True Heading Network Co., LTD respects and understands the importance of your privacy and is therefore committed to affording complete protection to the personal information of our customers, employees, job applicants, survey respondents, service users, and website visitors. Recognising the need for security and our obligations under global data protection laws including the EU/UK General Data Protection Regulation (GDPR), the California Privacy Rights Act (CPRA/CCPA), and the India Digital Personal Data Protection Act 2023 (DPDPA), we have established this Privacy Notice to govern the secure management of all personal information we collect and receive.
This Privacy Notice applies to our website: www.TrueHeadingSample.com (hereinafter referred to as the "Website") and the products and services offered through it (collectively the "Services").
The Website is owned and operated by True Heading Network Co., LTD, a company registered in the United States with its registered office at 1776 Broadway, Unit 1-1686, Denver, CO 80202, United States (hereinafter referred to as "we", "us", or "our"). Under applicable data protection laws, we act as the Data Controller (or Data Fiduciary) of your personal data.
As a general practice, we do not automatically collect personally identifiable information about website visitors unless you voluntarily submit information via our “Contact Us” form, chat form, or account registration. We obtain your informed consent when you submit such information, and we will use it only for the purpose disclosed at the time of submission.
Depending on your interaction with us, we may collect:
Identity and Contact Data: Name, email address, phone number, and physical address.
Survey and Panel Data: Demographic information provided during survey participation.
Employment Data: Resumes, employment history, and educational background if you apply for a job with us.
Technical & Usage Data: When you visit our Website, we automatically collect non-identifiable analytical data. This includes aggregated metrics such as visit volumes, session duration, and page views. We also capture IP addresses for geolocation purposes to serve you with regionally appropriate content; however, we do not link IP addresses to personally identifiable information.
We use cookies, web beacons, and similar tracking technologies to enhance your browsing experience, analyse website traffic, and optimise our Services.
Where required by law (such as in the EU/UK), we will ask for your explicit consent before placing non-essential cookies on your device. You can manage your cookie preferences at any time through our [Link to Cookie Consent Manager / Cookie Policy].
We process your personal data only where we have a valid lawful basis under applicable data protection legislation. Our lawful bases include:
Performance of a Contract: To deliver the Services you request or to manage your registration as a panelist.
Consent: Where you have provided explicit consent for a specified purpose (e.g., subscribing to newsletters).
Legal Obligation: To comply with applicable financial, tax, or regulatory obligations.
Legitimate Interests: For internal analysis of user behaviour to improve and secure our Services, provided such interests do not override your privacy rights.
Corporate Restructuring: In the event of a merger, acquisition, or sale of all or substantially all of our business assets, your personal information may form part of the transferred assets. We will ensure the acquiring entity maintains equivalent data protection standards. We will notify you via email and/or a prominent notice on our Website of any such change in ownership and any choices you may have regarding your personal information.
We respect your privacy and do not sell or share your personal information to third parties for cross-context behavioral advertising or independent marketing purposes.
We may share your personal information with approved technology service providers who perform limited processing on our behalf (e.g., web hosting, email delivery, analytics). All vendors we engage are GDPR, CPRA, and DPDPA compliant and have executed formal Data Processing Agreements (DPAs) to safeguard your personal data.
We may also disclose your personal information:
If required by law, subpoena, court order, or other binding legal processes;
To law enforcement authorities to enforce our Terms of Service, protect our rights, property, or the personal safety of our users and the public.
Where we transfer your personal data outside your country of residence (such as outside the European Economic Area or India), we rely on legally approved transfer mechanisms, including the European Commission’s Standard Contractual Clauses (SCCs) or other legally recognised safeguards, to ensure your personal data receives an adequate level of protection.
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected or to satisfy applicable legal, tax, or contractual obligations.
Retention periods vary based on the data category. For example, financial and transaction records may be kept for up to 7 years for legal compliance, whereas website analytics data or unsuccessful job applications are typically retained for a much shorter duration (e.g., 6 to 12 months). Once data is no longer required, it is securely deleted or anonymised.
We maintain robust technical and organisational security measures to protect personal data against loss, misuse, unauthorised access, disclosure, or alteration. Access to personal data is strictly restricted to employees and authorised personnel with a documented business "need-to-know," all of whom are bound by confidentiality obligations.
If you are located in the EEA or the UK, you have the right to:
Be informed about our processing activities;
Access a copy of your personal data;
Rectify inaccurate or incomplete data;
Request erasure ("right to be forgotten") where there is no lawful basis for retention;
Restrict or object to processing (including automated decision-making and profiling);
Data portability (receiving your data in a machine-readable format);
Withdraw consent at any time.
Under California law, you have the right to:
Know what personal data we collect, use, and disclose;
Request deletion or correction of your personal data;
Opt-out of the "sale" or "sharing" of personal data (Note: We do not sell or share your data);
Limit the use and disclosure of sensitive personal information;
Non-discrimination for exercising your privacy rights.
Under India's Digital Personal Data Protection Act, you have the right to:
Access information about your personal data and its processing;
Request correction, completion, or erasure of your data;
Right to Grievance Redressal: Raise a grievance with our designated Grievance Officer if your requests are not resolved.
Right to Nominate: Nominate an individual to exercise your rights in the event of death or incapacity.
Duties of Data Principals: Please note that under the DPDPA, you are obligated to provide verifiably authentic information and refrain from registering false or frivolous grievances.
How to Exercise Your Rights:
All data subject requests must be submitted via email at info@thsample.com or through our [Privacy Rights Request Link]. We will respond within the timeframes mandated by applicable laws (typically 30 days). We may take reasonable steps to verify your identity before disclosing or modifying data.
Our Website and Services are not directed to minors. We do not knowingly collect personal data from children under the age of 16 (or under 18 in India per the DPDPA, and under 13 in the US per COPPA). If you believe we have collected information from a child without valid parental consent, please contact us immediately for deletion.
Our Website may contain hyperlinks to third-party websites. We are not responsible for the privacy practices or content of external sites. We encourage you to review the privacy notices of any third-party sites you visit.
We may update this Privacy Notice periodically. Any revisions will be published on this page with an updated "Last Updated" date. If we intend to use your data for materially different purposes, we will notify you by email or a prominent website notice prior to the change becoming effective.
For enquiries relating to this Privacy Notice, to exercise your privacy rights, or to contact our Data Protection Officer (DPO) / Grievance Officer, please reach out to:
True Heading Network Co., LTD
Attention: Data Protection Officer / Grievance Officer
Email: info@thsample.com
Address: 1776 Broadway, Unit 1-1686, Denver, CO 80202, United States