TRUSTTOKEN PRIVACY POLICY

Last modified: May 14, 2018

Introduction

TrustToken, Inc. ("Company," "our," "we") understands the importance of privacy, especially when it comes to your personal information. Data privacy and your trust are our top priorities, and in this Privacy Policy we explain what information we collect from you when you apply to invest in our token sale (the "Application") and use our online asset tokenization platform (the "Platform"), how we will use this information, and the very limited ways that we may share your information. Please read this policy carefully to understand our policies and practices regarding your information, as you agree to this Privacy Policy by using the Platform. If you do not agree with our policies and practices, do not apply to invest in our token sale or use the Platform. This Privacy Policy is part of our Terms of Use available.

Users Under Age 18

The Platform and Application are only intended for adults eighteen (18) years of age and older. You are not allowed to apply to invest in our token sale, use the Platform, or provide information for either if you are under eighteen (18) years of age. If we learn we have received personal information from or about a child under 13 without verification of parental consent, we will delete that information immediately. If you believe we might have any information from or about a child under thirteen (13) without parental consent, please contact us immediately at legal@trusttoken.com.

Information We Collect About You

We collect several types of information from and about users of the Platform and Application depending on how they are using the Platform or submitting information into the Application, including:

  • Information about you, such as your name, address, phone number, and email address;
  • Information about your financial information, such as bank accounts and cryptocurrency wallet addresses;
  • Information about you that is needed to complete a Know Your Customer (KYC) & Anti-money Laundering (AML) check; and
  • Any other information you voluntarily provide on the Platform or Application in the ordinary course of the continuation of the relationship; and
  • Information about your internet connection, the equipment you use to access the Platform, Application, as well as Platform and Application usage details.

How We Collect Information From You

We collect information from you in two ways:

  • First, we collect information directly from you when you provide it to us, such as signing up for an account, or entering information into the Platform or Application when prompted or permitted through a series of questions provided to you on the Platform and Application.
  • Second, we collect generic information about your usage and equipment automatically as you navigate through the Platform and Application, such as usage details, IP addresses, web browser preferences, and information collected through cookies and other tracking technologies. Although we do not correlate tracking information to individuals, some information collected, such as IP addresses, will be unique.

Do Not Track Settings

We do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

How We Use Your Information

From time to time, it is necessary for customers to supply us with data in connection with the opening or continuation of accounts, and the establishment or continuation of facilities or provision of services, or in compliance with any laws or guidelines issued by regulatory or other authorities. We use information that we collect about you or that you provide to us, including personal information:

  • To continue the daily operation of the services and facilities provided to customers.
  • To meet the requirements to make disclosures under the requirements of any law binding on the Platform and Application under and for the purposes of any guidelines issued by regulatory or other authorities with which the Platform and Application are expected to comply.
  • To provide you with information, products, or services that you request from us.
  • To verify the information that you provide to use and validate you through the KYC/AML process required by us and our fiduciary partners.
  • To provide you with notices about your account and payments.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to the Platform and Application or any products or services we offer or provide though them.
  • In any other way we may describe when you provide the information.

Disclosure of Your Information

We only collect personal information that we believe to be relevant and required to conduct our business. We may share your personal information with our business partners and service providers, but only to the extent that they each need to know specific information to continue to provide the Platform, Application, or services to you. This includes:

  • Our contractors, employees, service providers, and other third parties that we use to support our business and improve the Platform and Application;
  • To our subsidiaries and affiliates;
  • To our fiduciary and other financial partners to provide the Platform services to you;
  • To a buyer or other successor in the event of a merger or reorganization if the personal information of our users is part of the assets transferred;
  • To fulfill the purpose for which you provide it;
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To third party contractors in order to analyze Platform and Application performance and user behavior and/or to improve the Platform, Application, or both;
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Platform and Application, our users, or others; or
  • For any other purpose disclosed by us when you provide the information. We may disclose aggregated information about our users, which means information that does not identify any individual, without restriction. As an example, we may include in our marketing materials that a certain percentage of our users are female, but we won't share a list of all female users in these materials.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Platform and visiting your account page or by contacting us to update your Application information. You may also send us an email at legal@trusttoken.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access. For example, access by a user to his or her personal information is available through a unique customer ID and password selected by the user that should be regularly updated. This information is encrypted through the Platform with Secure Socket Layer technology (SSL) and is also encrypted when it is stored by us to prevent unauthorized parties from viewing such information. Also, we perform regular malware scanning of the Platform, Application, and all servers and computers used by us to support the Platform and Application. All Company employees are required to adhere to our security and confidentiality procedures and undergo training related to maintaining the security of user personal information. The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and be careful about giving out information to other users on the Platform if requested. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform or Application. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform or Application.

Third Party Links

The Platform and Application may contain links that lead to other websites, and the Company is not responsible for the privacy practices, content, and/or activities of these linked websites. Nonetheless, we seek to protect the integrity of the Platform and Application and welcome any feedback about these external websites.

Changes to Our Privacy Policy

We will post any changes we make to our privacy policy on this page and you will be notified of any material changes on the Platform home page or Application and in an email to the most recent email address that you provided to us, if any.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at legal@trusttoken.com.