Privacy Policy

This is the Privacy and Cookies Policy for the website hosted at https://trustology.io/   ("we","us" and "our site") and our Trustology mobile application "our App". The site/App is operated by or on behalf of Trustology Ltd trading as Trustology.  We are committed to protecting and respecting your privacy.

This policy sets out:

  • Information we collect about you

  • Cookies and other technologies

  • How we use your information

  • Our promotional updates and communications

  • Who we give your information to

  • Where we store your information

  • Payment processing

  • How we protect your information

  • How long we keep your information

  • Your rights

  • Changes to this policy

  • Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By engaging with our site/App, you acknowledge you have read and understood this privacy policy.

For the purposes of UK and European Economic Area data protection law, (the "Data Protection Law"), the data controller is: Data Protection Officer, Trustology, 181, Queen Victoria Street, London EC4V 4EG, [email protected]

Information we collect about you

We will collect and process the following personal data from you:

  • Information you give us

This is information about you that you give us directly when you interact with us.

This is information about you that you give us by filling in forms on our site/App or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site and or the App (where applicable), subscribe to our service, search for a product, place an order on our site orvia our App, participate in discussion boards or other social media functions on or via our site/App, enter a competition, promotion or survey, submit a query, and when you report a problem with our site/App.

The information you give us may include your name, address, e-mail address and phone number, financial information, personal description and photograph, login and password details.

It may also include employment details if you send us a CV, resumé or other details of your employment history in connection with an advertised job vacancy or a general enquiry regarding employment opportunities with us.

  • Information we collect about you from your use of our site/App: We will automatically collect information from you each time you visit our site/use our App.  This includes:

    • Technical information

    • Information about your visit

    • Location data

​​Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team;

  • Location data - we collect location type of information through the site/App as to your real-time location to enable us to recognise your mobile browser or device when you return to the site/App;

  • Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (c) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier. See Cookies and other technologies for more information on the use of cookies and device identifiers on the site/App.

  • Information we receive from other sources. This is the information we receive about you:

    • If you use any of the other websites or apps we operate or the other services we provide.

    • From third parties we work closely with.

In this case, we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Cookies and other technologies

Our site/App uses cookies and/or other similar technologies such as device-IDs, in-App codes, pixel tags or web beacons to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

Our site/App uses cookies and similar technologies to distinguish you from other users of our site/App. This helps us to provide you with a good experience when you browse our site/use our App and also allows us to improve our site/App.

Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this.  We also give you information about how to disable cookies further below. However, you may not be able to take full advantage of our site or App if you do so.

A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser/or exit the App. Others are used to remember you when you return to the site/App and will last for longer.

We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use .

We use cookies and/or other similar technologies such as tracking images, web beacons pixel codes and in-app IDs, either alone or in combination with each other, to create a unique device ID.

We use the following types of cookies

  • Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting/Advertising cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our site/App and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We may also work with advertising networks that gather information about the content on our site /App you visit and on information on other websites and services you visit. This may result in you seeing advertisements on or through our site/App or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.co.uk

Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.  If you only disable third party cookies, you will not be prevented from making purchases on our site/App.  If you disable all cookies, you will be unable to complete a purchase on our site/App.

If you want to disable cookies on our site, you need to change your website browser settings to reject cookies.  How you can do this will depend on the browser you use.  Further details on how to disable cookies for the most popular browsers are set out below:

For Microsoft Internet Explorer:

1. Choose the menu “tools” then “Internet Options”

2. Click on the “privacy” tab

3. Select the setting the appropriate setting

For Google Chrome:

1. Choose Settings> Advanced

2. Under "Privacy and security," click “Content settings”.

3. Click “Cookies”

For Safari:

1. Choose Preferences > Privacy

2. Click on “Remove all Website Data”

For Mozilla firefox:

1. Choose the menu “tools” then “Options”

2. Click on the icon “privacy”

3. Find the menu “cookie” and select the relevant options

For Opera:

1. Choose the menu Files”> “Preferences”

2. Privacy

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the site/App.

Except for essential cookies, all cookies used on our site will expire after a set period of time.

You can find more information about the individual cookies we use and the purposes for which we use them below:

How we use your information

We use information held about you in the following ways:

  • Information you give to us:

We will use this information to:

  • Manage a private blockchain key that is unique to you;

  • Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:

    • conducting background checks including credit checks

    • administering your account with us;

    • verifying and carrying out  transactions you make online through the App/site;

    • notifying you about changes to our service.

  • Provide you with information about our own or third party goods or services which may be of interest to you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object  to such communications. See 'Our promotional updates and communications'.

  • Ensure in our legitimate interests that:

    • content from our site / App is presented in the most effective manner for you and for your computer.

    • we provide you with the information, products and services that you request from us.

  • Information we collect about you from your use of our site/App

We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:

  • To administer our site/App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

  • To keep our site/App safe and secure.

  • For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

  • To improve our site/App to ensure that content is presented in the most effective manner for you and for your computer.

  • To allow you to participate in interactive features of our service, when you choose to do so.

  • Information we receive from other sources

We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights) or, with your consent where required by law. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal data for marketing analysis and to provide you with promotional update communications by email about our own and third party products/services.

You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to [email protected]

Who we give your information to

We may give your information to:

  • Selected third parties.

Our selected third parties may include:

  • Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the site/App in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.

  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.  We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy.

  • Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual).

  • Business partners who jointly with us provide services to you and with whom we have entered into agreements in relation to the processing of your personal data describe types or, a list of whom can be found on the bottom of the Privacy Policy.

  • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

  • Payment processing providers who provide secure payment processing services your payment card details are not shared with us by the provider.

We will disclose your personal data to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.

  • If Trustology Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of insert company name, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where we store your information

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

We may transfer your personal data outside the EEA:

  • In order to store it.

  • In order to enable us to provide goods or services to you and fulfil our contract with you.  This includes order fulfilment, processing of payment details, and the provision of support services.

  • Where we are legally required to do so.

  • In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

We may transfer your personal data to the following countries outside the EEA:

Our data centres are located in the United Kingdom and your personal data will remain in the UK where we process it.

Where your personal data is shared by us with third parties and processed by them outside the EEA, we rely on the implementation of the standard contractual clauses, binding corporate rules or where applicable, a valid EU-US or Swiss-US privacy shield certification.

Payment processing

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the site or via the App are made through our payment gateway provider, Stripe.. You will be providing credit or debit card information directly to Stripe which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to Stripe is not within our control and is subject to Stripe's own privacy policy and terms and conditions. Your payment card details are not shared with us by Stripe.

How we protect your information

All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site/App, you are responsible for keeping this password confidential.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site/App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

How long we keep your information

We retain personal data for for as long as you have an account with us in order to meet our contractual,  legal or regulatory obligations and for seven years after that to identify any issues and resolve any legal proceedings We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

You have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;

  • to request the rectification or erasure of your personal data held by us;

  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);

  • to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section;

  • to request that your provided personal data be moved to a third party.

  • You may opt out at any time from allowing further access by us to your location data by changing settings on your iPhone. You can also stop all information collection by un-installing the App. You may use the standard un-install processes as may be available for your mobile device.

  • Your right to withdraw consent:

Where the processing of your personal data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section;

You can also exercise the rights listed above at any time by contacting us at [email protected]

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on September 20 2019.

Contact Us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

DATA PROTECTION OFFICER, TRUSTOLOGY LTD, 181 Queen Victoria Street, London, EC4V 4EG

External Parties acting as Data Processors:

  • Onfido - KYC/AML

  • Amazon - Cognito / Email

  • Intercom - Chat and client communication

cookie name purpose and lawful basis more information
XSRF-TOKEN XSRF Token This cookie is written to help with site security in preventing Cross-Site Request Forgery attacks. tiny.cc/qx8hdz
TSxxxxxxxx TSxxxxxxxx where x is replaced with a random series of numbers and letters Security tiny.cc/oz8hdz
TSxxxxxxxx TSxxxxxxxx where x is replaced with a random series of numbers and letters Security tiny.cc/oz8hdz
svSession SvSesson Identifies unique visitors and tracks a visitor’s sessions on a site tiny.cc/oz8hdz
SmSession SmSession Identifies logged in site members tiny.cc/oz8hdz
hs hs security tiny.cc/oz8hdz
_gid _gid Distinguish users in Google Analytics tiny.cc/u38hdz
_gat _gat Throttles request rate in Google Analytics tiny.cc/u38hdz
_ga _ga distinguishes users in Google Analytics tiny.cc/u38hdz
__cfduid __cfduid Identifies individual clients behind a shared IP address and apply security settings on a per-client basis. tiny.cc/k68hdz
intercom-ID-xxxxxxxx Intercom ID where x is replaced with a random series of numbers and letters Anonymous visitor identifier cookie, to provide better customer service through our chat interface tiny.cc/z78hdz
 
Updated: 27-09-2019