Last Modified: June 20th 2025
Thank you for taking the time to read our privacy policy (the “PrivacyPolicy”). At True Pedigree, LLC and True Pedigree Consulting LLC (collectively, “True Pedigree”, “we”, “our” or “us”),your privacy is of the utmost importance. This Privacy Policy describes the personal information we collect, how we use it, and the circumstances where we may share it.
By using our websites (notably https://www.truepedigree.com, https://www.truebquest.com, https://bp-analysis.com, https://tmforesight.com,https://tp-grayhunter.com, https://tp- genuscan.com) “Website”) or by using our platform or any of our products or services, such as Gray Hunter, TrueBQuest, GenuScan, BP Analysis, TMForesight and TPAudit (the “Services”), you acknowledge that you understand the practices and policies outlined below.
1. PERSONAL INFORMATION WE COLLECT
Customer Information:
In order to serve our Customers, we collect various information on our Customers, including:
Customer Information:
In order to serve our Customers, we collect various information on our Customers, including:
- Employee information including your name, title/role, company email, company name, company website URL
- Correspondence, which may include any personal information provided during an email correspondence or customer service engagement
- Billing, payment and administrative finance information.
- Information about how our Customers use our Services, including our website which may include engagement activities with our website, platform, or other Services, and communications. We may also use tools to measure your website and platform visits, such as time spent on our website and platform, the pages you may have clicked on, behavioral activity, and metadata associated with software interactions, for which we may use pixel tags and cookies.
- We may send email updates and collect information about your interaction with our emails, such as whether you opened or clicked on an email we sent you.
- Metadata and analytics for your use of our Website and Services, including IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages.
- We may use cookies, beacons, pixel tags, and other similar technologies to collect additional information automatically as you interact with the Website and Services and to personalize your experience with our Website and Services. Learn more about our cookie use below.
Our Customer’s User Information:
When our Customers use our Website and Services, they may enable us to process various types of personal information on their users (“Users”). Below, we provide a list of the commonly processed personal information of Users. Please note, the below list is not exhaustive of all personal information, and is intended to serve as a sample set.
Personal information of Users that may be processed by Gray Hunter, GenuScan, BP Analysis, TMForesight and TPAudit:
- Lists and contact information of potential Users of our Services, including those using our mobile applications.
- IP addresses or other unique identifiers associated with the use of our Services, or use of our Customer's products.
- Mobile equipment or other unique hardware identifiers associated with our Customers’ products.
Personal information that may be processed through the TrueBQuest Services:
- Contact information such as name, email address, phone number, postal address.
- Family or legal beneficiary information such names, email addresses, phone numbers or postal addresses and their familial or legal association with any Users.
- When necessary, with User consent or as otherwise permitted by applicable law, we may collect billing and financial information necessary to process donations, which may include historical and current banking or investment information.
- When necessary, with User consent or as otherwise permitted by applicable law, we may collect government identifiers such as social security numbers, drivers license, and state identification.
True Pedigree does not intend for this website or any of the Products to collect personal information from anyone under the age of 18, but some children’s information related to beneficiaries may be processed. If you are a parent or legal guardian of a minor whose information we have processed, you may contact us at privacy@truepedigree.com to exercise any privacy rights associated with our processing of that minor’s information.
2. HOW WE USE PERSONAL INFORMATION
Subject to the terms of our Customer agreements, we may use personal information for the following business purposes:
- Provide our Website and Services.
- To communicate with you, for example, making you aware of product and feature promotions.
- To provide customer service.
- To process payments securely.
- To improve our Website and Services.
- To personalize our Services.
- To receive and process job applications for careers with us.
- Aggregated or anonymous information about the various types of information, integrations, metadata and performance metrics to ensure our Website and Services are serving their intended purposes and for product improvements.
- For any legal purpose necessary, including IP protection, or if we are required to process information as a result of a court order or other legal or regulatory proceeding..
3. HOW WE DISCLOSE PERSONAL INFORMATION
We utilize various service providers to operate our Website and Services, which includes sharing Customer and/or User personal information for the following categories of business purposes:
- To facilitate the Services on written instructions from our Customers.
- With service providers that contractually agree to safeguard the information, such as cloud hosting, customer information management, customer communications, and website analytics.
- With any of our affiliated companies, including Sideman & Bancroft LLP, as well as any subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy)
- Anytime with your consent.
In addition, we may share personal information in order to;
- Protect the legal rights of our Customers, our company, our employees, our agents, and our affiliates.
- Protect the safety and security of those who access and use our Website and Services.
- Detect and protect against fraud.
- In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet law enforcement requirements or a court order, subpoena, or other judicial, administrative, or investigative proceedings.
- We may disclose personal information as part of a business transition. For example, we may disclose personal information with prospective purchasers exclusively to evaluate the proposed transaction. You will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
We may disclosed e-identified, aggregate, or anonymous information for any purpose. This means that the information we disclose does not identify specific individuals, nor is combined with other data to protect your privacy.
4. PRIVACY CHOICES
We provide you with the following choices with our use of your personal information:
- Access the personal information we maintain about you.
- Delete the personal information we maintain about you. Please note we may be required by law to retain certain information in compliance with accounting, tax or other legal obligations.
- Correct inaccurate personal information we maintain about you
- Opt out of certain uses of your personal information, notably:
- Marketing Emails: To opt out of marketing e-mail communications, you may click the ‘unsubscribe’ link in the marketing emails.
If you are a User associated with one of our Customers, and you would like to fulfill your rights to the personal information we maintain about you on behalf of that Customer, we encourage you to exercise these rights by reviewing the Customer’s privacy policy to determine the correct contact method for that Customer. Alternatively, if you email us at privacy@truepedigree.comand identify the Customer that is utilizing our Services, we can forward your request to the appropriate contact.
5. COOKIES AND OTHER TRACKING TECHNOLOGIES
Like many companies, we use cookies, pixels, and other tracking technologies to collect information about your browsing activities, your interactions with our Website or emails, and to personalize content on our website. We currently do not enable the use of third party pixel tags or cookies for advertising purposes, but may do so in the future. Please check back periodically if you would like to review and/or opt out of these future uses.
The following websiteanalytics services partnersoffer opt-out featuresthat let you opt-out of use of your information for our measurement purposes:
6. SECURITY
We maintain reasonable safeguards to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. Despite our efforts, we cannot guarantee that unauthorized access or use will never occur. It is important that you take steps to keep your information safe and secure. Choose an account password that is hard for others to guess and don’t reveal it to third parties. If you use a shared public computer, do not opt to have your login ID or password remembered and be sure to log out of your account when you finish.
7. RETENTION
We will retain Customer personal information only for as long as it is necessary for the purposes of fulfilling our Website and Services or otherwise as described in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. U.S. STATE-SPECIFIC NOTICE
Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CPRA” (collectively, the “CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Florida Digital Bill of Rights (“FDBR”), the Montana Consumer Data Privacy Act (“MTCDPA”), the Iowa Consumer Data Protection Act (“IADPA”), the Delaware Personal Data Privacy Act (“DEPDPA”), the Nebraska Data Privacy Act (“NEDPA”), the New Hampshire Privacy Act
(“NHPA”), the New JerseyData Privacy Act (“NJDPA”), the Tennessee Information Protection Act (“TNIPA”),the Minnesota Consumer Data Privacy Act (“MNCDPA”),the Maryland Online Data Privacy Act (“MDODPA”), the Indiana Consumer Data Protection Act (“INCDPA”), the Kentucky Consumer Data Protection Act (“KYCDPA”),and the Rhode Island Data Transparency and Privacy Protection Act (“RIDTPPA”) create additional privacy obligations for businesses and provide their residents with additional privacy rights.
Additional Privacy Rights:
In addition to the rights granted in ‘Your Privacy Choices’ above, if you are a resident of the above states, you may have the right to:
- Information. For details about the personal information we have collected over the last twelve months, including the categories of sources, please see the ‘Personal Information We Collect’ section above. We collect this information for the business and commercial purposes described in the ‘How We Use Your Personal Information’ section above. We share this information with the categories of third parties described in the ‘How We Disclose Your Personal Information’ section above.
- Opt outof the ‘sale’ or ‘share’ of your personal information for targeted advertising. We do not ‘sell’ or ‘share’ your personal information for monetary benefit nor use third party targeted advertising services.
- Sensitivepersonal information. Residents of Californian, Utah, and Iowa have the right to opt out of the use of their sensitive personal information, while residents of Virginia, Colorado, Connecticut, Oregon, Texas, Montana, Delaware,New Hampshire, Nebraska, and New Jersey have the right to opt in to the use of their sensitive personal information. We may process some information deemed‘ sensitive’ under state privacy laws to provide our TrueBQuest Services, but do so exclusively on our clients behalf and not for any other commercial use.
You can exercise these rights by contacting us at privacy@truepedigree.com.Appeal:
If we deny your privacy request, you may appeal that decision by emailing us at privacy@truepedigree.com. We will respond to your appeal within a reasonable period of time and as required by law. If, after we have processed your appeal, you are still unsatisfied with our response, you have the right to file a complaint with your state attorney general.
Authorized Agent:
If you are an authorized agent submitting a request on behalf of another person, you must provide a copy of a lawful power of attorney or written authorization from the consumer (along with proof of your identity). If you make a request as an authorized agent, you will receive additional instructions. Depending on the type of request, we may contact you or the consumer on whose behalf you claim to act to verify your authorization.
Controller/Business and Processor/Service Provider Designation:
We operate as a Controller (and a ‘Business’ under CCPA) with respect to all Customer information used to operate our business. We operate as a ‘Processor’ (and a ‘Service Provider’ under the CCPA) with respect to all User information in order to provide our Products and Services.
9. UK/EEA RESIDENTS NOTICE
Residents of the (“UK”) and European Economic Area (“EEA”) are provided certain privacy rights under the UK and EU General Data Protection Regulations (“GDPR”).
Legal Basis:
Under the GDPR,we process PersonalData under the following legal basis.
Controller and Processor Designation:
Under the GDPR, we are designated as a Controller with respect to all Customer information. With respect to all User information, we operate as a Processor under the GDPR.
Cross-Border Data Transfers:
We may transfer to, and store the data we collect about you, in countries other than the country in which the data was originally collected, including the United States, Canada or other destinations outside the EEA and the UK. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and applicable supplemental product privacy policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA or UK.
If you are located in the EEA or UK, we will only transfer your Personal Data if:
- The country to which the Personal Data will be transferred has been granted a European Commission adequacy decision; or
- We have put in place appropriate safeguards in respect of the transfer, for example we have entered into the Standard Contractual Clauses adopted by the European Commission and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.
Additional Rights for UK or EEA Residents:
In addition to the rights granted above,if you are a UK orEEA resident, the GDPR grants you the right to lodge a complaint againstus with your local dataprotection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
10. THIRD-PARTY LINKS
The Services may contain links to other websites or services. We do not exercise control over the information you provide, or is collected by these third party websites. We encourage you to read the privacy policies or statements of the other websites you visit.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time as we update or expand our Website and Services. If we make material changes, we will post the updated Privacy Policy on this page with a ‘Last Updated’ effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Website and Services.
12. CONTACT US
If you have any questions about our privacy or security practices, or if you are a Customer and would like to request access to or correction of your personal information, you can contact us by email at privacy@truepedigree.comor at:
True Pedigree, Inc.
Attn: Privacy
7500 Rialto Blvd., Suite 250
Austin, TX 78735 United States