This Privacy Policy, together with the TruBit User Agreement (which can be found at TruBit User Agreement) explains how TruBit Ltd. (from now on "TruBit" or the "Controller"), a British Virgin Island company with its address at Craigmuir Chambers, Road Town, Tortola, VG 1110, British Virgin Islands, lawfully processes, collects, uses, shares, and protects your information obtained through the website trubit.com (from now on the "Site"). The terms "we," "us," and "our" refer to TruBit Ltd. and its Affiliates (together "TruBit"). TruBit is a truly committed company with the fundamental rights and freedoms of Persons, in particular, with the rights to protection of personal data.
When we ask for specific personal information from users, it is because we are required by law to process this information, or it is relevant for particular purposes. If you choose not to provide us with this information, we won't be able to offer our services. Any non-required information you provide to us is done so voluntarily. You decide whether to provide us with this non-required information or not.
I. CONSENT
You, as the holder of personal data, acknowledge and agree:
(a) that you are legally an adult according to your country's laws;
(b) to you freely give us your consent to process your personal data to provide you with the TruBit Services;
(c) that this Privacy Policy has been made known to you;
(d) to you have read, understood and agreed to the terms set out in this Privacy Policy;
II. WITHDRAW OF CONSENT
You have the right to withdraw the consent given to TruBit for processing your personal data at any time. To remove your permission, you must send an e-mail to contact@trubit.com, which must contain at least the following information and documentation:
(a) Your name and email address, or other means to communicate the answer to your request;
(b) The valid documents proving your identity (simple copy in printed or electronic format of your ID or passport) or, if applicable, a simple copy in printed or electronic form of the power of attorney of the person that will represent you, and their corresponding ID or passport;
(c) A clear and precise indication that you desire to withdraw your consent, and
(d) Any other element or document that facilitates the location of your personal data.
To comply with your request, it will be done after authenticating your identity; TruBit will confirm the acknowledgment of your withdrawal instruction and, if possible, will destroy any personal data collected from you. Please note that if you withdraw your consent, TruBit won't be able to provide any services.
If you are not an adult according to your country's law, you are not entitled to our services or give us your personal data. If you are not an adult, please do not try to use or attempt to register.
III. INFORMATION TruBit PROCESSES
We want you to understand the types of information we process when you register for and use TruBit's services (hereinafter the "Data").
3.1 Information you provide to us at registration
When you create a TruBit Account, you provide us with personal information that includes your identification data such as:
Full Name and Surname without abbreviation
Date of birth
Gender
Birth state and country
Nationality
Username and password
E-mail address
Full personal address and zip code
Financial and wealth data
Employment data (except trade union membership)
Mobile phone number
Google authenticator to be used for 2FA verification for improved security.
Geolocation of the mobile device, or the IP address of the computer, from which you opened your account;
A valid official ID
3.2 Information on special categories of personal data
Regarding the due functioning and to apply the proper security measures to your TruBit Account, we process your personal data relating to physical characteristics and biometrics, such as facial recognition or fingerprints. As this information is considered as a special category of personal data, we need your explicit consent to process this information.
Your express consent to process your biometric data will be interpreted if you choose to use the "biometrics security" option in our TruBit App. TruBit does not handle any other particular category of personal data without your express consent.
3.3 Information we collect as you use TruBit Services
3.3.1 Service Usage Information
Through your use of the Site and our different TruBit Services, we also monitor and obtain tracking information related to usages such as:
(a) access date & time,
(b) device identification,
(c) operating system,
(d) browser type, and
(e) IP address.
A processor collects this information under the supervision of the Controller. This service usage data helps us our systems to ensure that our interface is accessible for users across all platforms and can aid during criminal investigations.
3.3.2 Transaction Information
For all TruBit User accounts, we collect transaction information, including deposit snapshots, account balances, trade history, withdrawals, order activity, and distribution history. This transaction data is monitored for suspicious trading activity for user fraud protection and legal case resolution.
IV. WHY DOES TruBit COLLECT THIS INFORMATION
4.1 To provide and maintain our services
We use the information collected to deliver the best quality of our services and verify user identity.
We use the IP address and unique identifiers stored in your device's cookies to help us authenticate your identity and provide our service. Given our legal obligations and system requirements, we cannot provide you with services without data like identification, contact information, and transaction-related information.
4.2 To protect our users
We use the information collected to protect our platform, TruBit Users' accounts, and archives.
We use IP addresses and cookie data to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.
We analyze trading activity to detect suspicious behavior early to prevent potential fraud and loss of funds to bad actors.
4.3 To comply with legal and regulatory requirements
Respect for the privacy and security of data you store with TruBit informs our approach to complying with regulations, governmental requests, and user-generated inquiries. We will not disclose or provide any personal information to third-party sources without review from our legal case team and/or prior consent from the user.
As well, to comply with global industry regulatory standards including Anti-Money Laundering (AML), Know-Your-Customer (KYC), and Counter-Terrorist Financing (CTF), TruBit requires user accounts to undergo user identity authentication for both Personal & Enterprise-level accounts. These services are conducted by a processor who delivers all the results to TruBit.
The procedure mentioned above is not automatic but is carried out only when the user decides to open a TruBit account. The user is the one who provides the data and can choose, among several options, with which documents to verify his identity.
4.4 To measure Site performance
We actively measure and analyze data to understand how our services are used. This review activity is conducted by our operations team to continually improve our platform's performance and to resolve issues with the user experience.
We continuously monitor our systems' activity information and communications with users to look for and quickly fix problems.
4.5 To communicate with you
We use personal information collected, like an e-mail address, to interact with users directly when providing customer support on a ticket or to keep you informed on logins, transactions, and security. Without processing your personal information for confirming each communication, we will not be able to respond to your submitted requests, questions, and inquiries. All direct communications are kept confidential and reviewed internally for accuracy.
4.6 To deliver our newsletter, which includes publicity and sales, when chosen
Subscribing to our news and publicity services is voluntary. We do not require to convey with publicity deliveries to keep and maintain our legal relationship we may have with you in a particular moment; therefore, you will always have the first option to not subscribe to our publicity systems; also, you will have the possibility at all times to opt-out from our advertising, sales and publicity messages. To do this, you only have to choose the "opt-out" option that will be attached in each message you receive.
4.7 To enforce our TruBit User Agreement and other agreements and policies
It is crucial for TruBit Users and us that we continually review, investigate, and prevent any potentially prohibited or illegal activities that violate our Terms of Service, Over The Counter Market Policies, Derivatives Trading Policies, and in general, our TruBit Rules. For the benefit of our entire user base, we carefully enforce our agreements with third parties and actively investigate violations of our posted terms and conditions for any of TruBit Services. TruBit reserves the right to terminate the provision of service to any user found engaging in activities that violate any of our TruBit Rules.
V. COOKIES POLICY
Cookies are text files that are automatically downloaded and stored on the hard drive of the user's computer when browsing a specific website. They allow the Internet server to remember some data about the user, including the user's preferences for viewing the pages on that server, username, and password.
TruBit informs you that it uses cookies on the Site to obtain personal information. In case you do not agree with the use of this technology, please disable the cookies from your browser or do not use our Site.
VI. WITH WHOM DOES TruBit SHARE YOUR PERSONAL DATA?
TruBit may transfer its customers' personal data to other companies or authorities for the purposes set out in this Privacy Policy. These data transfers include the following:
(a) Since TruBit is part of an international group, your personal data may be communicated to other companies within the same corporate group and the same data privacy policy, including our affiliates. Our affiliates have implemented measures and policies for its customers' data protection; these policies result consistent with ours and try to comply with the provisions set out by the law in each country and will abide by this Privacy Notice.
(b) TruBit may send all or a part of your personal data to processors as service providers that support us with some data processing activities. These processors include (i) technology companies that provide us with several communication or infrastructure services; and (ii) companies that provide us with publicity or loyalty program management services. In all these cases, TruBit ensures that these service providers assume contractual obligations that allow our customers' personal data is protected.
(c) Likewise, TruBit may transfer its customers' personal data to administrative or judicial authorities, when the transfer is necessary or legally required when safeguarding the public interest, TruBit's protection of rights, third parties' protection of rights, or for the enforcement and administration of justice. Additionally, TruBit may use or disclose your personal data when we consider, in good faith, that the applicable law allows us to use or disclose your data. It includes, for example, when such transfer is necessary to protect you, to answer to claims, or protect TruBit's property rights or security, its affiliates, or third parties' rights.
(d) Also, the customers' information may be communicated or transferred to a third party, in the course of a corporate transaction, including a merger or an asset sale or an acquisition, always in the best interests of the users.
(e) In other cases, when permitted by the applicable law or when it is express consent by you to perform the transfer.
(f) TruBit may share your personal data with third parties, including payment providers such as Mercuryo, and with other companies that operate within the financial and financial technology ecosystem, including banks, payment providers, digital wallets and exchanges, among others. In these cases, TruBit will share with those third parties only the information necessary for them to carry out the transaction that you initiated with us, and you will be requested to provide your consent in connection with the transfer. Please note that these third parties operate under their own privacy policies.
Please note that all transfers set out above may be of a local or cross border nature.
VII. WHAT OPTIONS DO I HAVE TO LIMIT THE WAY IN WHICH TruBit USES MY PERSONAL DATA?
Mexico offers you choices regarding how we use your personal data; we offer you several means to inform us about your decision.
If you wish not to receive advertisement messages from us or to cancel your subscription to our information services, you: (a) have the option to decline to receive this information before registering for our services; (b) you may unsubscribe to our email lists by using the mechanism set out in our emails.
VIII. HOW DOES TruBit PROTECT USER DATA
TruBit has implemented several security measures to ensure that your information is not lost, abused, or altered. Our data security measures include, but are not limited to: PCI Scanning, Secured Sockets Layered encryption technology, pseudonymization, internal data access restrictions, and strict physical access controls to buildings & files. TruBit keeps all Data secret, and we have taken precautions with his personnel to process all user data as confidential.
Please note that it is impossible to guarantee 100% secure transmission of data over the Internet nor method of electronic storage. As such, we request that you understand the responsibility to take safety precautions to protect your personal information independently.
If you suspect that your personal information has been compromised, especially account and/or password information, please lock your account and contact TruBit customer service immediately.
IX. PROCEDURE FOR EXERCISING PRIVACY RIGHTS
You have, at all times, the right to know what personal data we have about you, what we use it for, and the conditions of the use we give it (Access). Likewise, it is your right to request the correction of your personal information if it is outdated, inaccurate, or incomplete (Correction); that we remove it from our records or databases when you consider that it is not being used per the principles, duties, and obligations provided for in the regulations (Cancellation or right to be forgotten); you also have the right to receive your personal data provided to TruBit in a structured, commonly used and machine-readable format and, where technically feasible, you have the right to instruct us to transmit those data to another controller without hindrance; as well as to oppose and object the use of your personal data for specific purposes (Opposition). These rights are known as Privacy Rights.
To exercise any of the Privacy Rights, you must send an e-mail to contact@trubit.com, which must contain the following information and documentation:
(a) Your name and address, or other means to communicate the answer to your request;
(b) The valid documents proving your identity (simple copy in printed or electronic format of your ID or passport) or, if applicable, a simple copy in printed or electronic form of the power of attorney of the person that will represent you, and their corresponding ID or passport;
(c) A clear and precise description of the data on which you are seeking to exercise any of the Privacy Rights, and
(d) Any other element or document that facilitates the location of your personal data.
In the case of requests for the rectification of personal data, you must also indicate the modifications to be made and provide the documentation supporting your application.
To comply with the obligation of access to personal data, it will be done after authenticating your identity, making the information available on site at TruBit's offices (other ways can be agreed between you and TruBit whenever the requested information allows it).
The contact details of the person or department that will process the requests for the exercise of the Privacy Rights, as well as to respond to any doubt that you could have concerning the treatment of your information.
X CHANGES ON PRIVACY NOTICE
On occasion, TruBit may revise this Privacy Policy to reflect changes in law or our personal data collection and use practices. The modified Privacy Notice will be published in visible places on our Site and will be delivered to you through e-mail. You will be able to verify the Privacy Policy has been changed because the effective date will always be present. In case TruBit makes any substantial change with the treatment of your personal data, we will let you know through an e-mail and will announce such changes on our Site.
Every change made to our Privacy Policy will be effective the following day from its publication date. If you disagree with the modifications, please reach out to us on the following e-mail contact@trubit.com. The constant use you make of our Site after a Privacy Policy modification means you consent to the new Privacy Policy to the extent permitted by law.
TruBit encourages you to review our Privacy Policy periodically. We will ask for your consent before using your information for any purpose that is not covered in this Privacy Policy.
XI. CONTACT US
We are committed to respecting the freedoms and rights of all our TruBit users who have placed their trust in our service. If you should have any questions or concerns regarding this Privacy Policy, or if you would like to file a Data Protection request, please refer to our FAQ and contact us on our Support Page.