PRIVACY POLICY

Last updated: January 8, 2025

This Privacy Policy for Trueguard OÜ (“Trueguard”, "Company," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services, such as when you:

  • Visit our website at https://trueguard.io, or any website of ours that links to this privacy policy.

  • Engage with us in other related ways, including sales, marketing, or events.

This Privacy Policy is to be read in conjunction with our Terms of Service and Data Processing Agreement, all terms, conditions, and definitions outlined therein are incorporated herein by reference.

As outlined in our Terms of Service, by using our Services, you explicitly acknowledge and agree that you are acting on behalf of a legal entity which you represent. All actions taken on our platform, including the provision of information, are performed in your capacity as a representative of that entity, not as an individual consumer.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@trueguard.io.


Summary of Key Points

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Trueguard and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any sensitive personal information from third parties? We do not knowingly receive any sensitive personal information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

In what situations and with which types of parties do we share personal information? We do not share personal information with third parties for marketing or non-essential purposes. All sharing is strictly limited to fulfilling legal requirements or operational necessities. For detailed explanation see section 3.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? To exercise your rights, send your request via the email address associated with your registered account to ensure proper verification and prevent third-party interference. Requests should be emailed to info@trueguard.io and must clearly describe the nature of your request. We will review and act upon your request in accordance with applicable data protection laws.


Table of Contents

  1. What information do we collect?

  2. How do we process your information?

  3. When and with whom do we share your personal information?

  4. Do we use cookies and other tracking technologies?

  5. What is the legal basis for processing?

  6. Is your information transferred internationally?

  7. How long do we keep your information?

  8. How do we keep your information safe?

  9. Do we collect information from minors?

  10. What are your privacy rights?

  11. Controls for do-not-track features.

  12. Do California residents have specific privacy rights?

  13. Do we make updates to this notice?

  14. How can you contact us about this notice?


1. What information do we collect?

Personal information you disclose to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Names

  • Phone numbers

  • Email addresses

  • Mailing addresses

  • Passwords

  • Contact or authentication data

  • IP addresses

  • Device fingerprint

  • Network fingerprint

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor Stripe. You may find their Privacy Policy link(s) here: https://stripe.com/en-ee/privacy

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use network, GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, note that if you choose to opt out, you may not be able to use certain aspects of the Services.


2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

  • To deliver and facilitate delivery of Services to the user. We may process your information to provide you with the requested services.

  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

  • To update our proprietary dataset. We may process your information in a way that results in you having a whitelisted status in our proprietary dataset meaning that our customers will be aware that you are a legitimate user and not a bot.

  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.


3. When and with whom do we share your personal information?

We may share your personal information in the following situations:

  • With Service Providers. We may share your personal information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages, or features, and better understand online activity.

  • For Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • With Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

  • With Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

  • When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API). You may find Google’s Privacy Policy here. We obtain and store on your device ("cache") your location for six (6) months. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.

  • For Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

  • To Protect Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, and illegal activities, or as evidence in litigation in which we are involved.


4. Do we use cookies and other tracking technologies?

We use cookies and similar tracking technologies (such as pixels, web beacons, and scripts) to collect and store information about your interactions with our Services. These technologies help us improve functionality, analyze usage patterns, and enhance your overall experience.

Cookies enable us to:

  • Recognize you when you return to our Services.

  • Store your preferences and account settings.

  • Monitor site performance and troubleshoot issues.

  • Conduct analytics to better understand how users interact with our Services.

  • Deliver tailored content and advertising based on your interests and browsing behavior.

We allow select third parties and service providers to use cookies and other tracking technologies on our Services. These may include:

  • Analytics providers to track and analyze user activity on our Services.

  • Advertising partners to deliver relevant advertisements on our Services or other websites.

  • Service providers that assist with customer support, performance monitoring, or site improvements.

You can manage or disable cookies through your browser settings. However, please note that disabling certain cookies may impact the functionality of our Services and your user experience.

By continuing to use our Services, you consent to the use of cookies and similar technologies as described in this Privacy Policy.


5. What is the legal basis for processing?

We process your personal information in accordance with the General Data Protection Regulation (GDPR) under the following legal bases:

Consent: We rely on your consent for processing activities such as:

  • Sending you marketing communications.

  • Using cookies and similar technologies for non-essential purposes, where applicable.

Contractual Necessity: Processing is necessary to perform the contract between you and us, including:

  • Providing access to and use of our Services.

  • Managing account registration and authentication.

  • Fulfilling any orders or service agreements.

Legitimate Interests: Processing is necessary for our legitimate business interests, provided these are not overridden by your data protection rights. This includes:

  • Improving and optimizing the functionality and security of our Services.

  • Conducting analytics to better understand user behavior and enhance the user experience.

  • Preventing fraud and ensuring compliance with our Terms of Service.

Legal Obligations: Processing is necessary to comply with applicable laws and regulations, such as:

  • Responding to lawful requests from law enforcement or regulatory authorities.

  • Maintaining financial records in accordance with tax and accounting laws.

Vital Interests: In rare circumstances, we may process your personal data to protect your vital interests or those of another person, such as in an emergency.

If you have any questions about the legal basis for specific processing activities, please contact us at info@trueguard.io.


6. Is your information transferred internationally?

Our servers are located within European Union. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above).

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

Standard Contractual Clauses: We have implemented measures to protect your personal information, including by using Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all such recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.


7. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


8. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.


9. Do we collect information from minors?

We do not knowingly solicit data from or market to children under 18 years of age (or minors in general as the age might differ country-by-country). By using the Services, you represent that you are not a minor. If we learn that personal information from users less than 18 years of age (or minors in general as the age might differ country-by-country) has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from minors, please contact us at info@trueguard.io.


10. What are your privacy rights?

In some regions (like the European Economic Area, United Kingdom, and Canada), you have rights that allow you greater access to and control over your personal information. These may include the right to:

  • Request access to and obtain a copy of your personal information.

  • Request rectification or erasure.

  • Restrict the processing of your personal information.

  • If applicable, data portability.

  • Object to the processing of your personal information in certain circumstances.

In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the European Economic Area or United Kingdom and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.


11. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.


12. Do California residents have specific privacy rights?

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact info@trueguard.io.


13. Do we make updates to this notice?

Yes, we will update this Privacy Policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.


14. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at info@trueguard.io or by post to:

Trueguard OÜ
Valukoja 8/2
Tallinn, Harju 11415
Estonia


15. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request via email to info@trueguard.io.

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