Privacy Policy

Truggl, LLC (“Truggl,” “we,” “us,” or “our”) is a Delaware limited liability company located at 131 Continental Dr, Suite 305, Newark, DE 19713, USA. We are the controller of the personal data described in this policy, which means we decide how and why it is used.

Our team works from Tunisia and Indonesia, where team members are employed through local entities, and some contractors work from other countries. Everyone who handles personal data for Truggl does so under our instructions and a duty of confidentiality.

This policy covers our website, the messages you send us, the outreach we send you, payments made to us, and applications to join the team.

It does not cover the work we do inside a client engagement. Once a company becomes a client, the signed agreement between us governs how information shared during the engagement is handled. If you join Truggl, your employment information is handled under a separate notice from your employing entity.

We collect personal data in the situations below, and in each case only what we need for the purpose described.

3.1 When you visit our website

When you browse our site, we and our analytics providers collect information about your visit. This includes your IP address and approximate location, your device and browser, the pages you view, how you move between them, what you click, and how long you stay. It also includes the website, search, or campaign that brought you here.

We may use tools that identify the organization a visit comes from, based on information such as your IP address, and in some cases the business contact details associated with it. If you have been in touch with us before, we may connect your visits to the record we already hold about you.

We use this information to understand how the site is used, improve it, measure our marketing, and recognize interest from companies we work with or would like to. Where the law requires your consent for these technologies, we use them only after you have given it. Section 5 explains them in more detail.

3.2 When you contact us

When you submit a form on our site or email us, we collect the details you share, such as your name, work email, company, role, and message. We store them in our CRM, Attio, and use them to reply, continue the conversation, and keep a record of our relationship.

3.3 When we reach out to you

We contact people at companies we believe would benefit from working with Truggl. For this, we collect business contact details, such as your name, job title, company, work email, and professional profile, along with information about your company.

These details come from publicly available professional sources, including company websites, professional networking platforms, the press, and public web search. They can also come from introductions by people who know you, or from our own professional network. We keep them in our CRM, together with notes about our conversations and relationship.

We may use software, including AI tools, to research companies and decide who to contact first. These tools help us prioritize, and they never make decisions with legal or similarly significant effects on you.

You can ask us to stop contacting you at any time, and we will. We then keep a minimal record of the request, usually your email address and its date, so you are not contacted again.

3.4 When you apply to join the team

When you apply for a role, we collect the information you provide. This includes your name, contact details and phone number, location, CV, portfolio, professional profile, salary expectations, and any test project you complete.

Your application is seen only by the people hiring for the role: our HR and Finance Lead, the hiring manager, and our Executive Director. We may use software, including AI tools, to organize applications, but a person reviews every application and makes every hiring decision. Work you submit for a test project is used only to evaluate your application.

3.5 When you appear on our website

Our site features testimonials, members of our team, and work we have made for clients. Testimonials are published with the approval of the people who gave them, who know they appear on our website. Team members have approved the use of their names, photos, and words.

If you appear on our site, or believe content of yours is used without permission, you can ask us to remove it. This applies to any content on the site, including material that originated elsewhere. Section 13 explains how to reach us.

3.6 When you pay us

Payments are processed by Stripe. We accept cards issued in the US and internationally, ACH bank payments, SEPA Direct Debit, and, in specific cases, wire transfers.

Card and bank details entered through Stripe go directly to Stripe and are never stored by Truggl. We receive limited information, such as the payment method type, its last four digits, the billing contact, and the payment status. For wire transfers, we receive the details your bank includes with the payment. We use this information to process payments, issue invoices, and meet our tax and accounting obligations.

Where data protection law requires a legal basis for using personal data, we rely on the following:

• Legitimate interests: operating and improving our website, understanding how it is used, business-to-business outreach, and keeping our systems secure, where your interests and rights do not override ours.
• Consent: cookies and similar technologies that are not strictly necessary, where the law requires consent. You can withdraw it at any time.
• Contract: handling job applications, which are steps taken before a possible contract, and processing payments.
• Legal obligation: keeping financial records and responding to lawful requests from authorities.

Cookies are small files stored on your device when you visit a website. We and our providers use cookies and similar technologies, such as pixels and scripts, for the purposes below.

• Strictly necessary: keep the site working and secure. These cannot be switched off.
• Analytics: show how visitors use the site, including the pages they view, how they move between them, and how they arrived.
• Visitor identification: recognize the organization a visit comes from, and connect visits to contacts we already know.

Where the law requires consent, non-essential cookies run only after you agree, and you can change your choice at any time through the cookie settings on our site. You can also block or delete cookies in your browser settings, although parts of the site may then not work as intended.

We do not sell or rent personal data. We share it only where we need to run our business:

• Service providers that host our website, provide analytics and visitor identification, run our CRM, handle email and communication, process payments, and supply research and AI tools. Most act only on our instructions. Where a provider acts as an independent controller, its own privacy policy applies.
• Our local entities in Tunisia and Indonesia, whose team members help run our business.
• Professional advisers, such as lawyers and accountants, who are bound by confidentiality.
• Authorities, where the law requires us to share information.
• A buyer or successor, if Truggl is involved in a merger, acquisition, or sale of assets, who may use your data only as this policy describes.

Our site also links to services we do not control, including AI assistants through our “Ask AI” links. When you use them, their own privacy policies apply.

Truggl is based in the United States, our team works from Tunisia, Indonesia, and other countries, and our service providers operate in several countries. Your personal data may therefore be transferred to, stored in, or accessed from countries whose data protection laws differ from those where you live.

When we transfer personal data from the European Economic Area or the United Kingdom, we use recognized safeguards, such as the European Commission’s standard contractual clauses and their UK equivalent, or another lawful transfer mechanism. You can contact us for more information about these safeguards.

We keep personal data only for as long as we need it for the purposes in this policy:

• Website analytics: up to 24 months, or longer in anonymous, aggregated form.
• Messages and inquiries: while the conversation is active, then up to 24 months after our last contact.
• Outreach records: up to 24 months after our last contact.
• Requests to stop contact: for as long as needed to honor the request.
• Job applications: up to 12 months after the hiring process ends, unless you ask us to keep it on file longer or delete it sooner.
• Testimonials and featured content: while published, or until you ask us to remove it.
• Payment records: as long as tax and accounting law requires, usually up to seven years.

We may keep some data longer where the law requires it, or to establish, exercise, or defend legal claims.

We protect personal data with access controls, strong authentication, and confidentiality obligations for everyone who handles it, including contractors. Access is limited to the people who need it for their work. No system is completely secure, but if a breach affects your personal data, we will notify you and the relevant authorities where the law requires.

Depending on where you live, you may have the right to:

• Access the personal data we hold about you and receive a copy.
• Correct data that is inaccurate or incomplete.
• Delete data we no longer have a good reason to keep.
• Restrict how we use your data in certain circumstances.
• Object to our use of your data based on legitimate interests, including profiling. You can object to direct marketing at any time, and we will stop.
• Receive the data you gave us in a portable format, or have it sent to someone else.
• Withdraw consent at any time, where we rely on it, without affecting anything done before.

To exercise these rights, email contact@truggl.com. We will respond within 30 days, free of charge, and may first ask you to confirm your identity.

If you are unhappy with how we handle your data, you can complain to your local data protection authority, such as your national regulator in the EU or the Information Commissioner’s Office in the UK. We would appreciate the chance to resolve your concern first.

Our website and services are intended for businesses and are not directed at anyone under 18. We do not knowingly collect personal data from anyone under 18, and if we learn that we have, we will delete it.

We may update this policy as our website, tools, or legal obligations change. The date at the top shows when it last changed, and significant changes will be made clear on this page.

For questions about this policy, or to exercise your rights, email contact@truggl.com or write to Truggl, LLC, 131 Continental Dr, Suite 305, Newark, DE 19713, USA.