Truwho Ltd - Privacy Policy

Last revised: September 15, 2018

This Privacy Policy explains how Truwho Ltd (“Truwho”) collects, uses, shares, and protects user information obtained through the website. The terms “we,” “us,” and “our” refer to Truwho and its affiliates. Truwho is a platform in which users are seeking to securely have verified and/or have stored various personal information in order to use the various services offered by the platform. Any information you provide is done so voluntarily. You may not be able to access or utilize all of our services if you choose not to provide certain requested information.

By using the Truwho site, you consent to the data practices described in this Privacy Policy. On occasion, Truwho may revise this Privacy Policy to reflect changes in law or our personal data collection and use practices. If material changes are made to this Privacy Policy, the changes will be announced by posting on the site. We will ask for your consent before using your information for any purpose that is not covered in this Privacy Policy.

This privacy policy has incorporated elements from the General Data Protection Regulation (GDPR) as we act in accordance to its personal information processing rules within the European Economic Area (EEA).

Information Truwho Collects

We want you to understand the types of information we collect and process when you register for and subsequently use Truwho’s services.

Information processed at registration

When you create a Truwho account, you provide us with personal information that includes your basic contact information (email address, name, and a password). You can also choose to add a phone number to be used for two-factor-authentication (2FA) verification for improved security. Neither this basic account registration information nor any other personal identifying information is shared with third parties - only your TruID may be made available to third parties.

Information we collect and process when authenticating your identity

In keeping with global industry regulatory standards including Anti-Money Laundering (AML), Know-Your-Customer (KYC), and Counter Terrorist Financing (CTF), Truwho requires users that wish to acquire certain levels of TruID to undergo user identity authentication. This entails collecting varying degrees of personal identification and information corresponding to the level of TruID a user may be seeking to achieve. Users should note that third parties will only have access to a user’s TruID, and NOT any underlying personal information supplied to Truwho for authentication purposes..

Information we collect and process as you use our services

Service Usage Information -- Through your use of the Truwho platform, we also process information related to usage such as access date & time, device identification, operating system, browser type and IP address. This information may be directly obtained by Truwho or through third party services. This service usage data helps us opimize our systems to ensure that our interface is accessible for users across all platforms, browsers, etc..

Transaction Information -- For all user accounts, we collect and process transaction information including deposit snapshots,token purchases and account balances, token redemptions and transfers, withdrawals, and other token activity and related history. This transaction data is monitored for user fraud protection, and legal case resolution.

Why Does Truwho Collect This Information

To provide and maintain our services

We use the information collected to deliver our services and verify user identity and related information to the extent requested by the user, corresponding the the level of TruID requested. With regard to the personal identifying information you voluntarily supply in connection with seeking a TruID, such information is collected to verify your identity and ultimately generate a unique TruID which in turn Truwho enterprise partners can rely upon so that you may access the services offered by such other partners. We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and provide our service. Given our legal obligations and system requirements, we cannot provide you with services without data like identification, contact information and various related information.

To protect our users

We use the information collected to protect our platform, users’ accounts and vaults. We use IP addresses and cookie data to protect against automated abuse such as spam, phishing and Distributed Denial of Service (DDoS) attacks. We analyze token activity with the goal of detecting suspicious behavior early to prevent potential fraud and loss of funds to bad actors.

To comply with legal and regulatory requirements

Respect for the privacy and security of data you supply to and/or store with Truwho informs our approach to complying with regulations, governmental requests and user-generated inquiries. We will not disclose or provide any personal information to third party sources without review from our legal counsel and/or prior consent from the user.

To measure site performance

We actively measure and analyze data to understand how our services are used. This review activity is conducted by our team to continually improve our platform’s performance and to resolve issues with the user experience. We continuously monitor our systems’ activity information and communications with users to look for and quickly fix problems.

To communicate with you

We use personal information collected, like an email address (or Telegram username) to interact with users directly when providing customer support on a ticket or to keep you informed on logins, token transactions, and security. Without processing your personal information for confirming each communication, we will not be able to respond to your submitted requests, questions and inquiries. All direct communications are kept confidential and reviewed internally for accuracy.

To enforce our Terms of Use and other agreements

It is very important for us and our customers that we continually review, investigate and prevent any potentially prohibited or illegal activities that violate our Terms of Service. For the benefit of our entire user base, we carefully enforce our agreements with third parties and actively investigate violations of our posted Terms of Use. Truwho reserves the right to terminate the provision of service to any user found engaging in activities that violate our Terms of Use.

How Does Truwho Protect User Data

Truwho has implemented a number of security measures to ensure that your information is not lost, abused, or altered. Our data security measures include, but are not limited to: PCI Scanning, Secured Sockets Layered encryption technology, pseudonymisation, internal data access restrictions, and strict physical access controls to servers and files. Please note that it is impossible to guarantee 100% secure transmission of data over the Internet nor method of electronic storage. As such, we request that you understand the responsibility to independently take safety precautions to protect your own personal information.

Users should note that personal information stored in the “vault” feature is protected by “end-to-end” encryption, and as a result, Truwho cannot access information stored this way.

If you suspect that your personal information has been compromised please contact Truwho customer service immediately.

Regarding Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. If you block cookies, you will not be able to use all the features on our website. We may use cookies for purposes including but not limited to authentication you when you visit our website and as you navigate our website; (b) to help us to determine if you are logged into our website; (c) to store information about your preferences and to personalize the website for you; (d) to provide security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally; and (e) to help us to analyze the use and performance of our website and services. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

Retaining and Deleting User Data

Truwho has policies and procedures in place designed to comply with legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for the corresponding purpose(s). Any personal data provided for purposes of registration or and/or obtaining a TruID will be retained for a time period deemed sufficient in order to comply with legal obligations to which Truwho is subject. Personal data stored in the vault may be removed at any time by the user, and in any case, cannot be accessed by Truwho. All other usage and transaction data will be retained for purposes of platform analytics subject to specific user requests to have such data deleted.

Your rights regarding your data

You have the right to confirmation as to whether or not we process your personal data and, where we do, you have the right access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data (though only TruIDs are the only data point made available to third parties outside of Truwho). Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

You have the right to the erasure of your personal data without undue delay. This may happen if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing or personal data have been unlawfully processed. If you want to erase your personal data, make an inquiry to our official email address.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

To the extent that the legal basis for our processing of your personal data is (i) consent, or (ii) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Contact Us

We are committed to respecting the freedoms and rights of all our Truwho users who have placed their trust in our service. If you should have any questions or concerns regarding this Privacy Policy, or if you would like to file a Data Protection request, please contact us.