Privacy Policy

1. Introduction

Trustpay (referred to as "we", "us", or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website trustpay.com (the "Website") or use our advertising automation platform and related services (collectively, the "Services").

We are a data controller for the purposes of the European Union's General Data Protection Regulation (GDPR) and other applicable data protection laws. Our registered office is at Słonecznikowa 00A/29, 81-639 Bydgoszcz, Poland, and our company registration number is 60966915.

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Website or use our Services.

2. Information We Collect

We collect personal data in various ways, including when you provide it directly to us, when you use our Services, or from third parties. The types of personal information we may collect include:

2.1 Information You Provide to Us

• Account Information: When you register for an account, we collect your name, email address, company name, phone number, and billing information.
• Contact Information: When you contact us or submit a form on our Website, we collect your name, email address, phone number, and any message content you provide.
• Payment Information: When you make a purchase, we collect your payment details, billing address, and other transaction information. Note that payment card details are processed by our secure payment processors and are not stored directly on our systems.
• User Content: Information you provide when using our Services, such as advertising campaign settings, audience data, or custom configurations.

2.2 Information We Collect Automatically

• Device Information: We collect information about your device, including IP address, browser type, operating system, device identifiers, and mobile network information.
• Usage Information: We collect information about your interactions with our Website and Services, including pages visited, features used, actions taken, time spent, and referring URLs.
• Location Information: We may collect approximate location information derived from your IP address.
• Cookies and Similar Technologies: We use cookies and similar tracking technologies to collect information about your browsing activities. For more details, see our Cookies and Similar Technologies section below.

2.3 Information from Third Parties

• Advertising Platforms: With your consent, we may collect data from third-party advertising platforms (such as Google, Facebook, LinkedIn) that you connect to our Services.
• Analytics Partners: We may receive information from analytics providers to help us understand how our Services are used.
• Business Partners: We may receive information about you from our business partners, such as when you are referred to our Services.

3. How We Use Your Information

We use the information we collect for various purposes, including:

3.1 Providing and Improving Our Services

• To provide, maintain, and improve the functionality of our Website and Services
• To process transactions and manage your account
• To monitor and analyze usage patterns and trends to improve user experience
• To develop new products, services, features, and functionality
• To diagnose and resolve technical issues

3.2 Communication

• To respond to your inquiries, comments, or questions
• To send administrative messages, including confirmations, technical notices, updates, and security alerts
• To provide customer support and assistance
• To send marketing communications, promotional offers, newsletters, and other information about our products and services (with your consent where required by law)

3.3 Personalization

• To personalize your experience with our Website and Services
• To recommend features, products, or services that may be of interest to you
• To tailor content and marketing communications to your preferences

3.4 Security and Compliance

• To protect the security and integrity of our Website and Services
• To detect, prevent, and address fraud, unauthorized access, and other potentially illegal activities
• To comply with applicable laws, regulations, and legal processes
• To enforce our Terms of Service and other legal rights

3.5 Legal Basis for Processing (EU/EEA Users)

For users in the European Economic Area (EEA), we process your personal data based on the following legal grounds:

• Contract: Processing is necessary to perform the contract we have with you (such as our Terms of Service) or to take steps at your request before entering into a contract.
• Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms. Our legitimate interests include providing, improving, and securing our Services, preventing fraud, and marketing our products and services.
• Consent: Where required by law, we will process your personal data based on your consent, which you can withdraw at any time.
• Legal Obligation: Processing is necessary to comply with our legal obligations.

4. How We Share Your Information

We may share your information with the following categories of recipients:

4.1 Service Providers

We share information with third-party service providers that help us operate, provide, improve, and market our Website and Services, such as:

• Cloud hosting and infrastructure providers
• Payment processors
• Customer support and communication tools
• Analytics providers
• Marketing and advertising partners

These service providers are contractually bound to protect your personal data and may only use it for the specific purposes we authorize.

4.2 Advertising Partners

With your consent, we may share information with advertising platforms to help you manage and optimize your advertising campaigns. This sharing is essential for the functionality of our Services.

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Website of any such change in ownership or control of your personal information.

4.4 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). We may also disclose your information to:

• Enforce our Terms of Service and other agreements
• Protect and defend our rights or property
• Prevent or investigate possible wrongdoing in connection with the Website or Services
• Protect the personal safety of users of the Website or Services or the public

4.5 With Your Consent

We may share your information with third parties when you have given us your consent to do so.

4.6 Aggregated or De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you with third parties for various purposes, including to improve our Services and for business or marketing purposes.

5. Cookies and Similar Technologies

5.1 What Are Cookies

Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work more efficiently and provide information to the website owners. Other similar technologies, such as web beacons, clear GIFs, and local storage, may also be used for similar purposes.

5.2 Types of Cookies We Use

We use the following types of cookies on our Website:

• Essential Cookies: These cookies are necessary for the Website to function properly and cannot be switched off. They are usually set in response to actions you take, such as setting your privacy preferences, logging in, or filling in forms.
• Performance and Analytics Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us know which pages are the most and least popular and see how visitors move around the Website.
• Functionality Cookies: These cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
• Targeting Cookies: These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other websites.

5.3 Cookie Management

You can manage your cookie preferences through our cookie banner when you first visit our Website. You can also manage cookies through your browser settings, which allow you to refuse the setting of all or some cookies. However, if you block all cookies (including essential cookies), you may not be able to access all or parts of our Website.

5.4 Third-Party Cookies

We may allow third parties to place cookies on your device when you visit our Website. These third parties may include analytics providers, advertising networks, and social media platforms. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Website.

5.5 Do Not Track

Some browsers have a "Do Not Track" feature that signals to websites that you visit that you do not want to have your online activity tracked. Due to the lack of a common interpretation of Do Not Track signals across the industry, we currently do not respond to Do Not Track signals on our Website.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:

• Encryption of sensitive data both in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and vulnerability testing
• Employee training on data protection and security practices
• Monitoring for suspicious activities and unauthorized access attempts

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately using the information provided in the Contact Us section.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide Services to you
• Whether there is a legal obligation to which we are subject
• Whether retention is advisable in light of our legal position (such as for statutes of limitations, litigation, or regulatory investigations)

When we no longer need to use your personal information, we will either delete it from our systems or anonymize it so that it can no longer be associated with you.

8. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. These may include:

8.1 Access and Information

You have the right to request access to the personal information we hold about you and information about how we use it.

8.2 Correction

You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

8.3 Deletion

You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.

8.4 Restriction of Processing

You have the right to request that we restrict the processing of your personal information in certain circumstances, such as when you contest the accuracy of the data.

8.5 Data Portability

You have the right to receive a copy of the personal information you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

8.6 Objection

You have the right to object to our processing of your personal information in certain circumstances, such as when we process your data for direct marketing purposes or when we rely on legitimate interests as the legal basis for processing.

8.7 Withdrawal of Consent

Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your consent before its withdrawal.

8.8 Complaint to a Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority if you believe that our processing of your personal information violates applicable data protection laws.

8.9 How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided in the Contact Us section. We may need to verify your identity before fulfilling your request. We will respond to your request within the timeframe required by applicable law.

8.10 Marketing Communications

You can opt out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing emails or by contacting us directly. Please note that even if you opt out of marketing communications, we may still send you administrative messages related to your account or our Services.

9. Children's Privacy

Our Website and Services are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us using the information in the Contact Us section, and we will take steps to delete such information.

10. International Data Transfers

We are based in Poland, and your personal information may be transferred to, stored, and processed in countries outside the European Economic Area (EEA) where we or our service providers maintain operations. These countries may have data protection laws that are different from the laws of your country.

When we transfer personal information outside the EEA, we implement appropriate safeguards to ensure that your personal information receives an adequate level of protection, such as:

• Transferring to countries that have been deemed to provide an adequate level of protection by the European Commission
• Using specific contracts approved by the European Commission (Standard Contractual Clauses) that give personal data the same protection it has in Europe
• Transferring to organizations that are part of approved certification mechanisms, such as the EU-US Privacy Shield (where applicable)

For more information about these safeguards or to obtain a copy of them, please contact us using the information provided in the Contact Us section.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the "Last Updated" date displayed at the top of this Privacy Policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Trustpay
Słonecznikowa 00A/29
81-639 Bydgoszcz
Poland

Email: privacy@trustpay.com
Phone: +51 383 709 415

For EU/EEA data subjects, we have appointed a Data Protection Officer who can be contacted at dpo@trustpay.com.