This Privacy Policy (“Privacy Policy”) regulates the collection, use, and disclosure of Personal Data and other information when You use Trustee Plus and regulates the legal relationship in the field of Personal Data protection between You and Trustee Plus (UAB Trustee Global, company, registered in Lithuania, code 306099031, collectively, “We”, “Company”).
Rispettiamo e apprezziamo la privacy di tutti coloro che visitano il nostro sito web o utilizzano i nostri servizi, e raccogliamo e utilizziamo le informazioni solo in modi utili per l'utente e in modo coerente con i suoi diritti e i nostri obblighi ai sensi della legislazione sulla protezione dei dati.
L'Informativa sulla privacy è parte integrante delle Condizioni d'uso. Se non diversamente definito nella presente Informativa sulla privacy, i termini utilizzati nella presente Informativa sulla privacy hanno lo stesso significato delle Condizioni d'uso. Se l'utente non accetta la presente Informativa sulla privacy, non è autorizzato a utilizzare Trustee Plus.
Upon use of the Trustee Plus, You certify that You consent to the Privacy Policy and also accept the Terms of Use. By providing us with Your personal information, You also consent for us to collect, hold, use and disclose your Personal Data in accordance with this Privacy Policy.
1. Definition
1.1 Data Controller means a person who determines the purposes for which and the manner in which any personal information is, or is to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of Your Personal Data. If You have any questions, contact us at: [email protected]
1.2 Data Subject (or You) is any living individual who uses Trustee Plus and is the subject of Personal Data.
1.3 Personal Data means data about a living individual who can be identified from that data.
1.4 Processing means any operation or set of operations which is performed on Personal Data or on sets of personal data, whether by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
1.5 Third Party means a natural or legal person, public authority, agency or body other than the Data Subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data;
1.6 Website means a website that is operated by Trustee Plus and available at https://trusteeglobal.com
2. Legal grounds for the processing of Your Personal Data
2.1 Processing of Your Personal Data is necessary for the performance of our contract with You, the User of our Website and Services – GDPR Article 6(1)(b);
2.2 Processing of Your Personal Data is necessary for compliance with a legal obligation – GDPR Article 6(1)(c);
2.3 Processing of Your Personal Data is necessary for the legitimate interests of both Trustee Plus and You as the User and data subject – GDPR Article 6(1)(f). Specifically:
2.3.1 ensuring Trustee Plus’s systems are secure and for the purposes of performance and error monitoring and incident response;
2.3.2 improving the performance and User experience of the Trustee Plus.
3. Purposes of collecting Personal Data
3.1 Maintaining and providing You with the Trustee Plus / Website / our Services;
3.2 Providing, maintaining, delivering or improving our Website, the Trustee Plus provided through our software;
3.3 Making more of such Services available to You where possible and appropriate;
3.4 Fulfilling our legal or regulatory requirements, compliance with our policies and obligations, including, but not limited to, disclosures and responses in response to any requests from law enforcement authorities and/or regulators in accordance with any applicable law, rule, regulation, judicial or governmental order.
3.5 Providing You with the information or Services that You have requested;
3.6 Carrying out any actions for which we have received Your consent, carrying out any other purpose or reason for which the information was collected.
| Tipo di dati personali | Tempi e modalità di ricevimento | Scopo e/o attività | Base giuridica del trattamento |
| Numero di telefono | Durante la procedura di registrazione/accesso/verifica | Per registrarLa come nuovo cliente/
Per proteggere il vostro account con 2FA |
Consent/ Performance of a contract |
| Durante la procedura di registrazione/accesso/verifica | Per registrarLa come nuovo cliente/
Per proteggere il vostro account con 2FA |
Consent/ Performance of a contract |
|
Documenti per persone fisiche, se decidete di fornirceli:
|
Durante il processo di verifica | Per soddisfare i requisiti KYC, ai fini della verifica dell'individuo | Consenso/ Adempimento di un obbligo legale |
Dati sull'utilizzo del dispositivo e del sito web:
|
Durante l'utilizzo di Trustee Plus / Sito web nostro / Servizi | Per garantire la sicurezza degli account degli utenti e soddisfare i requisiti della politica antiriciclaggio. Utilizziamo questi tipi di dati anche per proteggere gli Utenti da abusi automatici come spam, phishing e attacchi DDoS (Distributed Denial of Service). | Consent/ Performance of a contract |
| Attività del conto:
1. attività commerciale; 2. la cronologia delle transazioni; 3. termini di ordinazione; 4. ordini creati; 5. stato del conto e notifiche; 6. valuta predefinita, lingua predefinita, fuso orario. |
Durante l'utilizzo di Trustee Plus / del sito web / dei nostri servizi | Garantire la sicurezza dei conti degli utenti e soddisfare i requisiti della politica antiriciclaggio. | Compliance with a legal obligation / Performance of a contract |
| Biscotti | Durante l'utilizzo di Trustee Plus / Portafoglio fiduciario / Sito web | To improve the quality of Services. You can easily remove any cookies that have been created in the cookie folder on Your browser settings. You can instruct Your browser to refuse all cookies or to indicate where a cookie is being sent. |
Consenso/ Esecuzione di un contratto |
| Le informazioni fornite volontariamente dall'utente quando contatta l'assistenza. | Durante l'utilizzo di Trustee Plus e nel processo di fornitura dell'assistenza all'utente | Per contattarLa in risposta alle Sue richieste, commenti e suggerimenti e per migliorare i nostri Servizi.
Conserveremo queste informazioni per il tempo necessario a fornirvi assistenza tecnica. |
Consenso/ Esecuzione di un contratto |
4. KYC Ecosystem Database. Disclosure of Personal Data
4.1 As a general principle, we collect and process Personal Data in order to facilitate or improve our Services or offers
4.2 In order to simplify Your use of all Trustee Plus features, we establish the KYC Ecosystem Database, the creation and use of which is in full compliance with GDPR, legislation and personal data protection regulations.
4.3 We protect KYC Ecosystem Database and Personal Data with appropriate physical, technological and organizational safeguards and security measures. The access to KYC Ecosystem Database and Personal Data is restricted and certain access rights are set.
4.4 We do not sell Your Personal Data or share this data with Third Parties, except to the extent stated in this Privacy Policy. We may disclose Personal Data only to the extent expressly permitted by applicable law and this Privacy Policy.
4.5 We engage qualified providers (Third Parties) on a contractual basis to ensure the security and lawfulness of the collection and processing of Personal Data that is part of the KYC Ecosystem Database.
4.6 The placement of Your Personal Data in the KYC Ecosystem Database and its transfer to Third Parties is done solely on the basis of Your consent, which we request from You. That said, You consent to the transfer of such data to Third Parties as set forth in agreements with Third Party service providers. If You do not provide such consent, You are not allowed to use Trustee Plus.
4.7 We may share Your Personal Data with the following Third Parties:
4.7.1 external services or authorities when such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect Your vital interests;
4.7.2 other Third Parties subject to Your consent.
4.8 When we disclose Your Personal Data to a Third Party, we take all reasonable steps to ensure that those Third Parties are bound by confidentiality and privacy obligations with respect to the protection of Your Personal Data. The disclosure is conducted in compliance with legal requirements, including entering into data processing agreements with the relevant Third Parties, to ensure that Personal Data is only processed in accordance with our instructions, applicable law and regulations and for the purpose specified by us and to ensure adequate security measures.
4.9 Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without Your consent, other than for the purpose of delivering the requested Services and improving our Services.
5. Storage / Retention / Deletion of Your Personal Data
5.1 We retain the information of You only as long as it is necessary, in accordance with the purpose of collecting the data and required by law. When Personal Data and other information is no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form.
5.2 All Personal Data can be removed by You if You choose to. You can revoke consent and/or request deletion of Your Personal Data at any time by contacting us at [email protected]
5.3 We reserve the right to store/process Personal Data in accordance with the specific purpose of their storage/processing without limitation of storage and processing time in cases stipulated by law.
5.4 Withdrawal of consent and/or deletion of Your Personal Data disables the use of certain Feature of the Trustee Plus by You.
5.5 We will erase Your Personal Data without undue delay where one of the following grounds applies:
5.5.1 the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
5.5.2 You withdraw consent on which the processing is based and where there is no other legal ground for the processing;
5.5.3 You object to the processing and there are no overriding legitimate grounds for the processing;
5.5.4 the Personal Data has been unlawfully processed;
5.6 he Personal Data has to be erased for compliance with a legal obligation in Union or Member State law to which the Data Controller is subject.
5.7 We may retain Your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject to, or in order to protect Your vital interests or the vital interests of another natural person in accordance with GDPR Article 6(1)(c).
6. Security of Personal Data
6.1 Data security is of great importance to us, and to protect Your Personal Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Websites and mobile application. Steps we take to secure and protect Your data include:
6.1.1 2FA;
6.1.2 the access control;
6.1.3 the ability to ensure the ongoing confidentiality, integrity, availability and resilience of our Services;
6.1.4 the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident.
6.2 If You suspect that Your Personal Data or User Account has been compromised, especially account and/or password information, please lock Your User Account and immediately contact us at [email protected]
7. International transfer of Personal Data
7.1 Some features and requirements of our service, involve transferring Your information to the Third Party service providers outside the EEA. Where such service providers are not established in a country ensuring an adequate level of protection within the meaning of GDPR, the transfers will be covered by the standard data protection clauses adopted by the European Commission or by another appropriate safeguard mechanism.
8. Data Subject’s rights
8.1 You have the right to:
8.1.1 get confirmation as to whether or not we process Your Personal Data and, where we do, to access the Personal Data. We will supply to You a copy of Your Personal Data;
8.1.2 modify and correct your Personal Data at any time and You are therefore responsible for the accuracy of Your Personal Data;
8.1.3 ask about Your Personal Data from us to data portability and also the right to request us to restrict the processing of Your Personal Data and/or to delete it in case obligation to retain the data is not set out by the law;
8.1.4 object to processing of Your Personal Data and/or to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
8.1.5 erasure of Your Personal Data.
8.2 Legal Basis for Processing Personal Data in the European Economic Area (EEA) stated in the General Data Protection Regulation (GDPR). We aim to take reasonable steps to allow You to correct, amend, delete, or limit the use of Your Personal Data.
8.3 If You are a resident of the European Economic Area (EEA), You have certain data protection rights stated in the General Data Protection Regulation:
8.4 The right to access, update or to delete the information we have on You. Whenever made possible, You can access, update or request the deletion of Your Personal Data directly. If You are unable to perform these actions yourself, please contact us to assist You.
8.5 The right of rectification. You have the right to have Your information rectified if that information is inaccurate or incomplete.
8.6 The right to object. You have the right to object to our processing of Your Personal Data.
8.7 The right of restriction. You have the right to request that we restrict the processing of Your Personal Data.
8.8 The right to withdraw consent. You also have the right to withdraw Your consent at any time where we relied on Your consent to process Your Personal Data.
8.9 You can exercise Your rights by contacting us at [email protected]
8.10 If You wish to be informed what Personal Data we hold about You and if You want it to be removed from our systems, please contact us at [email protected]
8.11 You have the right to complain to a Data Protection Authority about our collection and use of Your Personal Data. For more information, please contact Your local data protection authority in the European Economic Area (EEA).
9. Children’s Privacy
9.1 Wallet does not address anyone under the age of 18 (“Children”).
9.2 We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your Children have provided us with Personal Data, please contact us at [email protected]
9.3 If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information.
10. Amendments
10.1 We may change, update, delete or add this Privacy Policy at any time.
10.2 Any such changes will be effective upon the posting on a Website or mobile application. The effective date which is at the top of the Privacy Policy informs You about the latest version of the Privacy Policy.
10.3 Your continued use of the Wallet and/or Website constitutes Your acceptance of such changes and Your consent to the processing of Personal Data according to the latest version. If You do not agree with any such changes, do not continue to use the Trustee Plus and/or Website.
11. Questions and Complaints
11.1 Any questions about this Policy, the collection, use, and disclosure of Personal Data or access to Your Personal Data which is required by law (or would be so subject had the storage in question taken place in a relevant EU member state if the case may be but not otherwise) to be disclosed should be directed to [email protected]
11.2 In the event that You wish to make a complaint about how we process your Personal Data, please contact us in the first instance at [email protected] and we will endeavor to deal with Your request as soon as possible.