Privacy Policy

Last update: 08 January 2025

Protecting privacy should be a core belief for any Blockchain operator. This Privacy Policy describes our commitment.

We don’t collect or store your private keys, backup phrases, or passwords. The data we protect are the “Personal Data” which are the information related to an identified or identifiable person. This Policy is designed to comply with the regulatory requirements such as the General Data Protection Regulation (“GDPR”) in the European Union, California Consumer Privacy Act ("CCPA"), and all the other requirements of the jurisdictions in which we operate.

Debit cards, bank details, and other financial services–where available–are provided by third-party regulated companies. Always check their privacy policies before applying for their services.

If you do not agree with this Privacy Policy, in general, or any part of it, you should not use our Platform or any of the Services.

 

1. INTRODUCTION

Our Services are offered through one or more subsidiaries of Trustyfy Limited (each and collectively, “Trustyfy”, “Company”, “we”, “us”, or “our”). By using the Services, you understand that your Personal Data may be processed by one or more of those subsidiaries (each, a “Data Controller”).

You may contact our Data Protection Officer (“DPO”) anytime by email at privacy@trustyfy.com.

 

* Based on your country of residence.

We may collect data when you visit https://trustyfy.com and in general our websites, and our app https://app.trustyfy.com, each and collectively the “Platform”.

Please read this Policy carefully. If you do not agree with our policies and practices, in general or in any part of it, you should not use the Platform or any of the Services. By accessing or using the Platform, you agree to this Privacy Policy.

This Privacy Policy may change from time to time. By continuing to use the Platform after that, you accept those changes, so please check the policy periodically for updates.

2. YOUR DATA PROTECTION RIGHTS

This Privacy Policy is our commitment to protect your rights.

Access and rectification: You may request a copy of the information we process about you and ask us to rectify any incorrect data.

Erasure or restriction: You may ask us to delete or restrict our processing of your data that we are not legally required to collect and process.

Object to processing: In some circumstances, you may ask us to stop processing your data.

You should be aware that erasing, restricting, or objecting to processing may result in the Platform not working for you or not working well.

Data portability: In some circumstances, you may ask us to transfer your data to you or another organization.

Please get in touch with us if you have any questions about how we handle your data or want to exercise one of your rights. You are entitled to a reply within 30 days.

3. DATA COLLECTION

When you access or use the Services, we collect the following information:

Information you may provide to us: You may give us information about you by filling in forms on our websites or app, or by email and otherwise. This includes information you provide when you register to use the Services, including the Third-party Services, or when you report a problem about our Platform.

Information the Platform collects about you: When you visit the Platform, it will automatically collect automatic information to provide a better service, such as the type of browser and version you use, the time of access, the Internet Protocol (IP) address, the wallet addresses. Some information about the used devices and operating system are collected but anonymized (not tied to a specific person).

WE DO NOT AND CAN NOT COLLECT OR STORE YOUR PRIVATE KEYS, BACKUP PHRASES, OR PASSWORD.

Information required by law or regulation: When you apply for a paid service or a regulated third-party service, we may collect information regarding the payment transactions, and KYC (Know Your Customer) information such as your name, address, identification document, and so on.

Information from other sources: We may use web analytics tools and cookies that help us understand how users engage with our Platform. This information is used to improve the Platform and sometimes provide a personalized experience. You can opt-out of such third-party analytic tools and cookies, however you should be aware that the quality of your experience may be reduced.

4. HOW DO WE USE THE DATA

We use your Personal Data to:

• provide and improve our Services,

• develop new and enhance existing Services,

• address and resolve your requests,

• manage and develop our business,

• prevent and investigate criminal activities,

• meet legal and regulatory requirements.

We may aggregate Personal Data – meaning that the data are collected but anonymized (not tied to you or any other specific person) – to improve our Services and business.

WE DO NOT RENT, BUY OR SELL PERSONAL DATA FROM OR TO OTHERS, use automated decisions or profiling in the processing of your personal data, or process any special category data as per the GDPR Article 9.

Whom We Share Your Personal Data With

We practice privacy first and data minimization, so we will only use data suppliers to process your personal data when required (e.g. Stripe for Fiat payment processing).

To run our business efficiently and securely, we sometimes will have to share your personal data with other trusted parties such as:

• Data Processors,

• IT Support,

• Professional advisors,

• Public authorities, when it’s required to report to them.

Purpose and Lawful Basis

We only process your personal data when we have a purpose and a lawful basis for doing so. Under the GDPR Article 6-1, the lawful bases we rely on are:

• Your consent,

• A contract obligation,

• A legal obligation,

• A legitimate interest.

We do not process personal data for longer than necessary to fulfill the purpose for processing.

We will only retain data for as long as we are required to as per applicable laws, rules, or regulations.

5. DATA SECURITY

We are committed to the safeguard of your personal data. We will always do our outmost for the security of your information, including implementing dedicated measures and IT security personnel. The safety and security of your information also depends on you. Unfortunately, no transmission to the web is completely secure. Any transmission of personal information is also at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

6. TRANSFER OUTSIDE THE EU/EEA

If you are a resident of the European Union, you should be aware that – in some cases – your personal data may be transferred to an external country outside the EU/EEA (“third country”). For example, when we use email services.

We only use data processors we trust that are well known, reputable, and have a data processing agreement. We have ensured that every data processor in a third country has necessary safeguards in place like the EU adequacy decision, the SCC–Standard Contractual Clauses, and the BCR–Binding Corporate Rules.

7. CALIFORNIA RESIDENTS

This section provides additional privacy disclosures for California residents as required under the California Consumer Privacy Act (“CCPA”) concerning the collection and disclosure of Personal Information (as defined in the CCPA of California residents in the preceding 12 months.

In the preceding 12 months we collect:

• identifiers, such as name, contact information, online identifiers, email address, account name and other government-issued identifiers,

• commercial information, such as transaction information and transaction history,

• internet or network activity information, such as browsing history and interactions with our Platform,

• geolocation data, such as device location and IP location,

• professional or employment related information.

We may use this personal information to: (a) provide product and services, and to fulfill your requests, (b) operate, manage, and maintain our business, and (c) accomplish our business purposes and objectives.

Your Rights

Upon request and upon our verification of your identity, California residents may:

a) request access to the specific and Personal Information that we have collected about you over the past twelve months, the categories of sources of that information, our purposes for collecting the information, and the categories of third parties with whom the information was shared,

b) request and obtain a copy of your Personal Information in a format that would permit you to transfer that Information to another Repository,

c) request the deletion of your Personal Information, subject to certain exceptions,

d) to be free from unlawful discrimination for exercising your rights under the CCPA.

Please note that you must verify your identity and request before we take any further action. To do so, we will notify you of the requirement via email.

Do Not Sell My Personal Information

We do not and will never sell Personal Information. However, the CCPA define “Selling Information” in a broader sense, and it may include sharing the information to better operate the business. According to this definition, you may request us, subject to the exceptions in CCPA, to not “sell” your Personal Information. Be ensured that we will not make any adverse decision about you, or your account based upon your exercise of this right (“non-discrimination”).

You should be aware that certain sharing your Personal Information, such as sharing with Service Providers, is not considered “selling” by the CCPA.

Your request

To exercise any of these rights, you might contact us at privacy@trustyfy.com.

8. CHILDREN’S ONLINE PRIVACY PROTECTION ACT

We comply with the Children’s Online Privacy Protection Act (COPPA), which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13 years of age, or the above minimum age in the other relevant jurisdiction.

We do not knowingly collect, use or disclose personal information from children under such age without verifiable parental consent. However, it is possible that we may inadvertently receive information regarding to children under such age. If you believe so, please notify us at privacy@trustyfy.com.When we receive your notification, we will obtain the consent to retain the information or will delete it permanently.

9. CAYMAN ISLANDS DATA PROTECTION ACT

Subject to complying with the DPA, we may share your Personal Data with our subsidiaries and affiliate entities, service providers, and applicable regulatory and governmental authorities from time to time. Individuals have certain rights under the DPA with respect to their Personal Data, including the right to: (a) access your Personal Data, (b) have incomplete or inaccurate Personal Data corrected, (c) be informed about the purposes for which your Personal Data are processed, (d) restrict the processing of your Personal Data, (e) ask us to stop processing your Personal Data, (f) stop direct marketing, (g) be informed of a Personal Data breach (unless the breach is unlikely to be prejudicial to you); (h) complain to the Cayman Islands Data Protection Ombudsman, and (i) require us to delete your personal data in some limited circumstances.

10. CONTACTS

If you have any questions regarding this Privacy Policy or to access your information, please send a written request us by registered post or courier:

 

With an electronic copy to: privacy@trustyfy.com.

Or send an email to: