TruPortals Privacy Policy

1.Who we are

This Privacy Policy explains how TruCreatives LLC (“TruCreatives”, “TruPortals”, “we”, “us”, or “our”) handles personal information in connection with the TruPortals software platform and related services.

Our registered business details are:

Our services are primarily offered from, and governed by the laws of, the United States, but our Clients and end users may be located in other countries.

2.Controller vs. processor roles

Our role changes depending on how we interact with the data.

2.1 When we act as a controller

We act as a data controller when we decide how and why to process personal information, for example:

• Operating and improving TruPortals.
• Managing Client accounts and billing.
• Our own marketing, sales, security, and analytics.

2.2 When we act as a processor / service provider

We act as a processor (also called “service provider” or “contractor” under some laws) when we handle data on behalf of our Clients, for example:

• Fan, listener, customer, or contact data that a Client imports into TruPortals.
• Data collected through TruPortals forms, landing pages, and campaigns configured by a Client.

In those cases, the Client (such as an artist, label, or management company) controls how that data is used and is responsible for its own privacy notices. We follow their documented instructions and our contract with them.

If you are a fan, listener, customer, or contact of a specific artist or label using TruPortals, please review that artist or label’s privacy policy. This Policy explains what we do as the underlying platform provider.

3.Information we collect

What we collect depends on how you interact with us and with TruPortals.

3.1 Account and contact information (Clients)

Collected directly from you when you create an account, sign a contract, or contact us:

• Name, company/label/artist name, and role or job title.
• Email address, phone number, postal address.
• Login credentials (stored in hashed form) and account preferences.
• Communication history with our support, billing, or sales teams.

3.2 Fan, listener, and end-user data (processed for Clients)

Provided or collected on behalf of our Clients when they use TruPortals:

• Contact details: name, email address, phone number, social handles, general location.
• Interaction data, such as:
  • Form submissions, pre-saves, sign-ups, contest entries, RSVPs.
  • Email/SMS open, click, reply, bounce, and unsubscribe events.
  • Visits to TruPortals-powered landing pages and campaign engagement.
• Preferences and tags:
  • Artists or brands followed, events or cities of interest, communication preferences.
  • Custom fields created by the Client (for example: fan segment, VIP tier, favorite song).

We use this data only to provide services to the relevant Client, consistent with our contract with that Client.

3.3 Billing and transaction data

• Billing contact details for Clients.
• Payment method details handled by payment processors (card type, last four digits, expiration date).
• Invoices, subscription plans, transaction amounts, and payment history.

We do not store full card numbers or CVV codes. Those are handled by our payment service providers.

3.4 Technical and usage data

Collected automatically when you or end users access TruPortals interfaces, websites, or emails:

• IP address, device identifiers, browser type and version, operating system.
• Log data such as access times, pages viewed, referring URL, and error logs.
• Interactions with product features and user interface elements.
• Email interaction data (opens, clicks) for system and marketing emails.

3.5 Cookies and similar technologies

We use cookies, pixels, and similar technologies to:

• Keep you logged in and maintain sessions.
• Remember your preferences and settings.
• Measure usage and performance of our services.
• Support security and fraud prevention.
• Support our own marketing and audience measurement, where allowed by law.

You can control cookies through your browser settings and, where legally required, through our consent tools.

3.6 Information from third-party sources

We may receive information from:

• Services that a Client connects to TruPortals (for example: CRMs, email tools, ad platforms, payment gateways, and e-commerce platforms).
• Publicly available sources and social or professional platforms to maintain accurate business contact records.

What we receive depends on the permissions and settings in those third-party services.

4.How we use personal information

We use personal information for the purposes below. Where privacy laws require a legal basis (for example, in the EU or UK), we rely on performance of a contract, compliance with legal obligations, and our legitimate business interests.

4.1 Providing and operating TruPortals

• Create and manage Client accounts.
• Authenticate users and secure access to the platform.
• Deliver core features, automations, and integrations.
• Process payments, subscriptions, and billing.

4.2 Processing data for Clients

When we act as a processor or service provider for a Client, we:

• Execute automations, campaigns, messaging, and analytics configured by that Client.
• Store and organize fan and contact data within the Client’s account.
• Maintain, secure, and support the platform on the Client’s behalf.

We do not independently decide how a Client uses their fan or contact data.

4.3 Improving and securing our services

• Monitor usage to maintain performance, uptime, and reliability.
• Detect, prevent, and investigate fraud, abuse, and security incidents.
• Develop, test, and improve features, interfaces, and workflows.
• Produce aggregated or de-identified statistics to guide product and business decisions.

4.4 Communicating with you

• Respond to support requests, questions, and other inquiries.
• Send service, security, and account notices.
• Send transactional messages related to billing, account status, and product changes.

4.5 Marketing our own services

• Send Clients and prospective Clients information about TruPortals and related services.
• Tailor marketing based on your role, account type, interactions, and preferences.

You can opt out of marketing emails at any time using the unsubscribe link in our emails or by contacting us. We will still send non-marketing, service-related communications as needed.

4.6 Legal, compliance, and protection

• Comply with applicable laws, regulations, and legal processes.
• Respond to lawful requests from public authorities.
• Enforce our agreements and protect our rights, users, Clients, and the public.

5.How we share personal information

We do not sell personal information in the commonly understood sense (we do not sell lists of users, fans, or contacts).

We may share personal information as described below.

5.1 Service providers and sub-processors

We use trusted third parties to help operate TruPortals, including:

• Hosting and cloud infrastructure providers.
• Email and SMS delivery services.
• Payment processing and billing platforms.
• Logging, analytics, and monitoring tools.
• Customer support and helpdesk tools.

These providers are contractually required to use personal information only to provide services to us and to protect it appropriately.

5.2 Integrations and third-party platforms

At the direction of a Client or user, we may send or receive data to and from external services that are connected to TruPortals, such as:

• CRMs, email marketing tools, and ad platforms.
• Payment processors and e-commerce systems.
• Other third-party applications that a Client chooses to connect.

The use of data by those third parties is governed by their own privacy policies and terms, not this Policy.

5.3 Within TruCreatives and with partners

We may share personal information within TruCreatives and with carefully selected partners that help us deliver, support, or promote TruPortals, consistent with this Policy and applicable law.

5.4 Business transfers

If TruCreatives is involved in a merger, acquisition, financing, reorganization, or sale of all or part of its business or assets, personal information may be transferred as part of that transaction, subject to appropriate confidentiality and security protections.

5.5 Legal, security, and enforcement

We may disclose personal information where we reasonably believe it is necessary to:

• Comply with laws, regulations, legal processes, or governmental requests.
• Enforce our agreements, terms, and policies.
• Protect the rights, property, or safety of TruCreatives, our Clients, users, or the public.
• Detect, prevent, or address fraud, security, or technical issues.

5.6 Aggregated and de-identified data

We may share aggregated or de-identified information that cannot reasonably be used to identify any individual, for example overall usage statistics or performance metrics.

6.International data transfers

TruPortals and our core infrastructure are primarily operated from the United States. Personal information may be stored and processed in the United States and in other countries where we or our service providers operate.

If our processing involves personal information of individuals in jurisdictions such as the European Economic Area (EEA) or the United Kingdom, we use appropriate safeguards where required (such as standard contractual clauses or equivalent mechanisms) when transferring data to the United States or other countries that may have different data protection laws.

7.Data retention

We retain personal information only as long as reasonably necessary to:

• Provide TruPortals and related services.
• Comply with legal, tax, and accounting obligations.
• Resolve disputes and enforce agreements.

We determine retention periods based on:

• The type and sensitivity of the data.
• The duration of our relationship with the relevant Client or user.
• Legal requirements and applicable limitation periods.

When personal information is no longer needed, we delete it or irreversibly de-identify it, unless we are legally required to keep it longer.

For data we process only as a processor or service provider for a Client, we retain and delete that data in line with our contract and the Client’s written instructions.

8.Security

We use administrative, technical, and physical safeguards designed to protect personal information, including:

• Role-based access controls and authentication.
• Encryption in transit and, where appropriate, at rest.
• Logging, monitoring, and regular security reviews.
• Internal access limited to staff who need the data to perform their duties.

No system is perfectly secure, but we aim to keep risk at a commercially reasonable level given the nature of the data and the services.

9.Children’s privacy

TruPortals is not intended for children under 16 years of age, and we do not knowingly collect personal information directly from children under 16.

Clients are responsible for ensuring that their use of TruPortals complies with applicable age and consent requirements where they collect information from minors.

If you believe that a child has provided personal information to us directly, please contact us using the details in Section 13 and we will address the issue.

10.Your rights and choices

Your rights depend on your location and applicable law, but may include the ability to:

• Access personal information we hold about you.
• Correct inaccurate or incomplete information.
• Delete personal information in certain circumstances.
• Restrict how we use your information in some cases.
• Object to certain types of processing, including some direct marketing.
• Withdraw consent where we rely on consent (without affecting prior processing).

If we process your information on behalf of a Client (for example, you are a fan or customer of an artist using TruPortals), we may need to forward your request to that Client or ask you to contact them directly, because they control that data.

To exercise your rights, contact us using the details in Section 13. We may request additional information to verify your identity before responding, and we will respond in accordance with applicable law.

If your local law gives you the right to lodge a complaint with a data protection or privacy regulator, you may do so at any time.

11.Do Not Track

Some browsers send “Do Not Track” signals. We currently do not respond to these signals. You can control many tracking tools through browser settings, privacy extensions, and our consent tools (where available).

12.Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the “Last updated” date at the top.

If we make material changes, we will provide additional notice where required by law (for example, by email or a notice within the service). Your continued use of the services after the effective date of the updated Policy means you acknowledge the changes.

13.Contacting us

If you have questions about this Privacy Policy, our data practices, or you want to exercise your rights, you can contact us at: