Privacy Policy

Date published: December 2024

INTRODUCTION

‍At Trusto, we are committed to protecting your privacy and ensuring the security of your Personal Data. This Privacy Notice explains how we collect, use, disclose, and safeguard your Personal Data when you visit our website www.trusto.io (“Website”), use our services available through the Website (“Services”), or interact with us in other ways. We are dedicated to being transparent about how your data is handled and ensuring that your privacy rights are respected in accordance with applicable laws, including but not limited to the UAE Personal Data Protection Law (PDPL), General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other data protection regulations.

By accessing and using our website, you agree to the collection and use of your Personal Data as described in this Privacy Notice. In certain cases, we may obtain your explicit consent (for example, when you subscribe to our services or submit personal information) to process your data. In other instances, your consent may be implied through your actions, such as browsing our website or using our services. You are free to withdraw your consent at any time by contacting us using the information provided below.

We encourage you to read this document carefully so that you fully understand how we process your Personal Data and what choices you have in relation to it.

‍CONTENT

‍DEFINITIONS
ABOUT US
DATA COLLECTION AND USE
PURPOSES AND LEGAL BASES
AUTOMATED PROCESSING AND PROFILING
SECURITY
SHARING PERSONAL DATA WITH THIRD PARTIES
INTERNATIONAL TRANSFER
YOUR RIGHTS
CHILDREN'S PRIVACY
COOKIES
LINKS TO OTHER SITES
CHANGES TO PRIVACY NOTICE

‍DEFINITIONS

"Trusto," "we," "us," or "our" refers to Trusto L.L.C-FZ, a company registered in the United Arab Emirates with business license number 2422718.01, and registered address Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, UAE.
‍Data Controller – the natural or legal person who determines the purposes for which and the manner in which Personal Data is, or is to be, processed. For the purpose of this Privacy Notice, Trusto is a Data Controller of your Personal Data.
Data Subject – any individual whose Personal Data is being collected or processed.
‍Consent – permission given by an individual to allow their personal data to be processed. This can be given directly (such as ticking a box) or implied (such as continuing to use a service after being informed about data processing).
‍Cookies – small files placed on the user's device by websites to store information like login details, preferences, or browsing activities. They help improve website performance and track behavior for analytics or advertising.
Personal Data – any information that can identify a person, such as their name, contact details, or location.
Services – the chargeback prevention services and other related services offered by Trusto through the Website.
Website – the official website of Trusto, accessible at www.trusto.io.

ABOUT US

‍Trusto is a company registered under the laws of the United Arab Emirates, located in the Meydan Free Zone, Dubai, UAE. We specialize in providing chargeback prevention and related payment dispute management services to businesses worldwide.

As a Data Controller, we always take your privacy seriously and are committed to protecting the Personal Data you share with us. Should you have any questions or concerns, you may contact us via email at support@trusto.io

‍DATA COLLECTION AND USE
‍
‍We collect various types of data to provide and improve our services. Below is a detailed overview of the data we collect, the purposes for which it is processed, the legal basis for processing, and how long it is retained:‍

Personal Information
- Examples of Data Collected: Name, Email, Phone number, Job title, Company name
- Purpose of Collection: To provide services, communicate, and support you
- Legal Basis for Processing: Performance of a contract, Legitimate interest, Consent
- Retention Period: Duration of the business relationship or until consent is withdrawn

Account Information
- Examples of Data Collected: Login credentials (username, password), Preferences
- Purpose of Collection: To manage your account and provide personalized services
- Legal Basis for Processing: Performance of a contract
- Retention Period: As long as your account remains active

Payment Information
- Examples of Data Collected: Billing address, Transaction details
- Purpose of Collection: To process payments and prevent fraud
- Legal Basis for Processing: Performance of a contract, Legal obligation
- Retention Period: 7 years (for tax and accounting purposes)

Technical Data
- Examples of Data Collected: IP address, Browser type, Operating system, Device type
- Purpose of Collection: To maintain security, improve functionality, and analyze use
- Legal Basis for Processing: Legitimate interest
- Retention Period: 1 year

Usage Data
- Examples of Data Collected: Pages visited, Time on site, Clicks and interactions
- Purpose of Collection: To improve website experience and optimize services
- Legal Basis for Processing: Legitimate interest, Consent (for analytics cookies)
- Retention Period: 1 year or until consent is withdrawn

Cookies Data
- Examples of Data Collected: Cookie identifiers, Tracking data
- Purpose of Collection: To provide website functionality and personalized content
- Legal Basis for Processing: Consent
- Retention Period: Until cookies are deleted or consent is withdrawn
‍
Trusto may also process your Personal Data for the following additional purposes:

Providing Our Services: To ensure the smooth operation of our chargeback prevention services.
Maintaining Our Security: To detect and prevent fraud, security threats, and unauthorized access.
Handling Contacts and User Support Requests: To respond to your inquiries, support requests, and feedback.
Improving Our Services and Conducting Marketing Activities: To enhance our services, develop new features, and send relevant marketing communications (with your consent).

‍AUTOMATED PROCESSING AND PROFILING

‍We may use automated decision-making processes in certain circumstances, such as to enhance our Services, streamline operations, and comply with regulatory requirements. Automated decision-making involves using algorithms or software to make decisions without human intervention. Below is an overview of such practices:

‍How We Use Automated Decision-Making

Fraud Detection and Prevention:
We may use automated systems to identify potentially fraudulent activities based on transaction patterns, IP addresses, or other behavioral indicators.
This helps protect both our users and our platform from fraudulent or unauthorized activities.

‍Chargeback Dispute Management:
Automated tools may assist in analyzing transaction details and generating recommendations for managing or disputing chargebacks efficiently. This ensures faster and more accurate resolutions.
‍Service Optimization:
Automated processes are used to personalize user experiences, such as suggesting relevant content or improving platform functionality based on historical data.

‍Your Rights Regarding Automated Decisions

‍As a user, you have certain rights related to automated decision-making, including:
The right to request human intervention for decisions that significantly affect you.
The right to express your opinion and contest any decision made solely through automated means.
The right to receive an explanation of the logic behind such decisions.To exercise these rights or seek further information, please contact us at support@trusto.io

‍SECURITY

‍We use reasonable measures to help protect data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Furthermore, we restrict access to your Personal Data to authorized personnel, agents, contractors, and relevant third parties who have a legitimate business requirement to access such information. They are obligated to process your Personal Data solely based on our instructions and are bound by confidentiality obligations.

‍SHARING OF PERSONAL DATA WITH THIRD PARTIES

‍We may share your Personal Data with third parties under specific circumstances, as outlined below. All such transfers are conducted in accordance with this Privacy Notice and applicable data protection laws, including the UAE Personal Data Protection Law (PDPL).

‍Our Subcontractors, Affiliates, and Partner CompaniesTo deliver and maintain our Website and Services, we collaborate with subcontractors, affiliated companies, and partners. These entities may process your Personal Data on our behalf. All data transfers are secured through appropriate data transfer agreements to ensure compliance with applicable laws and this Privacy Notice.

‍Categories of Service Providers and Their Roles

‍We engage third-party providers for the following purposes:
‍Website and Data Hosting
To securely store and host the Website and associated data.
‍Marketing Services
For personalized marketing campaigns and audience engagement.
‍IT and Security Services
To maintain the integrity and security of our systems.
‍Customer Support Services
To provide efficient customer assistance using third-party platforms.
‍Payment Service Providers
To securely process transactions.
‍KYC, Anti-Fraud, and Compliance
To verify user identities, prevent fraud, and meet anti-money laundering obligations.
‍Audit, Legal, and Compliance Services
To fulfill regulatory or operational requirements.

‍Data Center Hosting

‍Our Website and Services are hosted on servers operated by trusted third parties. Data is stored in encrypted form, adding an extra layer of protection by ensuring it cannot be accessed without decryption keys.

‍Financial Institutions

‍We may share Personal Data with banks, payment processors, and financial entities to process transactions and comply with legal obligations. This includes data necessary for completing payments and fulfilling regulatory requirements.

‍Accreditation Bodies and Auditors

‍During audits or accreditation processes, your data may be shared with independent auditors or regulatory bodies. These entities are legally bound to handle your data in line with this Privacy Notice and applicable regulations.

‍Analytics Providers

‍We collaborate with analytics providers, such as Google Analytics, to:

Measure and understand user behavior on our Website.
Tailor marketing strategies to better serve our audience.
Improve the overall user experience.

Wherever possible, data shared with these providers is anonymized or aggregated.

‍INTERNATIONAL TRANSFER

‍We may transfer your Personal Data to countries outside the UAE to facilitate the delivery of our Services, engage with service providers, or for other operational purposes. These transfers are conducted in compliance with applicable data protection laws, ensuring your data remains protected at all times.

To ensure your data is protected during international transfers, We implement the following safeguards:

‍Adequate Jurisdiction Assessment. Transfers are made only to countries deemed to provide an adequate level of data protection under applicable UAE regulations or other recognized standards.

‍Standard Contractual Clauses (SCCs). Where necessary, we use SCCs or equivalent legal mechanisms approved by relevant authorities to safeguard data.

‍Explicit Consent. In situations where no other legal mechanism is available, we will obtain your explicit consent for transferring your data internationally.

‍YOUR RIGHTS

‍Under applicable data protection laws, including the UAE Personal Data Protection Law, you have certain rights concerning your Personal Data. These rights include:

‍Right to Access. You have the right to request a copy of your Personal Data that we hold.
‍Right to Rectification. If your Personal Data is inaccurate or incomplete, you have the right to request that we correct or complete it.
‍Right to Erasure. You can request the deletion of your Personal Data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.
‍Right to Object. You have the right to object to our processing of your Personal Data, including in cases where we process it based on legitimate interests or for direct marketing purposes.
‍Right to Restriction of Processing. You have the right to request the restriction of processing of your Personal Data, for instance, if you contest the accuracy of the data or if the processing is unlawful.
‍Right to Data Portability. You have the right to request a copy of your Personal Data in a structured, commonly used, and machine-readable format, and to transfer this data to another service provider, where technically feasible.
‍Right to Lodge a Complaint. If you believe that we have not complied with data protection laws, you have the right to lodge a complaint with a relevant supervisory authority, such as the UAE Data Office or other regulatory bodies.If you wish to exercise any of these rights, please contact us at support@trusto.io 

‍CHILDREN’S PRIVACY

‍Our Website and Services are not intended for use by individuals under the age of 18. If you are under 18, please do not use our Website, Services, or provide any Personal Data.If we become aware that we have collected Personal Data from an individual under the age of 18, we will take steps to delete that information promptly.

‍COOKIES

‍Our Website uses cookies and similar tracking technologies to improve user experience, analyze usage patterns, and personalize content and advertisements. Cookies are small files stored on your device that help us recognize you when you return to our Website. You can manage your cookie preferences at any time by adjusting your browser settings or using the cookie management tools provided on our Website.

‍Types of Cookies We May Use

Essential Cookies
These cookies are necessary for the functioning of our Website and cannot be disabled in our systems. They are typically set in response to actions such as logging in or filling out forms. 
‍Performance and Analytics Cookies
These cookies help us understand how visitors interact with our Website, enabling us to improve functionality and performance.
‍Functional Cookies
These cookies allow the Website to remember choices you make and provide enhanced, more personal features.
‍Advertising and Marketing Cookies
These cookies are used to deliver targeted advertisements and analyze the effectiveness of marketing campaigns. 

‍LINKS TO OTHER SITE

Our Website or Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy notice of every site you visit

‍CHANGES TO THE PRIVACY NOTICE
‍
‍We may update this Privacy Notice from time to time. When We update the Privacy Notice, we will revise the “Date published” above and post the new Privacy Notice.  We recommend that you review the Privacy Notice each time you visit the Website or use Services to stay informed of our privacy practices.Date published: December 2024