Trustopia adheres to the applicable data protection laws in the geographies within which its enterprise customers consume its services. In the European Economic Area, Trustopia must where applicable ensure individuals can exercise their rights as data subjects in the following ways:
Right to be informed: by being provided with privacy notices which are concise, transparent, intelligible and easily accessible, free of charge, that are written in clear and plain language, particularly if aimed at children and by keeping a record of how we use personal data to demonstrate compliance with the need for accountability and transparency.
Right of access: which we satisfy by enabling individuals have to access their personal data and supplementary information and by allowing individuals to be aware of and verify the lawfulness of our processing activities.
Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons:
- our legitimate interests;
- to enable us to perform a task in the public interest or exercise official authority;
- to send you direct marketing materials; and
- for scientific, historical, research, or statistical purposes.
If your objection relates to Trustopia processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
- we can show that we have compelling legitimate grounds for processing which overrides your interests; or
- we are processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Right to request data subject access (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so. Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws.
Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information held must meet one of the following criteria:
- the data is no longer necessary for the purpose for which we originally collected and/or processed them;
- where previously given, you have withdrawn your consent to us processing your data and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws. We would only be entitled to refuse to comply with your request to erasure for one of the following reasons:
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
- for public health reasons in the public interest;
- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:
- one of the circumstances listed below is resolved;
- you consent; or
- further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data. We are permitted to store personal data if it has been restricted, but not process it further. We must retain enough data to ensure the right to restriction is respected in the future.
Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. This must be done without delay, and no later than one month. This can be extended to two months with permission from the DPO. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Trustopia account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to:
- personal data that we process automatically (i.e. without any human intervention);
- personal data provided by you; and
- personal data that we process based on your consent or in order to fulfil a contract.
Rights in relation to automated decision making and profiling: which require us to respect the rights of individuals in relation to automated decision making and profiling including ensuring that individuals retain their right to object to such automated processing, have the rationale explained to them, and request human intervention.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.
To get in touch about these rights or if you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us by using the contact form on this site, emailing firstname.lastname@example.org or calling us on +44 (0)207 0521590. We will deal with your request without undue delay and in any event within one month (subject to any extensions to which we are lawfully entitled).
Please note that we may keep a record of your communications to help us resolve any issues which you raise.