Privacy

We are Trustonic Limited, a company registered in England with company number 07890730. We provide mobile security solutions for smart connected devices and their applications.

Our registered office address is Unit 1, 16 St John’s Innovation Centre, Cowley Road, Milton, Cambridge CB4 0WS, United Kingdom.

You can contact us by email via privacy@trustonic.com.

Our Information Commissioner’s Office (ICO) registration reference is Z3333414.

We are committed to:

• protecting your personal data,
• being transparent about our collection and use of your personal data, and
• respecting your privacy.

Personal data is any information that identifies an individual or can be used to help identify an individual; for example, a name, email address, IP address or location data.

We do our very best to keep your personal data secure.

This policy explains the following with respect to your personal data:

• what information we collect from you and how we collect it,
• why we collect it and our legal basis for doing so,
• how we use it,
• who we share it with,
• where we store it,
• how long we keep it for, and
• your rights.

References to the “GDPR” are to the General Data Protection Regulation (GDPR) (EU) 2016/679.

Our Privacy Officer can be contacted directly via privacy@trustonic.com.

What personal data do we collect and how do we collect it?

We only ever collect the personal data that we need from you and keep the personal data we hold on an ongoing basis to a minimum.

We collect and process your personal data when you use our site, and solutions, services or products. This may be personal data you provide to us, that we collect about you and/or information we receive from other sources.

Information you give us

The personal data you give us may include your:

• name,
• address,
• e-mail address;
• phone number,
• personal description.

Occasionally we collect financial and credit card information, and photographs.
We would ask you to ensure that the personal data you provide to us is kept up-to-date and therefore please contact us if you need to amend any of your personal data.

Information we collect about you

Each time you visit our site we automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources

We use approved third parties to provide services to us (including, for example business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Why do we collect your personal data and what is our legal basis for doing so?

We collect your personal data either to:

• provide you with a solution, service or product in response to your request,
• provide you with a more personalised service when you visit our site, or
• improve our services to you.

The legal basis that we rely on to enable us to collect and use your personal data for the purposes stated is either

• the performance of a contract between us (contract),
• compliance with a legal obligation (legal obligation),
• our legitimate organisational interests where there is no overriding prejudice to you (legitimate interests), or
• you have given your consent (consent).

In the section below “How do we use your Personal Data?” we provide more detail on the legal basis relied on in each case.

How do we use your personal data?

We use information that we hold about you in the following ways:

• to provide you with information about our solutions, services or products that you request from us (contract),
• to provide you with solutions, services or products that you have requested and to invoice you (contract),
• to provide you with information about other solutions, services or products we offer that are similar to those that you have already purchased or enquired about (legitimate interests on the basis that this would not be unexpected contact from us as you have purchased a solution, service or product already from us or made an enquiry),
• to notify you about changes to our solutions, services or products (legitimate interests on the basis that this would be useful information for you to receive as a current or former customer),
• to ensure that content from our site is presented in the most effective manner for you and for your computer (legitimate interests in that we have a business interest in presenting our content in the most effective manner),
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (legitimate interests in that we need to carry out regular maintenance and testing on our site),
• as part of our efforts to keep our site safe and secure (legitimate interests for us to maximise safety and security for both parties),
• to enable us to use cookies as detailed in our Cookies Policy (consent), and
• to provide you with marketing or sales information in response to your request (consent).

(For details of how to withdraw your consent at any time please see the section “Your Rights” below.)

Cookies policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Information we receive from other sources

In certain circumstances, we combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Who do we share your personal data with?

We share your information with selected third parties including:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, and
• analytics and search engine providers that assist us in the improvement and optimisation of our site.

Our selected third parties are required by us to treat your personal data as carefully as we would and may only act on our instructions with regard to their use of your personal data.

We may disclose your personal information to third parties in the event that:

• we sell or buy any business or assets, in which case we will be obliged to disclose your personal data to the prospective seller or buyer of such business or assets,
• if Trustonic Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets, or
• we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, our safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where do we store your personal data?

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).  Such destinations may include countries where the level of protection provided for your personal data is not considered adequate by the European Union authorities. However, in such situations, we ensure that we put in place adequate safeguards to protect your personal data. Your personal data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long do we keep your personal data for?

We keep personal data for the following time periods:

When we no longer need to keep your personal data, we undertake to delete it and dispose of it securely.

Your rights

You have the following rights in connection with your personal data:

• where we are processing your personal data on the basis of consent then you have the right to withdraw your consent at any time by contacting us by email via privacy@trustonic.com, and
• the right to obtain a copy of your personal data which we hold about you.

In certain circumstances you have the right to:

• have your personal data erased,
• restrict processing of your personal data,
• object to the processing of your personal data, or
• have your personal data transferred to a third party.

If you wish to exercise your rights, please contact our Privacy Officer by email via privacy@trustonic.com with “PRIVACY” in the subject of the email.

If you have an issue or complaint arising under this policy then, in the first instance, please contact our Privacy Officer by email via privacy@trustonic.com with “PRIVACY” in the subject of the email.If you are not satisfied with our handling of your issue or complaint then you have the right, under Article 77 of the GDPR, to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/).

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

Notification of any changes we may make to our privacy policy in the future will be posted on this page and on our website.

Governing law and jurisdiction

If you are a business, this privacy policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England.

If you are an individual acting in your own capacity (a ‘consumer’), please note that this privacy policy, its subject matter and its formation, are governed by English law. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Privacy Officer, by email via privacy@trustonic.com with “PRIVACY” in the subject of the email.