Privacy Policy

NWCNE LLC, doing business as TrueCycle Recovery Systems (“TrueCycle,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit https://true-cycle.com or submit information through the website (collectively, the “Site”).

By using the Site or submitting information through it, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

We may collect the following categories of information:

A. Information You Provide

When you complete a recovery assessment, contact form, or otherwise communicate with TrueCycle, you may provide:

• Name
• Company name
• Job title
• Business email address
• Telephone number
• Industry
• Number or location of facilities
• Material streams and estimated volumes
• Current disposition or recovery processes
• Operational challenges
• Reporting or documentation requirements
• Desired project timing
• Other information included in your inquiry

Please do not submit Social Security numbers, financial-account credentials, patient information, protected health information, medical records, or other highly sensitive personal information through the Site.

B. Information Collected Automatically

When you visit the Site, basic analytics and technical information may be collected automatically, including:

• Internet Protocol address
• Browser and device type
• Operating system
• Referring website or source
• Pages viewed
• Date and time of access
• General or approximate geographic area
• Site interactions and technical performance information

TrueCycle uses this information to understand Site usage, maintain security, diagnose technical issues, and improve website performance. The Site is not intended to use behavioral advertising, cross-site tracking, or targeted advertising technologies.

2. How We Use Information

TrueCycle may use information collected through the Site to:

• Respond to inquiries and recovery-assessment submissions
• Evaluate requested services or potential business opportunities
• Communicate about an active or prospective business matter initiated by the individual
• Understand materials, locations, operational requirements, and reporting needs
• Prepare for discovery conversations, site evaluations, pilot designs, or program proposals
• Administer existing client, vendor, or business relationships
• Operate, maintain, secure, and improve the Site
• Analyze general website traffic and performance
• Detect or prevent fraud, abuse, security threats, or unlawful activity
• Comply with legal obligations
• Establish, exercise, or defend legal claims
• Protect TrueCycle, Site visitors, clients, business partners, and others

3. Communications

TrueCycle does not use personal information collected through the Site to send promotional marketing emails. We may communicate with individuals to respond to an inquiry, evaluate requested services, follow up on an active or prospective business matter initiated by the individual, administer an existing business relationship, address security matters, or provide legal notices.

Submission of a recovery assessment or contact form does not enroll the individual in a newsletter, promotional mailing list, or automated marketing campaign.

4. Cookies and Basic Analytics

The Site may use cookies, local storage, or similar technologies that are reasonably necessary to:

• Enable website functionality
• Maintain security
• Remember basic preferences
• Measure general traffic and usage
• Diagnose performance or technical problems

TrueCycle may use a website hosting provider or basic analytics provider to process this information on TrueCycle’s behalf.

You may control or delete cookies through your browser settings. Disabling certain technologies may affect portions of the Site.

Because there is no universally accepted standard for browser-based “Do Not Track” signals, the Site may not respond to those signals. TrueCycle does not use information collected through the Site for targeted advertising or cross-context behavioral advertising.

5. How We Disclose Information

TrueCycle may disclose information in the following circumstances:

A. Service Providers

We may provide information to vendors that perform services on our behalf, including website hosting, form processing, email delivery, analytics, security, technical support, and data storage. These providers may use the information only as reasonably necessary to perform services for TrueCycle or as otherwise permitted by law.

B. Legal and Safety Requirements

We may disclose information when reasonably necessary to:

• Comply with applicable law, regulation, subpoena, court order, or legal process
• Respond to lawful requests from public authorities
• Investigate suspected fraud, security incidents, or unlawful activity
• Protect the rights, property, security, or safety of TrueCycle or others
• Establish, exercise, or defend legal claims

C. Business Transactions

Information may be disclosed or transferred in connection with a proposed or completed merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar business transaction, subject to applicable legal requirements.

D. At Your Direction

We may disclose information when you request or authorize us to do so.

6. Sale of Personal Information and Targeted Advertising

TrueCycle does not sell personal information collected through the Site for monetary consideration.

TrueCycle does not use personal information collected through the Site for targeted advertising or cross-context behavioral advertising.

TrueCycle does not disclose personal information to third parties for their independent promotional marketing purposes.

7. Data Retention

TrueCycle retains personal information for as long as reasonably necessary to:

• Respond to and administer an inquiry
• Evaluate or manage a prospective or existing business relationship
• Maintain business and operational records
• Meet legal, accounting, reporting, or compliance requirements
• Resolve disputes
• Enforce agreements
• Protect the security and integrity of the Site

Retention periods may vary depending on the nature of the information, the reason it was collected, and applicable legal requirements. Information may be deleted or de-identified when it is no longer reasonably necessary for these purposes.

8. Data Security

TrueCycle uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

No website, electronic transmission, or storage system can be guaranteed to be completely secure. Accordingly, TrueCycle cannot guarantee the absolute security of information transmitted through or stored in connection with the Site.

9. Your Privacy Choices and Rights

Depending on your state of residence and applicable law, you may have the right to request that TrueCycle:

• Confirm whether we process your personal information
• Provide access to certain personal information
• Delete personal information you provided
• Provide a portable copy of certain personal information
• Correct inaccurate personal information where required by applicable law
• Identify categories of information disclosed and categories of recipients
• Honor applicable rights concerning the sale of personal information or targeted advertising

TrueCycle does not sell personal information collected through the Site or use it for targeted advertising.

To submit a privacy request, email admin@true-cycle.com with the subject line “Privacy Request.” Please describe the request and provide sufficient information for TrueCycle to reasonably verify your identity and locate the relevant information.

TrueCycle may request additional information when reasonably necessary to authenticate a request. We will respond within the period required by applicable law.

If TrueCycle denies an applicable privacy request, you may submit an appeal by emailing admin@true-cycle.com with the subject line “Privacy Appeal” and explaining the basis for the appeal. TrueCycle will process the appeal as required by applicable law.

TrueCycle will not unlawfully discriminate against an individual for exercising an applicable privacy right.

10. Children’s Privacy

The Site is designed for businesses and business professionals and is not directed to children under 13 years of age.

TrueCycle does not knowingly collect personal information from children under 13 through the Site. If we learn that such information has been submitted, we will take reasonable steps to delete it. A parent or legal guardian who believes a child has provided personal information may contact admin@true-cycle.com.

11. Third-Party Websites and Services

The Site may contain links to third-party websites or services. TrueCycle does not control and is not responsible for the privacy, security, content, or practices of those third parties.

Visitors should review the privacy notices of third-party websites before providing information to them.

12. Geographic Scope

TrueCycle operates from the United States, and information submitted through the Site may be processed and stored in the United States.

If you access the Site from another jurisdiction, you understand that its privacy and data-protection laws may differ from those in your jurisdiction.

13. Changes to This Privacy Policy

TrueCycle may update this Privacy Policy periodically to reflect changes in the Site, business practices, technology, or legal requirements.

When the policy is updated, the revised version will be posted on this page and the “Last Updated” date will be changed. Material changes will be communicated through the Site or by other appropriate means when required by law.

14. Contact Us

For questions about this Privacy Policy or TrueCycle’s privacy practices, or to submit a privacy request or appeal, contact: