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TrustFinance

Personal Data Protection Policy

Introduction

Trust Financial Data Pte.Ltd. ("TrustFinance", "the Company," "us," "we," or "our") recognizes the importance of personal data protection. Protecting client’s personal data and maintaining security are among our highest priorities. Thus, TrustFinance has laid down this Personal Data Protection Policy (“the Policy'') to ensure its commitment to providing secure services and safeguard its client’s personal data with the highest standard. This Policy shall prescribe the process of data collection, usage, storage, transmission, and deletion, also including other rights of the Data Subject.

Clients are requested to carefully read through this Policy thoroughly, before entering into business relationship with TrustFinance or carrying out any activity with TrustFinance. Through entering into an agreement with TrustFinance, clients agree to the terms of our Policy, as set out in this document.

Purpose and Scope of the Policy

This Policy shall apply to its clients, contractors, users of websites operated under TrustFinance, and third-party service providers who have access to or process personal data (“Client,” “you,” “your”). This Policy shall cover all personal data collected, stored, processed, transferred, or deleted by TrustFinance in the course of our business operations. In this regard, TrustFinance shall act as the data controller for all additional personal data related to our platform, such as information you provide when you establish an account, post a review, or send a response. TrustFinance shall act in compliance with relevant data protection law and applicable laws and regulations.

Please be informed that if you've been invited to submit TrustFinance reviews by businesses that use our services, or by us on their behalf, those businesses will be the data controllers responsible for such invitations and any personal data linked with them. If you have any queries regarding such invites or want to exercise your rights in relation to any data used in that context, please contact the relevant businesses directly, since we cannot assist you.

Interpretation of Terms

Unless otherwise stated herein, the following terms shall have meaning as set forth here below:

“Data Controller” means any individual who or public body which, alone or jointly with others, determines the purposes and means of the processing of personal data and has decision making power with respect to the processing;
“Data Subject” means any individual, excluding legal entity, who can be identified from —

  • personal data; or
  • from personal data and other information to which the Company has or is likely to have access;

“individual” means a natural person, whether living or deceased;

“personal data” means any information relates to Data Subject and can identify such data subject, whether such information is —

  • true or not;
  • directly or indirectly;
  • in any printed or electronic form;

“processing” or “process” means any operation performed on individual’s personal data, including collection, usage, storage, transmission, and deletion of personal data;



Collection of Personal Data

When register a TrustFinance user account, write a review, create a business account on behalf of your company, or otherwise use our platform, Client agrees to have their personal data processed and specifically consent to the collection, systemization, aggregation, storage, revision (updating, changing), usage, anonymization, blocking, deletion, and distribution (transfer) of said personal data to third parties in accordance with the conditions set forth in this Policy. The Company shall collect personal data within the purpose, scope, and lawful and fair methods as is necessary for providing functional services, adherence to legal requirements, and using this data if a dispute arises between Client and TrustFinance. Accordingly, Company will inform the Data Subject to gain acknowledgment and consent through electronic or other methods as specified by the Company.



Scope of Personal Data Collection

TrustFinance collects personal data only for specific, legitimate purposes. The types of personal data we collect may include, but are not limited to:


  • Contact information: Your name and email address, as well as any other contact information you may provide to us at any time.
  • Device and location details: Your IP address, browser preferences (browser type, language, and time zone), and location.
  • User account information: Your username, password, photo, location and preferred language.
  • Business account information: Your password, your company name and domain, and certain other information you choose to add to your business profile, such as details about the type of services your company offers.
  • Usage and profiling information: Your TrustFinance search history, how you've interacted with our platform, or emails we send to you, including time you spend on our site, features or functions you’ve accessed, marketing emails you’ve opened and links you’ve clicked.
  • Details regarding reviews and ratings, including:
    • Which business you reviewed.
    • Which product you reviewed.
    • Whether you wrote a service review, a location review, or a product review.
    • Your review content and star rating.
    • Your product photos or videos (if you provide them together with your product review).
    • The location of the business you reviewed.
    • The dates you wrote your review, made any edits, or deleted the review.
    • Your reference number, order ID or similar (if you or the business provided one).
    • If we ask you to provide information or documentation to verify your experience, and you send us such documentation, we will collect and process the documentation for the purpose/s stated in the request.
  • Information about views, likes and how useful your review is for others: How many people read your review and how many people find your review “useful”. We also collect information if you click “useful” on someone else’s review.
  • Information about reports and replies to reviews from your business account: Your name, company details, the information you state in the reply to a review, which review you reported, the reason for the report, the date of the report.
  • Your verification data:
    • Information about whether your user account or your business domain is verified (your verification badge).
    • Data provided during the verification process for consumers and verification process for businesses:
      • Your first and last name.
      • Images of the documents you submitted.
      • Number and date of expiry of the documents you submitted.
  • Information about questions you asked on a business’s website:
    • Which business you asked a question.
    • The product you asked the question about.
    • The date you asked the question.
    • The business’s response to the question.
  • Data obtained with the "Find Reviewer" tool: Find Reviewer enables companies to contact reviewers in order to learn more about them and their experiences. We gather information that you choose to submit to the company, such as your complete name, phone number, email address, and reference ID.
  • Preferences data: Selected choices linked with your account, such as particular consents granted or denied, newsletters or similar email preferences, and cookies holding your preferences.
  • Communication information: This includes messages we receive from you via email and other electronic communication means, such as review notices, comments, assistance requests, and enquiries, as well as metadata linked with those interactions, such as time and date.
  • Call recordings: For training, quality control, and compliance purposes, all inbound and outgoing phone calls made to or through TrustFinance may be recorded. Personal data (such as name and contact information) given during a phone call will be digitally captured in order to provide suitable services.
  • Information from other services, including social networks: You may link your TrustFinance profile to your social media accounts, such as Facebook ("social network"). When you do this, we will automatically gather certain information about you from your social network, based on the information you have made public on that social network and your privacy settings for sharing such information on that social network. We may gather the following data:
    • Username and/or name
    • Profile picture
    • Email address
    • Your social networks

Providing this information is required for client identification and thus allows clients to write a review, or otherwise use our platform. The Company may also collect data to improve our understanding of their needs and preferences by communicating through communication with clients over the phone. Clients provide this data to us voluntarily. The Company uses the data that clients directly provide when communicating.


If you provide personal data of third parties, such as family members, emergency contacts, or reference persons, please inform such persons of the information described in this Policy. Also, in some cases, you may need to obtain consent from the individuals in order for us to process their personal data.


In the event that the Company requires to process the client's personal data for purposes beyond those initially specified, the Company shall inform the client accordingly. If such additional processing cannot be justified by any other legal bases, the Company shall seek the client's explicit consent before proceeding with the processing of personal data for the new purpose. The client will have the option to provide or withhold consent based on their preferences.


How We Collect Personal Data

In general, TrustFinance will directly collect your personal data through these processes or channels, including, but not limited to;

  • when receive directly via documents; and
  • when communicating directly via email or any social network.

However, we may collect additional personal data through third-party organizations.



Personal Data Received From Data Subject Directly

TrustFinance may gather its Client’s personal data directly via your identification documents or other information you entrust to TrustFinance during our course of business or as requested by TrustFinance with your consent for its operations, whether in the printed or digital for. It also includes information already held by TrustFinance arising from the use of services, interactions, visits, searches through digital channels, telephone communications, email communications, fax communications, postal communications, or various social media platforms. For example, when you enter your details to create an account with us or engage with our platform or marketing communications, such as by writing reviews or posting answers to reviews.


This includes when you enter into legal contracts or agreements with TrustFinance, when you submit documents and copies of documents to TrustFinance, when you make payments to TrustFinance, when you offer goods or services to TrustFinance. This also includes when you inquire, comment, provide feedback, or submit complaints to TrustFinance via telephone, electronic mail, email, fax, postal services, applications, or other means of communication.



Personal Data Received from Third Parties

TrustFinance may receive its Client’s personal data from third parties. Third parties refer to individuals or legal entities who are not the Data Subjects. This may include the collection of personal data through TrustFinance's contractual partners or intermediaries. When you sign up for a TrustFinance account through Facebook, for example, your account is instantly pre-populated with the information we receive from them. Similarly, when a company requests us to send you a review invitation on their behalf, they provide us with your name, email address, and a reference number, such as an order ID or something similar. In some cases, TrustFinance may collect your personal data from public sources, government agencies or state enterprises, sources related to your business, or commercial sources.



Personal Data Received From Data Subject Automatically

TrustFinance also automatically generates or collects information from your computer or device as you use our services, such as your IP address, location, information about the device and browser you're using to access TrustFinance, or information about your usage and profiling, such as your interaction with our platform or marketing emails.



Other Methods of Personal Data Collection

When TrustFinance collects its Client’s personal data, Client reserves the right to be informed of details as specified in the Policy. This includes, but is not limited to, the purposes and legal bases for the collection, use, disclosure, or any processing of personal data. If personal data processing requires your consent under the relevant data protection laws, TrustFinance will seek your explicit consent.


In cases where TrustFinance collected your personal data before the relevant data protection laws concerning the collection, use, disclosure, or any processing of personal data came into effect, TrustFinance will continue to collect and use your personal data for the original purposes previously notified to you. Clients have the right to withdraw consent by contacting TrustFinance using the contact details provided by the Policy. TrustFinance reserves the right to consider requests for withdrawal of consent and to proceed according to the requirements of the relevant data protection laws.



Processing of Personal Data

Under the provisions of data protection laws, TrustFinance will carry out any activities and process your personal data, according to the legal bases and the purposes as specified hereunder.


TrustFinance will process its Client’s personal data for any activities based on one or more of the following legal grounds:

  • Consent of the Data Subject;
  • Performance of a contract;
  • Compliance with legal obligations; and/or
  • Legitimate interests pursued by TrustFinance or a third party service provider who have access to or process your personal data.

TrustFinance shall processes your personal data for each activity according to the following purposes:

  • Provide our services to you, including displaying your reviews and giving you access to your user account and our platform, or providing you with access to your company’s business account and our website.
  • Identify you as a registered user when you log into our platform and revisit our platform.
  • Improve our platform and services.
  • Respond to your questions and provide customer service.
  • Send you our newsletters.
  • Engage in various internal business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying our platform and our services, including our TrustBoxes, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • Train our staff and for quality control purposes, helping us improve the quality of our services.
  • Exercise or comply with our own legal rights or obligations in connection with legal claims, or for compliance, regulatory and auditing purposes, where necessary. For example, we may retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body.

We may also use your personal data if you have a TrustFinance user account to:

  • Verify the authenticity of your reviews.
  • Invite you to leave more reviews.
  • Pass on a message from the business you reviewed or the business that invited you to review a service experience or a product via our platform.
  • Contact you if your review is flagged by businesses or other users and, if necessary, ask you to provide documentation to verify your review or experience.
  • Contact you by email to tell you how many times your review was read and whether other users find your review useful, or otherwise provide feedback concerning your user account or your review.
  • Facilitate the social sharing function, including giving you the option to connect with members of your network who are both users of TrustFinance and users of one or more social networks.
  • Display which members of your social networks are also users of TrustFinance in order to increase confidence in reviews and to create a better user experience on our platform.
  • Enforce our Terms & Conditions.

We may also use your personal data If you have a TrustFinance business account on behalf of your company to:

  • Notify you of a review of your company or the items you provide.
  • Check the authenticity of your responses to reviews.
  • Notify you when users leave feedback on your response to a review or your review report.
  • Apply our Terms and Conditions. We may also use the information in other ways for which we will notify you at the time of collection.

We need to process your personal data to:

  • Perform our contract with you or your company.
  • Exercise and comply with our own legal rights and obligations and operate an online review platform in compliance with applicable legal acts.
  • Pursue legitimate business interests related to operating our website and providing our services to you. Where we process your personal data based on a legitimate interest we will only do so where the processing is relevant, adequate and limited to what is necessary for the purpose it was collected for. And of course, we'll always ensure our legitimate interests don't unfairly impact on your own rights and freedoms.
  • Establish, exercise or defend legal claims, where necessary.

We will process your personal data according to the stated legal bases and the purposes. If there came upon a case where your personal data were to be processed for other purposes that cannot be justified by any other legal bases, we would inform you and ask for your consent to process personal data on such uses.


If you have expressly given us your consent to process your personal data, such as when subscribing to our newsletters or accepting certain cookies on your device, you have the right to revoke your consent at any time, either by using the functionality provided within the relevant product feature or by contacting us. Please note, however, that we may still be entitled to continue processing your information if justified by another legal basis as mentioned above.



Disclosure of Personal Data

When TrustFinance discloses its Client’s personal data to third parties, TrustFinance will implement appropriate measures to protect the disclosed personal data and comply with personal data protection standards and duties. This may include establishing a Data Processing Agreement as required by data protection laws.


In cases where TrustFinance sends or transfers your personal data abroad, TrustFinance will ensure that the destination country, international organization, or foreign data recipient has adequate personal data protection standards. Alternatively, TrustFinance will ensure that the transfer complies with the criteria set by data protection laws. This may also involve establishing a Data Processing Agreement. In certain events, TrustFinance may seek your consent for the international transfer of your personal data.



Disclosure of Personal Data with Third Parties

TrustFinance may disclose its Client’s personal data to the following third parties in accordance with the aforementioned legal bases, purposes, and legal requirements:

  • Affiliates of TrustFinance

    This includes the executives, directors, employees, staff, agents, and/or internal personnel of such companies as necessary for processing your personal data.

  • Business Partners

    This includes prospective partners, individuals associated with partners or prospective partners, service providers, and data processors appointed or hired by TrustFinance to manage/process personal data on TrustFinance's behalf in providing various services, such as information technology services, data recording services, payment services, postal services, parcel delivery services, printing services, data analysis services, research services, marketing services, or any other services that may benefit the Client or related to TrustFinance's business operations.

  • TrustFinance's Consultants

    This includes legal advisors, lawyers, auditors, or other experts, both internal and external to TrustFinance.

  • Government Agencies with Regulatory Authority

    This includes agencies that request the disclosure of personal data under legal authority or in connection with legal proceedings, or as permitted by relevant laws.

  • Other Individuals or Entities

    This includes any individuals or entities to whom the Client has consented to disclose your personal data.


For the cases where personal data are being disclosed or transferred to third-party organizations, we will ensure that the minimum amount of personal data are being disclosed or transferred, and may consider anonymization and pseudonymisation techniques for greater security. Further, the third-party organizations who will process your personal data for us will be required to have in place appropriate privacy policies. We do not permit these third-party organizations to use your personal data in a way that diverge from the agreed legal bases and purposes.



Retention of Personal Data

TrustFinance will store its Client’s personal data in both physical and digital formats or as electronic documents at TrustFinance's headquarters and branches. The personal data will be stored on servers accessible by TrustFinance, with appropriate security measures in place to protect the disclosed personal data and comply with personal data protection standards and duties as prescribed by data protection laws.


TrustFinance will retain its Client’s personal data for as long as necessary to achieve the purposes specified for processing such personal data. The retention period of personal data will vary based on the purposes specified for processing the personal data. Additionally, TrustFinance will retain personal data for the duration required by relevant laws, taking into account the legal prescription period for any legal actions that may arise from or relate to the documents or personal data collected. For example, to fulfill a contract between us, perform a service you requested, meet legal requirements, or for our legitimate interests.


Personal information you provide, including reviews, is retained for the duration of your TrustFinance account or as needed to provide you with our services. If you choose to deactivate your user account, we will keep a log that includes your name, email address, and the date you deleted your account. The log will be kept for three years. Even if you deactivate your TrustFinance account, we may preserve certain information for which we are obligated by law or have compelling legitimate interests. TrustFinance may retain some data for longer periods of time for a variety of reasons, including (but not limited to) security, fraud and platform abuse prevention, compliance with legal or regulatory obligations, and defending our lawful business interests.


Personal data received from companies that utilize our automated services to send you a review invitation is retained for three years.


After the aforementioned retention period and there is no longer a justifiable purpose for us to store your data, TrustFinance will either delete or destroy the personal data from its storage or systems and those of service providers to TrustFinance (if any), or render the personal data of its Client unidentifiable, unless TrustFinance is permitted to retain such personal data further as prescribed by data protection laws or other relevant laws. However, you can remove or request that we erase your personal data at any time in accordance with your rights as specified in this Policy.



Security Measures for Personal Data Protection

TrustFinance has implemented a variety of organizational, technological, and administrative safeguards and constantly evaluates our system for vulnerabilities to ensure the security of its Client’s personal data. In this connection, third-party organizations which process personal data on our behalf are required to ensure the security of your personal data, and to carry out the processing in appropriate manner.


We cannot, however, guarantee or warrant the security of the information you communicate to us since the internet is not a perfectly secure environment. Emails transmitted through the platform may not be encrypted, therefore please do not include any private information in your emails to us.



Rights of The Data Subject

If you have a TrustFinance user account, you may log in at any time to access, change, download, or remove the critical personal data linked with your profile. You can also modify your email subscription options from this page.


You also have rights in respect to the personal information we have on file for you. These rights may be limited, for example, if complying with your request might expose personal information about another person, or if you ask us to erase information that we are obligated by law or have strong legitimate interests in keeping. If your issues remain unanswered, you have the right to file a complaint with a data protection authority.


Access and download your personal data

If you have a TrustFinance user account, you may log in to see and download account information, including your reviews. Please check the Privacy section of our Support Center for further information on how to do so.


If you have a TrustFinance business account or no account at all, you can email [email protected] and request details about your personal data.


Correction and deletion of your personal data

If any of your personal data is incorrect or misleading, if your personal data changes, or if you no longer want to appear on the platform, you may rectify, edit, or remove the information yourself using your TrustFinance user account. Otherwise, you may send an email to [email protected] requesting that your information be corrected or deleted.


Other rights

In addition to the rights outlined above, you have the right to object to the processing of your personal data, as well as the right to have the processing of your personal data restricted (particularly where the data is not required to meet a contractual or other legal requirement, such as the processing of your personal data for direct marketing purposes).


You may withdraw your consent at any moment if we have requested it. You may withdraw your permission at any time by utilizing the capability provided within the relevant product feature or contacting us. If you request that TrustFinance stop processing your data, this will have no effect.


In some circumstances, TrustFinance may not be able to carry out and support exercise of your rights, including, but not limited to, the cases where a legal process is taking place or where we are required to oblige with the court order. However, where you have given consent to process personal data, you will continue to have the right to retract your consent by contacting us. We will therefore be required to terminate such processing as soon as possible. Please note that the retraction only applies to the processing carried out thereafter. Any processing carried out before the retraction will not be reversed.


Please be informed that we do record all requests to ensure all issues are resolved.


In the case where you intend to exercise your rights, or to file a complaint against your personal data processing, please contact our Data Protection Officer. We will process your request in a secure and timely manner as required by the laws.



Children’s information

Our platform is not intended for children under the age of 16, and we do not intentionally collect personal information from them. If you believe a child under the age of 16 has provided us with personal information, please notify us using the details provided below.



Data Protection Policy Revision

TrustFinance reserves the right to amend, revise, modify, change, or terminate the Policy at its sole discretion at any time. Any changes or updates of the Policy shall be effective immediately upon posting on the Company’s website. To keep updated, we will publish changes to this page and invite you to examine our Data Protection Policy.


In the event where TrustFinance modifies any term that fundamentally changes your data subject rights, such revision shall be notified to all related parties under this Data Protection Policy Through email or through our site. Continued use of our platform or services after we post or send a notification regarding policy changes means you acknowledge and agree to the updated policy.



Contact Us

We want this information to be as straightforward and open as possible. However, in case you wish TrustFinance to take any action, have any questions, or want to exercise your rights as specified in this Policy, please contact our Data Protection Officer at [email protected].

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