Privacy Policy

Last Updated: 20/06/2023

Welcome to TrueHandle (hereinafter referred to as "TrueHandle") Global Privacy Policy ("Privacy Policy"). Please take a few moments to read this Privacy Policy carefully before providing us with any personal information about you or anybody else.

Introduction

We value your privacy and are committed to safeguarding your personal information. TrueHandle B.V. (doing business under the trade name “TRUEHANDLE”) and its affiliates (collectively, "TRUEHANDLE") appreciate you trusting us with your personal information by visiting our website (the "Website") and, more broadly, by using any of our services (the "Services", which include the Website https://truehandle.com and https://truehandle.me). We take the protection of your personal information very seriously, and we hope that this privacy policy will help you understand what information we collect, how we use it, and what rights you have in connection to it. This Privacy Policy applies to TrueHandle and all TrueHandle services and its websites.

By using TrueHandle websites and services, you consent to the collection, storage, processing, and transfer of your personal information as outlined in this Privacy Policy. Please, take some time to read the following carefully to gain a better understanding of how we collect, view, and utilize your personal information because it is essential. If you do not agree with any of the terms and conditions in this privacy policy, please desist from using our services and the website immediately.

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.

The aim of this privacy policy

The main aim of this Privacy Notice is to explain how TrueHandle, its subsidiaries, and international branches (hereinafter referred to as "TrueHandle," "us," "we," or "our") collect, use, and share information about you through our online interfaces (collectively referred to herein as the "Site"). This Privacy Policy explains your privacy rights and how the EU General Data Protection Regulation ("GDPR") and the UK GDPR, a post-Brexit privacy law, protect you.

Please contact us at support@truehandle.com 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.

The data we collect about you

This Privacy Policy applies to information we obtain from you via our services and the site. Some of our Site's functionality can be accessed without revealing any Personal Data, however Personal Data is necessary for Services. You may be required to provide, or we may collect, "Personal Data" (which may also be referred to as "personally identifiable information" or "personal information") for you to be able to use certain features on our Site.

“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 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:

• Personal information that reveals a person's racial or ethnic origin.
• Opinions on politics
• Beliefs in religion or philosophy.
• Membership in a labor union.
• Processed genetic and biometric data with the goal of uniquely identifying a natural individual.
• Health-related information.
• Information about a person's sexual life or sexual orientation.

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 have given your explicit permission.
• Processing refers to personal information that you have knowingly made public.
• Processing is required to create, exercise, and defend legal claims.

You must provide us with true, complete, and accurate personal information, and you must inform us of any changes thereof.

What You Agree to By Using Our Site

It is important that you know the legal bases for using your personal information. They include:

• To fulfill our obligations under any contract we may have with you (for example, to comply with the Terms of Use of our Site, which you accept by browsing our website, and/or to comply with our contract to provide a handle in the form of an NFT to you, or any other organization that may be providing you with access to our Services); or
• To comply with our legal requirements; or
• Our legitimate interests or the legitimate interests of others require the use of your personal information. It is in our legitimate interests to:
  • carry out research and statistical analysis;
  • carry out marketing and business development;
  • for internal administrative and auditing purposes;
  • operate our Site and provide our Services;
  • select appropriately skilled and qualified suppliers;
  • build relationships with partners and educational institutions; and,
  • run, grow and develop our business;
• To send you some communications or collect certain information from you, or if local law requires us to rely on consent.

How We Collect Your Data

We acquire information from and about you through a variety of means, including:

• Direct Interactions: By directly interacting with us, such as by filling out forms, by email, or otherwise, you may provide us with your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data, and Marketing and Communications Data. This includes any personal information you give us when you:
  • visit our Site or other platforms;
  • apply for our Services;
  • create an account;
  • make use of any of our Services;
  • request marketing to be sent to you, for example by subscribing to our newsletters;
  • enter a competition, promotion, or survey, including through social media channels;
  • give us feedback/reviews or contact us.
• Automated technologies or Interactions: We will automatically collect Technical Data about your equipment, browsing actions, and habits as you engage with us via our Site or platforms. Cookies, server logs, and other similar technologies are used to collect this personal data. Transactional Data will also be collected. If you visit other websites that use our cookies, we may get Technical Data and Marketing and Communications Data about you. More information about how we use cookies can be found in our Cookies Policy.
• Third parties or publicly available sources: We also get information about you from other parties or publicly available sources. Among these sources are:
  • fraud and crime prevention agencies,
  • a customer referring you,
  • public blockchain,
  • publicly available information on the Internet (websites, articles, social media etc.)

How We Use Your Data

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 or from TrueHandle: We may use the information you give when you send us an email message or otherwise contact us to reply to your communication and/or as specified in this Privacy Policy. Where we are legally permitted to do so, we may also archive this information and/or utilize it for future communications with you. When we send you emails, we may keep track of how you interact with them (such as when you open an email or click on a link inside an email). We use this information to improve and customize our communications to you.

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.

Disclosure of Your Data

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:

• If you have granted us express consent to use your personal information for a specific purpose, we may handle your data. (Consent)
• When processing your data is reasonably necessary to achieve our legitimate business interests. (Legitimate Business Interests)
• If we have a contract with you, we may use your personal information to carry out the terms of that contract. (Contractual Performance)
• To comply with applicable legislation, governmental demands, a judicial procedure, court order, or legal process, such as in response to a court order or a subpoena, we may release personal information (including in response to public authorities to meet national security or law enforcement requirements). (Legal Obligations)
• We may disclose your information if we believe it is necessary to investigate, prevent, or act in connection with potential policy violations, suspected fraud, situations involving potential threats to the safety of any person, or illegal activities, or as evidence in litigation in which we are involved. (Vital Interests)

In the following circumstances, we may need to process your data or share your personal information:

• Transferring a business: We may share or transfer your information in connection with or during any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, or during any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Advertisers: When you access or use the Website, we may utilize third-party advertising businesses to show ads. These companies may use information from web cookies and other tracking technologies about your visits to our Site and other platforms to serve you advertising for services that you might be interested in.
• Affiliates: We may share your information with our affiliates, in which case we will require them to adhere to the terms of this Privacy Policy. Our parent company, as well as any subsidiaries, joint venture partners, or other firms that we control or share shared control with, are considered affiliates.
• Third-Party Service Providers : We may share your information with third-party service providers, contractors, or agents who perform services for us or on our behalf and need access to certain information to do so. Payment processing, data analysis, email delivery, hosting services, customer support, and marketing activities are just a few examples. We may allow certain third parties to use tracking technology on the Website to collect data on our behalf about how you interact with it over time. This information can be used to evaluate and track data, determine the popularity of specific content, pages, or features, and gain a better understanding of online activity. We do not disclose, sell, rent, or lease your personal information unless otherwise stated in this Privacy Policy.

Our Technology service providers include but not limited to:

• Google Ireland Ltd
• Vercel Inc

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

International Privacy Practices

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:

• The European Commission has determined that the country to which we transfer your personal data provides an adequate level of protection for personal data;
• A specific contract approved by the European Commission that provides safeguards for the processing of personal data, known as Standard Contractual Clauses.

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 support@truehandle.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.

Users in California

The California Consumer Privacy Act ("CCPA") gives California residents certain privacy rights. If you are a California resident, you have the following rights:

• “Right to Know”— You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
• “Right to Correction” — You have the right to have inaccurate personal information about you corrected.
• “Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
• “Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, TrueHandle will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
• “Right to Opt-Out” - You have the right to opt out of the sale of your personal information.

We do not sell your personal information or the personal information of any of our users in the traditional sense, we do use cookies that make non-personally identifiable information available to specified third parties, as defined by the CCPA. To exercise any of these rights under CCPA, please email support@truehandle.com.

Confidentiality and Security of Personal Data

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:

• Availability, integrity, and accessibility of data on a long-term basis: include but not limited to ensuring appropriate back-ups of personal data are held.
• Company Endeavors: include, but not limited to, policy development and staff trainings; and
• Technical safeguards: include, but not limited to, physical security of Data, pseudonymization, and encryption.

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.

Data retention

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:

• in accordance with relevant industry standards or guidelines;
• because of our legitimate business necessity to prevent abuse of the promotions we run. To avoid the appearance of abusive behavior, we shall save a customer's personal data for the duration of the offer and for a specific period after it has ended;
• if we have a reasonable expectation of litigation or any Alternative Dispute Resolution in connection with our relationship with you, or if we believe we need to keep information to defend possible future legal claims (e.g., email addresses and content, chats, and letters will be kept for up to 10 years following the end of our relationship, depending on the limitation period applicable in your country);
• in the event of a complaint;
• to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data:
  • We are required to retain your personal data for a period of 5 years after the end of the relationship between us as a company and you as a customer, under EU anti-money laundering legislation (Anti-Money Laundering Directives); this period may be extended in certain circumstances if so, provided by and in accordance with the applicable legislation; the same is true under UK anti-money laundering legislation.
  • if information is required for auditing and/or other purposes.

Your Legal Rights

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;

• Right to Access: request access to and a copy of your personal information. This permits you to request confirmation that we are processing your personal data, a copy of your personal data in our possession, and information about how we are using your personal data;
• Right to Rectification: request that we correct information that you believe is incorrect and complete information that you believe is missing, albeit we may need to verify the veracity of the new data provided by you;
• Right to Erasure: request erasure of your personal data by requesting that we erase or destroy any personal data we hold about you; nevertheless, we may not always be able to comply with your request for erasure due to some legal reasons that will be communicated to you;
• Right to Object: You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground because you believe it impacts on your fundamental rights and freedoms; in some cases, we may demonstrate that we have compelling legitimate grounds to process your data that override your rights and freedoms; you also have the right to obstruct processing of your personal data where we are relying;
• Right to Data Portability: request the transfer of your personal data to you or a third party, and we shall give your personal data in a structured, commonly used, machine-readable format to you or a third party you choose (where technically practicable); Please note that this privilege only applies to automated information that you gave us permission to use or that we utilized to fulfill a contract with you.
• Right to Withdraw: You have the right to withdraw your consent at any time. However, if you withdraw your consent, we may not be able to provide certain Services to you, but we will notify you if this is the case at the time you withdraw your consent; nevertheless, this will not affect the lawfulness of any processing carried out before you withdraw your consent;
• Right to Complaint: Any alleged breach should be reported to the appropriate authority, and damages should be sought through a competent court.

All requests shall be considered and responded to in compliance with applicable data protection legislation.

Children's Privacy

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.

Links to Other Websites

We may include links to sites maintained by third parties other than TrueHandle ("Third Party Sites"), that we believe may be of interest to you. We only share your Personal Data with these Third-Party Sites if we have a legal basis for doing so. As a result, we cannot guarantee the security or privacy of any information you supply when you visit such sites, and such sites are not subject to this privacy Policy. We do not endorse the Privacy Policies of these Third-Party Sites, and we are not responsible for them. If you choose to visit one of these Third-Party Sites, you should therefore read the privacy Policies on these third-party sites to see how they collect and use your Personal Data.

Cookies and Other Tracking Technologies

Cookies and other tracking technologies (e.g., web beacons, device identifiers, and pixels) are used by TrueHandle and our third-party partners, such as our advertising and analytics partners, to offer functionality and to recognize users across multiple Services and devices. We use cookies to track visitor activity on our Site to improve user experience, such as tracking pages viewed, how long someone stays on a webpage, whether error messages were received, remembering information you've provided to provide a more personalized experience, and storing username or related login credentials so you don't have to provide this information every time you visit the Site. The only reason for collecting this data is to understand how our customers and the general public consume our services.

Updates to this Privacy Policy

Please keep in mind that we review our privacy practices on a regular basis and that they are subject to change. Return to this page on a regular basis to verify that you are familiar with the most recent version of this Privacy Policy. Any change, update, or modification will go into effect as soon as it is posted on our Site. Any major modification to this Privacy Policy will be communicated to you by posting a notice on the homepage of our Site for a reasonable period following the amendment or by sending an email to the email address connected with your user account, if necessary. We will equally amend the effective date to reflect the latest date of the amendment.

Questions and Complaints

Please contact us at support@truehandle.com or mail us using the address below if you have any questions, requests, or complaints regarding how we process your personal information.