TroyTrust, along with our affiliates and subsidiaries (collectively referred to as “TroyTrust,” “us,” or “our”), presents this policy to delineate our practices regarding the safeguarding, acquisition, application, and sharing of your personal information. This applies when you interact with our services including:
- Website and Online Platforms: Our digital content accessible via www.TroyTrust.com and other online platforms we manage
- Social Media and Online Presence: Our official digital channels across various social media platforms.
- API and Service Usage: When utilizing the TroyTrust API or third-party applications that depend on our API, alongside other related services.
Please thoroughly review this policy as it is crucial for understanding our practices and your interaction with our services. If you have any queries, reach out to us at support@TroyTrust.com. Your use of our services signifies your acceptance of these terms. If you disagree with any part of this policy, please refrain from using our services.
Definition of Personal Data:
Personal data, as defined here, includes any information that:
- a) Directly or indirectly pertains to a living person.
- b) Allows for the identification of an individual, either directly or indirectly.
- c) Is accessible and processable.
As a visitor or user of our services, we collect necessary personal information to provide our services, comply with legal requirements, or as detailed herein. Providing personal data marked with asterisks is mandatory for service provision.
|What do we collect?
|How do we use it?
|Information collected by using our official website: pages visited, country location, date and time of requests, IP address, interaction with our Site(s), device, operating system and web browser user.
|We use the anonymous information to recognize your repeat visits and preferences, personalize the browsing experience, measure the effectiveness of campaigns, and statistically analyze the usage of our Site(s).
|Information collected when you register an account: email address, full name, workspace name, and password*
We use the contact information to display in the user interface and verify your identity when required. The information may also be used to:
|Information collected when messaging us through our contact form: Name, Email address, Company, and the message content
|We use this information to contact you to reply to your request and provide the most relevant information to you in our answers
|Information collected when subscribing to our newsletter: Name, Email address, Company profile
|If you explicitly agree to subscribe to our newsletter, we will use this data to provide personalized business information about new services and products as well as for industry trends research purposes
|Information collected when you request access to your data or correction of data: Name, ID/Passport, email address*
|We use this information to verify your identity to proceed with your request for DAR or DCR
Third-Party Data Collection
We may obtain your data from partners, affiliates, and external sources, including social media connections. This may encompass demographic information and identity verification via KYC processes (hereinafter referred to as the “KYC”).
Data Sharing With Third Parties
We might share your information with affiliates, service providers, government bodies, or other third parties under certain conditions with our affiliates or subsidiaries, service providers (eg. AML, CRM, communication services) vendors, agents, relevant government ministries, regulators, partners, or any third party, including but not limited to when third parties perform part of our Services on our behalf (e.g. for data processing, analytics, delivery of Services, and verification), when complying with legal obligations, to protect the rights, property, or safety of our company, clients or others. Some third-party processing your personal data either on TroyTrust behalf or any other circumstance may be located in a different country from the point of collection of your personal data including but not limited to the location of servers or cloud-based services. In the case where your personal information must be shared with third parties in circumstances that are not standard with our relationship with you, TroyTrust will request your consent unless the disclosure of your personal information is:
- (a) requested by Authority, law enforcement agency, or public agency;
- (b) without a doubt in your interests, and if consent cannot be obtained in a timely way;
- (c) necessary to respond to an emergency that threatens the life, health, or safety of yourself or another individual; or
- (d) required, permitted, or authorized based on the applicable laws and/or regulations.
External Links on TroyTrust Platforms
Data Storage and Processing
We may transfer, store, and process your personal data in various locations, including facilities operated by third parties like Google or Amazon Web Services or others. Despite the international nature of our data processing, we are committed to enforcing robust data and privacy protection standards.
Securing Personal Data
Our commitment to your data's security is unwavering. We adhere to the Personal Data (Privacy) Regulation and other relevant regulations to safeguard the confidentiality and integrity of your personal information. Despite rigorous electronic safeguards, we must acknowledge the possibility of unauthorized data disclosure. In such instances, our liability for any resulting harm to users or third parties is limited to the maximum extent permitted by law.
Your Rights Regarding Personal Information
As a user of TroyTrust services, you have specific rights regarding your personal data:
- Data Access and Correction: You can request a copy of your personal data we hold (Data Access Request, “DAR”) or request corrections (Data Correction Request, “DCR”) by writing to us.
- Objecting to Data Use: You can object to our use of your personal information by contacting support@TroyTrust.com. Note that this may impact your ability to use our services.
- Response Time: We aim to respond to your requests within 40 calendar days.
In some circumstances, we may decline to comply with your request in the following circumstances:
- (i) a government agency or regulator with jurisdiction over TroyTrust, directs TroyTrust not to comply with a visitor or user’s request;
- (ii) the information may, in our discretion, affect the safety of any person or persons;
- (iii) the data may be relevant to a regulator or official investigators (criminal conduct or breach of applicable laws)
- (iv) the data correction request is not made in Chinese or English writing;
- (v) it is unable to verify the identity and authority of the requestor;
- (vi) it is not satisfied that the personal data to which the DCR relates is inaccurate;
- (vi) it is not provided with sufficient information to ascertain that the data is inaccurate; or
- (vii) it is not satisfied that the correction provided in the DCR is accurate.
In case you decide to withdraw your consent for the use of your personal data by TroyTrust, you are advised to immediately discontinue using our services and inform us via email at XXX@TroyTrust.com. Upon receiving your request, we will process it promptly. Be aware that withdrawing consent may have legal implications and could impact our ongoing relationship. The extent of your consent withdrawal might necessitate the termination of your access to our services.
You have the right to request the erasure of your personal data in our control, commonly known as the "right to be forgotten." However, we may not always be able to fully comply due to legal obligations or technical limitations. We commit to erasing personal data when it's no longer needed for its original purpose, except where law or public interest prevents such erasure. When you submit an erasure request, we may ask for identification to verify your identity. For efficient processing, please specify the right you are exercising and provide necessary details. Incomplete information might result in a delay in processing your request.
TroyTrust retains your personal data for as long as your account remains active or as necessary for providing services, including for legal, accounting, or reporting requirements. This includes retention periods post-termination of our business relationship as mandated by applicable laws, such as anti-money laundering regulations. For further inquiries, contact us at support@TroyTrust.com. Upon account closure or when data is no longer needed, we may delete or destroy your information, except where retention is legally required or for other regulatory or audit purposes.
If you wish to ask or notify us for:
- (a) DAR or DCR;
- (c) Remove your consent for us to use your personal data; or
- (d) Erase personal data.
Please send us a notice to: support@TroyTrust.com
Cookies TroyTrust may use
What Are Cookies? Cookies are small amounts of data that are sent to your browser and stored on your computer’s hard drive to collect standard internet log information and visitor/user behavior information. When you visit our Sites or Channels, TroyTrust can automatically collect information from you through cookies or similar technologies. There may also be third-party cookies on our Websites and Channels.
For more information, please visit: www.allaboutcookies.org