TrueHunch

Privacy Policy

Last updated: 20 October 2026

TrueHunch Inc. (together with its subsidiaries and affiliates – “TrueHunch”, “TrueHunch.ai”, “we”, “our” or “us”) is committed to making sure that the personal data we process is kept safe and used properly, and that our data practices are clearly explained to our customers, users and prospects.

This Privacy Policy applies to our website at www.TrueHunch.ai (the “Website”), the TrueHunch conversation-intelligence platform and its related applications (the “Platform”), and our related services (together with the Website and the Platform, the “Services”). By using our Services, you acknowledge that you have read and understood this Privacy Policy. Certain processing activities rely on your consent, which you can give or withdraw at any time. Other processing is necessary to provide our Services or to comply with legal obligations.

Our Services are intended for business use by adults. Please see Section 14 for information about children’s data.

1. Our Roles: Controller and Processor

2. Data We Collect

We collect and process the following categories of personal data:

3. Location Data

When you accept our Platform Use Terms (the “Platform Terms”) and when you sign in to and use the Platform, we derive your approximate location from your IP address, for example your country, region and city (“Location Data”). We do not collect precise location such as GPS coordinates, and we do not track your movements. Location Data is personal data under the GDPR and similar laws, and we treat it accordingly.

What we record

Why we use it

Legal basis

We rely on contractual necessity (to provide the Platform and to record that you accepted the Platform Terms), legitimate interests (security, fraud prevention, legal compliance and service improvement, which we have balanced against your rights, in part because the data is approximate) and, where applicable, legal obligation. Accepting the Platform Terms is how we form the contract with you and record that you did so. It is not a request for your consent to anything beyond what this Section describes. If we ever want to use location for a purpose that requires your consent, such as precise location or location-based marketing, we will ask you separately, you will be free to refuse, and you will be able to withdraw your consent at any time.

Sharing, retention and your choices

We use a Service Provider to convert IP addresses into approximate locations, and we store Location Data in the regions described in Section 6. We keep acceptance records for as long as your account is active and afterwards for the period needed to evidence acceptance and defend legal claims. Other Location Data in activity logs is kept only as long as needed for security and diagnostics and is then deleted or aggregated, in line with Section 7. You can object to this processing or ask for access, correction or deletion by contacting privacy@TrueHunch.ai (see Section 12). A VPN or proxy may make your approximate location inaccurate. Where location is necessary for security or legal compliance, objecting may mean we cannot provide the Platform to you.

4. How We Use Personal Data and Our Legal Bases

We process personal data in accordance with applicable data protection laws, including the GDPR, for the purposes below and on the legal bases shown:

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before it. Where we process Customer Data as a processor, our customer determines the purposes and the legal basis.

5. AI Processing and Automated Decision-Making

The Platform uses artificial-intelligence models to transcribe and analyze communications and to generate insights such as intent, objections, sentiment, compliance flags, quality scores and recommended next actions. Where we use third-party AI model providers, they act as our sub-processors under written agreements that limit them to processing on our instructions. We do not use Customer Data to train AI models that are made available to other customers.

These outputs are decision-support insights for our customers. TrueHunch does not itself make decisions about individuals that produce legal or similarly significant effects. Customers decide how to use the outputs and, where outputs are used in connection with people’s employment or evaluation, they are responsible for ensuring appropriate human review and compliance with applicable law.

We may also use automated processing or profiling in limited circumstances, such as:

If we ever make a decision based solely on automated processing that produces legal or similarly significant effects on you, we will tell you, give you meaningful information about the logic involved and its significance and consequences, apply suitable safeguards, and let you request human intervention, express your point of view and contest the decision.

6. Data Location and International Transfers

We and our authorized Service Providers maintain, store and process personal data in the United States of America and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as required by law.

For transfers of personal data from the EEA and the UK to the United States or other countries that may not have an adequate level of data protection as determined by those jurisdictions, we implement appropriate safeguards, including:

7. Data Retention

We retain Customer Data strictly on our customers’ behalf, in accordance with their reasonable instructions.

We retain TrueHunch User Data and TrueHunch Website, CRM & Prospect Data for as long as is reasonably necessary:

all in accordance with our data retention policy. Except as required by applicable law or our specific agreements with you, we are not obligated to retain your personal data for any particular period, and we may securely delete it or restrict access to it at any time. If you have questions about our data retention policy, please contact us at privacy@TrueHunch.ai.

8. Data Sharing with Third Parties

We may share personal data with third parties for the following purposes:

We do not sell personal data. More information about our sub-processors is available on request and in our Trust Center.

9. Cookies and Tracking Technologies

We use cookies, pixels and similar technologies on our public website, www.TrueHunch.ai. When you first visit, a consent banner lets you choose which categories to allow. Nothing in the Analytics or Advertising categories runs until you accept it. You can change your choice at any time through the “Trust Center” link in the website footer, and we honour the Global Privacy Control browser signal as an opt-out of Analytics and Advertising. We do not use website cookies to sell personal information. The technologies we use fall into the following categories (last reviewed 20 October 2026):

If you decline Analytics or Advertising, Google services may still receive a cookieless, non-identifying signal that a page was viewed, with no cookies set and no personalisation. We review this list whenever we add or remove a service.

10. Communications

We send service-related communications necessary for the operation of our Services, and promotional communications that you can opt out of at any time.

11. Data Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including encryption, access controls and other security protocols. More detail is available in our Trust Center.

While we make efforts to protect your privacy and implement industry-standard security measures, we cannot guarantee that our Website, Platform or Services will be immune from wrongdoing, malfunctions, unlawful interception or access, or other forms of abuse and misuse.

12. Your Rights

Under the GDPR and similar data protection laws, you have the following rights regarding your personal data:

To exercise these rights, please contact us at privacy@TrueHunch.ai. We will respond to all data subject rights requests within one month. This period may be extended by up to two further months where necessary, taking into account the complexity and number of requests. If your personal data is contained in Customer Data, we may refer your request to the relevant customer, who is the controller of that data.

US state privacy rights

Residents of California and certain other US states may have the right to know and access the personal information we hold about them, to request deletion or correction, to opt out of the sale or sharing of personal information, to limit the use of sensitive personal information, and not to be discriminated against for exercising these rights. We do not sell personal information. Approximate location derived from an IP address is not precise geolocation, and we do not use it to infer characteristics about you. We honour the Global Privacy Control signal as described in Section 9. To make a request, contact us at privacy@TrueHunch.ai.

13. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

Where we act as a processor, we will notify the affected customer without undue delay so that they can meet their own obligations.

14. Children’s Data

Our Services are intended for business use by adults and are not designed to attract children. We do not knowingly collect personal data from children under the age of 16 and do not wish to do so.

If we learn that a person under the age of 16 is using the Website, Platform or Services, we will:

If you believe that we might have any data from or about a child under 16, please contact us by e-mail at privacy@TrueHunch.ai.

15. Changes to this Policy and Contact Details