Updated: March 20, 2023
This Policy sets the minimum standard and shall guide all TRUID, CO. employees and its vendors even if local law is less restrictive. Supplemental policies and practices will be developed to meet legal or departmental requirements. Supplemental policies and practices may provide for more strict or specific privacy and protection standards than this Policy outlines.
This Policy sets out what personal data we collect, how we process it, and how long we retain it.
This Policy applies to all our processing activities where we act as data controllers.
In this Policy, "we," "us," and "our" refers to TRUID, CO., a Delaware corporation company, and its subsidiaries. For more information about us, see this Policy's "Contact Us" section.
In this Policy, “personal data” means any information relating to you as an identified or identifiable natural person (“Data Subject”); an "identifiable natural person" can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
In this Policy, “processing” means any operation or set of operations which is performed on personal data (as defined in this Policy) or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We collect information about you when you:
The personal information we collect might include but is not limited to, your: name; email address; telephone number; date of birth; IP address; and the type of device through which you browse our website or use our services (including the operating system; your location; time date and duration of your visit to our website).
We use personal information about you in connection with the following purposes:
A. Provision of services and management:
B. Service Improvements:
C. Direct Marketing:
If you do not want your personal information to be used for marketing purposes, please contact us as set forth below. Alternatively, you can directly unsubscribe when you receive marketing materials from us.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to notify the browser when you receive a new cookie, or how to disable cookies altogether. Visitors to our Services who disable cookies can browse certain areas of the Services, but some features may not function.
We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this Policy. Records can be held on various media (physical or electronic) and formats. Retention periods are determined based on the record type, the nature of the record and activity, and the legal or regulatory requirements that apply to those records.
Where personal data is collected pursuant to a contract or before the creation of a contract, these are retained for 6 years after the termination of the contract pursuant to our legitimate interests in defending any legal claims which may be brought against us.
However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or where we have a legitimate interest to do so.
All personal data is retained in accordance with our internal Retention and Deletion Policy.
We may pass your information to our Business Partners, third-party service providers, agents, subcontractors, and other associated organizations for the purposes of completing tasks and providing our services to you.
To comply with our legal obligations, we use a third-party service provider to collect and process some of your personal data. This third-party service provider is bound by strict legal and contractual obligations to protect your personal data.
In addition, when we use any other third-party service providers, we will disclose only the personal information that is necessary to deliver the service required, and we will ensure, via contractual obligations, that this requires them to keep your information secure and not to use it for their own direct marketing purposes.
In addition, we may transfer your personal information to a third party as part of a sale of some or all of our business and assets or as part of any business restructuring or reorganization, or if we are under a duty to disclose or share your personal data to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.
You have certain rights under applicable legislation, particularly Regulation EU 2016/679 (General Data Protection Regulation or “GDPR”). We explain these below. You can learn more about the GDPR and your rights by accessing the European Commission’s website.
A. Right Information and Access
You have a right to be informed about processing your personal data (and if you did not give us information about the source), and this Policy intends to provide the information. Of course, you can contact us if you have any further questions - see below.
B. Right to Rectification
You have the right to rectify any inaccurate personal information about you and complete any incomplete personal information about you. You may also request that we restrict the processing of that information by contacting us - see below.
The accuracy of your information is important to us. If you do not want us to use your personal information in the manner set out in this Policy, or need to advise us of any changes to your personal information, or would like any more information about how we collect and use your personal information, please contact us - see below.
C. Right to Erasure (right to be ‘forgotten’) You have the general right to request the erasure of your personal information in the following circumstances:
We will proceed to comply with an erasure request without delay unless continued retention is necessary for the following:
To file an erasure request, please email [email protected] with the email address used to register your account.
D. Right to Restrict Processing and Right to Object to Processing
You have a right to restrict the processing of your personal information, such as where:
You also have the right to object to processing your personal information under certain circumstances, such as where the processing is based on your consent, and you withdraw that consent. This may impact our services, and we will explain this to you if you decide to exercise this right.
For data processing-related requests, please email [email protected] with the email used to register your account.
E. Right to Data Portability
Where the legal basis for our processing is your consent or the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract, you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format. Any such request should be directed to the contact information below.
F. Right to Freedom from Automated Decision-Making
Where automated decision-making takes place, you have the right, in this case, to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
G. Right to Object to Direct Marketing (opting out)
You have a choice about whether or not you wish to receive information from us. We will not contact you for marketing purposes unless:
You can change your marketing preferences anytime by contacting us at the details below. On each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data.
You may also opt out anytime by contacting us - see below.
Please note that any administrative or service-related communications (to offer our services or notify you of an update to this Policy or applicable terms of business, etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, 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 or as part of a contractual relationship we may have with you.
G. Right to Request Access
You also have a right to access the information we hold about you. We are happy to provide details of your personal information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which means we will require proof of identity from you before disclosing such information. You can exercise this right anytime by contacting us - see below.
H. Right to Withdraw Consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us - see below.
If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out below, and we will then investigate the matter.
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of your rights has taken place.
A. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We may provide hyperlinks from this website to the websites of other organizations or associated companies. Please note that we will not be liable for the contents of linked websites or any transactions with organizations operating those websites. The privacy policies of others may differ significantly from our Policy. Therefore, we encourage you to read the privacy statement/policy of each and every website that collects personal data.
C. Review of this Policy
We may make changes to this Policy from time to time. When we do so, we will notify those who have a business relationship with us or who are subscribed to our emailing lists directly of the changes and change the ‘Last updated’ date above. We encourage you to review the Policy whenever you access or use our website to stay informed about our information practices and the choices available to you. If you do not agree to the revised Policy, you should discontinue using this website.
D. Contact Us
Any questions regarding our Policy or your rights as a Data Subject should be sent to: [email protected].