EU Privacy Policy

Effective Date: May 25, 2018

ABOUT US

We are trueEX Group LLC with headquarters located at 22 West 21st Street, 9th Floor, New York, NY 10010,which is where we can be contacted with any questions regarding this privacy policy. Any personal information processed by trueEX is controlled by us and so we are considered the data controller of your personal information. We can be contacted at privacy@trueex.com.

DATA PROTECTION LAWS

We must comply with the Data Protection Act no 2472/1999, Law no 3471/2006 and the General Data Protection Regulation (EU) 2016/679 when keeping personal data about you when we obtain, use, disclose or otherwise process such data.

ABOUT THIS PRIVACY POLICY

We are committed to protecting your personal information and respecting your privacy. This policy explains the personal information we collect from you, and how we use and process your personal information in connection with your relationship with trueEX as a current or potential customer or affiliate, or a current or potential customer representative (including users of our various platforms). In particular, we explain the kinds of personal information that we collect from you, how we collect it, what we use it for, and with whom we may share your personal information. By “personal information” we mean information about you that identifies you, or could identify you.

CATAGORIES OF INFORMATION WE COLLECT

We collect personal information such as your name, business address, business email address, and business telephone number.

HOW WE COLLECT YOUR INFORMATION

We collect personal information about you directly from you or from your employer and during the sales and onboarding process for you to access our various platforms and service, or it is information you have provided to us in the normal course of doing business.

WHY WE COLLECT YOUR INFORMATION

We use your personal information for compliance with legal and regulatory purposes, for general corporate obligations and communications/marketing to provide you with the services that we are obligated to provide. The purposes for which we collect and process your information are deemed legitimate interests. We collect and process your information for the following purposes:

  • securely identify you when you log in to our platform;
  • provide customer support;
  • provide service related notifications;
  • individually identify you as a user of our services;
  • provide the services you have asked us to provide;
  • communicate with you about the services you have asked us to provide;
  • provide you with information about new products and services, service enhancements, software releases and other information and notices related to our operations;
  • monitor and improve our services; and
  • comply with our security and other regulatory obligations.

WHO ELSE MAY HAVE ACCESS TO YOUR INFORMATION

To best serve you, we may share your personal information with service providers that are essential to provide the services you expect. They are restricted from using your information in any manner other than in helping us to fulfil your expectations of the services provided by trueEX.

In order to provide our services to you, we may need to share your personal information with third parties such as third party contractors who deliver services to us, such as maintenance services, hosting services or development services.

We may share aggregated information, log data and usage statistics with third parties for the purposes of demographic, industry and marketing analysis, and for the formation of business relationships.

We may also disclose your personal information to a third party when you ask us to do so, when we believe it is required to provide to service providers in the normal course of providing services to you, or if required by law or regulation to which we or you are subject.

COUNTRIES HAVING ACCESS TO YOUR INFORMATION

For data storage reasons, we are unable to store all of your personal information in the European Economic Area. Our servers, storing and keeping your information secure, are located in the United States.

YOUR CONSENT

Because we collect your personal information only for legitimate interests, we are not required to ask for your consent. While we do not plan to do so, if we ever intend to use your personal information for other purposes that you would not expect or purposes which would not be construed to be for a legitimate interest, we will ask for your consent.

COLLECTING YOUR INFORMATION LEGALLY

We are able to legally collect and use your personal information either because it is necessary for legal and regulatory purposes for you to access our Platform, or is used for a lawful business objective in order for us to carry out our legitimate interests.

RETENTION OF YOUR INFORMATION

We will retain your personal information for as long as it is necessary as required by law. trueEX is subject to state and federal laws in the United States and other laws in jurisdictions outside of the United States, and is required to retain your information for the time period required by the laws of those jurisdictions.

YOUR RIGHTS

You have the right to:

  • be informed about the personal information we collect from you and use, which this privacy policy seeks to do;
  • obtain confirmation from us that your personal information is being collected and used by us and to know the personal information held about you by us;
  • have your personal information corrected if it is inaccurate or incomplete at any time;
  • erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information we hold about you at any time; (however,, please note that in certain circumstances we may need to keep your information to comply with various legal requirements, see RETENTION OF YOUR INFORMATION above).
  • block or suppress us collecting and using your personal information, which means we can continue to store your personal information but we cannot further collect or use it in any way;
  • obtain and reuse any personal information we hold about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from trueEX to another place notified by you to us in a safe and secure way without hindrance to the usability of your personal information; and
  • object to us collecting or using your personal information where this is based on a legitimate interest or the performance of a task in the public interest. In those instances, you will have the right to “unsubscribe” to emails sent by us for those purposes. If you object to us collecting or using your personal information for access to our services, we will be unable to continue providing you those services.

To make any requests as listed above, please contact us at privacy@trueex.com.

We will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.

WITHDRAWAL OF YOUR CONSENT

You can tell us to stop using your personal information at any time by emailing us at privacy@trueex.com or by choosing to unsubscribe, if that choice is available.

If you tell us to stop using your personal information, the consequences of doing so are the following:

  • access to our platform and services will no longer be available to you;
  • we will no longer provide you with information about new products and services, service enhancements, software releases and other information and notices related to our operations;

COOKIES

Our website uses “cookies”. We use cookies to distinguish you from other visitors, track your IP address and usage of our site, and to identify the name of the website from which you linked to our website, among other statistical data points. This information is used to help us serve you better by improving our website design, as well as our products and services. We do not otherwise track any information about your use of other websites. Non-personal information or anonymised/pseudonymised information obtained through cookies may be shared with or obtained by service providers on our behalf.

A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available. When you visit our website, we may use both session and persistent cookies. These cookies may contain information (such as a unique user ID) that is used to track your usage of our website. We may also use cookies to monitor and maintain information about your use of our website.

You can disable cookies at any time by using your browser options. You can find out more about cookies by following this link: https://ico.org.uk/for-the-public/online/cookies/.

CHILDREN’S PRIVACY

We do not knowingly collect any information from anyone under 16 years of age. Our website, products and services are all directed to people who are at least 16 years old or older. If you are under 16, do not use or provide any information on this website or on or through any of its features/register on the websiteor provide any information about yourself to us, including your name, address, telephone number or email address. If we learn we have collected or received personal information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@trueex.com.

LINKS TO OTHER WEBSITES AND SERVICES

Our website may include links to other Internet sites, content, or videos (embedded or direct links) maintained by third parties (“Linked Sites”). We provide Linked Sites to you solely as a convenience, and the inclusion of Linked Sites does not imply endorsement by us of the Linked Sites. You access Linked Sites at your own risk and by accessing them you leave our website. Linked Sites are not under our control and we are not responsible for the contents of any Linked Site, including the privacy policies or tracking technologies they may use. We encourage you to check the applicable privacy policy to determine how they will handle any personal information they collect from you.

YOUR INFORMATION, YOUR CHOICE

To update us with your information-sharing preferences, you may contact us by email at privacy@trueex.com;

COMPENSATION HISTORY

You are not asked to, and should under no circumstances, disclose your current or prior salaries, wages, benefits, allowances, retirement plans, bonuses, commissions, profit percentages or other compensation at any time to us.

SECURITY

We shall implement appropriate technical and organisational measures to ensure a level of security appropriate to potential risks, including:

  • the pseudonymisation and encryption of your personal information where appropriate;
  • ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  • ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs;
  • regular testing, assessment and evaluation of the effectiveness of our technical and organisational measures to ensure your personal information is secure;
  • transmitting your personal information over secure channels, and conducting penetration tests; and
  • providing physical and administratively security measures, strong authentication procedures and strict password protection.

We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us using our website.

BUSINESS TRANSITIONS

As we continue to develop our business, we may undergo a business transition such as acquiring another company, merging with an existing company, or selling a portion of our assets. In such transitions, customer information is typically one of the business assets that is transferred or acquired by a third party. In the event that trueEX or substantially all of its assets are acquired or enter a court proceeding, you acknowledge that such transfers may occur and that your personal information can continue to be used as set forth in this privacy policy.

POLICY CHANGES

This policy replaces all previous disclosures we may have provided you about our information practices. We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law. If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our website.

MAKING A COMPLAINT

We pride ourselves on excellent customer service, but if you would like to make a complaint about the way we have collected or used your personal information, please contact us at privacy@trueex.com

If you are unhappy about the way we have handled your complaint and/or you would like to take the matter further or make a complaint directly to our regulator without contacting us first, you can do so by contacting the Information Commissioner’s Office (“ICO”) by following this link: https://ico.org.uk/concerns/ or telephoning the ICO helpline, which is 0303 123 1113.