Last updated: May 3, 2022
Version 1, April 2022
Purpose and Scope
Definition of Personally Identifiable Information
First and last name
Student identification number
Name of school
Any combination of personal information that could be used to determine identity
Collection of Information
Automatically Collected Information
The following information may be automatically collected and retained if you look through our web pages or download information.
The internet domain and Internet Protocol (IP) address of the computer you are using to access our site;
The type of browser and operating system used to visit our site;
The date and time of when you access our site; and
Which portions of the website you visit
Information You Provide to Us
We collect information you provide directly to us when interacting with us or using the Services. The specific information we collect depends on the context of your interactions with Trula, as outlined below.
Prospective Trula Employees or Coaches
We collect information if you apply for a job or to become a coach, request customer support, or otherwise communicate with us. We will need to collect specific personal information from you to process your application, such as your name, email address, phone number, location, educational institution, GPA, area of study, a cover letter, resume, and references. This information is used to evaluate your experience and communicate with you, among others. The information we request from you helps us to provide coaching services and serves to help us:
Match you with a coach
Ensure eligibility for services
Determine emergency contact information
Select the modality for services
Understand what you hope to gain from our services
Sensitive Personal Information or Demographic Information
To be a Trula coach, we do not require submission of any sensitive information such as financial or demographic information. However, there may be times, such as in a survey or when we are testing a new feature or tool, where we will ask for your consent to collect demographic information such as race, gender, ethnicity, or pronouns, or we may ask for your consent to record a session. This information serves to help with client/coachee matching and quality assurance. If you provide consent, it may be withdrawn at any time.
As a Trula coach, if you have consented to the recording of your session(s), the recordings will only be made of practice sessions with other coaches and be used in the following ways:
Analysis of ratio of speaking to listening
Identification of use of key coaching skills and frameworks
Analysis of facial expression and body language
Quality assurance purposes
If you register to become a client/coachee and are using coaching services through our coach network, you will need to provide certain personal information to request coaching such as: name, email address, phone number, educational institution, student identification number, preferred modality for coaching, and what you would like to accomplish through coaching. This information is required at registration so we can 1) establish your eligibility 2) ensure you are matched with a coach 3) ensure you receive applicable surveys or questionnaires to provide quality services.
In addition to the uses described above, the information we collect from clients/coachees may also be used to:
Provide or deliver the products and services you request, process transactions, and send you related information;
Verify your identity for you to use the Services;
Respond to your comments, questions, or requests;
Send you technical notices and other administrative messages;
Communicate with you about products, services, offers, promotions, rewards, and events offered by us;
Monitor and analyze trends, usage, and activities in connection with the Services;
Conduct research, analysis, and surveys;
Personalize and improve the Services and provide content or features that match user profiles or interests;
SMS messages; and
Carry out any other purpose for which the information was collected.
If you are a client/coachee who is accessing the Services, we will share information about you with our coaches so they can provide services to you, such as responses to surveys as noted above, and/or contact information.
If you are a client/coachee who is referred to coaching from your institution, and you select “yes” that we can allow them to know you signed up for the Services, we will share limited information with them, such as your name and how many sessions you completed. We will not share any information about the content of your sessions with your institution that would be personally identifiable without your written consent.
Sharing Information in an Emergency
It is our policy that if a coach believes that a client/coachee is a danger to themself or others, the coach will promptly report the situation to their Trula Inc. Coach Supervisor.
In the case that a peer coach believes that a coachee exhibits signs or discloses information indicating suicide, self-harm, abuse, violence, depression, or hopelessness, a coach will escalate or refer the client/coachee to a professional healthcare provider or appropriate resource by following these steps:
The coach will recommend the client/coachee reach out to professional health services to seek medical or mental healthcare and provide the appropriate contact information to the client/coachee.
The coach will inform the client/coachee that the coach will contact their Coach Supervisor to notify them of the client/coachee’s concerns.
The coach will use their charting software to automatically notify their Coach Supervisor about a concern and contact them manually as well.
The Coach Supervisor will contact the coach to discuss their concern for the client/coachee and then reach out to the client/coachee to check on their status and refer to the appropriate professionals, as needed.
If the coach believes the client/coachee is in imminent danger, they will call 911 immediately prior to following the process outlined above.
HIPAA and Personal Health Information (“PHI”)
On behalf of health care providers, we may create, collect, receive, maintain or transmit information about you that is protected health information under the Health Insurance Portability and Accountability Act of 1996 as amended from time to time including Sections 13400 through 13424 of the Health Information Technology for Economic Clinical Health Act and the corresponding Standards for Privacy of Individually Identifiable Health Information, Security Standards and Notification in Case of Breach of Unsecured Protected Health Information (collectively, (“HIPAA”). We will only use and disclose such PHI as permitted under HIPAA and with your signed “Release of Information” document.
Information Collected by Cookies
We use different technologies to collect information, including cookies. Cookies are small text files placed on an individual’s computer by websites that the individual has visited. They are used to make websites work more effectively, such as allowing you to sign in more efficiently and providing analytics on our site’s usage and performance. No personal information is stored within them.
The data collected also serves as part of our statistical analysis about the use of our websites so we may better design online services and improve access to them. We do not attempt to gain personally identifiable information about individual users and associate it with IP addresses. Trula Inc. does not use the information automatically collected to ascertain your personally identifiable information. However, we may detect IP addresses for providing location-based user information and services. Trula Inc. does not maintain or collect user IP addresses or disclose such addresses to any third parties.
Except where specified, you do not have to provide personally identifiable information to visit, register or download information from our website. Unless you choose to make your personally identifiable information available to us, Trula Inc. does not collect such information from you.
We store the information we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
You may update, correct, or delete information about you at any time by contacting us at email@example.com. Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.
Sale of Personal Information
We do not sell any client/coachee personal information.
How Personally Identifiable Information Is Used by Trula Inc.
Email, telephone number, or other information requests submitted to the Trula Inc website may be saved and used to respond to the request, forwarded to the appropriate party, provided to the user’s educational institution only when the user gives consent, or provided to Trula Inc.’s web designer with valuable customer feedback to assist in improving the website and user experience.
Any personally identifiable information an individual provides to Trula Inc. will be used solely by Trula Inc, its entities, and third-party agents with whom it has contracted to perform a service on its behalf.
Collection and Use of Information – Children’s Personally Identifiable Information
Except as otherwise permitted by law, Trula Inc. does not knowingly collect and use or disclose the personally identifiable information of a child under the age of 13.
Data and Security Quality
We are committed to data security and the data integrity of Personally Identifiable Information available from or collected by Trula Inc. websites. We have taken precautions to protect personally identifiable information from loss, misuse, or alteration. Any authorized third parties responsible for this information are committed to the same principles and are required by contract to follow the same policies and guidelines as Trula Inc. in protecting this information. Visitors should be aware, however, that even though protections are in place, Trula Inc. cannot guarantee against the occurrence of hardware failure, unauthorized intrusion, or other technical problems.