Disclaimer & Privacy Policy
1. Introduction
In this policy, “we”, “us”, “our” and “TrustMonk” refer to TrustMonk and its affiliated products and services. We respect your privacy and are committed to protecting it through our compliance with this Policy.
This Privacy Policy applies when we are acting as a data controller with respect to the personal data of our users. It describes how we collect, use, and share personal data of consumer users across our websites including www.trustmonk.app (the Website), TrustMonk’s mobile and desktop applications (the App), and services offered to users (collectively with the Website and the App, the Services), and from our partners and other third parties.
When using any of our Services you consent to the collection, transfer, storage, disclosure, and use of your personal data as described in this Policy. This Policy does not apply to anonymised data, as it cannot be used to identify you.
Please read this Policy carefully to understand our policies and practices regarding your personal data and how we will treat it. By accessing or using the Services, you agree to this Policy. This Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
2. Personal Data We Collect and How We Collect It
There are three general categories of personal data we collect.
2.1 Information You Give to Us
(a) Account Data — We collect personal identification information such as your name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email address, as well as formal identification information such as Tax ID number, passport number, driver’s licence details, national identity card details, photograph identification cards, and/or visa information (collectively, Account Data).
Account Data may be processed for the purposes of providing our Services, satisfying anti-money laundering and know-your-customer obligations, ensuring the security of the Services, maintaining back-ups of our databases, and communicating with you. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide all requested Services.
(b) Payment Information — We process financial information such as bank account, credit card, or PayPal information when you order Services in order to facilitate the processing of payments. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, and our legitimate interest in the proper administration of our website and business.
(c) Correspondence Data — We may process information contained in or relating to any communication that you send to us, including the communication content and metadata. Correspondence Data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interest in the proper administration of our website and business.
(d) Profile Data — We may process information included in your personal profile, which may include your location, time zone, and website. Profile Data may be processed for the purposes of providing you a better user experience. The legal basis for this processing is your consent.
2.2 Information We Automatically Collect
When you use the Services, we may automatically process information about your computer and internet connection (including your IP address, operating system, and browser type), your mobile carrier, device information (including device and application IDs), search terms, cookie information, as well as information about the timing, frequency, and pattern of your service use, and information about transactions you make on our Services (Service Data).
Service Data is processed for the purpose of providing our Services. The legal basis for this processing is the adequate performance of the contract between you and us, compliance with legal obligations, and our legitimate interest in being able to provide and improve the functionalities of the Services.
2.3 Information We Collect from Third Parties
From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws.
3. Disclosure of Personal Data
3.1 We may disclose your personal data to any member of our group of companies (including our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
3.2 We may disclose Service Data to third party service providers insofar as reasonably necessary to improve the functionalities of the Services, including for analytics, in-app support, location data, and search engine functionality.
3.3 We may share aggregated or anonymised data for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
3.4 In the event of a dispute in a P2P transaction, we may disclose some of your personal data with the counterparty to the extent required to resolve the dispute.
3.5 We may also disclose your personal data where reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect your vital interests or the vital interests of another person; to protect the safety or integrity of the Services; to address fraud, security, or technical issues; or to protect our rights or property.
3.6 You have the opportunity to opt out of disclosure of your personal information to a third party or use for a materially different purpose than originally collected. To opt out, please write to us at legal@trustmonk.app.
4. Retaining and Deleting Personal Data
4.1 Personal data that we process shall not be kept for longer than is necessary for the purpose or purposes for which it is processed.
4.2 We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Services, you can request that we erase your personal information and close your account.
4.3 We may retain your personal data where such retention is necessary for compliance with a legal obligation, or in order to protect your vital interests or the vital interests of another person.
5. Children
Our Services are not intended for children. You must be old enough to consent to the processing of your personal data in your country without parental consent. No one under the age of 18 may provide any personal data through the Services. If you are under 18, do not use or provide any information through the Services, register an account, make any purchases, or provide any information about yourself to us.
6. Cookies
6.1 About Cookies
A cookie is a file containing an identifier that is sent by a web server to a web browser and stored by the browser. Cookies may be either persistent (remaining valid until their set expiry date) or session-based (expiring when the browser is closed). Cookies do not typically contain information that personally identifies a user, but personal information we store about you may be linked to information stored in cookies.
We also use other technologies with similar functionality, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device.
6.2 How We Use Cookies
We use these technologies to:
- Identify you and log you into the Services
- Store your preferences and personalise the Services for you
- Protect user accounts and prevent fraudulent use of login credentials
- Help us display content that is relevant to you
- Analyse the use and performance of the Services
- Store your preferences in relation to the use of cookies
6.3 Cookies Used by Service Providers
We use third party service providers to analyse the use of the Services. Each service provider gathers information via cookies, which is used to create reports about usage.
6.4 Managing Cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. Your mobile device may also allow you to control cookies through its settings. If you choose to decline cookies, some parts of the Services may not work as intended or may not work at all.
7. Data Security
7.1 We have implemented measures designed to secure your personal data from accidental loss and from unauthorised access, use, alteration, and disclosure. Where we have given you a password for access to certain parts of the Services, you are responsible for keeping this password confidential. Please do not share your password with anyone.
7.2 Steps taken to ensure data security include:
- All user information can only be accessed by authorised users
- Users must authenticate themselves with a username and password combination
- All data is hosted on Amazon AWS or Google Cloud Platform servers
7.3 The transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of data transmitted through the Services. Any transmission of personal data is at your own risk.
8. Changes to This Privacy Policy
It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat our users’ personal data, we will notify you by email to the primary email address specified in your account. You are responsible for ensuring we have an up-to-date, deliverable email address for you, and for periodically reviewing this Policy for changes.