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What Truly Different Looks Like

Privacy Policy

Last Updated: July 15, 2025

This privacy policy (“Privacy Policy”) for Truly Care Corp. (“Truly Care,” “we,” “us,” or “our”) describes our policies and procedures on the collection, use and disclosure of your information when You use the Truly Care website, mobile applications, and all related services (the “Service”), and tells You about Your privacy rights, the choices you may have, and how the law protects You. We use Your Personal Data to provide and improve the Service. Capitalized Terms used by not defined herein, have the meanings set forth in the Truly Care Terms of Service. Reading this Privacy Policy will help You understand Your privacy rights and choices. If You do not agree with our policies and practices, please do not use our Services. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

We may update and make changes to this Privacy Policy, so we encourage You to review it periodically. We will alert You about any changes by updating the “Last Updated” date of this Privacy Policy.

Definitions

For the purposes of this Privacy Policy:

Collecting and Using Your Personal Data

Types of Data Collected

We receive several types of information about You from various sources, including information and content that You give us, automatically collected information, and information from other sources.

Data You Give Us

We collect Personal Data that You voluntarily provide to us when You create an Account for the Service, express an interest in obtaining information about us or our products and the Service, when You participate in activities on the Service, or otherwise when You contact us. The Personal Data that we collect depends on the context of Your interactions with us and the Service, the choices You make, and the products and features You use.  Personal information that you give to us may include, but is not limited to:

All Personal Data that You provide to us must be true, complete, and accurate, and You must notify us of any changes to such Personal Data.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on the Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the Service. The technologies we use may include:

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Data Collected From Other Sources

To enhance our ability to provide relevant marketing, offers, and services to You and update our records, we may obtain information about You from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

Use of Your Personal Data

We may use Your Personal Data for the following purposes:

Sharing of Your Personal Data

Business Purposes

We may share Your Personal Data by disclosing it to a third party for a business purpose (“Business Purpose Disclosure”). We only make these Business Purpose Disclosures under written contracts that describe the specific purposes, require the recipient to keep Your Personal Data confidential, and prohibit using the disclosed information for any purpose except performing the contract.

Business Purpose Disclosures may include, but are not limited to, the following circumstances:

Business Transactions

If Truly Care is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, Truly Care may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

Truly Care may disclose Your Personal Data in the good faith belief that such action is necessary to:

Retention of Your Personal Data

Truly Care will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary 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.

Truly Care will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at Truly Care’s operating offices and in any other places where the parties involved in the processing are located. It means that this 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 than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

Security of Your Personal Data

The security of Your Personal Data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Your Personal Data, we cannot guarantee its absolute security. The safety and security of Your information also depends on You. Where we have given You (or where You have chosen) a password for access to certain parts of the Service, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone. Although we will do our best to protect Your Personal Data, transmission of Personal Data to and from the Service is at Your own risk. You should only access the Service within a secure environment.

CCPA Privacy Policy

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of Personal Data which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Data would only be collected if You provided such Personal Data directly to us.

Under CCPA, personal information does not include:

Sources of Personal Information

We obtain the categories of Personal Data listed above from the following categories of sources:

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose Personal Data we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If we decide to collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Data for business or commercial purposes:

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When we disclose Personal Data for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumers personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

Share of Personal Information

We may share Your Personal Data identified in the above categories with the following categories of third parties:

Personal Information of Minors Under 16 Years of Age

We do not knowingly collect Personal Data from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

If You have reason to believe that a child under the age of 13 (or 16) has provided us with Personal Data, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their Personal Data. If You are a resident of California, You have the following rights:

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your Personal Data.

Your request to Us must:

We cannot respond to Your request or provide You with the required information if we cannot:

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. For data portability requests, we will select a format to provide Your Personal Data that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your Personal Data. To exercise Your right to opt-out, please contact us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells Personal Data as defined by the CCPA law. If you wish to opt out of the use of Your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13, we will take steps to remove that information from our servers.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the privacy policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: