Last Updated: 20/06/2023
You equally confirm that you are of legal age to access and use our website and services in accordance with its terms and conditions.
If a minor supplies TrueHandle with personal information without his or her parent's or guardian's consent (as defined by applicable law), the parent or guardian may contact TrueHandle to request for the removal or deletion of the information.
Please contact us at firstname.lastname@example.org if you have any questions or concerns about our Privacy Notice. Our Terms and Conditions also apply to your usage of our services and website with regards to certain terms used but not defined in this Privacy Notice.
TrueHandle is a Netherlands based company. TrueHandle is the data controller of all Personal Data (as defined below) collected via this website and of certain Personal Data collected from third parties if you reside or are situated in the European Economic Area ("EEA"), as set forth in this Privacy Notice.
“Personal data” , often known as personal information, refers to any information on a living person who can be identified. This is a wide term that encompasses the kind of personal data we've discussed below. It excludes information that cannot be used to identify a specific individual, such as the registration number of a company.
A "Data Subject" is a person who may be identified by personal data, either directly or indirectly. This is commonly accomplished using an identifier like a name, identification number, location data, an online identifier, or one or more elements particular to that natural person's physical, physiological, genetic, mental, economic, cultural, or social identity.
We will collect, use, store, and transfer different types of personal data about you depending on whether and how you use our Services, Site, or App (if any), which we have divided into categories as follows:
Personal Data Classification
Specific examples of personal information
Including full name, username or similar identifiers, birthdate, biometric information including a visual image of your face...
Data on social identity
Including your group/company data, information on referrals related to you, behavioral data, risk assessment, compliance assessment...
Including residence details, billing address, email address and telephone numbers, proof of address documentation...
Data from Transactions
Including details about payments to and from you, other details of any transactions you enter into using our Services, the Site.
Including your username, your identification number as our user, information on whether you have an account with us and the email associated with your account, requests by you for products or services, your interests, preferences and feedback, other information generated by you when you communicate with us, for example when you address a request to our customer support.
Including information about how you use the Site, our Services, other applications made available by us to you, including: device download time, install time, interaction type and time, event time, name, and source.
Data on Marketing and Communications
Including your preferences in receiving marketing from us or third parties, your communication preferences, your survey responses.
Including internet connectivity data, internet protocol (IP) address, operator and carrier data, login data, browser type and version, device type, category, and model, time zone setting and location data, language data, application version and SDK version, browser plug-in types and versions, operating system and platform, diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and other information stored on or available regarding the devices you allow us access to when you visit the Site or our Services.
Including bank account, payment card details, virtual currency accounts, external account details, source of funds and related documentation.
Personal data in special categories
The legislation that applies to you provides additional protection for some types of sensitive personal data.
"Special categories" of personal data are what they're termed. The following are the special categories:
We will only use special categories of personal data for a specific purpose only when necessary and if we can meet both the lawful basis requirements listed below, as well as at least one of the extra conditions:
You must provide us with true, complete, and accurate personal information, and you must inform us of any changes thereof.
It is important that you know the legal bases for using your personal information. They include:
We acquire information from and about you through a variety of means, including:
Providing the Site and our Services: We use the Personal Data you give us to allow you to access and use the Site, as well as to provide you with any information, products, or services you request.
Security and technical support: Personal Data may be used to provide you with technical help and to protect the security of our Services and the Site.
Identity Verification: We may use the Personal Data we collect to validate your identity and authenticate the submissions made on the Site were made by you, that require identity verification. A third-party identity verification firm could be hired to provide this service.
Communications with our Business Partners: We may share your Personal Data with our business partners so that they can share information about their products and services that may be of interest to you when they are legally permitted to do so.
To execute tasks and deliver the Services to you on our behalf, we transfer your personal data with our third-party service providers, agents, subcontractors, and other related organizations and affiliates. When using third-party service providers, they are required to respect the security of your personal data and treat it in a legal manner.
Based on the following legal grounds, we may process or share your data:
In the following circumstances, we may need to process your data or share your personal information:
Our Technology service providers include but not limited to:
TrueHandle will not disclose personal information to other parties unless it is required by law. However, if the user's information is to be transmitted to a third party, the user will be notified in advance and given the opportunity to express his/her permission to such a transfer
Because some of our external third parties and affiliates will be located outside of the EEA or the UK, their processing of your personal data will need a data transfer outside of the EEA or the UK. This will necessitate the transfer of your personal information outside of the European Economic Area (EEA) or the United Kingdom as the case may be.
We provide a similar level of protection for your personal data if we send it outside of the EEA or the UK by implementing at least one of the following safeguards:
Be informed that we manage and run our site and Services from the Netherlands. Your Personal Data may be sent outside of the country in which you reside or are located, including to the Netherlands, to provide our Services to you.
If you would like more information on the exact method we use to transfer your personal data outside of the EEA or the UK, please get in touch with us at email@example.com.
We are dedicated to maintaining the privacy and secrecy of Personal Data throughout transit. To the extent permitted by applicable law, we take the necessary measures to offer the same level of protection for the processing carried out in any such countries as you would have within the EEA or other regions if you reside in the EEA, the United Kingdom, Switzerland, or another region that offers comparable protections.
The California Consumer Privacy Act ("CCPA") gives California residents certain privacy rights. If you are a California resident, you have the following rights:
We cannot guarantee the security of Personal Data since the Internet is not a 100 percent safe environment, and there is a chance that an unauthorized third party will find a way to circumvent our security mechanisms or that the transmission of your information over the Internet will be intercepted. We will protect your Personal Data with industry-standard physical, technical, and administrative security measures, and we will not share it with third parties unless otherwise stated in this Privacy Notice, or unless disclosure is required by law in special circumstances, such as a physical threat to you or others. It is your duty to keep your log-in information secure. Please keep in mind that most e-mail communications are not encrypted and should not be considered safe.
While any data shared over the internet carries a risk of being accidentally lost, misused, damaged, accessed in an unauthorized or unlawful manner, altered, or disclosed, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, misused, damaged, accessed in an unauthorized or unlawful manner, altered, or disclosed. Furthermore, we restrict access to your personal data to employees, agents, contractors, and other third parties with a valid business need to know. They will only process your personal data in accordance with our instructions and are bound by strict confidentiality obligations.
We shall implement the following suitable security measures, depending on the extent of the risks caused by the proposed processing of your personal data:
We have protocols in place to deal with any suspected personal data breach, and where we are legally required to do so, we will notify you and any applicable authority.
We keep your Personal information for no longer than necessary, and for the purposes for which the information is collected and processed. We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements when determining the appropriate retention period for personal data.
Here are some examples of the criteria we consider when considering how long we need to keep your personal information:
We need to make you aware of your rights. The rights you have are determined by the purpose for which we process your personal data. Please contact us if you require additional information or wish to exercise any of the rights listed below.
You have specific rights under applicable data protection legislation in some regions (such as the European Economic Area). These rights may include;
All requests shall be considered and responded to in compliance with applicable data protection legislation.
Our Site and Services are intended for a broad audience and are not meant for children under eighteen (18) years of age. As a result, in accordance with applicable legal and regulatory duties, we do not intentionally collect, use, solicit, or disclose personal information from children without first obtaining parental consent. We ask that you do not use our Site and Our Services if you are under the age of 18. We may request age-related information from you to comply with applicable legislation.
Upon learning of the existence of any Personal Data of persons under the age of 18 that has been collected on our Site without verified parental consent, we will take reasonable actions to remove such Personal Data with immediate effect upon the information coming into TrueHandle's notice.
Please contact us at firstname.lastname@example.org or mail us using the address below if you have any questions, requests, or complaints regarding how we process your personal information.