Privacy Statement
Last Updated: 30th May 2024.
Trusx Plus Inc. ( “we,” “us,” or “our”) deeply believes in the
importance of earning and maintaining your trust. As such, we
are strongly committed to protecting your privacy rights. You
should carefully read this Privacy Statement (“Statement”) to
inform yourself on how Trustr collects, uses, shares, or
otherwise processes information relating to individuals
(“Personal Data”), and to learn about your applicable rights
regarding such processing.
I. About the Statement – Processing Activities
This Statement applies Personal Data processed by Trustr when
you:
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visit this website (www.trustr.ai) and/or any other Trustr
website(s) which reference or link to this Statement
(collectively, “Website”);
-
use, download, access, as applicable, any of our various
internet-based offerings, including any paid or non-paid
subscriptions, newsletters, mobile platforms, webinars,
briefings, programs, software, or applications (collectively,
“Services”);
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visit Trustr’s branded social media sites;
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receive communications from us, including emails, phone calls,
or other electronic messages; or
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attend or register for any of our events, conferences,
networking/community offerings, etc.
It applies whether you have provided the information directly to
us or if we have obtained such information from a different
source, such as a third party. This Statement may be
supplemented by additional privacy notices provided to you.
Notwithstanding the foregoing, if you or your organization have
previously entered into a separate, written agreement with
Trustr governing your existing use of the Services (“Subscriber
Agreement”), any conflicting privacy terms of the Subscriber
Agreement shall control as set forth therein.
It is important to understand that the Website and the Services
may contain links to sites or offerings operated by individuals
or entities other than Trustr. Such links, where applicable, are
provided for your reference and convenience only. Trustr is not
responsible for the content or operation of such sites or
offerings, nor the security or privacy of any information
collected by such third parties. You are solely responsible for
determining the extent to which you may use any such content,
and you should review the corresponding privacy policies
applicable to these third-party sites or offerings.
II. Information We Collect
We collect some information directly from you (for example, via
forms you complete or products or Services you access, download,
or otherwise obtain). Such information is generally limited to:
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Name, job title, contact details, and company or organization;
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Your communications with Trustr personnel;
- Content you post on our social media sites;
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Information you provide on the Website, such as online
questionnaires, or feedback forms;
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Information you provide when you subscribe to email
newsletters such as your interest in specific Trustr research
areas;
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Limited billing information, collected and used strictly for
billing purposes only, is not shared or used for any other
purposes, and is and will be processed in accordance with all
applicable laws. To be clear, Trustr almost never collects
billing information from individuals, as typically our
offerings are paid by your company or organization.
Other information is received indirectly from you via use of the
Services or from your organization on your behalf (for example,
from observing your actions on the Website or to provision you
with account access). Such information is generally limited to:
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Information regarding usage of the Services or Website via web
logs collected automatically and passively using various
technologies, which generally will not specifically identify
you or other individuals. Examples may include IP addresses,
browser types, domain names, and other anonymous statistical
data regarding aggregate usage;
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Download restrictions or other such consumption limits, where
applicable, attributed to your Trustr account, username, email
address, registration, etc. Additionally, if you elect to
download and use any optional third-party applications with
the Services (for example, theChrome plugin), we will detect
and store information necessary for you to effectively use the
third-party application; and
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Information provided by your employer or organization, such as
name, email, other contact information, job title, etc., to
activate and manage your access to and use of the
organization’s subscription to the Service.
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With your further consent, scan an attendee badge or QR code,
which will provide contact information such as your name,
title, company name, and email address;
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Record or otherwise broadcast conference presentations or
locations; and
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Collect information regarding dietary requirements or any
reasonable accommodations needed to attend and enjoy the
event.
Lastly, we also collect Personal Data via other sources such as
public records, publicly available sources or internet sites,
vendors, data suppliers and service providers, commercially
available marketing lists or registries, telephone directories,
social networks (such as LinkedIn), news outlets and related
media. Such Personal Data collected via these sources is
typically limited to business contact information, such as
names, contact information, job titles, IP addresses, and
LinkedIn and other social media profiles.
III. Use of Cookies, Tracking Technologies, and other Electronic
Tools.
A “cookie” is a small text file with a unique identifier placed
on a browser or online device, used to collect limited
information about your online preferences and increase website
efficiency. When you visit the Website, Trustr or one of our
authorized third parties may place a cookie on your browser
and/or device. We also use web beacons in some email
communications. Trustr uses such cookies and other tracking
technologies to manage your preferences, customize and deliver
content and advertising, provide social media features, and
examine usage information pertaining to Website visits.
We may use both “session cookies” (which disappear once the
browser is closed or computer is turned off) and “persistent
cookies” (which remain in operation until deleted). You can
manage website cookies in your relevant browser settings, and
you always have the choice to change these settings by
accepting, rejecting, or deleting cookies. If you choose to
change your settings, you may find that certain Website or
Services functions and features will not work as intended.
The following describes how we use or may choose to use
different categories of cookies and similar technologies:
Required or essential cookies. These cookies are necessary for
the Website’s basic operations and there are no options to
disable. For example, session cookies needed to transmit the
Website, authentication cookies, and security cookies.
Social media cookies. These cookies allow users to share our
website, or materials on social media sites. Because these
cookies are not within our control, you should refer to their
respective privacy policies to understand how they work.
Advertising cookies. Advertising cookies track activity across
websites to understand a viewer’s interests, and to direct
specific marketing to them. Trustr may now or in the future
elect to contract with third-party advertising networks that
collect IP addresses and other information from web beacons on
our websites, from emails and on third-party websites.
Functionality cookies. These cookies help us customize our
website content based on a user's preferences. They remember the
user's choices, their language, the country pages visited and
any changes the user makes to text size or other parts of our
website pages. The information these cookies collect may be
anonymized and they cannot track browsing activity on other
websites.
At any time, you can prevent cookies from being set on your
browser. For instructions on how to block, delete or disable any
cookies, please consult your browser's “Help” or “Support”
section.
IV. Use of Personal Data
Trustr uses your Personal Data when: it is necessary to perform
our obligations or exercise our contractual rights; we have a
legitimate business interest to process such Personal Data; it
is necessary to comply with applicable laws or regulations; we
have your consent (where required under applicable law) to use
your information (where we rely on your consent, you have the
right to withdraw consent by contacting us as set forth below).
Such legal reasons are identified for the following common
instances: Administering our Website and Providing Services:
Personal Data is processed to perform our contractual
obligations, where applicable. In instances where we have not
entered into a contract with you, such processing is based on
our legitimate interest to manage and promote our business,
operate and administer the Website, provide and improve the
Services, and to provide requested content or materials (for
example, when you request to download one of our reports from
the Website).
User Registration: In accordance with our contractual
obligations or legitimate interest to provide Services, when you
register for an account with Trustr (whether as a paying client
or on a complimentary basis), we process your Personal Data as
needed to register and administer your account, provide
technical and client support and training, verify your identity,
and send important account, subscription, and Services
information.
Support Requests: If you request that Trustr contacts you (for
example, for free trial access or to learn about our offerings),
or if you contact us by other means, we process your Personal
Data to the extent it is necessary for our legitimate interest
in fulfilling your requests and communicating with you, or as is
required by contractual obligations.
Compliance; Security and Functionality of Website and Services:
For our legitimate interests in ensuring adherence to relevant
terms, we process your Personal Data to review compliance with
the applicable usage. Personal Data is also processed by
tracking use of the Website and Services, to perform our
contractual obligations, where applicable, to provide a secure
and functional experience. In instances where we have not
entered into a contract with you, such processing is based on
our legitimate interest in promoting the safety and security of
the Website, Services, systems and applications and in
protecting our rights and the rights of others, whereby we
reserve the right to monitor, investigate and report any
attempts to breach the security of the Website or Services,
verify accounts and activity, and enforce our terms and
policies.
Event Registration and Attendance: We process your Personal Data
to plan and host events, conferences, networking/community
offerings for which you have registered or attend, by sending
related communications to you, to perform of our contract with
you, or as part of our legitimate interest to operate and
improve our events business, enable peer networking
opportunities, promote our brand, and collect relevant
information for hospitality and health and safety purposes.
Improving Website and Services; Developing Offerings: We process
your Personal Data to analyze trends, usage, and interactions
with the Website and Services to the extent it is necessary for
our legitimate interest in improving the Website and Services,
developing new offerings, and providing individuals with
tailored content and to personalize your experience with our
Services. In certain instances, we will process your Personal
Data for such development by directly seeking your input (for
example, through surveys).
Identifying Client Interests and Opportunities: Because it is in
our legitimate business interest to meet our client demands and
ensure positive user experiences, we may process your Personal
Data to assess new potential customer opportunities as relevant.
Marketing Communications; Advertisement. It is our legitimate
business interest to promote our Website and Services, grow our
company, and advertise our offerings (whether via direct
marketing or providing personalized content advertisements), and
as such we will process your Personal Data by sending certain
marketing information, product recommendations, custom research,
and other communications (for example, newsletters, sales calls,
or other electronic communications) solely as necessary to
reflect such legitimate interests, or, if applicable, to the
extent you have provided your prior consent.
Payments: In the rare instances where you have provided
financial information to us, Trustr will process your Personal
Data to verify such information and to collect payments solely
as needed to complete a transaction and perform our contractual
obligations.
Legal Obligations: We may be required to process Personal Data
for legal and compliance reasons we believe to be necessary or
appropriate under applicable law (which may include laws outside
your country of residence). Such processing may be required to:
respond to requests from courts, law enforcement agencies,
regulatory agencies, and other public and government
authorities; enforce our terms of service or other terms and
conditions; or protect our rights, privacy, safety, or property,
or those of other persons.
V. Sharing Information.
Trustr may share Personal Data as follows:
Contracted Service Providers. As necessary to provide the
Services, conduct our business operations, or when we believe
that applicable law permits or requires disclosure, we may share
Personal Data with contracted service providers, including
entities which provide for hosting and system administration,
payment processing, analytics, marketing, data enrichment, or
client support, to the extent necessary and in accordance with
the legal bases set forth above. These service providers only
receive Personal Data necessary to fulfill the services they
provide to Trustr. Under no circumstances are such service
providers permitted to use obtained Personal Data for any
purpose other than to provide Trustr with the designated
services.
Your Employer. To the extent you are an authorized user of the
Services or have otherwise registered for Trustr offerings using
your corporate email address, we may share Personal Data with
your employer to the extent this is necessary to provide you
with access, to verify accounts and activity, investigate
suspicious activity, or enforce our terms and policies.
Event Sponsors. If you attend a Trustr event, conferences,
networking/community offerings, we may share limited Personal
Data with certain event sponsors. If you do not wish for your
information to be shared, you may choose not to participate in
the event, may contact our events team as described in
registration communications, or you may write to us as described
below.
Mergers or Acquisitions. In the event of a merger, acquisition,
consolidation, change of control, corporate divestiture, or
dissolution where we sell all or a portion of our business or
assets, we will disclose necessary Personal Data and such
information will be governed by the privacy policies of
acquiring entities. In accordance with applicable laws, we will
use reasonable efforts to notify you of any transfer of Personal
Data to an unaffiliated third party.
Data Analytics. Occasionally, we may share non-personal,
anonymized, and statistical data with third parties, for the
purpose of helping Trustr with such analysis and improvements.
Trustr may also use anonymous, aggregated utilization data for
typical business operations (for example, demonstrating the
audience size of our newsletter).
Public Forums: If any part of the Website or Trustr branded
social media sites permit public forum posting, the Personal
Data you choose to post, share, upload, or make publicly
available may be visible to others. You should never post or
share any information that is confidential or about others
unless you have permission to do so. We may use information you
provide to personalize your experience and to make content
recommendations.
VI. Location of Processing
Trustr operates from, the United States, India,and other global
locations. Additionally, we host US linked Services and process
US specific Personal Data solely in the United States. However,
it is possible that some of the service providers referenced
above may process Personal Data outside your jurisdiction, and
in countries that are not subject to an adequacy decision by the
European Commission or your local legislature and/or regulator,
and that may not provide for the same level of data protection
as your jurisdiction. We ensure that the information continues
to be protected wherever it is in a manner consistent with the
standards of protection required under applicable law, for
instance by entering into the appropriate back-to-back
agreements and, if required, standard contractual clauses for
the transfer of data as approved by the European Commission
(Art. 46 GDPR).
VII. Minors
Trustr’s Services are solely intended for business clients and
are not directed at minors. We do not knowingly collect Personal
Data from children under the age of 16. If you are a parent or
guardian and believe your child has provided us with Personal
Data without your consent, please contact us as set forth below
in Section XI, and we will take steps to delete such Personal
Data from our systems.
VIII. Retention Periods
Trustr shall typically retain Personal Data for time needed for
the original purpose of collecting or obtaining such data.
Appropriate retention periods are generally further determined
by the nature and sensitivity of such Personal Data, including
any potential risk of harm which could arise out of unauthorized
use or disclosure, as well as whether additional
legal/regulatory obligations require us to retain it. In most
instances this means we shall only retain Personal Data during
our relationship, where needed for tax or regulatory periods, or
any statutory limitation periods under applicable laws.
IX. Accessing and Controlling Your Information
Depending on applicable laws, you have certain rights regarding
your Personal Data. These rights may include:
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Right to access and/or rectify inaccuracies. You have the
right to access Personal Data we hold about you and, in most
circumstances, to be provided with a copy of this information.
You also have the right to correct any inaccuracies relating
to your Personal Data which we hold.
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Right to restrict use. to the extent permitted by law, you
have the right to restrict use of such processing.
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Right to request deletion. You have the right to request that
we delete your Personal Data from our systems. Please note, if
you prefer to opt-out of marketing communications, it is
preferable that we retain your basic contact information with
a strict “do not contact” mark applied, to ensure we do not
contact you in the future.
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Right to object to processing. Where we process your Personal
Data on a legitimate interest basis (for example, direct
marketing purposes), you can exercise your right to object at
any time to such processing without having to provide any
specific reason for such objection. In such cases, we will
stop processing your Personal Data until we verify that we
have compelling legitimate grounds for processing that
outweigh your interests, rights, and freedoms in asking us to
stop processing the data, or in limited cases where we need to
continue processing the data for the establishment, exercise,
or defense of legal claims.
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Right to withdraw consent. To the extent we base the
processing of your Personal Data on your consent, you have the
right withdraw consent at any time, without affecting the
lawfulness of the processing based on such consent before its
withdrawal.
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Right to data portability. In most instances, you have the
right to receive all Personal Data you have provided to us in
a structured, commonly used, and machine-readable format and
to transmit this data to another data controller, to the
extent such transfer is technically feasible.
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Right to lodge a complaint with a supervisory authority.
Provided you are in the EEA, you have the right to file a
complaint regarding the processing of your Personal Data with
the data protection authority (“DPA”) in the country where you
reside, where you work, or where the alleged infringement of
data protection laws has taken place.
How to exercise your rights
To exercise your rights, please contact us as set forth below in
Section XI. Any requests should include information to allow us
to verify your identity (e.g., your name, address, email
address, or other information reasonably required). If you are a
California resident, please refer to Section X below for more
detailed information on your rights under California law.
We use all efforts to respond to any legitimate requests within
one month. In the event we require additional information, we
will contact you and specify what is needed. In certain
circumstances, it may take longer than one month, for example if
we receive overly complex or numerous requests.
Occasionally it may take us longer than a month, considering the
complexity and number of requests we receive. We do not charge a
fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If
we determine that the request warrants a fee, we will tell you
why we made that decision and provide you with a cost estimate
before completing your request.
Marketing Communication Preferences.
Regarding electronic marketing communications, you may manage
your receipt of the same by clicking on the “unsubscribe” or
other equivalent link located on the bottom of any marketing or
sales emails, visit the applicable email preference center, or
contact us as described below in Section XI. As pertaining to
sales calls, if you want your phone number to be added to our
internal Do-Not-Call list, please contact us as described below
in Section IX (please include your first name, last name,
company, and the phone number you wish to add to our Do-Not-Call
list).
X. California Privacy Notice
This Privacy Notice for California Residents supplements the
information contained in the Statement applies solely to all
visitors, users, and others who reside in the State of
California. We adopt this notice to comply with the California
Consumer Privacy Act of 2018 (CCPA). This Notice does not apply
to employment-related personal information collected from
California-based employees, job applicants, contractors, or
similar individuals. As pertaining to California residents, we
have collected the following categories of personal information
within the last twelve (12) months:
Collected
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Identifiers. A real name, postal address, Internet Protocol
address, email address, account name. To be clear, we do NOT
collect identifiers such as a Social Security number, driver's
license number, passport number, or other similar identifiers.
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Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)). A
name, address, telephone number, education, employment,
employment history. To be clear, we do NOT collect personal
information such as a Social Security number, passport number,
driver's license or state identification card number,
insurance policy number, bank account number, credit card
number, debit card number, or any other financial information,
medical information, or health insurance information
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Commercial information. Records of Trustr products or services
purchased, obtained, or considered.
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Internet or other similar network activity. Browsing history,
search history, information on a consumer's interaction with a
website, application, or advertisement
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Geolocation data. Physical location, as related to IP address.
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Professional or employment-related information. Current or
past job history.
Not Collected
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Protected classification characteristics under California or
federal law.
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Biometric information.
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Sensory data.
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Non-public education information (per the Family Educational
Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R.
Part 99)).
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Inferences drawn from other personal information.
Sales of Personal Information
Based on the definition of “sell” under the CCPA and under
current regulatory guidance, we do not believe we engage in such
activity and have not engaged in such activity in the past
twelve months (including that we do not “sell” the personal
information of minors under 16 years of age).
Your Rights and Choices
The CCPA provides consumers (California residents) with specific
rights regarding their personal information. This section
describes your CCPA rights and explains how to exercise those
rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain
information to you about our collection and use of your personal
information over the past 12 months. Once we receive and confirm
your verifiable consumer request, we will disclose the same to
you.
Deletion Request Rights
You have the right to request that we delete any of your
personal information that we collected from you and retained,
subject to certain exceptions. Once we receive and confirm your
verifiable consumer request, we will delete your personal
information from our records, unless an exception applies.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights
described above, please submit a verifiable consumer by email to
hello@trustr.ai
Only you, or someone legally authorized to act on your behalf,
may make a verifiable consumer request related to your personal
information. You may also make a verifiable consumer request on
behalf of your minor child. You may only make a verifiable
consumer request for access or data portability twice within a
12-month period. The verifiable consumer request must:
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Provide sufficient information that allows us to reasonably
verify you are the person about whom we collected personal
information or an authorized representative.
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Describe your request with sufficient detail that allows us to
properly understand, evaluate, and respond to it. We cannot
respond to your request or provide you with personal
information if we cannot verify your identity or authority to
make the request and confirm the personal information relates
to you. Making a verifiable consumer request does not require
you to create an account with us. We will only use personal
information provided in a verifiable consumer request to
verify the requestor's identity or authority to make the
request.
Response Timing
We endeavor to respond to a verifiable consumer request within
forty-five (45) days of its receipt. If we require more time (up
to 90 days), we will inform you of the reason and extension
period in writing. If you have an account with us, we will
deliver our written response to that account. If you do not have
an account with us, we will deliver our written response by mail
or electronically, at your option. Any disclosures we provide
will only cover the 12-month period preceding the verifiable
consumer request's receipt. The response we provide will also
explain the reasons we cannot comply with a request, if
applicable. For data portability requests, we will select a
format to provide your personal information that is readily
useable and should allow you to transmit the information from
one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable
consumer request unless it is excessive, repetitive, or
manifestly unfounded. If we determine that the request warrants
a fee, we will tell you why we made that decision and provide
you with a cost estimate before completing your request.
XI. Questions Regarding this Statement and Your Information
If you have any questions or comments regarding this Statement
or your information, please contact us at hello@trustr.ai
XII. Security; Modifications to this Statement.
We implement technical and organizational measures to seek to
ensure a level of security appropriate to the risk to the
Personal Data we process. These measures are aimed at ensuring
the integrity, confidentiality, and availability of Personal
Data.
Trustr reserves the right to change this Statement at any time
by posting revisions on the Website. Such changes will be
effective upon posting and will modify the “Last Updated” date
above. We encourage you to periodically review this Statement to
stay informed about our processing of your Personal Data.