TrueArk Technologies, Inc., doing business as Proveniq ("Company," "we," "us," or "our"), respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services (collectively, the "Platform").
This Privacy Policy applies to all users of our Platform, including visitors, registered users, investors, and business partners. By using our Platform, you consent to the data practices described in this policy.
2. INFORMATION WE COLLECT
2.1 Information You Provide Directly
Account Information: Name, email address, phone number, company name, job title, and password when you create an account.
Identity Verification: Government-issued ID, selfie photos, and address verification documents for investor accreditation or KYC purposes.
Financial Information: Bank account details, investment history, and accredited investor documentation when accessing investor materials.
Communications: Messages, feedback, and correspondence you send to us.
Digital Signatures: Electronic signatures and initials captured through our document signing features.
2.2 Information Collected Automatically
Device Information: IP address, browser type, operating system, device identifiers, and hardware model.
Usage Data: Pages visited, time spent on pages, click patterns, referring URLs, and navigation paths.
Location Data: Approximate geographic location based on IP address.
Cookies and Tracking: Session cookies, persistent cookies, pixels, and similar technologies (see Section 8).
Social media platforms (if you connect your accounts)
3. HOW WE USE YOUR INFORMATION
We use your information for the following purposes:
3.1 Service Delivery
Provide, maintain, and improve our Platform and services
Process transactions and send related information
Verify your identity and investor accreditation status
Facilitate document signing and agreement execution
3.2 Communication
Send administrative messages, updates, and security alerts
Respond to your comments, questions, and requests
Send marketing communications (with your consent)
3.3 Security and Compliance
Detect, prevent, and address fraud, abuse, and security issues
Comply with legal obligations (KYC, AML, securities laws)
Enforce our Terms of Service and other agreements
Protect the rights, property, and safety of our users and the public
3.4 Analytics and Improvement
Analyze usage patterns to improve user experience
Conduct research and development
Generate aggregated, anonymized insights
4. LEGAL BASES FOR PROCESSING (GDPR)
For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process your personal data based on the following legal grounds:
Contract Performance: Processing necessary to provide our services to you.
Legitimate Interests: Processing for our legitimate business interests, such as fraud prevention, security, and service improvement.
Legal Obligation: Processing required to comply with applicable laws (e.g., securities regulations, tax laws).
Consent: Processing based on your explicit consent, which you may withdraw at any time.
5. INFORMATION SHARING AND DISCLOSURE
We do not sell your personal information. We may share your information in the following circumstances:
5.1 Service Providers
We share information with third-party vendors who perform services on our behalf, including:
Cloud hosting providers (AWS, Google Cloud)
Payment processors
Identity verification services
Email delivery services
Analytics providers
All service providers are contractually obligated to protect your information and may only use it for the specific services they provide to us.
5.2 Legal Requirements
We may disclose your information if required by law or in response to:
Subpoenas, court orders, or legal process
Requests from law enforcement or government agencies
To protect our rights, privacy, safety, or property
To enforce our Terms of Service
5.3 Business Transfers
In connection with a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change.
5.4 With Your Consent
We may share your information for other purposes with your explicit consent.
6. DATA RETENTION
We retain your personal information for as long as necessary to:
Provide our services to you
Comply with legal obligations (e.g., 7 years for financial records)
Resolve disputes and enforce our agreements
Maintain security and prevent fraud
When we no longer need your information, we will securely delete or anonymize it. You may request deletion of your data at any time (see Section 7).
7. YOUR RIGHTS AND CHOICES
7.1 All Users
Access: Request a copy of the personal information we hold about you.
Correction: Request correction of inaccurate or incomplete information.
Deletion: Request deletion of your personal information (subject to legal retention requirements).
Opt-Out: Unsubscribe from marketing communications at any time.
7.2 GDPR Rights (EEA, UK, Switzerland)
Data Portability: Receive your data in a structured, machine-readable format.
Restriction: Request restriction of processing in certain circumstances.
Objection: Object to processing based on legitimate interests.
Withdraw Consent: Withdraw consent at any time where processing is based on consent.
Lodge Complaint: File a complaint with your local data protection authority.
7.3 CCPA Rights (California Residents)
Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected.
Right to Delete: Request deletion of your personal information.
Right to Opt-Out: We do not sell personal information, but you may opt out of any future sales.
Non-Discrimination: We will not discriminate against you for exercising your rights.
To Exercise Your Rights
Email us at dpo@proveniq.com or use the privacy controls in your account settings. We will respond within 30 days (or 45 days for complex requests).
8. COOKIES AND TRACKING TECHNOLOGIES
We use the following types of cookies:
Essential Cookies: Required for the Platform to function (e.g., authentication, security).
Analytics Cookies: Help us understand how users interact with our Platform.
Preference Cookies: Remember your settings and preferences.
You can control cookies through your browser settings. Note that disabling certain cookies may affect Platform functionality.
9. DATA SECURITY
We implement industry-standard security measures, including:
256-bit AES encryption for data at rest
TLS 1.3 encryption for data in transit
Multi-factor authentication for sensitive operations
Regular security audits and penetration testing
SOC 2 Type II compliance (in progress)
Employee security training and access controls
While we strive to protect your information, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.
10. INTERNATIONAL DATA TRANSFERS
Your information may be transferred to and processed in countries other than your country of residence. When we transfer data outside the EEA, UK, or Switzerland, we use appropriate safeguards such as:
Standard Contractual Clauses approved by the European Commission
Binding Corporate Rules
Adequacy decisions
11. CHILDREN'S PRIVACY
Our Platform is not intended for children under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at privacy@proveniq.com.
12. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page and updating the "Last Updated" date. For significant changes, we will provide additional notice (e.g., email notification).
13. CONTACT US
If you have questions about this Privacy Policy or our data practices, please contact: