Privacy Policy

Truly Clear Privacy Policy

Effective date: September 21, 2025
Last updated: September 21, 2025

Truly Clear ("we," "us," "our") respects your privacy. This policy explains what personal information we collect, how we use and share it, and the choices you have. It applies to our website trulyclear.com, related pages, and any services that link to this notice (collectively, the "Site").

If you have questions or want to exercise your privacy rights, contact us at support@trulyclear.com.

Note for shoppers: Some processing is done by Shopify and other service providers on our behalf. See "How we share information" for details.

1) Information we collect

We collect information in three ways: directly from you, automatically from your device, and from third parties.

a) You provide

  • Contact details (name, email, phone, shipping/billing address)

  • Account and profile data

  • Order details (items, payment method, transaction totals)

  • Messages to support, survey responses, contest entries

  • Marketing preferences (email/SMS opt-in choices)

b) Collected automatically

  • Device and usage data (IP address, browser, app/device IDs, pages viewed, time on page, referring/exit URLs)

  • Cookie and pixel data for analytics and ads (see Cookies & Ads)

c) From third parties

  • Payment processors (limited payment details such as tokenized card info and status, not full card numbers)

  • Shipping and address validation partners

  • Marketing/analytics platforms (e.g., campaign performance metrics)

2) Why we use data (purposes)

We use personal information to:

  • Provide, operate, and improve the Site and our products

  • Process and deliver orders, returns, and refunds

  • Authenticate logins and secure the Site

  • Provide customer service and respond to requests

  • Personalize content and measure performance

  • Send marketing by email/SMS when you opt in; you can unsubscribe/opt out anytime

  • Comply with law, prevent fraud, and protect our rights

Legal bases (EEA/UK): consent, contract performance, legitimate interests (e.g., security, fraud prevention, analytics, and improving services), and legal obligation. You can object to processing based on legitimate interests.

3) How we share information

We do not sell personal information. We share limited data with:

  • Ecommerce platform: Shopify (store hosting, checkout, payments, fraud prevention)

  • Payments: Shopify Payments/Stripe, PayPal, Apple Pay, etc. (we don’t store full card numbers)

  • Fulfillment & logistics: warehouses, carriers, and shipping software

  • Customer support & marketing: email/SMS platforms (e.g., Klaviyo), review platforms (e.g., Judge.me), advertising partners (e.g., Google, Meta) where you’ve consented and as allowed by law

  • Analytics & security: Google Analytics and anti-fraud tools

  • Professional services: auditors, advisors, and legal counsel

  • By law or business transfer: when required by law, or in connection with mergers or acquisitions

We only allow vendors to process data under instructions and with appropriate safeguards.

4) International transfers

If you are outside the United States, your information may be processed in countries with different data protection laws. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) for transfers.

5) Retention

We keep personal information only as long as necessary for the purposes above, including to meet legal, tax, accounting, and reporting requirements. Typical retention periods:

  • Orders and invoices: 7–10 years

  • Support communications: 3–6 years

  • Marketing preferences: until you unsubscribe or request deletion

  • Analytics data: per the provider’s configurable retention settings

6) Your privacy choices and rights

All users can:

  • Opt out of marketing emails via the unsubscribe link

  • Opt out of SMS by replying STOP (see SMS Terms)

  • Control cookies with our consent banner and your browser settings

  • Request access, correction, deletion, portability, or restriction where applicable

California (CCPA/CPRA) and other U.S. state rights: You may request to know, access, correct, delete, or opt out of the sale or sharing of personal information (we do not sell), and limit the use of sensitive personal information. You can also appeal a decision about your request.

EEA/UK (GDPR) rights: You may request access, rectification, erasure, restriction, portability, and object to certain processing. You can withdraw consent at any time. You also have the right to complain to a supervisory authority.

To exercise rights, email support@trulyclear.com with the subject line: "Privacy Request". We will verify your request and respond within the time required by law. Authorized agents may submit requests with proof of authority.

7) Cookies, analytics, and advertising

We use cookies and similar technologies to run the Site, understand performance, and personalize content/ads. Categories include:

  • Strictly necessary: core site and checkout functionality

  • Performance/analytics: traffic, conversions, feature usage

  • Functional: remembering preferences

  • Advertising: measuring campaigns and showing more relevant ads

Controls:

  • Use our cookie banner to accept or reject non-essential cookies

  • Adjust browser settings to block or delete cookies

  • Use platform controls (Google/Meta) and industry opt-outs where available

Google Analytics: We use GA to understand site performance. GA provides data retention controls and IP masking options. See provider documentation for details.

8) Email and SMS marketing

Email: We send marketing only with your consent or as permitted by law. Unsubscribe at any time via the link in our emails.

SMS/MMS mobile messaging terms:

  • By opting in, you consent to receive automated marketing texts at the number you provide. Consent is not required to buy. Message frequency varies.

  • Message and data rates may apply.

  • To opt out, reply STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, or QUIT. To get help, reply HELP or email support@trulyclear.com.

  • We may send a one-time confirmation text