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Last Modified: January 11,2022

PRIVACY POLICY

This Privacy Policy explains how Perm Solutions AB. (“Company”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our website located at https://trueroas.io (the “Site”) and the related content, platform, services, and other functionality offered on or through the online services (collectively, the “Services”).It does not address our privacy practices relating to job applicants, employees and other personnel.

Information We Collect

We collect Personal Information three ways: (1) directly from an individual when an individual provides us information when interacting with us in some way, (2) automatically when an individual interacts with our Services; and (3) from third-party sources, which may be even before our first direct interaction with the user.

Information You Provide to Use Directly

In registering for email, signing up for any account with us, placing orders via the Site or through other means, and for communicating with us about our products, you provide, and we, in turn, collect some Personal Information about you, which means information that can directly or indirectly associate or otherwise identify you as a natural person. While, at some times, you may be providing this information or otherwise engaging with us as an employee of another company, the information you provide and that we may collect, may include information including your name, personal or work email, personal or work physical address, personal or work phone number, billing information, information about the products/services you are/have been interested in or otherwise purchased or returned.

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you. When you interact with us, below are the categories of information we collection, including Personal Information:

Information We Collect Automatically

As is true of most digital platforms, we and our third-party providers may also collect Device Information, which includes your browsing actions and site usage patterns that are collected automatically when you visit or interact with our Site. This data, which, depending on where you are located, can include Personal Data, and may include: log data (such as internet protocol (IP) address, operating system, browser type, browser ID, the URL entered and the referring page/campaign, date/time of visit, time zone, the amount of time spent on our Site, errors that occurred during the Site visit, analytics data (such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site), and location data (such as general geographic location based on the log data we or our third-party providers collect).

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our Site. More information about the use of Google Analytics for these analytical and non-advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.

To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Site, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.

Information We Obtain From Third Parties

We also obtain Personal Information from third parties, which we often combine with Personal Information we collect either automatically or directly from an individual. We may receive the same categories of Personal Information as described above from the following third parties:

− Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions;

you

Comply with legal obligations; and
For any other reason for which you give us consent or that we otherwise notify that we may use your Personal Information.

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.

The legal basis for the associated processing of your Personal Information is Art. 6 (1)(f) GDPR (balancing of interests, based on our legitimate interest in constantly and profitably improving the content, functionality and attractiveness of the app by analyzing your usage) as well as Art. 6 (1)(b) GDPR (performance of a contract) and Art. 6 (1) a) GDPR (your consent).

How We Share or Otherwise Disclose Your Personal Information

We do not sell, rent or lease and Personal Information and have not in the immediate 12 months preceding the effective date of this Privacy Policy.

We may share, transfer and/or disclose your Personal Information to or with third parties in order to provide the Services or products requested or purchased by you, and under the following circumstances:

− Otherwise with Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.

EEA/EU Data Subject Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA) or European Union (EU), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.

If you wish to be informed about what Personal Information we hold about you, have a copy of it, correct or otherwise rectify it, and/or if you want it to be removed from our systems, please contact us using the contact information set out below.

In certain circumstances, you have the following data protection rights:

marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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 Privacy Officer, Perm Solutions AB, Högalidsgatan 34D, 11730, Stockholm, Sweden or via email to: rasmus@trueroas.io. We will respond to one request per California customer each year, and we do not respond to requests made by means other than as set forth above.

Notice to California, Nevada, and Utah residents

We do not disclose a user’s personal data to any third party for such third-party's direct marketing purposes nor do we sell, rent or lease your Personal Information. California, Nevada and Utah allow their residents to opt-out of the sale of their Personal Information, however, we do not sell any such information at this time. If you are a California, Nevada or Utah resident we want you to know that, in the event we sell your Personal Information, you will have choices and can opt-out and can affect them by contacting us via mail at Privacy Officer, Perm Solutions AB, Högalidsgatan 34D, 11730, Stockholm, Sweden or via email to: rasmus@trueroas.io.

Do Not Track (Including California Do Not Track Disclosure)

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Web browser “do not track” settings or signals. We deploy cookies and other technologies on our Service to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.

Children’s Privacy

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13 (16 in the EEA/EU). If an individual is under the age of 13 (16 in the EEA/EU), they should not use our Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 (16 in the EEA/EU) has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13 (16 in the EEA/EU), we will promptly delete that Personal Information.

Links to Third-Party Website Via Our Site and/or Services

Our Site and Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy policies.

Data Retention

We will retain your Personal Information for as long as is reasonable or appropriate for the purposes set out in this Privacy Policy. We will also retain and use your Personal Information to the extent necessary or reasonable to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Device Information for internal analysis purposes. Device Information then the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Transfer of Personal Information

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

If you are located outside the United States, please note that we transfer data, including Personal Information, to the United States and process it there.

By using the Services, you understand and acknowledge that your Personal Information will be transferred to and processed in the United States, which may have different data protection rules than in your country.

We will take steps reasonably designed to treat your Personal Information securely and in accordance with this Privacy Policy.

Protecting Your Information

We implement security measures designed to maintain the security of your Personal Information. These security measures are implemented both during transmission of Personal Information and once received. The security of your Personal Information is important to us. Certain sensitive information submitted, such as credit card information, is encrypted using secure layer technology (SSL). However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

We also implement encryption and tokenization of all personal data, making it unreadable. As TrueROAS never uses your customer personal data for other use, than matching to a certain source of revenue.

Communications Opt-Out

You may opt out of receiving marketing or other communications from us at any time by following the opt-out link or other unsubscribe instructions provided in any email message received, or by contacting us using the contact information provided below. If you wish to opt

out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email. Note that, even if you opt out of receiving marketing communications from us, we will still send you order confirmations and other non-marketing related messages.

Updates or Changes to This Privacy Policy

We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on this Site or our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

For users in the EEA, the EU, the United Kingdom, or Switzerland, any changes or modifications will be effective upon your express consent, as you will be notified of any changes by virtue of a pop-up, banner, or other notification mechanism when you seek to access the Site or Services after we issue a change or modification. Upon consent, the revisions on the Site or Services shall apply to all use of the Site or Services and all acts or omissions occurring after the effective date of the revised Privacy Policy.

Severability and Enforceability

To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

Our Contact Information

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to rasmus@trueroas.io

Alternatively, inquiries may be addressed to:

Perm Solutions AB.
Högalidsgatan 34D, 11730, Stockholm, Sweden