TrustCloud Privacy Policy

Effective as of May 9, 2023.

Please click here to view the previous version of our Privacy Policy.

California Notice at Collection: See the California privacy rights section below for important information about your rights under California law. 

NOTICE TO EUROPEAN USERS: If you are located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly), please also see the Notice to European Users section, below.

TrustCloud Corporation (“TrustCloud,” “we“, “us” or “our“) provides an integrated trust assurance platform that helps companies automate compliance control verification, accelerate security, privacy and compliance audit readiness, use AI to answer security questionnaires, and unlock sales delays by inviting customers to transparently view security, privacy and trust programs. This Privacy Policy describes how TrustCloud processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website and web applications, application extensions, social media pages, marketing activities, live events and other activities described in this Privacy Policy) (collectively, the “Service”)). 

Our websites, products and services are designed and intended for businesses and their representatives.  We do not offer products or services for use by individuals for their personal, family or household purposes.  Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant business and not their individual capacities.

You can download a printable copy of this Privacy Policy by printing this webpage. 

Table of Contents

 

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, email address, phone number, professional title, and company name.

  • Profile data, such as your username and password or other authentication credentials that you may set to establish an online account with us, or information such as your photograph, interests and preferences. 

  • Content you choose to upload to the Service, such as text, files, images, audio, and video, along with the metadata associated with the files you upload.

  • Feedback or correspondence data based on our exchanges with you, including when you contact us through the Service, communicate with us via our chat function, social media, or otherwise. 

  • Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history. 

  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

  • Registration data, such as information related to a service, account or event you register for.

  • User-generated content data, such as comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. 

  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources. 
  • Social media sources. For example, we may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
  • Business and marketing partners, such as joint marketing partners and event co-sponsors and business partners that share your contact information with us if you have expressed interest in our products or services or the types of products or services we offer.
  • Third-party log-in services, such as authentication providers and social media services, that you use to log into, or otherwise link to, your Service account (e.g., log-in via Google, Microsoft, SSO or your email provider). This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. 

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, location, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

Chat technologies, We may use chat technologies, such as those provided by HubSpot that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. Our chatbot provider(s) and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so. 

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide, operate and improve the Service and our business;
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • communicate with you about the Service, including by sending Service-related announcements, notifications, reminders, messages to archive content and links to Service-related features, updates, security alerts, and support and administrative messages;
  • facilitate social features of the Service, such as by providing chat or messaging functionality;
  • understand your needs and interests, and personalize your experience with the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information to reach out to you for research and development purposes, including to analyze and improve the Service and our business, and to develop new products and services. 

Marketing. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing purposes:

  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.  
  • Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications, and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the ‘Your choices’ section of our Cookie Policy

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
  • enforce the terms and conditions that govern the Service; and 
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Affiliates. Our affiliates, such as our corporate parent, subsidiaries and other affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics). 

Advertising partners.  Third-party advertising companies for the interest-based advertising purposes described above. 

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you 

Other users of the Service and/or public communities, at your explicit request. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public (for example, to post in a forum). You may also be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we may display information such as your name, username, and a link to your user profile along with the content you submit. We may make available settings through a “Settings” page that enables you to exercise choice regarding certain information that is displayed publicly or to other users.  We do not control how other users or third parties use any personal information that you make available to other users or the public. 

Third-party platforms. If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in TrustCloud, financing of TrustCloud, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of TrustCloud as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in California, and Europe can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. 

Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Policy.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Third-party log-in services and other third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. 

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Users in Europe should read the important information provided below about transfer of personal information outside of Europe. 

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Please direct any questions or comments about this Policy or privacy practices to privacy@trustcloud.ai.

California privacy rights notice

This section describes how we collect, use and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, (collectively, “CCPA”) and the rights these users may have with respect to their Personal Information.  

For purposes of this section, the term “Personal Information” has the meaning given in the CCPA and does not include information exempted from the scope of the CCPA.  

This section does not apply to our collection, use, and sharing of Personal Information of our job applicants and employees.  

Your California privacy rights. California residents have the rights listed below.  However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. 

  • Information. You can request the following information about how we have collected and used your personal information during the past 12 months:

    • The categories of personal information that we have collected.

    • The categories of sources from which we collected personal information.

    • The business or commercial purpose for collecting and/or selling or sharing personal information.

    • The categories of third parties to whom we disclose personal information.

    • The categories of personal information that we sold or disclosed or shared for a business purpose.

    • The categories of third parties to whom the personal information was sold, shared or disclosed for a business purpose.

  • Access.  You can request a copy of the specific pieces of personal information that we have collected about you. 

  • Deletion.  You can ask us to delete the personal information that we have collected from you.

  • Correction. You can ask us to correct inaccurate personal information that we have collected about you.

  • Opt-out of sales.  You can opt-out of any “sale” of your personal information. 

    • Note that TrustCloud does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.

  • Opt-out of sharing. You can opt-out of any “sharing” of your personal information for cross-context behavioral advertising.

  • Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA. 

  • Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.

Exercising your right to information/know, access, correction, and deletion. You may submit requests to exercise your right to information/know, access, appeal, correction, or deletion via our Contact Us form, or via email to privacy@trustcloud.ai

Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information.   Like many companies, we use services that help deliver interest-based ads to you.  Our use of some of these services may be classified under California law as “selling” or “sharing” your personal information with the advertising partners that provide the services because they use personal information from our users (e.g., device information and technical usage information) to provide cross-context behavioral advertising.  You can request to opt-out of this “selling” or “sharing” of your personal information here: Do Not Sell or Share My Personal Information, or by broadcasting the global privacy control signal.

Verification of identity; authorized agents. We will need to verify your identity in order to process your information/know, access, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.  

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465.  If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CPRA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. 

Personal Information (“PI”) we collect

CCPA statutory category

Categories of third parties to whom we “disclose” PI for a business purpose

Categories of third parties to whom we “sell” or “share” PI

· Contact data

· Identifiers

· Commercial information

· California customer records

· Any of the parties identified in the How we share your personal information section above

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Profile data

· Identifiers

· Commercial information

· California customer records

· Any of the parties identified in the How we share your personal information section above

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Feedback or correspondence data

· Identifiers

· Commercial information

· California consumer records

· Internet or Network Information

· Any of the parties identified in the How we share your personal information section above

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Transactional data

· Commercial information

· California consumer records

· Any of the parties identified in the How we share your personal information section above

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Marketing data

· Identifiers

· Commercial information

· California customer records

· Internet or Network Information

· Affiliates

· Advertising partners

· Business and marketing partners

· Professional advisors

· Authorities and others

· Business transferees

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Registration data

· Identifiers

· Commercial information

· California customer records

· Internet or Network Information

· Affiliates

· Advertising partners

· Business and marketing partners

· Professional advisors

· Authorities and others

· Business transferees

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· User-generated content

· Sensory Information

· California consumer records

· Affiliates

· Service providers

· Business and marketing partners

· Authorities and others

· Business transferees

· None

· Data about others

· Identifiers

· California consumer records

· Any of the parties identified in the How we share your personal information section above

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Device data

· Identifiers

· Internet or Network Information

· Any of the parties identified in the How we share your personal information section above

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Online activity data

· Identifiers

· Commercial information

· Internet or Network Information

· Any of the parties identified in the How we share your personal information section above

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Communication interaction data

· Identifiers

· Commercial information

· California consumer records

· Internet or Network Information

· Any of the parties identified in the How we share your personal information section above

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

· Data derived from the above

· Inferences

· Affiliates

· Service providers

· Advertising partners

· Business and marketing partners

· Authorities and others

· Business transferees

· Advertising partners (to facilitate online advertising)

· Business and marketing partners

 

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom (“UK”) and the European Economic Area (“EEA”) (UK and EEA jurisdictions are together referred to as “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.   

Controller. TrustCloud is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

Our legal bases for processing 

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. 

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).

  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.

  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).  

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’

Purpose

Categories of personal information involved

Legal basis

Service delivery and operations

· Contact data

· Profile data

· Feedback or correspondence data

· Transactional Data

· User-generated content data

· Marketing data

· Registration data

· Data from Third Party sources

· Device data

· Contractual Necessity

Service improvement and analytics

· Contact data

· Device data

· User-generated content data

· Online activity data

· Communication interaction data

· Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences.

· Consent, in respect of any optional cookies used for this purpose.

Direct marketing

· Contact data

· Feedback or correspondence data

· Transactional data

· Marketing data

· Communication interaction data

· Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.

· Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.

Interest-based advertising

· Marketing Data

· Device data

· Online activity data

· Consent

Compliance and protection

· Any and all data types relevant in the circumstances

· Compliance with Law.

· Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

Research and development

· Any and all data types relevant in the circumstances

· Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers.

To create aggregated, de-identified and/or anonymized data

· Any and all data types relevant in the circumstances

· Legitimate interest. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Services and how we use Personal Information is as un-privacy intrusive as possible.

Further uses

· Any and all data types relevant in the circumstances

· The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.

· Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.  

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. 

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

  • Provide you with information about our processing of your personal information and give you access to your personal information.

  • Update or correct inaccuracies in your personal information.

  • Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request. 

  • Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.

  • Object. Object to our processing of your personal information where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.

  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.  

Exercising These Rights. You may submit these requests by email to privacy@trustcloud.ai. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.  

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. 

  • For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

  • For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow – Cheshire SK9 5AF

Tel. +44 303 123 1113

Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.  

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented: 

  • Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).

  • Transfers to territories without an adequacy decision.

    • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).  

    • However, in these cases:

      • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or 

      • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer. 

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.