Truthful Acting Privacy Policy
Last Updated: January 2023
1. Overview
Truthful Acting Online And Truthful Acting Studios (“Truthful Acting”) is committed to protecting your privacy. As part of this commitment, we have adopted a Privacy Policy that governs how we collect, store, and use information obtained from customers who visit our websites, located at https://truthfulacting.com (the “Website”). While providing all of our services, we aim to protect your privacy through this policy, which also ensures that we comply with international data privacy regulations.
2. Our Privacy Policy: What Information Does Truthful Acting Collect From You?
To enhance your experience on the Truthful Acting Website, we collect the following information (“Personal Information”) that you provide to us. Although you may visit some pages on our website without providing all of the Personal Information listed below, you must provide certain information to take advantage of particular features, such as registering for classes, and interacting with fellow artists and students via the Truthful Acting Discord server.
The Website collects the following Personal Information:
• Name
• City, state, and region of residence
• Email address
• Phone number
• Payment information
• Password
• Date of birth
• IP address
• Gender
Additionally, when you access the Website using a mobile device, we may collect the following additional information:
• Unique identification number associated with your device (“Device ID”)
• Mobile carrier
• Device type and manufacturer
• Telephone number
• Depending on your mobile device settings, your geographical location data, including GPS coordinates or similar information regarding the location of your mobile device
We collect this information from you when you register on the Website or request products or services that the Website offers. You may be asked to provide information if you post or access any content on Discord servers, chat rooms, or blogs operated by Truthful Acting.
Cookies Policy
The Website also collects non-personally identifiable information automatically through the use of electronic tools such as “cookies”. Cookies help provide a customized web experience by enabling us to identify web users who visit our website.
The types of cookies we use on the Truthful Acting website:
• Strictly Necessary: These cookies are essential to provide you with the services on the Truthful Acting website and to enable you to use some of its features. For example, cookies are necessary to keep you logged into your Truthful Acting account and access courses / classes. For that reason, without these cookies, the Truthful Acting website cannot provide you with its services.
• Functionality Cookies: Functionality cookies remember your preferences and settings when you return to our site. This helps us provide you with a more efficient, personalized experience. For example, if you are in the United Kingdom, our website will provide information specific to the UK, rather than information about other countries.
• Tracking/Performance/Advertising Cookies: These cookies are used to track information about traffic to the Truthful Acting website and to collect information about what you do on our website. This includes what content you viewed, the links you followed and clicked on, the type of device you’re on, and your IP address. These cookies are used to optimize our website and marketing campaigns. These cookies are administered by third-parties like Google and YouTube. Where a third party collects personal data through an advertising or targeting cookie placed through our website, the third party’s use of your personal data is governed by the third party’s privacy policy. Do not forget to check the websites of these providers for their data protection regulations.
How you can opt out of having cookies placed on a device:
If you do not want Truthful Acting to track or use your Cookies, you can adjust your internet browser security settings to refuse cookies. Refusing cookies, however, may limit your ability to access certain pages available on the Website and may prevent you from enjoying the features on our website enabled by cookies. You can change your preference at any time. If you wish to remove previously stored cookies, please clear your cookie browser history.
The Website may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Website. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analyzing and improving the Website.
3. Purposes of Information Collection
To enhance your experience on the Website, we collect the following information (“Personal Information”) that you provide to us. Although you may visit some pages on our website without providing all of the Personal Information listed below, you must provide certain information to take advantage of particular features, such as registering for courses / classes, and joining the Truthful Acting Discord server to interact with fellow students and artists.
Specifically, we use your Personal Information to accomplish the following legitimate purposes:
• Communicating with you regarding our courses / classes, features, and services available through the Websites.
• Sharing our courses.
• Helping students build healthy relationships to benefit their careers and continued artistic development, including connecting students using third-party communication services such as Discord.
• Troubleshooting and website administration.
• Complying with a legal obligation where necessary, such as being compelled to share Personal Information by a law enforcement or government agency.
4. Consent for Collection and Use of Personal Information
A. Consent by Adults (Aged 18 and over)
By providing information to us in the manner described in Section 2 (“Our Privacy Policy”), you consent for us to use your Personal Information for the explicit purposes listed in Section 3 (“Purposes of Information Collection”) of the Privacy Policy. You may withdraw your consent at any time by any of the following methods:
• For all website users who provide us with Personal Information, you may opt-out from our services completely at any time by unsubscribing from marketing communications or adjusting your cookie settings. If you do so, we shall remove any Personal Information that we have collected from you based on your consent.
• For Truthful Acting registered students, we shall retain your contact information in case you choose to register in additional courses / classes, but we will not collect any additional information. You may communicate with us if you wish for us to permanently delete your contact information. Otherwise, we will delete your information periodically, as outlined by our data retention policy under Section 5(C)(i) (“Data Retention”) of the Privacy Policy below.
Please allow up to 30 business days for us to process your request. After opting out, you may still receive email messages about the status of your account, to resolve technical issues, or to confirm a purchased courses / classes.
5. Your Privacy-Related Rights
A. Your EU Privacy Rights
Residents of the EU have certain rights afforded to them by the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”).
i. Transfers out of the European Economic Area
We are based in Orlando, FL, and the Website is hosted by third parties that are also based in the United States. Accordingly, when you provide Personal Information to us, it is transferred outside of the European Economic Area (“EEA”). To ensure an adequate degree of protection is afforded to your Personal Information when it is transferred outside of the EEA, we only transfer your Personal Information to the United States, and only with your consent as outlined in the Privacy Policy. Additionally, we will only transfer your Personal Information to the United States on the condition that your rights are protected and that you have access to an effective legal remedy.
ii. Your EU legal rights
You have the right to:
1. Request access to your Personal Information. We will send you a copy of your Personal Information that we have on record, which will enable you to check that we are using it within the lawful guidelines of the Privacy Policy. For data security purposes, you will be required to provide some information to verify your identity prior to receiving the copy of your Personal Information.
2. Request correction of the Personal Information that we hold about you, where the information is incorrect.
3. Request deletion of your Personal Information. As noted above, this may involve ending further participation in Truthful Acting’s courses / classes.
4. Object to us using your Personal Information. You may object on grounds that you feel it impacts your fundamental rights and freedoms, or on grounds that we are using your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Information which overrides your rights and freedoms.
5. Request restriction of our use of your Personal Information. You may make this request (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your Personal Information to you or a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Lodge a complaint with the appropriate supervisory authority
If you wish to exercise any of these rights, please contact us using the form at the end of this policy. We may need to request additional information from you to help us confirm your identity. We try to respond to all legitimate requests within one month. It may take us longer to respond to your request if your request is particularly complex or if you have made multiple requests. In that case, we will notify you and keep you updated on the status of your request.
B. Your California Privacy Rights
If you reside in California, you may request information about our disclosures of your Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us by using the form at the end of this policy.
Within thirty days of receiving such a request, we will provide a list of the categories of personally identifiable information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than as specified in the above paragraph.
Registered minor users of the Websites in California may remove, or request removal of, any content that they post to the Websites or applications, subject to certain exceptions. In order to request that user-supplied content be removed, please contact us using the form at the end of this policy. Note that removing, or requesting removal of, content does not ensure complete or comprehensive removal of the content from the Websites or applications.
C) Other Privacy Rights
The following provisions apply to all users of the Websites, regardless of location.
i. Data Retention
We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for; namely, to provide you with the benefits of purchasing and taking our courses / classes. Periodically, and at least once every four years, we delete Personal Information of persons who no longer actively engage with our courses and/or Discord community, and whose contact information no longer is active. In addition, we will attempt to communicate via email prior to deleting any information, and we will retain only enough Personal Information to ensure that persons who have opted out of Truthful Acting communications are not opted back in to receive such communications.
ii. Data Breach Notification
In the event of any data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so. For EU data subjects, we shall notify the competent supervisory authority of any data breach that is likely to result in a risk to the rights and freedoms of natural persons within 72 hours of the breach, or else accompany our notification with reasons for the delay. This notification shall describe the nature of the Personal Information at risk, including the categories and approximate number of data subjects concerned, the name and contact details of the data protection officer, the likely consequences of the breach, and the measures taken to address the breach. We will also notify you without undue delay of any data breach that is likely to result in a high risk to your rights and freedoms.
iii. Updates to the Privacy Policy
Truthful Acting may amend the Privacy Policy at any time, as necessary to comply with evolving international data privacy standards and regulations. Please check the Privacy Policy page periodically for changes. We will post a notice on this website if and when this policy changes to alert visitors that a new policy is in place. Information collected prior to the time any change is posted will be used according to the privacy policy and applicable laws in place at the time the information was collected. Your continued use of the Website indicates your acceptance of the updated Privacy Policy.
6. Security
To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of all Personal Information, we have put in place physical, electronic, and administrative procedures to protect the Personal Information we collect online. No data transmission over the Internet, however, can be guaranteed to be completely secure. While we strive to protect your Personal Information, Truthful Acting cannot completely ensure or warrant the security of personally identifiable information you provide to us.
7. Third-Party Links
The Website currently interacts with the following third-party services that may have access to the Personal Information provided by the user as part of creating an account on the Websites. We use these third-parties to provide services on our behalf, assist us in providing new features, benefits, or service enhancements; enhance targeted advertising based on your browsing activities, interests and relevant geographical location; apply market research to generate audience insights; and develop and improve courses / classes and products.
Truthful Acting is not responsible for the privacy practices of these third-party services although we try to provide the minimal Personal Information necessary to use them. Please review the applicable third-party data policies:
Discord – https://discord.com/privacy
Google Analytics – https://marketingplatform.google.com/about/analytics/terms/us/ (website user analytics)
Learndash – https://www.learndash.com/privacy-policy/
Woocommerce – https://woocommerce.com/document/marketplace-privacy/
CartFlows – https://cartflows.com/privacy-policy/
8. Privacy By Design Standard
As we carry out all of our operations and programs, we are committed to protecting the privacy of your Personal Information. To this end, no practice shall be implemented without consideration of the risks to data privacy and implementation of any necessary measures to protect your privacy rights.
9. Implementation and Sanctions
Any Truthful Acting employee or volunteer who has access to Personal Information shall be trained on the content of the Privacy Policy and shall agree not to use the Personal Information collected for a purpose not authorized by this policy.
Truthful Acting conducts regular reviews and monitoring of its workforce members’ use and disclosure of Personal Information.
10. Contact
If you wish to discuss any issues relating to privacy or your Personal Information that you have provided to us, would like to exercise any of the rights outlined in the Privacy Policy, or have any questions or comments regarding the Privacy Policy, please contact us using the form below.