Privacy Policy

This document contains the information about the data handling of Trustaas Ltd. (hereinafter refers to: Data Controller) on the www.trustaas.com website.

The Privacy Policy was prepared in accordance with the General Data Protection Regulation (2016/679) (hereinafter referred to: Regulation).

Contact details:

Registered office: TrustaaS Ltd. 1117 Budapest, 111 Budafoki str., HUNGARY

Email: dpo@trustaas.com

  1. The scope of the data processed, the legal basis and the purpose of the data processing, and the duration of the data processin

Use of Contact form, description of the data processing case, and the purpose of the data processing 

You can connect us with the use of contact forms.

In the contact forms you should give to us the following personal data:

    • name (required),
    • company name,
    • email ((required),
    • subject of the message,
    • message text

We use this information’s to the following goal’s:

    • handle the contact,
    • service recommendation,
    • reconciliation of questions.

Legal basis of data processing

The legal basis of data processing is the Article 6 Section (1) point a) of the Regulation.

Duration of data controlling

Personal data will not be stored for longer than is strictly required in order to realize the purpose for which the data was collected. All data collected in relation to the provision of our services will be deleted as soon as possible after the transaction has been completed in full.

  1. Data processors

During our data processing we use the following data processors:

    • Kinsta Inc. 9 E. Loockerman St., Suite 311, Dover, DE 19901
  1. Data transmission

Your personal data will not be forwarded to a third party unless you agree, but in such cases we always ask for your consent in advance for data transfer.

  1. Your rights regarding data controlling

Within the duration of data controlling you have the following rights under the provisions of the Regulation:

    • Right to access the information in connection with the personal data and data processing
    • Right to rectification
    • Right to restriction of processing
    • Right to erasure (“right to be forgotten”)
    • Right to data portability
    • Right to object
    • Right to withdrawal of consent

If you intend to exercise your rights, it involves your identification and we will need to communicate with you. Therefore, for the identification, personal data will be required (but the identification may only be based on data that we may otherwise treat you). Your complaints regarding the data processing will be able to access in our e-mail account within this privacy policy’s time frame.

Complaints regarding data controlling will be answered no later than 30 days.

Right to withdrawal of consent

You may at any time be entitled to withdraw your consent to the processing of your data, in which case the provided information will be deleted from our systems.

The right of access to personal data and information

You are entitled to receive feedback on whether your personal data is being processed and, if data processing is in progress you are entitled to:

    • receive access to the treated personal data and
    • be informed about the following information:
    • the purposes of the processing;
    • the categories of your personal data;
    • information about the recipients or categories of recipients to whom your personal data have been or will be disclosed by us;
    • the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    • the existence of the right to request from us rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject or to object to such processing in the case of data processing based on legitimate interests;
    • the right to submit a complaint to the supervisory authority;
    • if the data was not collected from you,any available information about your personal data source;
    • the existence of automated decision-making process (if it is used), including profiling, and at least in those cases the meaningful information about logic involved as well as the significance and the envisaged consequences of such processing for you;

The purpose of the exercise of the right is to establish and control the lawfulness of data processing and therefore, upon requesting multiple information, we may charge a reasonable cost reimbursement in return for the fulfillment of information.

The access to your personal data is granted to you by sending the treated personal data and information via e-mail, after that we have made your identification.

Please indicate in your claim that you are requesting access to personal data or requesting information about data controlling.

Right to rectification

You are entitled to request the rectification of your inaccurate personal data.

Right to restriction of processing

You are entitled to request the restriction of processing where one of the following applies:

    • you dispute the accuracy of your personal data, for a period enabling us to verify the accuracy of the personal data,if no verification is required, no restrictions will be applied;
    • the processing is unlawful and you oppose the erasure of personal data and requests the restriction of their use instead;
    • we do not need the personal data for the purpose of the processing, but they are required by you for the establishment, exercise or defense of legal claims; or
    • You have objected to the processing, but because our legitimate interest can be a legal ground to our processing, in this case the restriction is pending until the end of the verification whether our legitimate grounds override those of yours.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

You will be informed before (at least 3 working days prior to the release of the restriction) the restriction of processing is lifted.

Right to erasure (“right to be forgotten”)

You are entitled to request to erasure of your personal data without undue delay if one of the following reasons consist:

    • personal data are no longer longer necessary in relation to the purpose for which they were collected or processed;
    • you withdraw your consent on which the processing is based and there is no other legal basis for data controlling;
    • you are object against the legitimate interest-based data controlling and there is no overriding legitimate grounds(as legitimate interest) for the data controlling,
    • we have processed the personal data unlawfully and this was established on the basis of the complaint,
    • the personal data have to be erased for compliance with a legal obligation in Union or Member States’ law to which we are subject.

If we have made the personal data public and is obliged pursuant any of the abovementioned to erase the personal data, we, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data. As the main rule, your personal information will not be disclosed.

Erasure shall not apply if data processing is required:

    • to exercise the right of freedom of expression and information;
    • to compliance with a legal obligation (such as billing processing, since the retention of the bill is required by law)which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
    • to establish, exercise or defense of legal claims (e.g. if we have a claim against you and you have not yet completed that, or a consumer, or a data processing complaint handling is in progress).
Right to object

You are entitled to object,on grounds relating to your particular situation, at any time to processing of your personal data based on legitimate interest. In this case, we are not be able to process your personal data unless compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims it is demonstrated by us.

Right to data portability

If your data processing is necessary for the performance of the contract or data processing is based on your voluntary consent, you have the right to request that the information you have provided to us be provided to you in a machine-readable format, in XML, JSON, or CSV.If this is technically feasible, you can request that the data be forwarded to another data controller in this format.

Remedies

If you believe that we have violated any statutory provision on data processing or have not completed your request, you have the right to initiate a procedure in order to eliminate a putative unlawful data processing before the National Data Protection and Information Authority (address: 1530 Budapest, Pf .: 5, e-mail: ugyfelszolgalat@naih.hu).

We also inform you that you have the right to initiate a civil lawsuit before the court.

  1. Data security

During the operation of IT systems, the necessary access management, internal organization and technical solutions ensure that your data cannot be accessed by unauthorized persons, unauthorized persons cannot delete, save from the system or modify the data.

Data protection and data security requirements are also enforced against our data processors.

We keep a record of possible privacy incidents, and if necessary, we will inform you about the incidents that are occurring.

  1. Other provisions

We reserve the right to modify this Privacy Policy in a way that does not affect the purpose and legal basis of the data controlling.

However, if we intend to perform further data process the personal data for a purpose other than that for which the personal data were collected, we will inform you prior to the further processing with the information on that other purpose and with any relevant further information about the followings:

    • the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    • your right to request from us rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject or to object to such processing in the case of data processing based on legitimate interests;and in the case of data processing is based on a consent or contractual relationship, you have the right to request ensuring the right to data portability;
    • In the case of consent-based data processing, you have the right to withdraw your consent at any time;
    • the right to initiate a complaint to the supervisory authority;
    • whether the provision of personal data is based on a legal or contractual obligation or it is a prerequisite for the conclusion of a contract and whether you are obliged to provide personal data,as well as the possible consequences of the lack of data provision;
    • the existence of automated decision-making process (if it is used), including profiling, and at least in those cases the meaningful information about logic involved as well as the significance and the envisaged consequences of such processing for you.

If the legal basis of the data processing is a contribution, you have to consent to the processing of data in addition to the information you provide, and data processing can only be initiated after this consent.

This Privacy Policy is valid from 2019. 10. 21.