Privacy Statement
TrueTribe B.V. values your privacy and the protection of your personal data. This Privacy Statement describes how we handle your data and what rights you have when visiting our website (www.jointruetribe.com), using the TrueTribe App or platform, contacting us, or interacting with us in any other way.
We understand that such documents can sometimes be difficult to read, so we've tried to make this statement as brief and clear as possible. We may update this Privacy Statement from time to time. If we do, we will notify you on this website and via the app. We recommend reviewing this statement again when it's updated.
If you have any questions about this Privacy Statement or would like more information, feel free to contact us at privacy@jointruetribe.com , and we will get back to you as soon as possible.
Who are we?
TrueTribe is a digital platform of TrueTribe B.V., which helps organizations gain insight into and work on the well-being of employees, teams, and organizations, and supports employees in proactively managing and improving their own well-being.
TrueTribe B.V. is located in the Netherlands at Vivaldiplantsoen 200, 3533 JE Utrecht, registered with the Chamber of Commerce under number 61061387, and is responsible for the processing of personal data as described in this privacy statement.
Which data do we process?
TrueTribe processes personal data that you provide directly or indirectly to us. This may include the following data:
Category of personal data | Description |
|---|---|
Identity data | This includes your first and last name, email address, date of birth, location, department/team, and an employee ID (or similar identification provided by your employer if necessary). |
Profile data | Your username and password, interests, preferences, feedback, and responses to surveys. |
Marketing and communication data | Your preferences regarding receiving marketing and other communications from us. We always offer you the opportunity to unsubscribe. |
Behavioral data | Data derived or inferred from your behavior and interests based on your activity on the TrueTribe app. This information helps us understand the popularity of features and tailor your experience. |
Technical data | Internet protocol (IP) address, login details, browser type and version, timezone setting and location, browser plugins, device ID, usage data, operating system and platform, and other technologies used to access the website or our services. Technical data also includes information about your interaction with the platform, such as which links you click and how often you visit certain pages. For organizations using the Microsoft Teams integration, additional data is stored, such as: Active Directory ID, Microsoft ID, Tenant ID, Service URL, Conversation ref ID, and the encrypted email address used to log into MS Teams. |
User-generated data | Information and content that you enter yourself on our platform, such as in free text fields. |
Aggregated data | Aggregated data is information collected from multiple sources and individuals in an anonymous format. This data is used to create summaries or reports for our clients (your employer). Aggregated data is not personal data because it does not reveal your identity directly or indirectly. We apply an anonymity threshold of five or more individuals to ensure data is not traceable. |
Special categories of personal data | Special categories of personal data include health information such as well-being data and biometric data. At TrueTribe, you may choose to enter information about your mood or mental state, for example, when using the TrueTribe scans. The personal data you provide may contain health data or other special categories of personal data. This may be in the form of a free-text field or scalable responses within a questionnaire. Using these features is entirely voluntary. TrueTribe will never require you to provide special categories of personal data to use our service. If you choose to use these features, we base this on your consent and the performance of a contract with your employer. |
Why do we collect this data?
TrueTribe uses your data for the following purposes:
- (With your consent) To provide our services: Such as registration and offering personalized insights and recommendations through the TrueTribe platform.
- To improve the platform: By analyzing usage statistics and feedback.
- To provide support: Such as technical assistance or answering questions.
- To comply with legal obligations: For example, for data security and tax purposes.
- (With your consent) For research and development: In anonymized form, we use data to improve TrueTribe's offerings, develop and distribute whitepapers, conduct and publish research, and share data with health professionals and academics. If you choose to share this data with us, we may process special personal data anonymously. The legal grounds for this are your consent and our legitimate interests.
- Communication: When you download our mobile app, you can choose whether to receive push notifications. If you later change your mind, you can disable these at the device level.
We emphasize that using TrueTribe is entirely voluntary. Without your consent, we cannot use your data, and the app cannot be activated. If you are convinced of the benefits of the app, the use can only take place based on your explicit consent. For services you wish to receive within the app from companies providing specialized services, we will explicitly ask for your consent again beforehand.
How do we protect your data?
TrueTribe takes appropriate technical and organizational measures to protect your data against loss, misuse, unauthorized access, or disclosure. Examples include:
- Encryption of sensitive data.
- Secure connections via HTTPS.
- Strict access controls for employees.
Who do we share your data with?
TrueTribe does not share your data with third parties, unless it is necessary for the delivery of our services, such as:
- IT service providers who help us with hosting and securing the platform. This ensures you have a smooth, secure, and uninterrupted experience.
- Research partners, but only in fully anonymized or aggregated form.
- Legal authorities: This only occurs when we are legally required to report processing activities, for example, to comply with applicable legislation or respond to a valid legal request from law enforcement or other governmental agencies.
- Our external health and wellness partners: We only do this with your explicit consent and where necessary to ensure that users who sign up through this method can receive the proper support.
In the context of TrueTribe's services, the following parties may also be involved:
- TrueTribe B.V. as the data controller involves various (sub)processors;
- Third parties within our own health network where you, solely after your consent, can access further specialized services;
- Anonymous and aggregated (i.e., non-identifiable) data with your employer and/or occupational health services (e.g., to comply with legal obligations under the Occupational Health and Safety Act).
In all cases, we ensure that your privacy is protected through strict requirements imposed on processors through data processing agreements or other appropriate measures.
How long do we keep your data?
TrueTribe retains your personal data no longer than necessary for the purposes for which it was collected.
What are your rights?
You have the right to:
- Access the personal data we process about you.
- Correct incorrect data.
- Request the deletion of your data, unless this conflicts with legal obligations.
- Object to the processing of your data.
- Request a restriction of processing under certain conditions.
Request your data in a structured, commonly used, and machine-readable format. You can exercise these rights by contacting us using the contact details below. Any consent you provided in the app can be withdrawn in the same way.
Questions or complaints?
Do you believe the processing of your personal data is not in accordance with privacy laws? Or do you have a question or complaint regarding the GDPR and/or privacy? Contact our Data Protection Officer via privacy@jointruetribe.com. You can also file a privacy complaint with the Dutch Data Protection Authority (see:https://www.autoriteitpersoonsgegevens.nl/een-tip-of-klacht-indienen-bij-de-ap) or contact the competent court. This can only be done after you have submitted your complaint to TrueTribe B.V.
Version 01.2025 was updated on January 28, 2025. TrueTribe may modify this privacy statement and the cookie statement. Therefore, we recommend reviewing this privacy statement periodically. Changes will be communicated via the website and app.