We at Trust365 Limited(“we”, “us” or “the Company”) are committed to protect the privacy of our customers who are licensed to use our software (“Software”) on their internal network (“Client(s)”), as well as authorized end users who have access to any of the data resources monitored by our Software on the Client’s behalf (“End Users”).
Please note that the term “you” shall refer to Clients and End Users, as applicable.
When providing our Services, we may act in one of two distinct roles:
What type of information we collect
We collect two types of data and information from our users.
Non-personal Information which is being collected may include usernames and passwords, directory names, server names, file names, configurations, other software you use, event logs and browsing events.
We may also collect clickstream data, aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.), in order to enhance the functionality of our Services.
We may collect the following types of Personal Information when using our Services:
In addition, as part of the registration process, you may be required (depending on the specific product you wish to use or purchase as part of the Services) to provide us, or our third party service providers, additional information, including your billing information. Such information may include your phone number, credit card number, etc.
o The content of emails;
o Names and email addresses of senders/ recipients of emails;
o Photographs, images, and videos;
o Device identifiers – such as the Internet Protocol (IP) address and other types of unique device identifiers; and
o Personal documents.
User Data which is collected and processed by us may also include sensitive data, which may reveal your ethnic origin, health data, religion, sexual orientation, etc. (e.g. “Sensitive Information”).
Please note that the User Data is exclusively controlled by the Client, meaning that the Client maintains ownership of their related information and determines their own policies regarding the access permission and retention of such User Data.
You also acknowledge that part of this User Data may include Personal Information which relates to other individuals. You warrant that you have all the required authorizations, consents, and approvals from these individuals to allow us to access and process such information.
To the extent that the Company processes Personal Information, such processing is based on the consent of the data subject or where such processing is necessary for the performance of a contractor for the fulfilment of a legitimate interest pursued by the Company.
How we use the information we collect
In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for the following purposes:
With whom we share the information we collect
In addition to the different uses listed above, we may transfer or disclose Personal Information to affiliated companies and subcontractors. In addition, Personal Information may be disclosed to other trusted third-party service providers or partners for:
iii. performing research, technical diagnostics and analytics with regard to the Services.
We may disclose Personal Information or any information you submitted via the Services, if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to
iii. investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
You may request to:
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the aforementioned rights or receive more information, please contact our data protection officer, Steve Boland, email@example.com.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
However, if you are an End User of our Client, please contact the Client directly. Likewise, if you have any questions or requests regarding the handling of your User Data, please direct all inquiries to the relevant Client, which has the control over your information and the ways by which such information is collected and processed.
We will retain your personal information for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.
We value your privacy and control over your Personal Information, and therefore you may, at any time, request to change and update it by emailing us at firstname.lastname@example.org.
You can also request that we will correct errors or that we will erase your Personal Information (except for data that we are required to keep under applicable laws) by emailing us at email@example.com.
However, if you are an End User of our Client, please contact the Client who interacts with us directly. Likewise, if you have any questions or requests regarding the handling of your User Data, please direct all inquiries to the applicable Client, which has the control over your information and the ways by which such information is collected and processed.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.
How do we safeguard and transfer your information?
We take great care in implementing and maintaining the security of the Services and your information.
We employ industry standard procedures and policies to ensure the safety of our users’ information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Transfer of data outside the EEA
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. In such cases, we will transfer your data only to such countries as approved by the European Commission as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
We may use Client’s Personal Information, such as Client’s name and email address, ourselves or by using our third-party subcontractors for the purpose of providing Clients with promotional materials and newsletters concerning our Services, which we believe may interest our Clients. Out of respect to your right to privacy, at any time, you may request to unsubscribe.
How to contact us
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us at firstname.lastname@example.org.