Privacy Policy

Last updated October 13, 2023

Introduction

TrustGenius LTD, herein referred to as “the Company,” “we,” “us,” or “our,” is steadfast in its commitment to respect and protect the privacy and confidentiality of the personal information, herein referred to as “Personal Data,” that you, herein referred to as “User,” “you,” or “your,” divulge or otherwise share with us. This Privacy Policy, herein referred to as the “Policy,” delineates the nature of Personal Data that we may collect, the modalities through which we process, store, and utilize such data, as well as the options and rights that you possess in relation to our collection, use, and disclosure of your Personal Data.

This Policy is applicable to all interactions you may have with TrustGenius’ website, software applications, and any other services offered by TrustGenius, collectively known as the “Services.”

Article 1: Collection of Personal Data

Section 1.1: Personal Identifiable Information

The Company may collect and process personally identifiable information (“Personal Data”), which could include but is not limited to your name, electronic mail address (email), contact numbers, and any other ancillary information you willingly provide during the processes of account creation, subscription to the Services, or any direct correspondence with us.

Section 1.2: Usage Data and Technical Information

The Company also reserves the right to collect information regarding the manner in which you access and utilize the Services (“Usage Data”). This could encompass data such as your computer’s Internet Protocol address (IP address), browser type, browser version, the specifics of the Services you use, the time and date of your access, the time expended on those pages, and other diagnostic information that aids in enhancing service quality.

Section 1.3: Financial Transaction Data

While the Company employs third-party financial transaction processors like Stripe for handling payments, we may acquire a limited set of payment-related data for verification and record-keeping purposes. Such information may include, but is not limited to, the last four digits of your credit/debit card and the card’s expiration date.

Article 2: Utilization of Collected Data

Section 2.1: Provision and Maintenance of Services

The Company employs your Personal Data and Usage Data to facilitate the provision of Services you have requested or subscribed to. This encompasses ensuring the continued functionality and improvement of our Services.

Section 2.2: Communication Regarding Account and Subscription

We may use your Personal Data, specifically your contact information such as email and phone number, to communicate with you about matters pertaining to your account or subscription, including but not limited to, account verification, purchase and billing confirmations and reminders, changes or updates to features of the Services, and technical and security notices.

Section 2.3: Customer Support Services

Your Personal Data may be utilized to respond to your queries, troubleshoot issues, and provide other customer support services as deemed necessary for the effective management of your relationship with the Company.

Section 2.4: Legal Compliance and Dispute Resolution

We reserve the right to use the collected data, both Personal and Usage Data, to comply with applicable laws, regulations, legal processes, or governmental requests. Furthermore, such data may be used to protect the safety, rights, or property of the Company, the users of our Services, or any third party, and also to detect, prevent, or otherwise address fraud, security or technical issues as well as operational imperatives and policy enforcement, including the resolution of disputes and enforcement of our contracts.

Article 3: Disclosure and Sharing of Collected Data

Section 3.1: Prohibition Against Selling, Trading, or Renting Personal Data

The Company explicitly affirms that it does not engage in the selling, trading, or renting of your Personal Data to third-party entities for their promotional purposes or otherwise.

Section 3.2: Prohibition Against Sharing Mobile Information

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Section 3.3: Sharing with Trusted Third Parties

Notwithstanding Section 3.1, we may share your Personal Data with third-party service providers, agents, or contractors (“Trusted Third Parties”) to assist in the provision, maintenance, and analysis of our Services. These Trusted Third Parties are contractually obligated to adhere to confidentiality provisions and to comply with this Privacy Policy, as well as applicable laws and regulations concerning data protection and privacy.

Article 4: Security Measures for Data Protection

Section 4.1: Implementation of Security Protocols

We employ a variety of industry-standard security measures aimed at safeguarding your Personal Data. These measures may include, but are not limited to, encryption, firewalls, and secure socket layer (SSL) technology.

Section 4.2: Limitation of Security Guarantees

Despite the robust security protocols in place, we must acknowledge that no electronic storage method or data transmission over the internet is 100% secure. Consequently, while we strive to use commercially acceptable means to protect your Personal Data, we cannot provide absolute guarantees concerning the impermeability of such data to unauthorized access, acquisition, or disclosure.

Article 5: Use of Cookies and Similar Technologies

Section 5.1: Implementation and Purpose

The Company utilizes cookies and similar tracking technologies, such as pixels and web beacons (“Cookies”), to facilitate site navigation, personalize your experience, analyze usage of our Services, and deliver targeted advertisements where applicable.

Section 5.2: User Options for Cookies

You retain the right to disable the usage of Cookies via your browser settings. However, you acknowledge that disabling Cookies may render certain functionalities of our Services inoperative or less efficient.

Article 6: Amendments to This Privacy Policy

Section 6.1: Reservation of Rights

We expressly reserve the right, at our sole discretion, to modify or replace this Privacy Policy at any given time.

Section 6.2: Notification of Changes

Any modifications to this Privacy Policy will be duly updated on this page, accompanied by an amendment to the “Last Updated” date stated herein. Your continued usage of the Services post-amendment signifies your acknowledgment and acceptance of the revised Privacy Policy.

Article 7: Contact Information

Section 7.1: Queries Regarding the Privacy Policy

Should you have any inquiries, concerns, or require clarification regarding any aspect of this Privacy Policy, you may contact us at:

TrustGenius LTD

7 Coronation Road, Dephna House, LAUNCHESE, London, NW10 7PQ, UNITED KINGDOM

compliance@trustgenius.io

UK: +442035764097

Article 8: Compliance with General Data Protection Regulation (GDPR) for Users Resident in the European Economic Area (EEA) and the United Kingdom

Section 8.1: Legal Basis for the Processing of Personal Data Under GDPR

For Users who are residents of the European Union (EU), the European Economic Area (EEA), or the United Kingdom (UK), the Company conducts the processing of Personal Data in strict compliance with the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”). The legal basis for such processing activities are as follows:
  1. Consent: The Company may process your Personal Data if you have freely provided your explicit and informed consent for specific and documented purposes, which may be revoked at any time in accordance with GDPR provisions.
  2. Contractual Necessity: The Company may process your Personal Data when it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract.
  3. Legitimate Interests: The Company may process your Personal Data based on legitimate business interests, provided that such interests are not overridden by your rights and interests. Legitimate business interests include but are not limited to fraud prevention, ensuring network and information security, and conducting data analytics.
  4. Legal Obligations: The Company may process your Personal Data as required by law or regulatory requirements, including but not limited to, complying with statutory regulations, court orders, or other legal processes.

Section 8.2: Rights of Data Subjects Under GDPR

Pursuant to the GDPR, Users who are residents of the EU, EEA, or the UK are conferred with specific rights relating to their Personal Data. These rights include:
  1. Right to Access: You have the right to obtain confirmation as to whether or not your Personal Data is being processed by the Company, as well as various other information relating to the Company’s use of your Personal Data.
  2. Right to Rectification: You have the right to request the rectification of inaccurate Personal Data and the provision of incomplete Personal Data.
  3. Right to Erasure (‘Right to be Forgotten’): Under certain conditions, you have the right to request the erasure of your Personal Data.
  4. Right to Restriction of Processing: You have the right to request the limitation of the processing activities related to your Personal Data under certain circumstances.
  5. Right to Data Portability: You have the right to receive the Personal Data concerning you in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller without hindrance from the Company.
  6. Right to Object: You have the right to object to the processing of your Personal Data based on legitimate interests pursued by the Company or a third party unless the Company demonstrates compelling legitimate grounds for such processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
  7. Right to Lodge a Complaint: You have the right to lodge a complaint with the relevant Data Protection Authority if you believe that your rights under GDPR have been violated.

Article 9: Compliance with California Consumer Privacy Act (CCPA) for California Residents

Section 9.1: Rights Accorded to California Consumers Under CCPA

Pursuant to the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100 to 1798.199) and any subsequent amendments (“CCPA”), California residents are entitled to specific rights concerning their Personal Data. These rights include:
  1. Right to Know: You have the unalienable right to request that the Company disclose the categories and specific pieces of Personal Data that it has collected about you, as well as the sources from which such data was sourced, the purposes for collecting it, and the categories of third parties with whom we have shared your Personal Data.
  2. Right to Delete: Subject to certain exceptions defined by the CCPA, you possess the right to request the Company to delete any Personal Data concerning you that the Company has collected or processed.
  3. Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format, in compliance with the provisions of the CCPA.
  4. Right to Non-Discrimination: You have the right to exercise your privacy rights under CCPA without being subjected to discriminatory practices as enumerated under the CCPA.

Section 9.2: Prohibition Against the Sale of Personal Data

The Company hereby unequivocally declares that it does not, and will not, sell, trade, lease, or otherwise disseminate your Personal Data to third parties for any purposes, including but not limited to direct marketing, without your prior explicit consent. If there should arise any future circumstance requiring such an action, the Company will furnish a conspicuously accessible mechanism, commonly known as a “Do Not Sell My Personal Information” link, on its website, thereby facilitating your ability to opt out of the sale of your Personal Data.

Section 9.3: Procedures for Exercising CCPA Rights

To exercise any of the above-mentioned rights, or to seek further clarifications regarding these rights, California residents may submit a verifiable consumer request to the Company through the contact information provided at the end of this Policy. The Company commits to respond to a verifiable consumer request within forty-five (45) days of its receipt, an extension for which, if needed, will be communicated to you as prescribed by the CCPA.

Article 10: Compliance with Virginia Consumer Data Protection Act (CDPA) for Virginia Residents

Section 10.1: Rights Accorded to Virginia Consumers Under CDPA

In alignment with the Virginia Consumer Data Protection Act (Va. Code Ann. §§ 59.1-572 to 59.1-581), effective as of January 1, 2023, and any subsequent amendments (“CDPA”), residents of the Commonwealth of Virginia are vested with specific rights with regard to their Personal Data:
  1. Right to Access: Virginia residents are entitled to request that the Company disclose the specific types and categories of Personal Data that it has collected about them, including the purpose for which such data is being processed and the entities with whom the data is being shared.
  2. Right to Correction: Virginia residents have the right to request corrections to any inaccurate or incomplete Personal Data that the Company holds pertaining to them.
  3. Right to Deletion: Subject to certain exceptions defined by CDPA, Virginia residents possess the right to request that the Company delete their Personal Data stored or processed by the Company.
  4. Right to Data Portability: Virginia residents have the right to receive a copy of their Personal Data in a structured, commonly used, and machine-readable format.
  5. Right to Opt-Out: Virginia residents have the right to opt out of the processing of their Personal Data for the purposes of targeted advertising, sale, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Section 10.2: Procedures for Exercising CDPA Rights

To exercise any of the rights enshrined under the CDPA, or to seek further clarification regarding these rights, residents of Virginia are encouraged to submit a verifiable consumer request to the Company through the contact information provided at the end of this Policy. The Company will acknowledge receipt of your request within a reasonable time frame and will proceed to verify and execute the request in accordance with the CDPA and other applicable laws.

Section 10.3: Non-Discrimination for Exercising CDPA Rights

The Company is prohibited from discriminating against you for exercising any of your CDPA rights. This includes not denying goods or services, charging different prices or rates, or providing a different level or quality of goods or services to you.

Article 11: Compliance with Personal Information Protection and Electronic Documents Act (PIPEDA) for Canadian Residents

Section 11.1: Rights Afforded to Canadian Residents Under PIPEDA

In accordance with the Canadian Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), residents of Canada have the following rights with respect to their Personal Data:
  1. Right to Access: Canadian residents have the right to request details about the nature, scope, and purpose of the Personal Data that the Company collects, uses, and discloses about them.
  2. Right to Correction: Canadian residents are entitled to correct inaccuracies and omissions in their Personal Data, provided that the Personal Data is under the Company’s control.
  3. Right to Withdraw Consent: Residents have the right to withdraw their consent for the processing of their Personal Data, subject to legal or contractual obligations that may apply.
  4. Right to File a Complaint: Canadian residents have the right to file a complaint with the Privacy Commissioner of Canada or other supervisory authorities if they feel their rights under PIPEDA have been violated.

Section 11.2: Mechanisms for Exercising PIPEDA Rights

To exercise any rights under PIPEDA, residents of Canada are requested to submit a verifiable consumer request to the Company via the contact details provided at the conclusion of this Policy. Upon receipt of a verifiable request, the Company will take adequate measures to authenticate the identity of the requesting party before proceeding to action the request. Subsequently, the Company will notify the resident of any actions taken or to be taken in response to the request.

Section 11.3: Data Security and Integrity Measures Under PIPEDA

In alignment with PIPEDA requirements, the Company employs reasonable security safeguards to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. These safeguards include but are not limited to, cryptographic measures, access control mechanisms, and secure data storage facilities.

Section 11.4: Cross-Border Data Transfers

The Company may transfer your Personal Data to other countries for processing, but will ensure that any such transfers are compliant with PIPEDA’s cross-border data transfer regulations.

Article 12: Contact Information and Queries

12.1 Contact Details

Should you have any questions, concerns, or require clarification regarding these Privacy Policy, you are encouraged to contact the Company using the following contact details:

TrustGenius LTD

7 Coronation Road, Dephna House, LAUNCHESE, London, NW10 7PQ, UNITED KINGDOM

compliance@trustgenius.io

UK: +442035764097

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