This Privacy Statement relates solely to the online information collection and use practices of the accessible at the address www.trustt.com (hereinafter “website”) and our Mobile Applications located at TrustT (hereinafter “Mobile Apps”), and not to any subdomains of this website and Mobile Apps.
We recognize that many visitors and users of this website and Mobile Apps are concerned about the information they provide to us, and how we treat that information. This Privacy Statement, which may be updated from time to time, has been developed to address those concerns. On that subject, you are informed, therefore hereby agree that we will collect and manage your personal data in accordance with the applicable law, as well as with the General Data Protection Regulation (hereinafter the “GDPR”).
Once you use our services; “services” meaning the Mobile App, and customer support, we collect your personal information including, but not limited to:
1. Identification Information, which includes first name, last name, date of birth, and other data on government-issued IDs.
2. Contact Information, which includes email address, phone number and mailing address.
3. Financial Information, which includes information related to your bank accounts and debit / credit card details.
4. Device Information, which includes device type, device’s identification number, language, time zone, geolocation information, device’s operating system, permissions (contacts, camera, storage, notifications), and IP address
All these types of personal information collected serve to know your identity, background, and your financial standing to comply with the KYC / AML regulations expected from the identity verification service provided by our third-party. You bear the responsibility of providing personal information that is true, accurate and updated. If there are any changes or modification regarding your personal data, you must notify us and send us the most recent and updated information by e-mail at email@example.com.
Your personal information will be obtained from yourself and from different sources including but not limited to:
1. Through your information provided during the application process, surveys, customer support, and once using our services.
2. Through information provided during your verbal communication with TrustT customer support and your written emails.
3. From third parties and from other sources such as employers, and information providers agencies.
Additional Documents for verification process:
TrustT is allowed to request additional documents including but not limited to additional forms of governmental issued identification, utility bills, and bank statements from the user during the verification process in order to confirm that you comply with the KYC / AML regulations enforced by our third-party. If any alerts arise from the identity verification third-party, informing suspicious details and fraud activities, TrustT reserves the right to block your account, transactions and hold your personal information until this matter has been resolved.
Individuals interested in applying for our services are required to provide 2 picture IDs (Passport, Driver License, valid government issued ID, etc.) and a proof of address. The documentation request will vary from one user to another.
If the user meets the registration requirements, we will collect usage information including but not limited to how you use our services, your interactions with other users, information about your account transactions, and people with whom you connect for fraud prevention and other similar purposes.
Data storage period:
The documents collected, and the personal information collected by TrustT will be all stored together for the duration of the business relationship or up to five (5) years after contract termination. This time frame is subject to be changed accordingly with the Anti Money Laundering Act.
Cookies are text files, often encrypted, which are downloaded to your used device automatically and stored within its hard drive. Cookies are used to recognize you as a user, for statistical purposes as well as improve our website, provide a better service and product, and learn about our users’ preferences.
We use different types of cookies and based on their purpose, cookies can be:
1. Technical cookies, which are essential for the usage of the website and navigation. Disabling them may limit you from some of the website’s features.
2. Preference cookies, which store and recognize user’s preferred language, font size, preferred country, and website preferences.
3. Security cookies, which protect the user and website from network attackers and hackers.
4. Analysis cookies, which measures how users interact with the website content.
5. Advertising cookies, which gather information in relation to the user’s activity across the website and the frequency of the user’s interaction with advertisement so the ads are more relevant to the user.
Cookies can be blocked or disabled via your browser settings. As a reminder, by configurating your browser to reject all cookies may obstruct the normal functioning of certain services within our website.
In TrustT your data will be handled based on your consent when you accept our terms and conditions, and we are determined to protect your rights.
The right to access, where you have the right to be informed of the way we use your personal information and to request access to the personal data we hold about you.
The right of rectification, when if the information TrustT holds about you is incomplete or incorrect, you have the right to update and change your personal information.
The right to erasure, the right to request that TrustT deletes all your personal data.
The right to restrict, when you have the right to request that TrustT temporarily or permanently stops processing all or part of your personal data, with the exception the data must be considered for legal reasons.
The right to object, which is the right to object to your personal information to be processed for marketing and statistical purposes.
The right to data portability, the right to request a copy of your personal information to be transmitted to another service provider or third-party.
In order to enable you to exercise all your rights, you can contact our privacy team by sending us an email at firstname.lastname@example.org . Our privacy team will provide you with any needed information related to the processing of your personal data.
We use non-identifying information collected on our website in the aggregate to better understand your use of the website and to enhance your enjoyment and experience. For example, we may use the information to improve the design and content of our website or to analyze the programs and services that we offer. We may employ other companies and individuals to perform functions on our behalf. Our employees, agents and contractors who have access to personally identifiable information are required to protect the information in a manner that is consistent with this Privacy Statement.
We use your personally identifiable information to certify the registration process and adhere to the KYC obligations our third-party requires; once it has been approved it will also be used to provide you with the information or content that you have requested and deliver our services to you. In some cases, we will contact you about our programs, suggestions and recommendation, updates on our products, features or services. If you no longer wish to receive press releases or any other type of information from us, you may send us an email through our “Contact Us” link or use our E-mail Alert form to change your preferences.
All data collected by TrustT is solely used to verify the identity of its users and ensure high standards of KYC/AML regulations within its network. TrustT will be processing your personal data as described below:
1. To process any service provided by TrustT and/or business partners.
2. To notify you about any changes related to our terms and conditions, policies, products/services features, and your TrustT account updates.
3. To follow up with our users regarding any enquiry received to our customer support through phone calls, emails, and online request.
4. To be processed by our third parties / agencies / TrustT’s various departments and units for strategic, selling, marketing, advertisement, and budgeting purposes.
5. To respond to regulatory requirements and law enforcements.
6. To collect our debts and enforce our rights and obligations.
7. To improve our services and products.
8. To look and report any suspicious activities and transactions.
9. For legal purposes.
10. To protect TrustT’s interests, rights, and purposes.
To process TrustT payments and fulfill the KYC/AML verification process, we need to share some of your personal information with TrustT’s third parties. Your contact information, payment methods’ details, historical transactions and other verification metrics may be provided to third parties once the transaction has been concluded, or through TrustT.
We will not share your personally identifiable information in ways unrelated to those described above without providing you with an opportunity to opt out of such use or otherwise prohibit such unrelated uses. Also, we will handle your personal data to assure security, contend harmful behaviors and avoid breach of our Terms and Conditions or other policies.
We treat your personal information in accordance to the consent you give us when the Mobile App is downloaded and in execution of the Terms and Conditions that regulate our appropriate compliance with our legal obligations.
We may provide access to your personally identifiable information when its legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorized use of our website, to limit our legal liability and protect our rights, or to protect the rights and safety of visitors of this website or the public. In those instances, the information is provided only for that limited purpose.
Before engaging in any business relationship with any third parties / agencies / service providers, TrustT is determined to keep your personal information safe, so we will ensure that your personal information will be treated with strict measures of privacy, security, and confidentiality. Also, your personal data will not be used for commercial purposes between TrustT and any third parties, agencies or service providers. We will not engage in selling or leasing your personal information to third parties for their use in marketing and promotional activities.
Your personal information may be disclosed, disseminated, and transferred to:
1. Business units and departments within TrustT network.
2. Licensees, business partners, third parties, agencies, and service providers.
3. Professionals including but not limited to, lawyers, consultants, advisors, bankers, debt-collectors, and brokers in order to receive needed advice and expertise.
4. Agent, business representatives, contractors acting on our behalf.
5. Regulators, federal agencies, investigators, law enforcement or revenue authorities.
6. With your consent
In such circumstances we may permit access to certain aspects of your personal information or provided documentations, but only once they have agreed to treat data with the strictest levels of security and confidentiality.
Also, this website is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our website, participating in any of our services and / or providing us with your information, you consent to this transfer.
The services provided by TrustT are not aimed to persons of underage, we don’t knowingly collect personal information from anyone under the age of 18. If you think we might have personal data from an underage person, please contact us through e-mail at email@example.com.
If you engage with our Mobile App and you provide us with personally identifiable information, you may modify, update or delete such information at any time within the features of the Mobile App, you will have the opportunity to access and revise certain personally identifiable information that you have provided, and to update your preferences regarding what information you want to receive from us, or you can also click on our “Contact Us” link and send us an e-mail. You should be aware, however, that it is not always possible to completely remove or modify information from our database. In addition, please be aware that your ability to opt out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website.
TrustT will keep your personal data as long as necessary to provide you with our services, fulfill our business purposes, maintain high performance level, take data-driven business decisions related to our services and products, and comply with our KYC/ AML obligations and legal obligations. TrustT will hold all your personal information or some as long as you are in a relationship with TrustT. Upon your request, TrustT will delete or anonymize all your personal data, unless one of the following situations applies:
1. If there is an unresolved issue related to your account such as unpaid credit or debt, and / or unresolved claim or dispute, we are legally allowed to maintain your personal information until resolution stage.
2. If we are required to retain your personal information for any legal, tax, audit, and accounting purposes.
TrustT will retain your personal information in compliance with this Privacy Notice as well as the Terms and Conditions Agreement for the time necessary, for the protection of TrustT’s interest and of its users and business partners.
When you decide to apply for our services and become an active user, you automatically agree to provide us with personal information under circumstances and conditions previously described. You expressly give us consent to collect your personal data in accordance with this Privacy Notice and applicable legislation.
We take reasonable steps to maintain the security of the personally identifiable information that we collect, including limiting the number of people who have physical access to our database servers, as well as installing electronic security systems that guard against unauthorized access. However, no data transmission over the Internet can be 100% guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security of any information that you transmit to us, so you do so at your own risk.
The security of your personal information is our priority. TrustT protects your personal information in a secure manner by taking reasonable measures in maintaining physical, electronic and procedural safeguards, in compliance with applicable regulations.
Data that is provided to us is stored on secured servers managed, controlled and exclusively accessed by us. Details relating to any transactions entered on our TrustT services will be encrypted to ensure its safety. TrustT incorporates authentication and authorization mechanisms that require users to prove their identities and limit their data access.
TrustT’s third party will ensure to TrustT users a better detection and prevention of fraud with the integration of the advanced machine learning tools utilized by our payment processing third-party, who is a certified PCI Service Provider. To remain Payment Card Industry Data Security Standards (PCI-DSS) compliant, TrustT will transmit all sensitive data directly to the payment processing third-party, without passing through its servers. Trust is responsible for the transmit of personal data required by our identity verification third-party for the verification of our users. Additionally, TrustT performs the process of data transmission by using TLS and HTTPS to encrypt and verify the integrity of traffic between the users’ servers and ours.
We are committed to keep your TrustT account safe. We implement appropriate technical and organizational measures including but not limited to web application firewall, keys protected on a vault, and Auth 2.0 as authentication and authorization mechanism to help protect your web access and mobile TrustT account; however, please note that no system is ever completely secure. Additionally, we have implemented various policies such as, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.
You acknowledge and accept that during your logged-in session all the data transferred between TrustT and its users, are passed across the internet using the https protocol which is not completely guaranteed and secure, therefore we are unable to guarantee the security of data transfer and reception electronically; that’s why it remains entirely at your own risk.
You are solely responsible to ensure the reliability of your email address and its high security and confidentiality levels.
Your personal and financial data held by TrustT are protected from unauthorized access by a password which you are solely responsible to keep it confidential.
Your password protects your user account, so we encourage you to use a unique and strong password, modify your password from time to time, limit access to your computer and browser, and log out after having used the TrustT Mobile App and website.
We will notify you in advance by sending you a prominent notice by email.
Thank you for being part of our Network! If you have any questions or comments about this policy, please feel free to contact our privacy team through email firstname.lastname@example.org. We are here to assist you and provide you with our services within a strictly protected confidential environment.