Effective January 2019
For the purposes of UK data protection legislation, Truebeacon is the data controller of your personal information.
User: A person who has signed up and is registered with the Website or the App for the use or potential use of the Service
The information we collect:
Truebeacon collects personal information to deliver our Service to you, including through our Website and App. We collect personal information from you, such as:
Things you and others do and provide:
Account Information: We collect information when you create or update your Xplore account. This may include your name, email address, photo, birthday, country, language, currency, password, mobile phone number, social accounts, should you choose to connect them, and your banking information (including related payment verification information). We may also ask you about your preferences.
Your Location: Truebeacon requires your consent to track geo-location for use of the App. When you use the App through your mobile device, we will track your geo-location information, on a real time basis. Depending on which other products and services you use, we may also collect your precise or approximate location through your IP address or Wifi. You may use the App without enabling Truebeacon to track your location; however, this will affect the functionality available to you.
Your network and connections: If you provide us access to your address book or social connections, we may collect names and other profile information from these sources. If you provide us access to your calendar, we may collect event information from this source (event information may include your response (YES/NO), date and time, location, subject/content, and number of attendees).
User content: We may collect information that you submit when you contact Truebeacon customer support, or any information you submit about our partners including ratings, tags, compliments, photos, or comments. We will also track any content you submit relating to your lists or guides.
Usage information: We collect information about how you interact with our Service. This includes information such as access dates and times, which features you used and which pages you viewed, crashes and other system activity, and third-party sites you were interacting with before using our Service.
Technical data: When you use our App, we also process technical data such as IP address, Device ID or MAC address, and information about the manufacturer, model, settings, and operating system of your mobile device. We will also capture your application version. When you visit our Website, we may process technical data such as your IP address, visited webpages, the internet browser you use, your previous/next visited websites and the duration of a visit/session.
Survey or demographic data: We may offer you the opportunity to participate in one of our customer surveys or research. If you choose to participate, we use the optional information and survey results to help us understand our customers and to tailor and enhance our service offerings, and promotions.
Career Information: If you wish to apply for a job on our Website we will collect personal information such as your name, email address, phone number and additional information such as resume. We use the information collected within this area of the Website to register and process your application, to determine your qualifications for the position for which you have applied and to contact you.
How we use your information
Truebeacon uses the information it collects for the following purposes:
Provide our service to you: Truebeacon uses the information we collect to provide, maintain, personalize, and improve our products. We will use your information to:
Create and manage your account. This includes using your phone number or email address to verify your identity.
Show you lists or guides near you. We use your location to allow you to view the lists or guides in your area. Your location also allows us to provide a walk distance to places in the lists or guides.
Process or facilitate payments.
Enable the various features of our product for our legitimate interests where we have considered that these are not overridden by your rights. For example, personalization or sharing features. Personalization features may include showing you recommendations while content features include allowing you to share reviews, ratings, tags, and discussions.
Troubleshoot software bugs and operational problems.
User content and communication: Truebeacon may use content you submit, such as ratings, comments, or photos, to surface recommendations to other users and to facilitate the operations of our business. Truebeacon may also allow users to communicate with others. Truebeacon may also allow content creators to communicate with users. For example, the creator of a guide may contact you directly if there are updates.
Research and development: Truebeacon uses your personal information for testing, research, analysis, and development of our products. This allows us, for our legitimate interests, to improve our products, improve the in store experience our merchants offer, and to determine where we should offer or focus our Service. We may share this information with third parties for industry analysis and statistics.
Customer support: We use your profile, account, and usage information to assist you when you contact customer support. This allows us to direct your inquiry appropriately, investigate and assist you with your inquiry, and follow up to ensure the problem does not persist. We may also use your information to monitor and improve our customer service responses.
Communications from Truebeacon: Truebeacon uses your contact information to communicate with you about your activity, our services, your account, and, if we have your prior consent, about Xplore news, special offers, and events. We may also contact you about studies and surveys.
We may also need to communicate with you about your account or Truebeacon's service. For instance, we may send you an email to verify your username and password or let you know when our Service is temporarily suspended for maintenance.
Only where we have your prior consent to do so, Truebeacon may also use your contact details to send you general updates regarding Truebeacon news, special offers, promotions, and contests. We may also display tailored advertisements on third party websites and other platforms. You may opt-out of receiving these updates at any time by following the instructions in each of our communications.
Public forums: The Website and the App may offer publicly accessible blogs and community forums. We will use your personal information such as your name, email address, the messages or content you choose to post to administer and provide you with these services.
Cookies and Related Technology:
We do not collect children's personal information. Truebeacon cares about the safety of children. Because the Service is not directed towards children under 13, they are not allowed to register with or use the Service, or provide personal information. We do not knowingly collect personal information from anyone under the age of 13.
What is our legal basis for processing data?
We will only collect and process personal data about you where we have a lawful basis. Lawful bases include complying with a legal obligation, consent (where you have given consent to, say, receive updates and marketing emails), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Truebeacon Services you have requested)) and “legitimate interests”.
We may process your personal data for the purposes of our legitimate interests, provided that such processing shall not outweigh your rights and freedoms. For example, we may process your personal data to:
Protect you, us, or others from threats (such as security threats or fraud).
Enable or administer our business, such as for quality control, consolidated reporting, and customer service.
Manage corporate transactions, such as mergers or acquisitions.
Understand and improve our business or customer relationships generally.
Enable us, Members, and Visitors to connect with each other, express opinions, exchange information, and conduct business.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer at[email protected]
How do we share or disclose your personal information?
Sharing with our Service Providers: We may employ third party companies and individuals in Canada, the US or other jurisdictions to facilitate or provide certain services on our behalf, such as to process payments, provide customer support, provide geo-location information to our Restaurants, to host our job application form, to perform Website-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Website's features) or to assist us in analyzing how our Service is used.
These third parties have access to your personal information only to perform these tasks on our behalf and are contractually bound not to disclose or use it for any other purpose. For additional information about the way in which our service providers treat your personal information, contact us as set out below.
We may transfer your personal information to the following countries and using the following safeguards outside the EEA:
Canada - European Commission Adequacy Decision
United States - Privacy Shield
United States – Model Clauses
Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Truebeacon or as part of a corporate reorganization or other change in corporate control.
Legal Requests: Truebeacon, our Canadian and US businesses, and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an organization in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, US or English law. Truebeacon may also disclose your personal information to the extent that this is legally required, or necessary for the establishment, exercise or defence of legal claims and legal process; to investigate or prevent actual or suspect loss or harm to persons or property; to detect, prevent or suppress fraud; or in the event of an emergency pertaining to your health and/or safety; or to our auditors, legal advisors and other professional advisors.
Information for our EU customers:
How can you exercise your rights under the GDPR?
You have the right under certain circumstances to:
be provided with a copy of your personal information held by us;
request the rectification or erasure of your personal information;
request that we restrict the processing of your personal information;
object to the further processing of your personal information, including the right to object to marketing; and,
request that your personal information be moved to a third party.
You can exercise the rights listed above at any time by contacting us at [email protected]
You may opt out at any time from allowing further access by us to your location data by updating settings on your device. You can also stop all information collection by un-installing the App. You may use the standard un-install processes as may be available for your mobile device.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer at [email protected]
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see European Commission: What are Data Protection Authorities (DPAs)?). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal information, as well as deal with any complaints that you have about our processing of your personal information.
How long does Truebeacon retain personal information?
Retention of personal information: We will generally retain your personal information until you cancel your Truebeacon account in order to meet our contractual obligations to you or until it is no longer required for the purposes stated above or to otherwise meet legal requirements. If you wish to cancel your Truebeacon account or request that we no longer use your information to provide you services, please contact us at [email protected] After deletion of your account, we will anonymize your data, unless this data is necessary to comply with a legal obligation or resolve disputes.
How does Truebeacon protect personal information?
Our safeguards: Truebeacon has taken appropriate technical, physical and organizational security measures to protect personal information in our custody and control against unauthorized access, use, modification and disclosure. For example, we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) as well as physical safeguards at the locations where data is stored. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet. Any transmission of information by you to Truebeacon is at your own risk. We recommend that you do not disclose your password to anyone.
How do I contact Truebeacon?