriate safeguards are in place as described in Section 12 below.
We may employ other companies and people to perform tasks on our behalf and need to share your Personal Information with them to provide products or services to you. These agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Where these agents process personal data on our behalf and are subject to the GDPR, we enter into data processing agreements with them as required by Article 28 of the GDPR. These agreements require our processors to process personal data only on our documented instructions and to maintain appropriate security measures.
TruCentive is based in the United States. If you are located in the EEA, the UK, or another jurisdiction with data transfer restrictions, please be aware that your personal data may be transferred to, stored, and processed in the United States or other countries outside your jurisdiction.
Where transfers of personal data from the EEA or UK to a third country (including the United States) are required, we rely on one or more of the following transfer mechanisms to ensure adequate protection of your personal data:
You may request a copy of the safeguards we rely on for international transfers by contacting us at support@trucentive.com.
Certain user profile information, including the user’s name, location, e-mail address and picture that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address the user’s request for our services.
In the event TruCentive is involved in a merger, acquisition or sale of all or a portion of its assets, we may share and/or transfer Personal Information in connection with such transaction. Also, if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party. We will provide notice of any such transfer and of any choices you may have regarding your personal data to the extent required by applicable law.
We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law, a subpoena, court order or government request or to investigate fraud; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of you, the Company, our employees, our users, or others.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by Article 33 of the GDPR. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you without undue delay as required by Article 34 of the GDPR. Such notification will include a description of the nature of the breach, the likely consequences, and the measures taken or proposed to address it.
Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and against accidental loss, destruction, or damage, in accordance with Article 32 of the GDPR. These measures take into account the nature, scope, context, and purposes of processing as well as the risk to individuals. However, we cannot guarantee complete security, as unauthorized entry, hardware or software failure, and other factors may compromise the security of user information at any time.
Where required by the GDPR, we have appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Policy and applicable data protection laws. You may contact our DPO by writing to:
Data Protection Officer
TruCentive, Inc.
Email: support@trucentive.com
If you are located in the EEA, you also have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities and their contact details is available at https://edpb.europa.eu. If you are located in the UK, you may lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk.
All personal data that we process must be done on one of the lawful bases described in Section 2 above: consent, contract, legal obligation, vital interests, public task, or legitimate interests. To ensure our processing of data is lawful, fair and transparent, we maintain a register of systems, which we review at least annually. We note the appropriate lawful basis of data collection in the register of systems. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent is kept with the personal data.
Depending on your location and applicable law, you may be entitled to the following rights with respect to your personal data. EEA and UK residents have these rights under the GDPR:
To exercise any of these rights, please contact us at support@trucentive.com. We will respond to your request within one month of receipt. We may extend this period by a further two months where the request is complex or we receive a number of requests, in which case we will inform you within one month of the reason for the extension. We will not charge a fee for exercising your rights unless the request is manifestly unfounded or excessive.
You may access, and, in some cases, edit or delete the following information you have provided to us: name and password; e-mail address; billing and payment details; phone number; location; and social media account information. The information you can view, update, and delete may change as the Services change. When you update information, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: support@trucentive.com.
We will retain your personal data for as long as your account is active or as needed to provide you Services, and for a period of no longer than seven years thereafter, unless a longer retention period is required by applicable law. We determine the appropriate retention period by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you delete your account, we may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements, to the extent permitted by applicable law.
We do not knowingly collect or solicit personal data from children under the age of 13, or under the age of 16 where required by the GDPR or other applicable law. If you are under the applicable age threshold, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal data from a child below the applicable age threshold without parental consent where required, we will delete that information as quickly as possible. If you believe that a child may have provided us personal data, please contact us at support@trucentive.com.
TruCentive may make changes or amendments to this Privacy Policy from time to time. We will alert users to material changes by placing a notice on www.trucentive.com, by sending you an e-mail, and/or by other means. Where required by law, including the GDPR, we will obtain your consent to material changes or give you the opportunity to opt out. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes, to the extent permitted by applicable law.
If you have any questions or concerns regarding this Privacy Policy or our data protection practices, please send a detailed message to support@trucentive.com. We will try to resolve your concerns and will respond in accordance with applicable law, including the GDPR where relevant. Please keep in mind that certain Services will not be available if you withdraw your consent or otherwise delete or object to our processing of certain Personal Information.
EEA and UK residents who are not satisfied with our response also have the right to lodge a complaint with the relevant supervisory authority as described in Section 16 above.
