Privacy Policy
Privacy Policy
Last Updated Jun 30, 2024
1. OVERVIEW
True Offers USA, LLC d/b/a Deal Boss Project ("Deal Boss Project," "Company," "we," "us," and "our") respects your privacy and is committed to protecting it through compliance with this Privacy Policy ("Privacy Policy"). This Privacy Policy describes how we collect and use your Personal Information when you visit our website at https://www.dealbossproject.com, use our True Lead Creation CRM platform, participate in our educational programs, or otherwise use our services as described in our Terms of Service.
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will handle it. If you do not agree with our policies and practices, do not use our services. By accessing or using our services, you agree and consent to this Privacy Policy.
Deal Boss Project may change this Privacy Policy at any time, at its discretion. Your continued use of our services after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.
This Privacy Policy is subject to and governed by the Deal Boss Project Terms of Service. Our services include our CRM platform, educational programs, and related tools described in the Terms of Service.
2. INFORMATION WE COLLECT AND HOW WE COLLECT IT
Deal Boss Project may collect two types of information from you: Personal Information and Non-Personal Information (collectively "Information").
"Personal Information" refers to data by which you may be personally identified, such as name, email address, phone number, billing address, business information, and payment details.
"Non-Personal Information" means data that is about you but does not identify you specifically, such as browser type, device information, and aggregated usage statistics.
2.1 Information We Collect Directly From You
Account Registration and Profile Information:
- Name, email address, phone number, business information
- Billing and payment information (credit card details, billing address)
- Account credentials and security information
- Profile preferences and settings
Educational Program Participation:
- Course progress and completion data
- Assessment results and performance metrics
- Communication preferences for educational content
- Event registration and attendance information
CRM and Platform Usage:
- Contact lists and customer data you upload
- Campaign and automation configurations
- Phone numbers purchased through our platform
- SMS and email content you create and send
- Call recordings and voicemail data
- Real estate property data and investment information
Customer Support Communications:
- Support ticket information and correspondence
- Chat logs and communication history
- Feedback and survey responses
2.2 Information We Collect Automatically
Platform Usage Data:
- Login times, feature usage, and navigation patterns
- CRM activity logs and system interactions
- API usage and integration data
- Performance metrics and error logs
Device and Technical Information:
- IP address, browser type, and operating system
- Device identifiers and mobile device information
- Geolocation data (if location services are enabled)
- Cookies and similar tracking technologies
Communication and Marketing Data:
- Email open rates and click-through data
- SMS delivery and response metrics
- Website interaction and engagement data
- A2P 10DLC registration and compliance data
2.3 Information From Third-Party Sources
Third-Party Platform Integrations:
- Data from Go High Level, LeadConnector, and Twilio integrations
- Google API Services data (including YouTube API data when connected)
- Social media platform information when you connect accounts
- Payment processor information (Stripe, PayPal)
Business Partners and Data Providers:
- Lead generation and market data services
- Public records and property information for Market Domination services
- Industry event and conference data
- Referral and affiliate program information
Data Verification Services:
- Identity verification and fraud prevention data
- Phone number validation and carrier information
- Email verification and deliverability data
2.4 AI AND MACHINE LEARNING DATA USAGE
Personal Information in AI Interactions: When you interact with our AI systems, we may process personal and business information you provide to generate educational responses.
No AI Training Use: We do NOT use your personal information, business details, or AI interaction data to train general AI models or improve AI systems for other users.
AI Response Storage: AI interactions may be stored for quality assurance and to improve your individual educational experience.
Third-Party AI Services: Our AI systems may utilize third-party AI services. Your interactions are subject to our privacy practices, not those of AI service providers.
3. HOW WE USE YOUR PERSONAL INFORMATION
We use Personal Information for the following purposes:
3.1 Service Provision and Platform Functionality
- CRM Operations: Manage your customer data, automate marketing campaigns, track communications, and provide analytics
- Educational Services: Deliver course content, track progress, provide assessments, and issue certifications
- Communication Tools: Enable SMS, email, and voice communications through our platform
- Data Services: Provide Market Domination data, property analytics, and investment insights
- Account Management: Create and maintain user accounts, process payments, and provide customer support
- AI Educational Tools: Process your inputs to generate personalized educational content and recommendations for learning purposes only
3.2 Platform Development and Improvement
- Performance Optimization: Analyze usage patterns to improve platform functionality and user experience
- Feature Development: Develop new tools and capabilities based on user needs and feedback
- AI and Machine Learning: Enhance automation features and content generation (we do NOT use your data to train generalized AI models)
- Security Enhancement: Monitor for threats, prevent fraud, and maintain platform security
- Quality Assurance: Test new features and ensure platform reliability
3.3 Business Operations
- Financial Management: Process payments, manage subscriptions, and handle billing inquiries
- Legal Compliance: Meet regulatory requirements, respond to legal requests, and maintain records
- Customer Support: Provide technical assistance, resolve issues, and improve service quality
- Marketing and Sales: Promote our services, conduct market research, and manage affiliate programs
3.4 Communication and Marketing
- Service Communications: Send account notifications, security alerts, and service updates
- Educational Content: Deliver newsletters, training materials, and industry insights
- Marketing Messages: Share product announcements, promotional offers, and event invitations
- Personalization: Customize content and recommendations based on your interests and usage
3.5 Legal Basis for Processing (EEA/UK Residents)
For users in the European Economic Area and United Kingdom, our legal basis for processing includes:
- Contract Performance: Processing necessary to provide our services
- Legitimate Interests: Business operations, security, and service improvement
- Legal Compliance: Meeting regulatory and legal obligations
- Consent: Where you have provided specific consent for processing
4. THIRD-PARTY PLATFORM INTEGRATIONS
Our services rely on several third-party platforms to provide functionality. By using our services, you acknowledge and agree to the data practices of these platforms:
4.1 Core Platform Providers
Twilio (Communications):
- Privacy Policy: https://www.twilio.com/legal/privacy
- Handles SMS, voice calls, and phone number provisioning
4.2 Google Services Integration
Google API Services:
Our platform's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
YouTube API Services:
If you connect your YouTube account, the Google Privacy Policy (https://policies.google.com/privacy) applies. You may revoke our access via Google security settings (https://security.google.com/settings/security/permissions).
4.3 Payment and Financial Services
4.4 Analytics and Marketing
Google Analytics:
- Privacy Policy: https://policies.google.com/privacy
- Opt-out: https://tools.google.com/dlpage/gaoptout
5. HOW WE SHARE YOUR INFORMATION
We share Personal Information in the following circumstances:
5.1 Service Providers and Business Partners
- Technology Vendors: Third-party platforms that power our services (Go High Level, Twilio, etc.)
- Payment Processors: Companies that handle billing and payment processing
- Cloud Services: Data hosting and storage providers
- Analytics Providers: Services that help us understand platform usage and performance
- Customer Support: Tools and services that help us provide customer assistance
5.2 Business Operations
- Affiliates and Subsidiaries: Within our corporate family for business purposes
- Professional Advisors: Attorneys, accountants, and consultants as needed
- Business Transfers: In connection with mergers, acquisitions, or asset sales
- Legal Requirements: When required by law, court order, or government request
5.3 Marketing and Advertising
- Advertising Partners: For targeted advertising and marketing campaigns
- Analytics Services: To measure marketing effectiveness and user engagement
- Social Media Platforms: When you choose to connect or share content
5.4 With Your Consent
We may share information with other parties when you provide explicit consent for such sharing.
Important: We do NOT sell your Personal Information for monetary compensation. We do NOT share your phone number or SMS opt-in consent with third parties without your express written consent.
6. DATA RETENTION
We retain Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including:
- Account Data: Retained while your account is active and for a reasonable period after cancellation
- Educational Records: Maintained to provide ongoing access to completed courses and certifications
- Communication Data: Stored according to legal requirements and business needs
- Financial Records: Kept for accounting, tax, and legal compliance purposes
- Usage Analytics: Aggregated data may be retained indefinitely for business intelligence
Upon Account Cancellation: Most personal data is deleted within 24 hours, though some information may be retained for legal, security, or business continuity purposes.
7. INTERNATIONAL DATA TRANSFERS AND COMPLIANCE
7.1 Data Privacy Framework Compliance
True Offers USA, LLC d/b/a Deal Boss Project complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
We have certified our adherence to the DPF Principles regarding the processing of personal data received from the European Union, United Kingdom, and Switzerland. If there is any conflict between this privacy policy and the DPF Principles, the Principles shall govern.
To learn more about the DPF program and view our certification, visit: https://www.dataprivacyframework.gov/
7.2 International Transfers
When we transfer Personal Information internationally, we ensure appropriate safeguards are in place, including:
- Data Privacy Framework protections for EU/UK/Swiss data
- Standard contractual clauses where applicable
- Adequacy decisions and approved transfer mechanisms
8. YOUR PRIVACY RIGHTS
8.1 General Rights
Access and Portability: Request copies of your Personal Information
Correction: Update or correct inaccurate information
Deletion: Request deletion of your Personal Information (subject to legal requirements)
Opt-Out: Unsubscribe from marketing communications
Account Control: Manage your privacy settings through your account dashboard
8.2 U.S. State Privacy Rights
California (CCPA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA):
Residents of these states have additional rights including:
- Right to know what Personal Information is collected and how it's used
- Right to delete Personal Information
- Right to correct inaccurate Personal Information
- Right to opt out of targeted advertising
- Right to non-discrimination for exercising privacy rights
To Exercise Your Rights: Contact us at [email protected] or use our privacy request portal.
8.3 European Privacy Rights (GDPR)
EEA/UK/Swiss Residents have additional rights:
- Right of access to your Personal Information
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object to processing
- Rights related to automated decision-making
EU Representative Contact:
IITR Datenschutz GmbH
Marienplatz 2, 80331 München, Germany
089-18917360
Complaints: You may file complaints with your local data protection authority.
9. SECURITY MEASURES
We implement comprehensive security measures to protect your Personal Information:
Technical Safeguards:
- Encryption of data in transit and at rest
- Secure access controls and authentication
- Regular security monitoring and threat detection
- Secure development practices and code reviews
Administrative Safeguards:
- Employee training on data protection
- Access controls based on job responsibilities
- Incident response and breach notification procedures
- Regular security assessments and audits
Physical Safeguards:
- Secure data centers with restricted access
- Environmental controls and monitoring
- Secure disposal of hardware and media
Vendor Management:
- Due diligence on third-party security practices
- Contractual security requirements
- Regular vendor security assessments
10. CHILDREN'S PRIVACY
Our services are not intended for children under 18. We do not knowingly collect Personal Information from children under 16. If we learn that we have collected information from a child under 18, we will delete it promptly. If you believe a child has provided us with Personal Information, please contact us at [email protected].
11. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar technologies to:
- Enable platform functionality and remember your preferences
- Analyze usage patterns and improve our services
- Provide personalized content and advertising
- Ensure security and prevent fraud
Cookie Management: You can control cookies through your browser settings, though disabling cookies may affect platform functionality.
For detailed information about our cookie practices, please see our Cookie Policy.
12. MARKETING AND COMMUNICATION PREFERENCES
Email Communications:
- Unsubscribe links in all marketing emails
- Account dashboard communication preferences
- Separate controls for different types of communications
SMS Communications:
- Reply "STOP" to opt out of SMS messages
- Manage preferences through your account settings
- Compliance with TCPA and carrier requirements
Phone Communications:
- Do Not Call list compliance
- Opt-out options for marketing calls
- Respect for communication preferences
13. CALIFORNIA PRIVACY RIGHTS DETAILED DISCLOSURE
13.1 Categories of Personal Information Collected (Last 12 Months)
| Category | Collected | Sources | Business Purposes | Third Parties Shared With ||----------|-----------|---------|-------------------|---------------------------|
| Identifiers (name, email, phone, IP address) | Yes | You, affiliates, partners | Account management, service provision, marketing | Service providers, affiliates, advertising partners |
| Customer Records (billing info, payment data) | Yes | You, payment processors | Payment processing, account management | Payment processors, service providers |
| Commercial Information (purchase history, preferences) | Yes | You, platform usage | Service improvement, marketing, analytics | Service providers, analytics partners |
| Internet Activity (browsing, platform usage) | Yes | Automatic collection | Platform optimization, security, analytics | Service providers, analytics partners || Geolocation Data | Yes | Device/browser | Service personalization, security | Service providers |
| Audio/Visual (call recordings, uploaded content) | Yes | You, platform usage | Service provision, quality assurance | Service providers |
| Professional Information (business details, industry) | Yes | You | Service customization, marketing | Service providers, affiliates |
| Inferences (preferences, characteristics) | Yes | Data analysis | Personalization, marketing, service improvement | Service providers, advertising partners |
13.2 Business Purposes for Collection
- Providing and maintaining our services
- Processing transactions and managing accounts
- Customer support and communication
- Security, fraud prevention, and legal compliance
- Marketing and advertising
- Service improvement and development
- Analytics and business intelligence
13.3 Third-Party Sharing
We share Personal Information with:
1. Service Providers: Technology vendors, payment processors, cloud services
2. Affiliates: Related companies for business purposes
3. Advertising Partners: For marketing and advertising services
4. Professional Advisors: Legal, accounting, and consulting services
No Sale of Personal Information: We do not sell Personal Information for monetary consideration.
14. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:
- Posting the updated policy on our website
- Sending email notifications for significant changes
- Providing in-platform notifications
Your continued use of our services after changes become effective constitutes acceptance of the updated Privacy Policy.
15. CONTACT INFORMATION
For Privacy Questions and Requests:
General Inquiries:
True Offers USA, LLC d/b/a Deal Boss Project
ATTN: Legal & Compliance Department
931-E South Main St STE 246
Kernersville, NC 27284
Email: [email protected]
Data Protection Officer:[email protected]
Customer Support:[email protected]
For DPF-Related Complaints:
If you have complaints regarding our handling of personal data under the Data Privacy Framework, contact us first at [email protected]. For unresolved complaints, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) for free dispute resolution. Under certain conditions, binding arbitration may be available.
16. ADDITIONAL STATE-SPECIFIC DISCLOSURES
16.1 Virginia Consumer Data Protection Act (VCDPA)
Virginia residents have the right to:
- Confirm whether we process your Personal Information
- Access and obtain a copy of your Personal Information- Correct inaccuracies in your Personal Information
- Delete Personal Information provided by or obtained about you
- Obtain a copy of your Personal Information in a portable format
- Opt out of targeted advertising, sale of Personal Information, or profiling
Appeals Process: If we decline your request, you may appeal by contacting [email protected] within a reasonable time after receiving our response.
16.2 Colorado Privacy Act (CPA)
Colorado residents have similar rights to Virginia residents, plus:
- Right to opt out of certain profiling activities
- Right to appeal denied requests
Appeals: Contact [email protected] if we decline your request.
16.3 Connecticut Data Privacy Act (CTDPA)
Connecticut residents have the same rights as Virginia and Colorado residents.
Appeals: Available for declined requests through [email protected].
16.4 Utah Consumer Privacy Act (UCPA)
Utah residents have rights to:
- Access Personal Information
- Delete Personal Information
- Opt out of targeted advertising and sale of Personal Information
17. INDUSTRY-SPECIFIC DISCLOSURES
17.1 Real Estate Investment Education
Educational Content: We collect data about your learning progress, course completions, and educational preferences to provide personalized learning experiences and track certification requirements.
Investment Data: Property information, market analysis data, and investment strategies you input are used to provide educational context and personalized recommendations.
Compliance: We do not provide investment advice. All educational content is for informational purposes only.
17.2 CRM and Marketing Automation
Customer Data: Information you upload about your customers is processed to provide CRM functionality, automation services, and analytics.
Communication Tracking: We track email opens, SMS delivery, call connections, and other communication metrics to provide service analytics.
TCPA Compliance: You are responsible for ensuring compliance with all applicable laws when using our communication tools.
17.3 Market Domination Services
Public Records: We aggregate publicly available property and ownership data to provide market insights and lead generation services.
Data Accuracy: All data is provided "as-is" and you are responsible for verifying accuracy before making business decisions.
Usage Restrictions: Data is provided for legitimate business purposes only and must comply with applicable laws
18. AUTOMATED DECISION-MAKING AND AI
AI Content Generation: Our platform may use AI to help generate marketing content, property analyses, and communication templates. You retain ownership of content you create using these tools.
No Automated Decisions: We do not use automated decision-making that produces legal or similarly significant effects without human involvement.
AI Training: We do NOT use your Personal Information to develop, improve, or train generalized AI or machine learning models.
Transparency: When AI tools are used, we provide clear indication of their involvement in content generation.
19. BIOMETRIC INFORMATION
We do not collect, store, or process biometric information such as fingerprints, facial recognition data, or voice prints.
20. SENSITIVE PERSONAL INFORMATION
We limit our collection and use of sensitive Personal Information to:
- Information you voluntarily provide for specific purposes
- Information necessary to provide requested services
- Information required for legal compliance- Uses authorized by applicable law
Categories of Sensitive Information We May Collect:
- Financial account information for payment processing
- Precise geolocation data (only if you enable location services)
- Communication content (emails, SMS, call recordings you create)
21. CROSS-BORDER DATA TRANSFERS
Transfer Mechanisms:
- Data Privacy Framework for EU/UK/Swiss transfers
- Standard Contractual Clauses where applicable
- Adequacy decisions for approved countries
- Your consent for specific transfers
Safeguards: All international transfers include appropriate technical and organizational measures to protect your Personal Information.
22. DATA BREACH NOTIFICATION
Our Commitment: We will notify affected individuals and relevant authorities of data breaches as required by applicable law.
Notification Timeline:
- Regulatory authorities: Within 72 hours where required
- Affected individuals: Without undue delay when high risk is likely
- Communication method: Email, account notifications, or public notice as appropriate
Information Provided: Nature of breach, categories of data involved, likely consequences, and measures taken to address the breach.
23. VENDOR AND THIRD-PARTY OVERSIGHT
Due Diligence: We conduct security and privacy assessments of vendors who process Personal Information.
Contractual Requirements: Vendors must agree to appropriate data protection terms and security measures.
Monitoring: We regularly review vendor compliance with our data protection requirements.
Incident Response: Vendors must notify us immediately of any security incidents involving our data.
24. RECORD KEEPING AND COMPLIANCE
Documentation: We maintain records of our data processing activities as required by applicable privacy laws.
Regular Reviews: We conduct periodic assessments of our privacy practices and update procedures as needed.
Training: Our employees receive regular training on data protection requirements and best practices.
Compliance Monitoring: We monitor compliance with this Privacy Policy and applicable laws through regular audits and assessments.
Privacy Policy
Last Updated Jun 30, 2024
1. OVERVIEW
True Offers USA, LLC d/b/a Deal Boss Project ("Deal Boss Project," "Company," "we," "us," and "our") respects your privacy and is committed to protecting it through compliance with this Privacy Policy ("Privacy Policy"). This Privacy Policy describes how we collect and use your Personal Information when you visit our website at https://www.dealbossproject.com, use our True Lead Creation CRM platform, participate in our educational programs, or otherwise use our services as described in our Terms of Service.
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will handle it. If you do not agree with our policies and practices, do not use our services. By accessing or using our services, you agree and consent to this Privacy Policy.
Deal Boss Project may change this Privacy Policy at any time, at its discretion. Your continued use of our services after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.
This Privacy Policy is subject to and governed by the Deal Boss Project Terms of Service. Our services include our CRM platform, educational programs, and related tools described in the Terms of Service.
2. INFORMATION WE COLLECT AND HOW WE COLLECT IT
Deal Boss Project may collect two types of information from you: Personal Information and Non-Personal Information (collectively "Information").
"Personal Information" refers to data by which you may be personally identified, such as name, email address, phone number, billing address, business information, and payment details.
"Non-Personal Information" means data that is about you but does not identify you specifically, such as browser type, device information, and aggregated usage statistics.
2.1 Information We Collect Directly From You
Account Registration and Profile Information:
- Name, email address, phone number, business information
- Billing and payment information (credit card details, billing address)
- Account credentials and security information
- Profile preferences and settings
Educational Program Participation:
- Course progress and completion data
- Assessment results and performance metrics
- Communication preferences for educational content
- Event registration and attendance information
CRM and Platform Usage:
- Contact lists and customer data you upload
- Campaign and automation configurations
- Phone numbers purchased through our platform
- SMS and email content you create and send
- Call recordings and voicemail data
- Real estate property data and investment information
Customer Support Communications:
- Support ticket information and correspondence
- Chat logs and communication history
- Feedback and survey responses
2.2 Information We Collect Automatically
Platform Usage Data:
- Login times, feature usage, and navigation patterns
- CRM activity logs and system interactions
- API usage and integration data
- Performance metrics and error logs
Device and Technical Information:
- IP address, browser type, and operating system
- Device identifiers and mobile device information
- Geolocation data (if location services are enabled)
- Cookies and similar tracking technologies
Communication and Marketing Data:
- Email open rates and click-through data
- SMS delivery and response metrics
- Website interaction and engagement data
- A2P 10DLC registration and compliance data
2.3 Information From Third-Party Sources
Third-Party Platform Integrations:
- Data from Go High Level, LeadConnector, and Twilio integrations
- Google API Services data (including YouTube API data when connected)
- Social media platform information when you connect accounts
- Payment processor information (Stripe, PayPal)
Business Partners and Data Providers:
- Lead generation and market data services
- Public records and property information for Market Domination services
- Industry event and conference data
- Referral and affiliate program information
Data Verification Services:
- Identity verification and fraud prevention data
- Phone number validation and carrier information
- Email verification and deliverability data
2.4 AI AND MACHINE LEARNING DATA USAGE
Personal Information in AI Interactions: When you interact with our AI systems, we may process personal and business information you provide to generate educational responses.
No AI Training Use: We do NOT use your personal information, business details, or AI interaction data to train general AI models or improve AI systems for other users.
AI Response Storage: AI interactions may be stored for quality assurance and to improve your individual educational experience.
Third-Party AI Services: Our AI systems may utilize third-party AI services. Your interactions are subject to our privacy practices, not those of AI service providers.
3. HOW WE USE YOUR PERSONAL INFORMATION
We use Personal Information for the following purposes:
3.1 Service Provision and Platform Functionality
- CRM Operations: Manage your customer data, automate marketing campaigns, track communications, and provide analytics
- Educational Services: Deliver course content, track progress, provide assessments, and issue certifications
- Communication Tools: Enable SMS, email, and voice communications through our platform
- Data Services: Provide Market Domination data, property analytics, and investment insights
- Account Management: Create and maintain user accounts, process payments, and provide customer support
- AI Educational Tools: Process your inputs to generate personalized educational content and recommendations for learning purposes only
3.2 Platform Development and Improvement
- Performance Optimization: Analyze usage patterns to improve platform functionality and user experience
- Feature Development: Develop new tools and capabilities based on user needs and feedback
- AI and Machine Learning: Enhance automation features and content generation (we do NOT use your data to train generalized AI models)
- Security Enhancement: Monitor for threats, prevent fraud, and maintain platform security
- Quality Assurance: Test new features and ensure platform reliability
3.3 Business Operations
- Financial Management: Process payments, manage subscriptions, and handle billing inquiries
- Legal Compliance: Meet regulatory requirements, respond to legal requests, and maintain records
- Customer Support: Provide technical assistance, resolve issues, and improve service quality
- Marketing and Sales: Promote our services, conduct market research, and manage affiliate programs
3.4 Communication and Marketing
- Service Communications: Send account notifications, security alerts, and service updates
- Educational Content: Deliver newsletters, training materials, and industry insights
- Marketing Messages: Share product announcements, promotional offers, and event invitations
- Personalization: Customize content and recommendations based on your interests and usage
3.5 Legal Basis for Processing (EEA/UK Residents)
For users in the European Economic Area and United Kingdom, our legal basis for processing includes:
- Contract Performance: Processing necessary to provide our services
- Legitimate Interests: Business operations, security, and service improvement
- Legal Compliance: Meeting regulatory and legal obligations
- Consent: Where you have provided specific consent for processing
4. THIRD-PARTY PLATFORM INTEGRATIONS
Our services rely on several third-party platforms to provide functionality. By using our services, you acknowledge and agree to the data practices of these platforms:
4.1 Core Platform Providers
Twilio (Communications):
- Privacy Policy: https://www.twilio.com/legal/privacy
- Handles SMS, voice calls, and phone number provisioning
4.2 Google Services Integration
Google API Services:
Our platform's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
YouTube API Services:
If you connect your YouTube account, the Google Privacy Policy (https://policies.google.com/privacy) applies. You may revoke our access via Google security settings (https://security.google.com/settings/security/permissions).
4.3 Payment and Financial Services
4.4 Analytics and Marketing
Google Analytics:
- Privacy Policy: https://policies.google.com/privacy
- Opt-out: https://tools.google.com/dlpage/gaoptout
5. HOW WE SHARE YOUR INFORMATION
We share Personal Information in the following circumstances:
5.1 Service Providers and Business Partners
- Technology Vendors: Third-party platforms that power our services (Go High Level, Twilio, etc.)
- Payment Processors: Companies that handle billing and payment processing
- Cloud Services: Data hosting and storage providers
- Analytics Providers: Services that help us understand platform usage and performance
- Customer Support: Tools and services that help us provide customer assistance
5.2 Business Operations
- Affiliates and Subsidiaries: Within our corporate family for business purposes
- Professional Advisors: Attorneys, accountants, and consultants as needed
- Business Transfers: In connection with mergers, acquisitions, or asset sales
- Legal Requirements: When required by law, court order, or government request
5.3 Marketing and Advertising
- Advertising Partners: For targeted advertising and marketing campaigns
- Analytics Services: To measure marketing effectiveness and user engagement
- Social Media Platforms: When you choose to connect or share content
5.4 With Your Consent
We may share information with other parties when you provide explicit consent for such sharing.
Important: We do NOT sell your Personal Information for monetary compensation. We do NOT share your phone number or SMS opt-in consent with third parties without your express written consent.
6. DATA RETENTION
We retain Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including:
- Account Data: Retained while your account is active and for a reasonable period after cancellation
- Educational Records: Maintained to provide ongoing access to completed courses and certifications
- Communication Data: Stored according to legal requirements and business needs
- Financial Records: Kept for accounting, tax, and legal compliance purposes
- Usage Analytics: Aggregated data may be retained indefinitely for business intelligence
Upon Account Cancellation: Most personal data is deleted within 24 hours, though some information may be retained for legal, security, or business continuity purposes.
7. INTERNATIONAL DATA TRANSFERS AND COMPLIANCE
7.1 Data Privacy Framework Compliance
True Offers USA, LLC d/b/a Deal Boss Project complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
We have certified our adherence to the DPF Principles regarding the processing of personal data received from the European Union, United Kingdom, and Switzerland. If there is any conflict between this privacy policy and the DPF Principles, the Principles shall govern.
To learn more about the DPF program and view our certification, visit: https://www.dataprivacyframework.gov/
7.2 International Transfers
When we transfer Personal Information internationally, we ensure appropriate safeguards are in place, including:
- Data Privacy Framework protections for EU/UK/Swiss data
- Standard contractual clauses where applicable
- Adequacy decisions and approved transfer mechanisms
8. YOUR PRIVACY RIGHTS
8.1 General Rights
Access and Portability: Request copies of your Personal Information
Correction: Update or correct inaccurate information
Deletion: Request deletion of your Personal Information (subject to legal requirements)
Opt-Out: Unsubscribe from marketing communications
Account Control: Manage your privacy settings through your account dashboard
8.2 U.S. State Privacy Rights
California (CCPA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA):
Residents of these states have additional rights including:
- Right to know what Personal Information is collected and how it's used
- Right to delete Personal Information
- Right to correct inaccurate Personal Information
- Right to opt out of targeted advertising
- Right to non-discrimination for exercising privacy rights
To Exercise Your Rights: Contact us at [email protected] or use our privacy request portal.
8.3 European Privacy Rights (GDPR)
EEA/UK/Swiss Residents have additional rights:
- Right of access to your Personal Information
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object to processing
- Rights related to automated decision-making
EU Representative Contact:
IITR Datenschutz GmbH
Marienplatz 2, 80331 München, Germany
089-18917360
Complaints: You may file complaints with your local data protection authority.
9. SECURITY MEASURES
We implement comprehensive security measures to protect your Personal Information:
Technical Safeguards:
- Encryption of data in transit and at rest
- Secure access controls and authentication
- Regular security monitoring and threat detection
- Secure development practices and code reviews
Administrative Safeguards:
- Employee training on data protection
- Access controls based on job responsibilities
- Incident response and breach notification procedures
- Regular security assessments and audits
Physical Safeguards:
- Secure data centers with restricted access
- Environmental controls and monitoring
- Secure disposal of hardware and media
Vendor Management:
- Due diligence on third-party security practices
- Contractual security requirements
- Regular vendor security assessments
10. CHILDREN'S PRIVACY
Our services are not intended for children under 16. We do not knowingly collect Personal Information from children under 16. If we learn that we have collected information from a child under 16, we will delete it promptly. If you believe a child has provided us with Personal Information, please contact us at [email protected].
11. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar technologies to:
- Enable platform functionality and remember your preferences
- Analyze usage patterns and improve our services
- Provide personalized content and advertising
- Ensure security and prevent fraud
Cookie Management: You can control cookies through your browser settings, though disabling cookies may affect platform functionality.
For detailed information about our cookie practices, please see our Cookie Policy.
12. MARKETING AND COMMUNICATION PREFERENCES
Email Communications:
- Unsubscribe links in all marketing emails
- Account dashboard communication preferences
- Separate controls for different types of communications
SMS Communications:
- Reply "STOP" to opt out of SMS messages
- Manage preferences through your account settings
- Compliance with TCPA and carrier requirements
Phone Communications:
- Do Not Call list compliance
- Opt-out options for marketing calls
- Respect for communication preferences
13. CALIFORNIA PRIVACY RIGHTS DETAILED DISCLOSURE
13.1 Categories of Personal Information Collected (Last 12 Months)
| Category | Collected | Sources | Business Purposes | Third Parties Shared With ||----------|-----------|---------|-------------------|---------------------------|
| Identifiers (name, email, phone, IP address) | Yes | You, affiliates, partners | Account management, service provision, marketing | Service providers, affiliates, advertising partners |
| Customer Records (billing info, payment data) | Yes | You, payment processors | Payment processing, account management | Payment processors, service providers |
| Commercial Information (purchase history, preferences) | Yes | You, platform usage | Service improvement, marketing, analytics | Service providers, analytics partners |
| Internet Activity (browsing, platform usage) | Yes | Automatic collection | Platform optimization, security, analytics | Service providers, analytics partners || Geolocation Data | Yes | Device/browser | Service personalization, security | Service providers |
| Audio/Visual (call recordings, uploaded content) | Yes | You, platform usage | Service provision, quality assurance | Service providers |
| Professional Information (business details, industry) | Yes | You | Service customization, marketing | Service providers, affiliates |
| Inferences (preferences, characteristics) | Yes | Data analysis | Personalization, marketing, service improvement | Service providers, advertising partners |
13.2 Business Purposes for Collection
- Providing and maintaining our services
- Processing transactions and managing accounts
- Customer support and communication
- Security, fraud prevention, and legal compliance
- Marketing and advertising
- Service improvement and development
- Analytics and business intelligence
13.3 Third-Party Sharing
We share Personal Information with:
1. Service Providers: Technology vendors, payment processors, cloud services
2. Affiliates: Related companies for business purposes
3. Advertising Partners: For marketing and advertising services
4. Professional Advisors: Legal, accounting, and consulting services
No Sale of Personal Information: We do not sell Personal Information for monetary consideration.
14. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:
- Posting the updated policy on our website
- Sending email notifications for significant changes
- Providing in-platform notifications
Your continued use of our services after changes become effective constitutes acceptance of the updated Privacy Policy.
15. CONTACT INFORMATION
For Privacy Questions and Requests:
General Inquiries:
True Offers USA, LLC d/b/a Deal Boss Project
ATTN: Legal & Compliance Department
931-E South Main St STE 246
Kernersville, NC 27284
Email: [email protected]
Data Protection Officer:[email protected]
Customer Support:[email protected]
For DPF-Related Complaints:
If you have complaints regarding our handling of personal data under the Data Privacy Framework, contact us first at [email protected]. For unresolved complaints, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) for free dispute resolution. Under certain conditions, binding arbitration may be available.
16. ADDITIONAL STATE-SPECIFIC DISCLOSURES
16.1 Virginia Consumer Data Protection Act (VCDPA)
Virginia residents have the right to:
- Confirm whether we process your Personal Information
- Access and obtain a copy of your Personal Information- Correct inaccuracies in your Personal Information
- Delete Personal Information provided by or obtained about you
- Obtain a copy of your Personal Information in a portable format
- Opt out of targeted advertising, sale of Personal Information, or profiling
Appeals Process: If we decline your request, you may appeal by contacting [email protected] within a reasonable time after receiving our response.
16.2 Colorado Privacy Act (CPA)
Colorado residents have similar rights to Virginia residents, plus:
- Right to opt out of certain profiling activities
- Right to appeal denied requests
Appeals: Contact [email protected] if we decline your request.
16.3 Connecticut Data Privacy Act (CTDPA)
Connecticut residents have the same rights as Virginia and Colorado residents.
Appeals: Available for declined requests through [email protected].
16.4 Utah Consumer Privacy Act (UCPA)
Utah residents have rights to:
- Access Personal Information
- Delete Personal Information
- Opt out of targeted advertising and sale of Personal Information
17. INDUSTRY-SPECIFIC DISCLOSURES
17.1 Real Estate Investment Education
Educational Content: We collect data about your learning progress, course completions, and educational preferences to provide personalized learning experiences and track certification requirements.
Investment Data: Property information, market analysis data, and investment strategies you input are used to provide educational context and personalized recommendations.
Compliance: We do not provide investment advice. All educational content is for informational purposes only.
17.2 CRM and Marketing Automation
Customer Data: Information you upload about your customers is processed to provide CRM functionality, automation services, and analytics.
Communication Tracking: We track email opens, SMS delivery, call connections, and other communication metrics to provide service analytics.
TCPA Compliance: You are responsible for ensuring compliance with all applicable laws when using our communication tools.
17.3 Market Domination Services
Public Records: We aggregate publicly available property and ownership data to provide market insights and lead generation services.
Data Accuracy: All data is provided "as-is" and you are responsible for verifying accuracy before making business decisions.
Usage Restrictions: Data is provided for legitimate business purposes only and must comply with applicable laws
18. AUTOMATED DECISION-MAKING AND AI
AI Content Generation: Our platform may use AI to help generate marketing content, property analyses, and communication templates. You retain ownership of content you create using these tools.
No Automated Decisions: We do not use automated decision-making that produces legal or similarly significant effects without human involvement.
AI Training: We do NOT use your Personal Information to develop, improve, or train generalized AI or machine learning models.
Transparency: When AI tools are used, we provide clear indication of their involvement in content generation.
19. BIOMETRIC INFORMATION
We do not collect, store, or process biometric information such as fingerprints, facial recognition data, or voice prints.
20. SENSITIVE PERSONAL INFORMATION
We limit our collection and use of sensitive Personal Information to:
- Information you voluntarily provide for specific purposes
- Information necessary to provide requested services
- Information required for legal compliance- Uses authorized by applicable law
Categories of Sensitive Information We May Collect:
- Financial account information for payment processing
- Precise geolocation data (only if you enable location services)
- Communication content (emails, SMS, call recordings you create)
21. CROSS-BORDER DATA TRANSFERS
Transfer Mechanisms:
- Data Privacy Framework for EU/UK/Swiss transfers
- Standard Contractual Clauses where applicable
- Adequacy decisions for approved countries
- Your consent for specific transfers
Safeguards: All international transfers include appropriate technical and organizational measures to protect your Personal Information.
22. DATA BREACH NOTIFICATION
Our Commitment: We will notify affected individuals and relevant authorities of data breaches as required by applicable law.
Notification Timeline:
- Regulatory authorities: Within 72 hours where required
- Affected individuals: Without undue delay when high risk is likely
- Communication method: Email, account notifications, or public notice as appropriate
Information Provided: Nature of breach, categories of data involved, likely consequences, and measures taken to address the breach.
23. VENDOR AND THIRD-PARTY OVERSIGHT
Due Diligence: We conduct security and privacy assessments of vendors who process Personal Information.
Contractual Requirements: Vendors must agree to appropriate data protection terms and security measures.
Monitoring: We regularly review vendor compliance with our data protection requirements.
Incident Response: Vendors must notify us immediately of any security incidents involving our data.
24. RECORD KEEPING AND COMPLIANCE
Documentation: We maintain records of our data processing activities as required by applicable privacy laws.
Regular Reviews: We conduct periodic assessments of our privacy practices and update procedures as needed.
Training: Our employees receive regular training on data protection requirements and best practices.
Compliance Monitoring: We monitor compliance with this Privacy Policy and applicable laws through regular audits and assessments.
All Rights Reserved © 2024
931-E South Main St STE 246
Kernersville NC, 27284