Effective Date: January 2019
Trūata Limited (“Trūata”, “we”, “us”, or “our”) respects your privacy. This Privacy Statement applies to the processing of Personal Information collected (i) in the context of our website available at www.truata.com (the “Site”) or when you otherwise interact with us; and (ii) in the context of the anonymization solution we offer to our clients (the “Anonymization Solution”). For the purpose of this Privacy Statement, “Personal Information” means any information relating to an identified or identifiable individual.
This Privacy Statement describes:
- the types of Personal Information we collect
- the purposes for which we collect that Personal Information;
- the other parties with whom we may share it;
- the measures we take to protect the security of your Personal Information;
- your rights and choices with respect to your Personal Information; and
- how you can contact us in relation to our privacy practices.
Table of Contents
Processing in the context of the Site or Other Interactions with Trūata
This section explains how we process Personal Information about you in the context of the Site or when you otherwise interact with us. It does not cover the processing of your Personal Information in the context of the Anonymization Solution, which is described in a separate section below.
Personal Information We May Collect
We obtain Personal Information relating to you from the following sources:
- If you contact us with a query, we may collect the content, date and time of the query and our responses to it, as well as the contact details you used to contact us.
- If you register for a restricted part of the Site, we will collect your username and password.
- You may choose to submit Personal Information directly to us, including in response to marketing or other communications, through social media, by signing up for a Trūata product or service, through participation in an offer, program or promotion, or in connection with an actual or potential business or employment relationship with us. The information you provide may include your contact details (such as name, postal or e-mail address, and phone number), business contact information (such as job title, department and name of organization) and any other Personal Information you provide to us.
- We may collect any Personal Information you provide to us, a recruiter or an employee who refers you to us, in the context of your job application. You may apply via our career page at https://www.truata.com/careers/, social media outlets such as LinkedIn, or via other means. More information is available here.
- We use Matomo, a third party analytics provider, to collect information about your interactions with the Site via cookies and similar technologies. Matomo only collects such information on our behalf to help us understand how visitors use the Site and how we can improve it.
- We may collect Personal Information from publicly available resources, including social media, to perform market research.
- Our business contacts (e.g., your colleagues) may provide us with your contact information in order to establish a connection between you and us.
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information that is necessary to provide you with our products and services, or if we are legally required to collect it, you may not be able to benefit from them.
If you provide us with any Personal Information relating to another individual, you should make sure that the sharing with us and our further use as described to you from time to time is in line with applicable laws, so for example you should duly inform that individual on the processing of her/his Personal Information and obtain her/his consent, as may be necessary under applicable laws.
How We May Use Personal Information We Collect
We may use the Personal Information we collect to:
- Provide, evaluate and improve the Site.
- Communicate with you about products and services of Trūata and its partners, and respond to your queries.
- Manage our business relationships.
- Evaluate your interest in employment and contact you regarding possible employment with Trūata.
- Analyze our activities and develop new products and services.
- Comply with applicable legal requirements, industry standards and our policies.
- Create and manage any accounts you may have with us.
- Perform accounting, auditing, billing, reconciliation and collection activities.
We will only process your Personal Information when we have a valid legal ground for the processing, including if:
- You have consented to the use of your Personal Information.
- We need your Personal Information to provide you with products and services or to respond to your queries.
- We have a legal obligation to process your Personal Information.
- We, or a third party, have a legitimate interest to process your Personal Information. In particular, we have a legitimate interest to process your Personal Information to improve the Site and to develop new products and services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
- We do not share or otherwise disclose Personal Information we collect about you, except as described in this Privacy Statement or otherwise disclosed to you at the time the data is collected
- We may share your Personal Information with our service providers who perform services on our behalf and in relation to the purposes described in this Privacy Statement. We authorize these service providers to use or disclose the information only as necessary to perform those services on our behalf or comply with legal requirements. We require these service providers by contract to safeguard the privacy and security of Personal Information they process on our behalf.
- We may disclose information about you (i) if we are required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, or (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity.
- We also reserve the right to transfer Personal Information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use Personal Information you have provided to us in a manner that is consistent with this Privacy Statement.
Your Rights and Choices
You can at any time opt out from receiving marketing communications by clicking on the unsubscribe link within such communications or by e-mailing us at email@example.com. Subject to applicable law, you have the right to:
- Request access to and receive information about the Personal Information we maintain about you; update and correct inaccuracies in your Personal Information; restrict or object to the processing of your Personal Information; have the information anonymized or deleted, as appropriate; and easily transfer your Personal Information to another company (data portability);
- Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge (we will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal); and
- Lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
These rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us as indicated below.
Features and Links to Other Sites
You may choose to use certain features for which we partner with other entities, or click on links to other sites for your convenience and information. These features may operate independently from Trūata. They may have their own privacy policies, which we strongly suggest you review. To the extent any features or linked sites you visit are not owned or operated by Trūata, we are not responsible for their content or privacy practices.
Processing in the context of the Anonymization Solution
To provide customers with our Anonymization Solution, we obtain de-identified data from our customers and apply further de-identification techniques to anonymize it. We apply analytics on the anonymized data to provide our customers with anonymized information such as compilations, analyses, analytical and predictive models and rules, and other aggregated reports. We only share such information with the relevant customer. More information is available here.
Trūata relies on the legitimate interest legal ground to anonymize the data we receive from our customers. The types of data collected vary depending on the customer. For more information or to exercise your rights in relation to the data we receive from our customers, please contact the relevant customer.
We maintain appropriate administrative, technical, and physical safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. We use SSL encryption on our website from which we transfer certain Personal Information and restrict access to Personal Information about you to those employees who need to know that information to operate our business.
We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations. For example, we only keep data collected via cookies and similar technologies for 13 months.
International Data Transfers
We store your Personal Information in the European Economic Area. However, we may transfer or disclose Personal Information we collect about you to recipients in countries other than your country. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer or disclose your Personal Information to other countries, we will protect that information as described in this Privacy Statement.
We comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Information to countries other than the country where you are located. In particular, we may transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information to third parties, such as the European Commission's Standard Contractual Clauses, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable. You may contact us as specified in the “How to Contact Us” section below to obtain a copy of the safeguards we use to transfer Personal Information outside of the European Economic Area.
Updates to this Privacy Statement
This Privacy Statement may be updated from time to time to reflect changes in our privacy practices. We will notify you of any significant changes to our Privacy Statement and indicate at the top when it was most recently updated.
How to Contact Us
Trūata Limited is the entity responsible for the processing of your Personal Information. If you have any questions or comments about this Privacy Statement or our privacy practices, or if you wish to contact our Data Protection Officer or would like to exercise your rights and choices, you may:
- e-mail us at: firstname.lastname@example.org; or
- write to us at: Trūata Limited, 1st Floor, Silverstone House, Ballymoss Road, Sandyford, Dublin 18, D18 A7K7, Ireland.