Privacy Policy

ACCESSING, DOWNLOADING OR OTHERWISE USING TRUU LTD (“Truu”, “We”, “Our” or “Us”) WEBSITE, APPS, DIGITAL IDENTITY SERVICES, OR OTHER INTERACTIONS, SUCH AS ONLINE, EMAIL, PHONE OR OTHER OFFLINE METHODS (COLLECTIVELY, THE “SERVICES”) INDICATES THAT YOU ACCEPT AND AGREE TO BE BOUND BY THIS PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT ACCESS, DOWNLOAD OR OTHERWISE USE THE SERVICES. YOU ACKNOWLEDGE (A) THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY; AND (B) THIS PRIVACY POLICY SHALL HAVE THE SAME FORCE AND EFFECT AS A SIGNED AGREEMENT.

Introduction

Truu respects your privacy and it is fundamental to Our principles. Our website, applications (both web and mobile) and other Services that We offer are designed to minimise the amount of data that we, or one of Our clients collect about “You”. In order to interact with you and improve the Services, We do collect some information. The purpose of this Privacy Policy (“Policy”) is to inform you about Our privacy practices and to ensure that you understand the purposes for which We collect and process your personal data.

Changes to This Privacy Policy

We may update Our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page.

This policy was last updated on 26 May 2020.

1. WHAT INFORMATION DO WE COLLECT?

In short: We collect personal information that you provide to us such as name, contact information and occupation details. If you choose to back up your passport using our servers, we may hold, but couldn’t access, your encrypted back up and encryption keys

We may collect information that could be used to personally identify you, if you choose to provide it. This information can come from a number of sources:

Given by You directly or authorise someone else to give to Us. When you register or use Our Services, you may be asked to provide certain information including, but not limited to, first and last name, email address, phone number, occupation, employer and other information you choose to provide to us.

Digital Credentials. Our Services include the provision of apps that let individuals’ access, manage and share personal information in the form of digital credentials. These credentials can be stored on the end-user’s device or in the cloud. Where the end-user chooses to use Our cloud storage for backup or as a proxy digital wallet, We may store the data on Our servers or through third-party cloud service providers. As part of this cloud storage service that We provide, We may also hold encryption keys relating to the end-user’s digital wallet on the end-user’s behalf. Where We provide this cloud storage, end-user data is stored in an encrypted form that does not enable the identification of the user or allow access to the encryption keys by Us or any third party.

Aggregated Data. We may collect aggregated data about you or your use of Services, or any other aggregated form of the other types of User Information set forth above. Aggregated data that We collect cannot be specifically associated with you individually.

2. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.

We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.

We may process or share data based on the following legal basis:

Consent: We may process your data if you have given Us specific consent to use your personal information for a specific purpose. Legitimate Interests: We may process your data when it is reasonably necessary to achieve Our legitimate business interests. Performance of a Contract: Where We have entered into a contract with you, We may process your personal information to fulfil the terms of Our contract. Legal Obligations: We may disclose your information where We are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Vital Interests: We may disclose your information where We believe it is necessary to investigate, prevent, or take action regarding potential violations of Our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which We are involved. More specifically, We may need to process your data or share your personal information in the following situations:

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for Us or on Our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with Us over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, We do not share, sell, rent or trade any of your information with third parties for their promotional purposes. Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Our business to another company. Affiliates. We may share your information with Our affiliates, in which case We will require those affiliates to honour this privacy policy. Affiliates include any subsidiaries, joint venture partners or other companies that We control or that are under common control with us. Business Partners. We may share your information with Our business partners to offer you certain products or services related to Our Services.

3. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information.

Cookies. We may collect User Information by sending cookies to your device. Cookies are small data files that are stored on your hard drive or in your device memory when you use the Services. A cookie may also convey information to Us about how you use the Services (e.g., the pages you view, the links you click and other actions you take) and allow Us or Our third-party analytics tools We use to track your usage of the Services. There are at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent use of the Services. Persistent cookies can be removed by following your Web browser’s directions for removal of cookies. A session cookie is temporary and disappears after you close your browser. You can typically remove and reject cookies from Our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject Our cookies, it could affect how the Services are provided.

Analytics Information. We collect, measure and analyse traffic and usage trends in connection with Our Services. We use Google Analytics to provide analytics services. On Our website, no personally identifiable information is collected about you unless you explicitly submit that information. The anonymous information generated by Google Analytics cookies about your use of Our website is transmitted to Google – not Truu. This information is processed to compile statistical reports on website activity for this site only. We use these reports to evaluate aggregate visitor usage. This is essential for Us to operate Our website.

For further information about how Google Analytics uses cookies and IP address data, see: http://www.google.com/intl/en/analytics/privacyoverview.html

Device Identifiers. We may access, collect, monitor and/or remotely store one or more "device identifiers," such as a universally unique identifier when using Our Services from a mobile device. Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may convey information to Us about your Service usage and effectiveness. A device identifier may remain persistently on your device to enhance your navigation of the Services. Some features of Our Services may not function properly if use or availability of device identifiers is impaired or disabled.

Web Beacons. We may collect User Information using web beacons. Web beacons are electronic images that may be used in connection with the Services. We may use web beacons to deliver cookies, track the number of visits to the Services, understand Service usage and effectiveness, and determine whether an email has been opened and acted upon.

We may use other third-party services such as Firebase to analyse personal data of users who provide Us with feedback. This allows Us to understand more about the use of Our Services. This includes, but is not limited to, who is using them, how they are using them, and ways to improve the Services. Such third-party analytics tools and services may use cookies and persistent device identifiers to collect and store information including, but not limited to time of visit, pages visited, time spent on each page, IP address, unique device ID, advertising tags and type of operating system used.

4. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

In short: We process personal data for legitimate interests based on lawful basis, Your consent, contractual or legal obligations. We abide by the General Data Protection Regulations.

We rely on the following lawful bases for the processing of your personal data relating to Our operations and Services that We offer to individuals within the European Economic Area or subject to the General Data Protection Regulation (Regulation (EU) 2016/679):

• Our legitimate interests in (among other things) delivering Our Services, conducting commercial research, improving and maintaining Our Services, personalising and tailoring content made available to you through Our Services, protecting the security or integrity of Our databases, protecting Our business or reputation, taking precautions against legal liability, dealing with Our assets in the event of a business change (see further below), protecting and defending Our legal rights or property, or for resolving disputes, investigating and attending to enquiries or complaints with respect to your use of Our Services;
• Where relevant, your express consent, for example, if you use Our Services to send your digital credentials to a third-party;
• Where relevant, the fulfilment of Our contractual obligations to you under Our terms and conditions of service; and
• Where relevant, for compliance with legal obligations to which We are subject.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In short: We may transfer, store, and process your information in countries other than your own.

Our servers are located primarily in the United Kingdom. If you are accessing Our Services from outside this location, please be aware that your information may be transferred to, stored, and processed by Us in Our facilities We may store and otherwise process data (including personal data) through third-party cloud service providers and other IT service providers which may be located or operate in other countries, including countries which do not guarantee the same level of protection to privacy as the European Economic Area.

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

Our Services may contain advertisements from third parties that are not affiliated with Us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When We have no ongoing legitimate business need to process your personal information, We will either delete or anonymise 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.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information We process. However, We cannot ensure or warrant the security of any information you transmit to Us or guarantee that information on the Services may not be accessed, disclosed, altered or destroyed. Emails sent to or from the Services may not be secure. We cannot guarantee that transmissions of your personal data will be fully secure and that third parties will never be able to defeat Our security measures or the security measures of Our partners. You should use caution whenever submitting information online and take special care in deciding what information you send to Us via email. Although We will do Our best to protect your personal information, transmission of personal information to and from Us, it is at your own risk. We cannot guarantee that transmissions of your personal data will be fully secure and that third parties will never be able to defeat Our security measures or the security measures of Our partners.

We will not be liable for any damages, claims, liability, or causes of action that arise as a result of any such security breach or transmissions errors, third-party access or causes beyond Our control.

9. DO WE COLLECT INFORMATION FROM MINORS?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using Our Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If We learn that personal information from users less than 18 years of age has been collected, We will deactivate the account and take reasonable measures to promptly delete such data from Our records. If you become aware of any data We have collected from children under age 18, please use the contact details provided below.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If We are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe We are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

11. CONTROLS FOR DO-NOT-TRACK FEATURES

In short: We don’t currently respond to Do-Not-Track features as there is no uniform technology standard.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalized. As such, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that We must follow in the future, We will inform you about that practice in a revised version of this Privacy Policy.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits Our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) We disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which We shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to Us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Our Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact Us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on Our Services, but please be aware that the data may not be completely or comprehensively removed from Our systems.

13. DO WE MAKE UPDATES TO THIS POLICY?

In short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If We make material changes to this privacy policy, We may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how We are protecting your information.

Continued use of the Services following notice of changes to this Policy shall indicate your acknowledgement and acceptance of such changes and agreement to be bound by the updated Policy.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email Truu at privacy@truu.id