Surf Privacy Policy

Last Update: September 1, 2021

SURF PRIVACY POLICY

Trufan Inc. (“Trufan”, “we”, or “us”) values and respects your privacy. We have prepared this privacy policy to explain the way we collect, use, and disclose personal information when you access or use our website located at joinsurf.com, browser extension and application (the Surf Extension).

TABLE OF CONTENTS
- Collection and Use of Personal Information
- Sharing of Personal Information
- Your Choices
- Access to Information
- Safeguards and Retention
- Updates to The Privacy Policy
- Contact Us

HOW DOES SURF WORK?
The Surf Extension is a free browser extension that rewards you for browsing the Internet. By using Surf while you browse the Internet, you can earn points that can be redeemed for various rewards. We also provide you with other opportunities to earn points, such as by providing us with information about yourself or referring your friends. We collect your internet browsing activity (including the URLs and timestamps for all web pages you visit) and analyze this information along with other information you provide to better understand your interests and provide you with tailored offers and rewards on Surf. We also share information on an aggregated and de-identified basis with our clients so that they can better understand consumer interests and behaviors and provide more relevant offers and advertising.

We want to ensure you understand how we collect, use, and disclose your personal information and what options you have with respect to the data we collect through Surf. Please review our Privacy Policy and let us know if you have any questions by contacting us at the contact information below.

If you are using a shared computer or device to use Surf, please ensure you have permission from all other users for Surf to collect browsing information or log out of Surf each time you are not using the device.

COLLECTION AND USE OF PERSONAL INFORMATION
We may collect personal information when you:
- Create an Account and/or Profile
- Use the Surf Extension
- Redeem Rewards
- Put a Reward on your Wishlist
- Receive Offers and Communications
- Refer Friends
- Provide Feedback
- Contact Us

Create an Account:
To use the Surf Extension, you will need to create an account and provide your name, month and year of birth, gender identity (optional), and a password that you create. We use this information to create and administer your online account. We use date of birth and gender identity (if provided) to help us analyze your data and provide more relevant information to our clients. We will also collect your phone number to send you a one-time verification code to verify that you are the person who created the account. If you sign in using your social account (such as Facebook or Google), we will collect your login credentials and request permission to access and collect your name, email address and age to create and administer your Surf account.

Complete your Profile:
From time to time, we may provide you with an opportunity to provide us with additional information about yourself on an optional basis in exchange for points. For example, you can tell us your favorite brands and where you live. We use this information to better understand and analyze your information, and to provide you with more relevant offers and rewards within Surf. You can edit or update this information at any time through the Settings page on the Surf Extension (please note: if you change your location more than once in a short time span, you will need to go through support to change it again).

Using the Surf Extension: When you browse the Internet while logged into to your account on the Surf Extension, we will collect information such as the URLs/timestamps of the pages that you visit as well as information about your device such as browser type and operating system. For example,

Your browsing data is maintained for 30 days. You have the opportunity to delete any information you share with us within 24 hours. When we share your browsing data with clients, we de-identify it so that it is no longer associated with your name or other contact information. Your data will be bundled into cohorts (based around age, location, gender, etc).

Rewards/Wishlist:
We will maintain a history of the rewards you have redeemed. You can view which rewards you’ve redeemed in your Transactions History. You can also create or edit a wish list to remember rewards that you are interested in.

Receive Offers and Communications:
Surf may send you marketing communications or notifications by email and within the Surf Extension including communications regarding eligibility for rewards, new rewards and giveaways, product announcements and other information. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving marketing communications by going to your Settings and toggling notifications off. Please note that you may continue to receive transactional or account-related communications from us. For further information on how to adjust your preferences, please see “Your Choices” below.

Refer-a-Friend:
We may provide you with the opportunity to refer your friends to Surf in exchange for rewards. If you choose to participate, we will collect your friend’s name and email address. We will provide you with a referral code to share through email, social media, or other channels, or you can choose to send an email to your friends through Surf (in which case we will send your friend a single email on your behalf with information). We will notify you you’re your referral joins the platform, and you will be able to see their status in your referral’s portal. We do not use the names or email addresses submitted in these circumstances for any other purpose without consent to do so. You are responsible for ensuring that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the referral email message. To learn more, see our Refer-a-Friend Terms and Conditions.

Contact Us:
When you contact us with a comment, question or complaint or provide feedback about Surf, you may be asked for information that identifies you, such as your name, email address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future, to follow-up with updates or questions regarding your feedback, and to improve our customer service and products.

SHARING OF PERSONAL INFORMATION
We may share your personal information with third parties as set out below.

Brand Partners:
We also share information on an aggregated and de-identified with our partner brands so that they can better understand consumer interests and behaviors and provide more relevant offers and advertising. We may be compensated for sharing your data. Our brand partners do not and will never have access to any of your personal information.

Service Providers:
Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as hosting or storing data, sending communications, and providing advertising and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be in the U.S. and Canada.

Legal and Compliance:
The are certain circumstances where we may be required or permitted to disclose personal information under applicable laws. We and our Canadian, U.S. and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Trufan and Surf or as part of a corporate reorganization or other change in corporate control.

YOUR CHOICES
We want to provide you with control over the information we collect. We have set out below choices you have with respect to your personal information.

Browsing Data:

Communications:
Through the Settings Page in the Surf Extension, you can:

ACCESS TO INFORMATION
Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody or control.

You can browse your activity history over the past 30 days through the Activity History page on the Surf Extension. You can also download this data through the Settings Page on the Surf Extension.

You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

You can also see your activity history and download all your data on our Web App, as described in the ‘Your Choices’ section above.

SAFEGUARDS AND RETENTION
We have implemented reasonable administrative, technical, and physical measures to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification, and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.

We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.

UPDATES TO THE PRIVACY POLICY
We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.

CONTACT US
If you have any questions or comments about this privacy policy or the way we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to our collection of your personal information, please contact us at:

Swarochish Goswami (CEO & Co-Founder, Trufan)

1 (888) 605-0550 (Trufan toll-free)

[email protected]