Effective as of August 20, 2020
Use of Personal DataWe will use your Personal Data, to:
- Understand and strive to meet your needs and preferences in using our Services;
- Develop new and enhance existing service and product offerings;
- Manage and develop our business and operations;
- Carry out any actions for which we have received your consent;
- Prevent and investigate fraudulent or other criminal activity;
- To address service requests and resolve user questions; and
- Meet legal and regulatory requirements.
- We also reserve the right to use aggregated Personal Data to understand how our users use our Services, provided that those data cannot identify any individual.
Security of Your Personal DataWe protect Personal Data with appropriate physical, technological and organisational safeguards and security measures. Your Personal Data comes to us via the internet which chooses its own routes and means, whereby information is conveyed from location to location. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Every member of TrustSwap is committed to our privacy policies and procedures to safeguard Personal Data. Our site has security measures in place to protect against the loss, misuse and unauthorised alteration of the information under our control.
Retention of Your Personal DataThe length of time we retain Personal Data outside our back-up system varies depending on the purpose for which it was collected and used, as follows:Data you provide to us when subscribing for our Services (if applicable): while the user remains active, stored in United States.
- Country location data: while the user remains active, stored in United States.
- Data on your preferences: while the user remains active, stored in United States.
- IP address login: until subsequent login from a new IP, stored in United States.
- When Personal Data is no longer necessary for the purpose for which it was collected, we will remove any details that identifies you or we will securely destroy the records, where permissible. However, we may need to maintain records for a significant period of time (after you cease using a particular Service) as mandated by regulation.
Storage of Personal DataTrustSwap stores your Personal Data at secure locations in Canada. TrustSwap ensures that appropriate security standards are in place regarding the safeguarding, confidentiality, and security of Data.The information that we collect from you will be transferred to, and stored in, destinations outside of your country as described below:We may transfer your Personal Data outside Canada to other company subsidiaries, service providers and business partners (i.e. Data Processors) who are engaged on our behalf. To the extent that we transfer your Personal Data outside of Canada, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with relevant privacy laws.
Your RightsYour Rights The rights that are available to you in relation to the Personal Data we hold about you are outlined below.Information Access: if you ask us, we will confirm whether we are processing your Personal Data and, if so, what information we process and, if requested, provide you with a copy of that information within 30 days from the date of your request.Rectification: it is important to us that your Personal Data is up-to-date. We will take all reasonable steps to make sure that your Personal Data remains accurate, complete and up-to-date. If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your Personal Data to others, we will let them know about the rectification where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly. You may inform us at any time that your personal details have changed by emailing us at email@example.com and we will change your Personal Data in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof that we are required to keep for regulatory or other legal purposes.Erasure: you can ask us to delete or remove your Personal Data in certain circumstances such as if we no longer need it, provided that we have no legal or regulatory obligation to retain that data. Such requests will be subject to any agreements that you have entered into with us, and to any retention limits, we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your Personal Data to others, we will let them know about the erasure request where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly.Processing restrictions: you can ask us to block or suppress the processing of your Personal Data in certain circumstances, such as, if you contest the accuracy of that Personal Data or object to us processing it. It will not stop us from storing your Personal Data. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your Personal Data to others, we will let them know about the restriction of processing where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly.Data portability: in certain circumstances, you might have the right to obtain Personal Data you have provided us with (in a structured, commonly used and machine-readable format) and to re-use it elsewhere or ask us to transfer this to a third party of your choice.Objection: you can ask us to stop processing your Personal Data, and we will do so if we are:Relying on our own or someone else’s legitimate interests to process your Personal Data, except if we can demonstrate compelling legal grounds for the processing;
- Processing your Personal Data for direct marketing; or
- Processing your Personal Data for research, unless we reasonably believe such processing is necessary or prudent for the performance of a task carried out in the public interest (such as by a regulatory or enforcement agency).
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