BE-TRUTH
Privacy Policy
PRIVACY POLICY
Effective Date: March 25, 2026
Last Updated: March 25, 2026
1. INTRODUCTION AND IDENTITY OF THE DATA CONTROLLER
This Privacy Policy ("Policy") describes how AXIUM SYSTEMS GROUP LLC, a Wyoming limited liability company ("Company," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information in connection with your use of the website located at https://be-truth.com (the "Website") and our plugin services, including the Rating Plugin, Sharing Plugin, and any other plugins or features offered as a web service (collectively, the "Services").
This Policy applies to the following categories of persons: (a) Website Operators, meaning individuals or entities who register an account and embed BE-TRUTH plugins on their own websites (also referred to as "Site Owners" or "Operators"); (b) End Users, meaning visitors to Operator websites who interact with embedded BE-TRUTH plugins; and (c) General Visitors, meaning persons who browse the Website without registering.
Contact Information:
AXIUM SYSTEMS GROUP LLC
30 N Gould St, STE R
Sheridan, WY 82801
United States of America
Email: hello@be-truth.com
Website: https://be-truth.com
2. INFORMATION WE COLLECT
2.1 Information You Provide Directly
Account Registration Data. When creating an account, we collect your email address, username, and password. Passwords are stored only in cryptographically hashed form and are never accessible to Company personnel in plain text.
Profile Data. You may optionally provide your name, company name, and website URLs you associate with your account.
Support Communications. We collect messages, queries, and any attachments you submit through our support form or email.
Newsletter Subscription. We collect the email address you provide when subscribing to our newsletter or marketing communications.
Subscription and Payment Data. When subscribing to a paid Plan, we collect your email address and subscription selection. We do not collect, store, or transmit your full payment card number, card verification value (CVV), bank account number, or any other sensitive payment instrument data on our own servers. All payment instrument data is collected directly by our Payment Processors (Stripe, Paddle, or Polar) on their own PCI-DSS compliant infrastructure. We may receive limited non-sensitive payment metadata from Payment Processors, including the last four digits of your payment card, card expiration date, billing country and postal code, transaction ID and date, subscription status, and payment method type.
2.2 Information Collected Automatically
When you visit our Website or when End Users interact with our embedded plugins, we and our service providers may automatically collect the following information.
Technical Data: IP address, browser type and version, operating system, device type, referring URL, pages viewed, and time spent on pages.
Plugin Interaction Data: Rating scores submitted, sharing actions taken, page URLs on which plugins are embedded, timestamps of interactions, and user role (Site Owner, Registered User, or Unregistered User).
Cookie and Tracking Data: Information collected via cookies and similar technologies, as described in our Cookie Policy at https://be-truth.com/cookie-policy.
Server Log Data: Records of requests made to our servers, including request timestamps, response codes, and request paths.
2.3 Data Collected via Embedded Plugins on Operator Websites
When an Operator installs BE-TRUTH plugin code on their website, our platform receives and processes data from visitors to that Operator's website, including IP addresses, session identifiers, and plugin interaction data. In this context, we act as a data processor on behalf of the Operator, who is the data controller in respect of those visitors' data. The terms of this processing relationship are governed by our Data Processing Agreement (DPA), available at https://be-truth.com/dpa.
2.4 Information Received from Payment Processors
Our Payment Processors may share limited account and transaction information with us to enable subscription management, refund processing, billing dispute resolution, and legal compliance. The privacy practices of each Payment Processor are governed by their respective privacy policies. Stripe's Privacy Policy is available at https://stripe.com/privacy. Paddle's Privacy Policy is available at https://www.paddle.com/legal/privacy. Polar's Privacy Policy is available at https://polar.sh/legal/privacy.
3. HOW WE USE YOUR INFORMATION
We use personal information for the following purposes.
To provide, operate, and maintain the Services. Legal basis under GDPR: performance of contract. Under US law: contractual necessity.
To create and manage your account. Legal basis under GDPR: performance of contract.
To deliver plugin functionality, including ratings, sharing, and future features. Legal basis: performance of contract and legitimate interest.
To process subscription payments, issue invoices, manage billing, and process refunds. Legal basis: performance of contract and legal obligation.
To send transactional communications, including account notices, receipts, renewal reminders, and service notifications. Legal basis: performance of contract.
To send promotional newsletters and marketing communications, but only with your prior express consent. You may withdraw consent at any time by unsubscribing. Legal basis: consent.
To analyze usage and improve the Website and Services. Legal basis: legitimate interest.
To detect, prevent, and investigate fraud, abuse, security incidents, and violations of our Terms. Legal basis: legitimate interest and legal obligation.
To comply with applicable laws, regulations, and lawful governmental requests. Legal basis: legal obligation.
To enforce our Terms of Service, Refund Policy, and other agreements. Legal basis: legitimate interest.
To calculate and display ratings and to operate AI-assisted content integrity filters. Legal basis: performance of contract and legitimate interest.
We do not use personal information for fully automated individual decision-making that produces legal or similarly significant effects without human review.
4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We do not sell, rent, or trade your personal information to third parties for monetary consideration, and we do not share personal information for the purpose of cross-context behavioral advertising.
Payment Processors. We share your email address, subscription plan details, and limited account information with our Payment Processors (Stripe, Paddle, and Polar) as necessary to process payments, manage subscriptions, issue refunds, and handle billing disputes. When Paddle or Polar acts as Merchant of Record, those entities are independent data controllers for the billing transaction and process your personal data pursuant to their own privacy policies. Stripe processes payment data as a payment processor on our behalf under its own data processing terms.
Service Providers and Sub-Processors. We engage third-party vendors to provide cloud hosting, email delivery, analytics, and customer support. These providers access personal information only to the extent necessary to perform their services, are bound by written confidentiality and data processing obligations, and are prohibited from using your data for any other purpose. A list of current sub-processors is available upon written request to hello@be-truth.com.
Operators. Plugin interaction data collected through BE-TRUTH plugins embedded on an Operator's website is made accessible to that Operator through the BE-TRUTH admin panel as part of the Services delivered to that Operator.
Business Transfers. In the event of a merger, acquisition, reorganization, sale of assets, or insolvency proceeding, your personal information may be transferred to the acquiring or successor entity. We will provide you with reasonable advance notice via email and/or a prominent Website notice before your information becomes subject to a materially different privacy policy.
Legal Requirements and Protection of Rights. We may disclose personal information if required to do so by applicable law, regulation, legal process, or enforceable governmental request, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of the Company, our users, or the public.
With Your Consent. We may share personal information with third parties for purposes not described in this Policy when we have obtained your explicit prior consent.
5. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies on our Website and through our embedded plugins. For detailed information about the types of cookies we use, their purposes, their duration, and how you can manage your preferences, please refer to our Cookie Policy at https://be-truth.com/cookie-policy.
In summary: essential functional cookies are always active and cannot be disabled. Analytics and advertising cookies are disabled by default and are activated only upon your consent. We recognize and honor the Global Privacy Control (GPC) signal transmitted by California residents as a valid opt-out request under CCPA/CPRA.
6. DATA RETENTION
We retain personal information for as long as necessary to fulfill the purposes described in this Policy and to satisfy our legal, accounting, tax, and compliance obligations.
Account data is retained for the duration of your active account and for three (3) years following account closure.
Plugin interaction data, including ratings and sharing events, is retained for the duration of the associated Operator account and for five (5) years thereafter.
Payment and billing records are retained for seven (7) years as required by applicable tax and accounting laws.
Support communications are retained for three (3) years from the date of the last communication.
Newsletter and marketing subscriber data is retained until you unsubscribe, and for one (1) additional year thereafter for compliance record-keeping.
Server logs and technical data are retained in active storage for up to twelve (12) months and in backup or archival storage for up to three (3) years.
Upon expiry of the applicable retention period, personal information is securely deleted or irreversibly anonymized in accordance with applicable data protection standards.
7. INTERNATIONAL DATA TRANSFERS
Our primary servers are located in the United States. If you access our Services from the European Economic Area (EEA), the United Kingdom, Switzerland, or other jurisdictions whose laws impose restrictions on international data transfers, your personal information may be transferred to and processed in the United States.
For transfers of personal data from the EEA or the United Kingdom, we rely on the Standard Contractual Clauses (SCCs) adopted by the European Commission under Implementing Decision (EU) 2021/914 (Module 2: Controller to Processor), which are incorporated by reference into our Data Processing Agreement. For transfers of personal data from the United Kingdom, we rely on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs, as applicable.
By using our Services, if you are located outside the United States, you acknowledge that your information will be transferred to and processed in the United States in accordance with the safeguards described in this section.
8. SECURITY OF PERSONAL INFORMATION
We implement and maintain reasonable and appropriate technical and organizational security measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit using TLS/SSL protocols, encryption of sensitive data at rest, role-based access controls, multi-factor authentication for administrative access, regular security monitoring and vulnerability assessments, and documented incident response procedures.
We do not store full payment card data. All payment instrument data is processed exclusively by PCI-DSS Level 1 certified Payment Processors.
No information security system is completely impenetrable. We cannot guarantee the absolute security of information transmitted to or from our Services. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users and applicable supervisory authorities as required by applicable law.
9. CHILDREN'S PRIVACY AND COPPA COMPLIANCE
Our Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect personal information from children under 13. In compliance with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. sections 6501 through 6506, and FTC regulations at 16 C.F.R. Part 312, we do not knowingly collect, use, or disclose personal information from children under 13 without verifiable parental consent.
If you are a parent or legal guardian and believe that your child has provided us with personal information without your consent, please contact us immediately at hello@be-truth.com. We will take prompt steps to delete such information from our records.
10. YOUR PRIVACY RIGHTS
10.1 Rights Under GDPR (EEA and UK Residents)
If you are a resident of the European Economic Area or the United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR) or UK GDPR.
Right of Access (Article 15). You may request a copy of the personal information we hold about you.
Right to Rectification (Article 16). You may request correction of inaccurate or incomplete personal information.
Right to Erasure, also known as the Right to be Forgotten (Article 17). You may request deletion of your personal information, subject to limited exceptions, for example where we are required by law to retain it.
Right to Restriction of Processing (Article 18). You may request that we temporarily suspend the processing of your personal information in certain circumstances.
Right to Data Portability (Article 20). You may request to receive your personal information in a structured, commonly used, and machine-readable format.
Right to Object (Article 21). You may object to processing based on our legitimate interests, or to direct marketing at any time.
Right to Withdraw Consent (Article 7(3)). Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Right to Lodge a Complaint. You have the right to lodge a complaint with the data protection supervisory authority in your country of residence.
To exercise any of the above rights, contact us at hello@be-truth.com with the subject line "GDPR Rights Request." We will respond within one (1) calendar month of receiving your request. We may request reasonable verification of your identity before fulfilling your request.
10.2 California Residents' Rights (CCPA / CPRA)
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California Civil Code section 1798.100 et seq.
Right to Know. You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purposes for collection, and the categories of third parties with whom we share it.
Right to Delete. You may request deletion of personal information we have collected from or about you, subject to certain legal exceptions.
Right to Correct. You may request correction of inaccurate personal information we maintain about you.
Right to Opt-Out of Sale or Sharing. We do not sell or share personal information as defined under CCPA/CPRA, and we do not engage in cross-context behavioral advertising. We honor the Global Privacy Control (GPC) signal transmitted by California residents as a valid opt-out request under CCPA/CPRA.
Right to Limit Use of Sensitive Personal Information. You may request that we limit our use and disclosure of sensitive personal information to purposes specifically authorized by law.
Right to Non-Discrimination. We will not discriminate against you in the provision of Services for exercising any of your CCPA rights.
To submit a verifiable consumer request, contact us at hello@be-truth.com with the subject line "CCPA Rights Request." We will respond within forty-five (45) calendar days of receipt. We may extend this period by an additional forty-five (45) days where reasonably necessary, provided we give you prior written notice. We will verify your identity before processing a deletion or disclosure request.
10.3 Rights Under Other Applicable State Privacy Laws
Residents of Virginia (Consumer Data Protection Act), Colorado (Colorado Privacy Act), Connecticut (Connecticut Data Privacy Act), Utah (Utah Consumer Privacy Act), and other U.S. states that have enacted applicable privacy laws may have rights similar to those described in this Section. To the extent such rights are applicable and legally enforceable, we will honor them. To submit a request, contact hello@be-truth.com.
11. CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CalOPPA) COMPLIANCE
In compliance with the California Online Privacy Protection Act (CalOPPA), California Business and Professions Code sections 22575 through 22579:
Users may visit our Website anonymously. A link to this Privacy Policy appears on our Website homepage and is identifiable by use of the word "Privacy." Users will be notified of material changes to this Privacy Policy through an update to this page and, for registered users, by email. Users may request updates to their personal information by contacting hello@be-truth.com.
Regarding Do-Not-Track (DNT) signals: our Website does not currently respond to DNT browser signals or other similar mechanisms. We will revisit this position as industry standards and applicable legal requirements develop.
12. PAYMENT DATA AND PCI DSS
The Company does not directly collect, store, process, or transmit cardholder data or payment account data. All such data is handled exclusively by our Payment Processors, each of which maintains PCI-DSS Level 1 compliance. By subscribing to any paid Plan, your financial data is subject to the security standards and privacy protections maintained by the applicable Payment Processor.
13. DUAL ROLE AS DATA CONTROLLER AND DATA PROCESSOR
The Company operates in two distinct roles depending on context. With respect to personal information collected directly from Website Visitors and registered Operators, the Company acts as an independent data controller, determining the purposes and means of processing. When BE-TRUTH plugins embedded on Operator websites process personal data from those Operators' End Users, the Company acts as a data processor on behalf of the Operator (the data controller). The terms and conditions of this data processing relationship are set forth in the Data Processing Agreement available at https://be-truth.com/dpa.
14. LINKS TO THIRD-PARTY SERVICES
Our Website and Services may contain links to third-party websites, platforms, and services that are not owned or controlled by the Company. This Privacy Policy does not apply to those third-party services, and we are not responsible for their content, privacy practices, or data handling. We encourage you to review the privacy policy of any third-party service you access through our Website.
15. ELECTRONIC COMMUNICATIONS AND E-SIGN ACT CONSENT
By using our Website or Services, you consent to receive communications from us in electronic form, including but not limited to privacy notices, terms updates, receipts, and service notifications, in accordance with the Electronic Signatures in Global and National Commerce Act (E-SIGN Act), 15 U.S.C. sections 7001 through 7006. Electronic records and communications delivered or made available by the Company satisfy any legal requirement that such communications be provided in writing.
16. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or our Services. When we make material changes, we will update the "Last Updated" date at the top of this Policy, post a prominent notice on our Website homepage, and send a notification to the email address associated with your registered account. Your continued use of the Services after the effective date of any material changes constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must stop using the Services and close your account.
17. CONTACT US
For any questions, concerns, or requests relating to this Privacy Policy or our personal data practices, please contact us at:
AXIUM SYSTEMS GROUP LLC
30 N Gould St, STE R
Sheridan, WY 82801
United States of America
Email: hello@be-truth.com
Website: https://be-truth.com
For EEA and UK data subjects: if you are not satisfied with our response to your request, you have the right to lodge a complaint with the competent data protection supervisory authority in your jurisdiction.
Copyright 2026 AXIUM SYSTEMS GROUP LLC. All rights reserved.
Effective Date: March 25, 2026
Last Updated: March 25, 2026
1. INTRODUCTION AND IDENTITY OF THE DATA CONTROLLER
This Privacy Policy ("Policy") describes how AXIUM SYSTEMS GROUP LLC, a Wyoming limited liability company ("Company," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information in connection with your use of the website located at https://be-truth.com (the "Website") and our plugin services, including the Rating Plugin, Sharing Plugin, and any other plugins or features offered as a web service (collectively, the "Services").
This Policy applies to the following categories of persons: (a) Website Operators, meaning individuals or entities who register an account and embed BE-TRUTH plugins on their own websites (also referred to as "Site Owners" or "Operators"); (b) End Users, meaning visitors to Operator websites who interact with embedded BE-TRUTH plugins; and (c) General Visitors, meaning persons who browse the Website without registering.
Contact Information:
AXIUM SYSTEMS GROUP LLC
30 N Gould St, STE R
Sheridan, WY 82801
United States of America
Email: hello@be-truth.com
Website: https://be-truth.com
2. INFORMATION WE COLLECT
2.1 Information You Provide Directly
Account Registration Data. When creating an account, we collect your email address, username, and password. Passwords are stored only in cryptographically hashed form and are never accessible to Company personnel in plain text.
Profile Data. You may optionally provide your name, company name, and website URLs you associate with your account.
Support Communications. We collect messages, queries, and any attachments you submit through our support form or email.
Newsletter Subscription. We collect the email address you provide when subscribing to our newsletter or marketing communications.
Subscription and Payment Data. When subscribing to a paid Plan, we collect your email address and subscription selection. We do not collect, store, or transmit your full payment card number, card verification value (CVV), bank account number, or any other sensitive payment instrument data on our own servers. All payment instrument data is collected directly by our Payment Processors (Stripe, Paddle, or Polar) on their own PCI-DSS compliant infrastructure. We may receive limited non-sensitive payment metadata from Payment Processors, including the last four digits of your payment card, card expiration date, billing country and postal code, transaction ID and date, subscription status, and payment method type.
2.2 Information Collected Automatically
When you visit our Website or when End Users interact with our embedded plugins, we and our service providers may automatically collect the following information.
Technical Data: IP address, browser type and version, operating system, device type, referring URL, pages viewed, and time spent on pages.
Plugin Interaction Data: Rating scores submitted, sharing actions taken, page URLs on which plugins are embedded, timestamps of interactions, and user role (Site Owner, Registered User, or Unregistered User).
Cookie and Tracking Data: Information collected via cookies and similar technologies, as described in our Cookie Policy at https://be-truth.com/cookie-policy.
Server Log Data: Records of requests made to our servers, including request timestamps, response codes, and request paths.
2.3 Data Collected via Embedded Plugins on Operator Websites
When an Operator installs BE-TRUTH plugin code on their website, our platform receives and processes data from visitors to that Operator's website, including IP addresses, session identifiers, and plugin interaction data. In this context, we act as a data processor on behalf of the Operator, who is the data controller in respect of those visitors' data. The terms of this processing relationship are governed by our Data Processing Agreement (DPA), available at https://be-truth.com/dpa.
2.4 Information Received from Payment Processors
Our Payment Processors may share limited account and transaction information with us to enable subscription management, refund processing, billing dispute resolution, and legal compliance. The privacy practices of each Payment Processor are governed by their respective privacy policies. Stripe's Privacy Policy is available at https://stripe.com/privacy. Paddle's Privacy Policy is available at https://www.paddle.com/legal/privacy. Polar's Privacy Policy is available at https://polar.sh/legal/privacy.
3. HOW WE USE YOUR INFORMATION
We use personal information for the following purposes.
To provide, operate, and maintain the Services. Legal basis under GDPR: performance of contract. Under US law: contractual necessity.
To create and manage your account. Legal basis under GDPR: performance of contract.
To deliver plugin functionality, including ratings, sharing, and future features. Legal basis: performance of contract and legitimate interest.
To process subscription payments, issue invoices, manage billing, and process refunds. Legal basis: performance of contract and legal obligation.
To send transactional communications, including account notices, receipts, renewal reminders, and service notifications. Legal basis: performance of contract.
To send promotional newsletters and marketing communications, but only with your prior express consent. You may withdraw consent at any time by unsubscribing. Legal basis: consent.
To analyze usage and improve the Website and Services. Legal basis: legitimate interest.
To detect, prevent, and investigate fraud, abuse, security incidents, and violations of our Terms. Legal basis: legitimate interest and legal obligation.
To comply with applicable laws, regulations, and lawful governmental requests. Legal basis: legal obligation.
To enforce our Terms of Service, Refund Policy, and other agreements. Legal basis: legitimate interest.
To calculate and display ratings and to operate AI-assisted content integrity filters. Legal basis: performance of contract and legitimate interest.
We do not use personal information for fully automated individual decision-making that produces legal or similarly significant effects without human review.
4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We do not sell, rent, or trade your personal information to third parties for monetary consideration, and we do not share personal information for the purpose of cross-context behavioral advertising.
Payment Processors. We share your email address, subscription plan details, and limited account information with our Payment Processors (Stripe, Paddle, and Polar) as necessary to process payments, manage subscriptions, issue refunds, and handle billing disputes. When Paddle or Polar acts as Merchant of Record, those entities are independent data controllers for the billing transaction and process your personal data pursuant to their own privacy policies. Stripe processes payment data as a payment processor on our behalf under its own data processing terms.
Service Providers and Sub-Processors. We engage third-party vendors to provide cloud hosting, email delivery, analytics, and customer support. These providers access personal information only to the extent necessary to perform their services, are bound by written confidentiality and data processing obligations, and are prohibited from using your data for any other purpose. A list of current sub-processors is available upon written request to hello@be-truth.com.
Operators. Plugin interaction data collected through BE-TRUTH plugins embedded on an Operator's website is made accessible to that Operator through the BE-TRUTH admin panel as part of the Services delivered to that Operator.
Business Transfers. In the event of a merger, acquisition, reorganization, sale of assets, or insolvency proceeding, your personal information may be transferred to the acquiring or successor entity. We will provide you with reasonable advance notice via email and/or a prominent Website notice before your information becomes subject to a materially different privacy policy.
Legal Requirements and Protection of Rights. We may disclose personal information if required to do so by applicable law, regulation, legal process, or enforceable governmental request, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of the Company, our users, or the public.
With Your Consent. We may share personal information with third parties for purposes not described in this Policy when we have obtained your explicit prior consent.
5. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies on our Website and through our embedded plugins. For detailed information about the types of cookies we use, their purposes, their duration, and how you can manage your preferences, please refer to our Cookie Policy at https://be-truth.com/cookie-policy.
In summary: essential functional cookies are always active and cannot be disabled. Analytics and advertising cookies are disabled by default and are activated only upon your consent. We recognize and honor the Global Privacy Control (GPC) signal transmitted by California residents as a valid opt-out request under CCPA/CPRA.
6. DATA RETENTION
We retain personal information for as long as necessary to fulfill the purposes described in this Policy and to satisfy our legal, accounting, tax, and compliance obligations.
Account data is retained for the duration of your active account and for three (3) years following account closure.
Plugin interaction data, including ratings and sharing events, is retained for the duration of the associated Operator account and for five (5) years thereafter.
Payment and billing records are retained for seven (7) years as required by applicable tax and accounting laws.
Support communications are retained for three (3) years from the date of the last communication.
Newsletter and marketing subscriber data is retained until you unsubscribe, and for one (1) additional year thereafter for compliance record-keeping.
Server logs and technical data are retained in active storage for up to twelve (12) months and in backup or archival storage for up to three (3) years.
Upon expiry of the applicable retention period, personal information is securely deleted or irreversibly anonymized in accordance with applicable data protection standards.
7. INTERNATIONAL DATA TRANSFERS
Our primary servers are located in the United States. If you access our Services from the European Economic Area (EEA), the United Kingdom, Switzerland, or other jurisdictions whose laws impose restrictions on international data transfers, your personal information may be transferred to and processed in the United States.
For transfers of personal data from the EEA or the United Kingdom, we rely on the Standard Contractual Clauses (SCCs) adopted by the European Commission under Implementing Decision (EU) 2021/914 (Module 2: Controller to Processor), which are incorporated by reference into our Data Processing Agreement. For transfers of personal data from the United Kingdom, we rely on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs, as applicable.
By using our Services, if you are located outside the United States, you acknowledge that your information will be transferred to and processed in the United States in accordance with the safeguards described in this section.
8. SECURITY OF PERSONAL INFORMATION
We implement and maintain reasonable and appropriate technical and organizational security measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit using TLS/SSL protocols, encryption of sensitive data at rest, role-based access controls, multi-factor authentication for administrative access, regular security monitoring and vulnerability assessments, and documented incident response procedures.
We do not store full payment card data. All payment instrument data is processed exclusively by PCI-DSS Level 1 certified Payment Processors.
No information security system is completely impenetrable. We cannot guarantee the absolute security of information transmitted to or from our Services. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users and applicable supervisory authorities as required by applicable law.
9. CHILDREN'S PRIVACY AND COPPA COMPLIANCE
Our Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect personal information from children under 13. In compliance with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. sections 6501 through 6506, and FTC regulations at 16 C.F.R. Part 312, we do not knowingly collect, use, or disclose personal information from children under 13 without verifiable parental consent.
If you are a parent or legal guardian and believe that your child has provided us with personal information without your consent, please contact us immediately at hello@be-truth.com. We will take prompt steps to delete such information from our records.
10. YOUR PRIVACY RIGHTS
10.1 Rights Under GDPR (EEA and UK Residents)
If you are a resident of the European Economic Area or the United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR) or UK GDPR.
Right of Access (Article 15). You may request a copy of the personal information we hold about you.
Right to Rectification (Article 16). You may request correction of inaccurate or incomplete personal information.
Right to Erasure, also known as the Right to be Forgotten (Article 17). You may request deletion of your personal information, subject to limited exceptions, for example where we are required by law to retain it.
Right to Restriction of Processing (Article 18). You may request that we temporarily suspend the processing of your personal information in certain circumstances.
Right to Data Portability (Article 20). You may request to receive your personal information in a structured, commonly used, and machine-readable format.
Right to Object (Article 21). You may object to processing based on our legitimate interests, or to direct marketing at any time.
Right to Withdraw Consent (Article 7(3)). Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Right to Lodge a Complaint. You have the right to lodge a complaint with the data protection supervisory authority in your country of residence.
To exercise any of the above rights, contact us at hello@be-truth.com with the subject line "GDPR Rights Request." We will respond within one (1) calendar month of receiving your request. We may request reasonable verification of your identity before fulfilling your request.
10.2 California Residents' Rights (CCPA / CPRA)
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California Civil Code section 1798.100 et seq.
Right to Know. You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purposes for collection, and the categories of third parties with whom we share it.
Right to Delete. You may request deletion of personal information we have collected from or about you, subject to certain legal exceptions.
Right to Correct. You may request correction of inaccurate personal information we maintain about you.
Right to Opt-Out of Sale or Sharing. We do not sell or share personal information as defined under CCPA/CPRA, and we do not engage in cross-context behavioral advertising. We honor the Global Privacy Control (GPC) signal transmitted by California residents as a valid opt-out request under CCPA/CPRA.
Right to Limit Use of Sensitive Personal Information. You may request that we limit our use and disclosure of sensitive personal information to purposes specifically authorized by law.
Right to Non-Discrimination. We will not discriminate against you in the provision of Services for exercising any of your CCPA rights.
To submit a verifiable consumer request, contact us at hello@be-truth.com with the subject line "CCPA Rights Request." We will respond within forty-five (45) calendar days of receipt. We may extend this period by an additional forty-five (45) days where reasonably necessary, provided we give you prior written notice. We will verify your identity before processing a deletion or disclosure request.
10.3 Rights Under Other Applicable State Privacy Laws
Residents of Virginia (Consumer Data Protection Act), Colorado (Colorado Privacy Act), Connecticut (Connecticut Data Privacy Act), Utah (Utah Consumer Privacy Act), and other U.S. states that have enacted applicable privacy laws may have rights similar to those described in this Section. To the extent such rights are applicable and legally enforceable, we will honor them. To submit a request, contact hello@be-truth.com.
11. CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CalOPPA) COMPLIANCE
In compliance with the California Online Privacy Protection Act (CalOPPA), California Business and Professions Code sections 22575 through 22579:
Users may visit our Website anonymously. A link to this Privacy Policy appears on our Website homepage and is identifiable by use of the word "Privacy." Users will be notified of material changes to this Privacy Policy through an update to this page and, for registered users, by email. Users may request updates to their personal information by contacting hello@be-truth.com.
Regarding Do-Not-Track (DNT) signals: our Website does not currently respond to DNT browser signals or other similar mechanisms. We will revisit this position as industry standards and applicable legal requirements develop.
12. PAYMENT DATA AND PCI DSS
The Company does not directly collect, store, process, or transmit cardholder data or payment account data. All such data is handled exclusively by our Payment Processors, each of which maintains PCI-DSS Level 1 compliance. By subscribing to any paid Plan, your financial data is subject to the security standards and privacy protections maintained by the applicable Payment Processor.
13. DUAL ROLE AS DATA CONTROLLER AND DATA PROCESSOR
The Company operates in two distinct roles depending on context. With respect to personal information collected directly from Website Visitors and registered Operators, the Company acts as an independent data controller, determining the purposes and means of processing. When BE-TRUTH plugins embedded on Operator websites process personal data from those Operators' End Users, the Company acts as a data processor on behalf of the Operator (the data controller). The terms and conditions of this data processing relationship are set forth in the Data Processing Agreement available at https://be-truth.com/dpa.
14. LINKS TO THIRD-PARTY SERVICES
Our Website and Services may contain links to third-party websites, platforms, and services that are not owned or controlled by the Company. This Privacy Policy does not apply to those third-party services, and we are not responsible for their content, privacy practices, or data handling. We encourage you to review the privacy policy of any third-party service you access through our Website.
15. ELECTRONIC COMMUNICATIONS AND E-SIGN ACT CONSENT
By using our Website or Services, you consent to receive communications from us in electronic form, including but not limited to privacy notices, terms updates, receipts, and service notifications, in accordance with the Electronic Signatures in Global and National Commerce Act (E-SIGN Act), 15 U.S.C. sections 7001 through 7006. Electronic records and communications delivered or made available by the Company satisfy any legal requirement that such communications be provided in writing.
16. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or our Services. When we make material changes, we will update the "Last Updated" date at the top of this Policy, post a prominent notice on our Website homepage, and send a notification to the email address associated with your registered account. Your continued use of the Services after the effective date of any material changes constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must stop using the Services and close your account.
17. CONTACT US
For any questions, concerns, or requests relating to this Privacy Policy or our personal data practices, please contact us at:
AXIUM SYSTEMS GROUP LLC
30 N Gould St, STE R
Sheridan, WY 82801
United States of America
Email: hello@be-truth.com
Website: https://be-truth.com
For EEA and UK data subjects: if you are not satisfied with our response to your request, you have the right to lodge a complaint with the competent data protection supervisory authority in your jurisdiction.
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