TRUSTEV LIMITED - PRIVACY POLICY

Trustev is committed to protecting your privacy. Our Privacy Policy sets out what information we collect and access, how we collect and access it, what we do with it and how we protect this information.

1. The Types of Information We Collect and Access

We collect and access two types of information about you:

1.1 Personal Data

Trustev Limited is a private limited company registered in Ireland. Some of the information we collect about you is Personal Data within the meaning of the Irish Data Protection Acts 1998 & 2003. Personal Data is data that identifies you or can be used to identify or contact you and can include your name, address, telephone number, date of birth, gender, occupation and Social Network Application ID. For further information regarding the legislation that governs Personal Data and your rights please visit the website of the Irish Data Protection Commissioner www.dataprotection.ie.

1.2 Non-Personal Data

Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non- Personal Data comprises information that cannot be used to identify or contact you and which can be used to help us to make our site more user friendly and improve the services we provide.

2. How We Collect Information About You

2.1 Information/Access You Provide to Us Directly

You may provide information to us directly using this website. You may also grant us direct access to your Facebook, Twitter, Linkedin or other social network accounts (“Social Network Accounts”), see Paragraph 3 below.

2.2 Information/Access Shared with Us by Merchants

When you set up a user account or place an order with an online retailer who partners with us (“Merchant”) you may consent to the Merchant sharing information about you with us. If you have given the Merchant access to your Social Network Accounts you this consent will extend to the Merchant sharing such access with us, see Paragraph 3 below.

2.3 Access to Social Media Accounts

In order to provide our services, we need to have access to one or more of your Social Network Accounts. Typically, you grant another person access to your Social Network Account by granting an application or ‘app’ developed by that person access to the account.
If you grant us access to your Social Network Accounts directly we will access certain categories of information depending on the type of Social Network Account- for further information please click here [Hyperlink to page setting out permissions sought for each Social Network be inserted]. If a Merchant shares the access you have granted them with us, we will only be able to access the same categories of information as that Merchant.
We will store some of the information we access on our database for ease of retrieval. For information regarding the termination of our right to access your Social Network Accounts, see Paragraph 5 below.
We collect information using cookies. Please see Paragraph 3 below.

3. How We Use Information We Collect About You

3.1

We combine the information we collect about you with your browser fingerprint (described in Paragraph 3.3 below) and Internet Protocol address to generate a profile of you and your internet use (your “Trustev Profile”). We use your Trustev Profile to generate a Trustev Score which is an indicator of your credit worthiness for online transactions. This process by which the Trustev Score is generated is an automated process carried out by our proprietary software.

3.2

We provide Trustev Scores to Merchants who have registered with us. While a Merchant may with your permission share information about you with us which we will take into account in generating a Trustev Score we will not disclose any of your Personal Data to a Merchant.

3.3

We use the information about you that we hold or access to automatically populate information fields on a Merchant’s website with your information when you visit them. This feature can greatly speed up the speed with which you can create a user account or place an order with a Merchant, particularly on mobile devices. When fields are automatically populated, the information is sent to the browser on your device and is not sent to the Merchant until you confirm the information is correct and click through to the next page of the Merchant’s website. This feature may be disabled by logging in to your Trustev Profile on this website, please see the Managing My Profile section of our FAQ [Hyperlink to FAQ to be inserted].

3.4

We may disclose information, including Personal Data, we hold about you to contracted companies who act as "data processors" on our behalf. This includes companies like Microsoft who provide the secure servers on which we host information.

3.5

We will use information we hold about you for statistical analysis and systems testing and customer relations communications.

3.6

We will not share your Personal Data with third parties unless you have given us permission to do so OR we are required to do so in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.

3.7

We will not use your Personal Data for direct marketing purposes.

3.8

We may share Non-Personal Data with third parties, where such information is combined with similar information of other users of our website, for the purpose of the further development of this web site and our services.

3.9

If you do not agree with the proposed use of your Personal Data set out in this Paragraph 3, you should not (a) send us information through our website, (b) grant our App access to your Social Network Account, or (c) grant a Merchant permission to share information and Social Network Account access with us. If we already hold information about you, you can instruct us to delete all Personal Data we hold about you and revoke our permission to access your Social Network Accounts- see Paragraph 5 below.

4. Cookies

4.1

When you (a) grant a Merchant who partners with us permission to share information or access to your Social Network Accounts with us or (b) visit our website we place cookies on the device you are using to browse the web. Cookies are small text files that are transferred to your device through your web browser.

4.2

Some cookies are used to improve the functionality of this website. When you log in to your Trustev Profile a cookie allows the website to recognise that you are logged in so that you don’t have to re-enter your log in details on every page of the secure area of the site.

4.3

Other cookies enable us to recognise your browser and help us to track your internet use. This allows us to compile a ‘browser fingerprint’ which is unique to the browser on the device you are using to access the web.

4.4

Cookies are also used to facilitate the automatic population of information fields on Merchants’ websites with your information as described at Paragraph 3.3 above.

4.5

We also use cookies that are performance related. They are set by Trustev.com and third parties, [including Comscore and Google Analytics]. Performance cookies allow us to collect statistical information about our visitors, such as whether they have visited the site before and the pages they view. This information is gathered anonymously - it does NOT enable us to identify who you are.

4.6

Most internet browsers automatically accept cookies, but, if you wish, you can set your browser to prevent it from accepting cookies. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. The cookies we use do not detect any information stored on your computers. For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org If you set your browser not to accept cookies this may affect the calculation of your Trustev Score.

5. Managing the Personal Data We Hold/Access

5.1

You may use your Social Network Account username and password to log in to view your Trustev Profile on this site and (a) opt in or out of features such as the automatic population of information fields in Merchants’ websites (see Paragraph 3.3 above) (b) order a copy of the Personal Data about you held by us, (c) request that we review such Personal Data and amend it so that it is accurate and up to date, (d) instruct us not to use certain Personal Data about you, or (e) instruct us to delete your Trustev Profile. Please see the Managing My Profile section in our FAQ [hyperlink to be inserted] for further information.

5.2

Our security procedures require that we only send copies of Personal Data to an email address associated with one of your Social Network Accounts. We may request further proof of identity in addition to your Social Network Account username and password before we disclose Personal Data.

5.3

If you instruct us not to use certain Personal Data about you this may negatively affect your Trustev Score.

5.4

On deletion of your Trustev Profile we will (a) delete all Personal Data we hold about you including the access tokens that we use to access your Social Network Accounts (b) cease to access your Social Network Accounts and (c) cease to provide Trustev Scores to Merchants in relation to you. We will retain certain Non- Personal Data which we have collected in relation to your internet use that has been aggregated with data collected from other users and can no longer be used to identify or contact you.

5.5

If we do not receive a request from a Merchant for a Trustev Score in relation to you for a period of twelve months we will automatically delete your Trustev Profile.

5.6

Please note that if following the deletion of your Trustev Profile you grant a Merchant consent to share information or access with us a new Trustev Profile will automatically be generated.

6. Security

6.1

The nature of the internet is such that we cannot guarantee or warrant the security of any information transmitted to us via the Internet. No data transmission over the internet can be guaranteed to be 100% secure. The use by you of this website and the continued holding of your Personal Data by us is at your sole risk. If you do not accept this risk you can instruct us to delete your all Personal Data we hold about you and revoke our permission to access your Social Network Accounts as outlined at Paragraph 5 above.

6.2

We will take all reasonable steps to protect your Personal Data. These steps include the use of Secure Socket Layer (SSL) technology to encrypt your Personal Data held by us. When you log into your Trustev Profile, you will see the padlock in your browser's security display indicating the transfer of all data between your browser and our site has been encrypted. We use the same technology when receiving transfers of your Personal Data from Merchants.

6.3

Your Personal Data is held on secure servers hosted by our trustedthird party providers. Details of those providers can be requested by email to info@trustev.com.

7. Links to Third Party Websites

This privacy statement only covers our website. It does not cover links to other websites and accordingly any information collected by those parties that own and control those websites or their use of cookies. Please be aware that individual organisations operate their own policies regarding the use and sale of personal information and the use of cookies. If you have a concern regarding the way your personal information will be used on other sites then you are advised to read the relevant privacy statement or in the absence of such a statement on the site, contact the company concerned.

8. Contact Us

We can be contacted:

8.1

By email: privacy@trustev.com

8.2

By post: Trustev Limited,2100 Cork Aiport Business Park, Cork, Ireland.

9. Changes to Privacy Statement

Our Privacy Statement may change from time to time and any changes to the statement will be posted on this page.