Privacy Policy

1. Introduction

Truvana, LLC ("Truvana," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our human resources management platform ("Service").

This policy is designed to comply with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and the California Online Privacy Protection Act (CalOPPA).

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, job title, organization name, phone number.
• Employee Records: Employee names, positions, departments, employment dates, performance data.
• Infraction & Discipline Records: Incident descriptions, dates, witnesses, corrective actions, documentation.
• Evaluation Data: Performance ratings, competency assessments, goals, feedback.
• Student Education Records: Student names, state IDs (SSID), demographics, and disciplinary records (including suspensions, expulsions, and California EdCode 48900 violations) as provided by educational agencies.
• Uploaded Content: Documents, evidence files, and attachments you upload to the Service.

2.2 Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers.
• Usage Data: Pages visited, features used, time spent, click patterns.
• Cookies: Authentication tokens and session identifiers (see our Cookie Policy).

2.3 Information from Third Parties

We may receive information from your organization's HR systems through integrations you authorize.

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Process and manage employee records, evaluations, and disciplinary documentation
• Generate AI-assisted summaries and recommendations (with human review)
• Send administrative notifications and updates
• Respond to customer support requests
• Ensure security and prevent fraud
• Comply with legal obligations

4. AI Features & Third-Party Services

Truvana uses artificial intelligence to enhance productivity. We are transparent about these uses:

• Google Gemini: Used to generate discipline summaries and documentation suggestions. All prompts are automatically sanitized of student PII (names, IDs) before transmission.Data is processed according to Google's AI data policies and is not used to train general models.
• AssemblyAI: Used for audio transcription of meetings or hearings when enabled. Audio data is processed securely and deleted after transcription.

For more details, see our AI Ethics Statement and Sub-processor List.

5. How We Share Your Information

We do not sell your personal information. We may share information with:

• Your Organization: Authorized administrators within your organization can access data you create.
• Service Providers: Third-party vendors who assist in operating our Service (see Sub-processor List).
• Legal Requirements: When required by law, subpoena, or to protect our rights.
• Business Transfers: In connection with a merger, acquisition, or sale of assets.

6. Your California Privacy Rights

Under CCPA/CPRA, California residents have the right to:

• Know: Request disclosure of what personal information we collect, use, and share.
• Delete: Request deletion of your personal information, subject to certain exceptions.
• Correct: Request correction of inaccurate personal information.
• Opt-Out: Opt out of the sale or sharing of personal information (we do not sell data).
• Non-Discrimination: Not be discriminated against for exercising your privacy rights.

To exercise these rights, contact us at privacy@truvana.com or submit a request through your account settings.

7. "Do Not Sell or Share My Personal Information"

Truvana does not sell your personal information. We do not share your personal information for cross-context behavioral advertising. As such, we do not offer an opt-out mechanism for "sales" because no sales occur.

8. Data Security

We implement industry-standard security measures including:

• Encryption of data at rest and in transit (TLS 1.2+)
• Secure authentication with token-based access
• Regular security audits and penetration testing
• Role-based access controls

For more details, see our Security & Compliance page.

9. Data Retention

We retain your data for as long as your account is active or as needed to provide services. Employee records are retained according to your organization's policies and applicable legal requirements. Upon account termination, data is deleted within 90 days unless legal retention requirements apply.

10. Student Data Privacy (FERPA, SOPIPA, AB 1584)

FERPA: We function as a "School Official" with a legitimate educational interest in the student data we process. We do not use student education records for any purpose other than to provide the Service.

SOPIPA: We do not use student data for targeted advertising, nor do we build profiles of students for any non-educational purpose. All data remains the property of the educational agency.

AB 1584: Our agreements with LEAs include specific provisions regarding data ownership, deletion, and security as required by California law.

Children's Privacy: Truvana is designed for use by adult school officials. We do not knowingly collect personal information directly from children under 13. Student data is provided solely by the educational institution.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by posting a notice on our website or sending you an email. Your continued use of the Service after changes become effective constitutes acceptance of the updated policy.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, contact us at:

Truvana, LLC
Email: privacy@truvana.com
Address: California, USA