Effective Date: 14-12-2023
Version: 3
1. Introduction and Scope
This Privacy Statement sets out how Trustmoore uses your personal data as a user and visitor of our websites. This Privacy Statement applies only to the personal data processed via our websites. For any personal data collected via cookies please refer to our Cookies Policy. By accessing and using our websites you accept this Privacy Statement and agree to be bound by it.
Controller of the personal data processed via our websites is Trustmoore Netherlands B.V., a company operating in the Netherlands, registered with the Dutch Chamber of Commerce under company number 34324886, having its registered office at De Lairessestraat 145 A, 1075 HJ Amsterdam, the Netherlands, which company is responsible for the protection of your personal data.
2. DEFINITIONS
For the purposes of this privacy statement, the following terms shall have the definitions as set below:
“Controller”: The entity, which, alone or jointly with others, determines the purposes and means of the processing of personal data;
“Data Subject”: Identified or identifiable natural person;
“Personal Data”: Any information relating to a data subject and identifying a data subject directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, account number, etc. Anonymous data is not included in this category;
“Processing”: Any operation, or set of operations, which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“our websites”: the website https://trustmoore.com or any other website owned by the Trustmoore group;
“TMG”: Trustmoore Group;
“You”: Any user of our websites;
3. TYPES OF PERSONAL DATA COLLECTED AND PROCESSED VIA OUR WEBSITES:
The personal data that Trustmoore collects via our website is as follows:
- Communication Data: Includes any message you send to us, whether through the communication forms on our site, by email or any other type of message sent. We process this data for the purpose of communicating with you, for record keeping and for establishment, exercise or defense of legal claims. The legal basis for this processing is our legitimate interest, which in this case is to respond to messages sent to us, to maintain records and to establish, exercise or defense legal claims.
- User data: Includes data about how you use our website and other online services, together with any data you post on our websites or through other online services. We process this data to operate our websites and to ensure that we provide you with relevant content, to ensure its security, to maintain backup copies of our websites and/or database and to enable us to manage and administer our websites, other online services and business. The legal basis for this processing is our legitimate interest, which in this case allows us to properly administer our websites.
- Technical data: Includes data relating to the use of our website and online services, such as your IP address, login details, details of your browser, duration of your visit on our website pages, page views and navigation paths, details of the number of visits to our website, the time zone settings and other technologies of the devices you use to access our websites. The source of this data is from our analytics tracking system. We process this data to analyze the use of our website and other online services, to administer and protect our websites, to provide relevant content and advertisements, and to understand the effectiveness of our advertisements. The legal basis for this processing is our legitimate interest, which in this case will allow us to properly administer our websites, develop our business and determine our marketing strategy.
- Marketing data: Includes data related to your preferences for receiving marketing information from us and your preferred method of communication. We process this data so that we can include you in our newsletters. The legal basis for this processing is our legitimate interest, which in this case will help us to study how customers use our products/services, develop them, develop our business and determine our marketing strategy.
4. SPECIAL CATEGORIES OF PERSONAL DATA AND SENSITIVE PERSONAL DATA
We do not collect any special categories of personal data about you via our websites, e.g. data related to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political views, membership in trade unions, information about your health, genetic and biometric data are confidential. We do not collect information about criminal convictions and crimes via our websites. We do not collect or process personal data relating to children. If any of these types of data is submitted via our websites, we will take immediate action for their deletion.
5. HOW WE USE YOUR PERSONAL DATA
We will use your personal data only for the purpose for which it was collected. For more information, please write to us at: [email protected]. In the event that we need to use your data for an undisclosed purpose, we will notify you, setting out the legal reasons for our actions.
We may process your personal data without your knowledge or consent, but only to the extent permitted by law.
We do not perform automated decision-making or automated profiling.
6. HOW WE COLLECT PERSONAL DATA VIA OUR WEBSITES
We collect your personal data:
- Provided to us personally by you (for example, by filling in forms on our site or by sending emails);
- Automatic collection of certain data obtained from you when you use our websites through the use of cookies and other similar technologies. Please see our cookie policy for more details.
7. HOW WE SHARE YOUR PERSONAL DATA COLLECTED VIA OUR WEBSITES:
We share your personal data with the following parties:
- Data controllers within the TM Group: Your personal data will be shared between the Trustmoore entities that may use your personal data as described in this Privacy Statement for internal administrative purposes, management purposes, analytical purposes and other business-related purposes. Your personal data will only be used by us for marketing purposes if you have given your explicit consent thereto and/or where we have legitimate interest to do so.
- Service providers and processors: We engage with third party processors to provide services on our behalf, who may have access to your personal data, including: suppliers (such as IT service providers); marketing and advertising companies that carry out marketing activities on our behalf; analytics and search engine providers that assist us in the improvement and optimisation of our websites, such as Google Analytics. In providing their services, they will access, receive, maintain or otherwise process personal data on our behalf. Our agreements with these service providers do not permit use of your personal data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your personal data and only process it in accordance with our instructions.
- Third parties in case of legal requirement: We will disclose your personal data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process served on us, or to protect the rights or safety of our websites, Trustmoore or TM Group.
8. SECURITY
Trustmoore keeps the personal data confidential and will ensure that its staff and processors, and sub-processors are bound by the same confidentiality obligation. We implement appropriate technical and organizational measures to protect your personal data, preventing unauthorized or unlawful access to it. We provide access to your personal data only to employees on a need-to-know basis. They are instructed to process your personal data according to our instructions and policies and to comply with the confidentiality rules. We have a procedure in place to deal with a suspected breach of your personal data and will notify you and the relevant regulatory bodies of such breaches if, and when, necessary.
6. DATA RETENTION
We retain your personal data as long as required to satisfy the purpose for which they were collected and used, unless a longer period is necessary in order to fulfill our legal obligations or to meet our legitimate interests.
7. YOUR RIGHTS
We take appropriate measures to comply with data protection laws in order to ensure data subjects’ rights. In case you have any questions, requests or complaints regarding your rights, you are encouraged to contact us via [email protected]. A written question, request or complaint should have a clear subject related to your rights as a data subject, which are as follows:
- The right to be informed: You have the right to receive and request any information relating to the processing of your personal data. In case you cannot find the necessary information in this Privacy Statement, you can always request additional information at [email protected];
- The right of access: You have the right to receive information as to whether or not your personal data is being processed;
- The right to rectification: You have the right to obtain, without undue delay, the rectification of inaccurate personal data or completion of incomplete personal data;
- The right to erasure : You have the right to erase personal data, without undue delay, and subject to the applicable legal acts and regulations;
- The right to restrict processing: You have the right to obtain restriction of processing subject to the applicable legal acts and regulations;
- The right to data portability: You have the right to receive the personal data concerning you, which you provided to Trustmoore, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from us to which the personal data has been provided;
- The right to object: You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you;
- The rights in relation to automated decision making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- The right to withdraw your consent: You have the right to withdraw any consent given regarding the processing of your personal data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You can exercise any of the rights stated above by sending an email to: [email protected] specifying your request.
You may lodge a complaint with a supervisory authority, in particular in your member state of residence or the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at PO Box 93374 2509 AJ DEN HAAG or at telephone number: (+31)-(0)70-8888500, if you consider that the collection and use of your personal data infringes this Privacy Statement or applicable law.
8. CHANGES TO THIS WEBSITE PRIVACY STATEMENT
This website Privacy Statement may be revised from time to time. If a fundamental change to the nature of the use of your personal data is involved or if the change is in any other manner relevant to you, we will ensure that information is provided to you well in advance of the change actually taking effect.
9. Contact Us
If you have any questions, comments or complaints in relation to this Privacy Policy or the processing of your personal data, please feel free to contact your customary Trustmoore representative or our compliance team via [email protected] or +31204712707.
