LAST UPDATED: 20 SEPTEMBER, 2021

TrustElevate App Privacy Policy

Welcome to TrustElevate! 

At TrustElevate, responsible delivery of our service is our top priority. This includes respecting your privacy and protecting your personal data. This Privacy Policy sets out how we use and protect any personal information that you give us when you use TrustElevate’s website, app. For quick access, click through to jump to a specific section below. 

Introduction

The personal data, in any format in which we collect and/or hold it, is important to us and is handled in accordance with this Policy. We are committed to ensuring that your privacy is protected.  Where we ask you to provide information by which you can be identified when using our services, you can be assured that it will only be used in accordance with this Privacy Policy.  We will always explain clearly what data we are collecting about you and why.  We will only collect data we need to improve and deliver our services to you; to meet our responsibilities to you; and to give you a better experience.

For all queries and concerns relating to this Privacy Policy and our handling of personal data, please contact privacy@trustelevate.com.

Alternatively, you can write to us at:

The Privacy Officer

TrustElevate

20 Air Street, Soho

London, W1B 5DL, UK.

 

We are registered under the Companies Act, 2006, and our registration is: 08046357.

Our registered office address is:  8 Coldbath Square, London, United Kingdom, EC1R 5HL.

We are registered with the UK Office of the Information Commissioner ICO Number   ZA476685.

According to Article 27 of the European Union’s General Data Protection Regulation, our representative in the EEA is TrustElevate limited (company registration number C97824), with a registered office at 103, Palazzo Pietro Stiges, Strait Street, Valletta VLT 1436, Malta.

About us

TrustElevate is a provider of age verification and consent technology and the focus of our work is on making the internet safe through supporting businesses that handle children, young people and adults’ data to meet data protection requirements and age-appropriateness standards.

TrustElevate provides a one-stop-shop for compliance requirements with respect to age and identity verification for children, young people, and adults so that businesses, young people and parents can make informed choices. This Privacy Policy relates to our website, App and TrustElevate’s products including but not limited to VeriPass, KYC Youth, AgeCheck, and MyFamily. TrustElevate enables a parent to grant, deny and revoke consent for data processors, i.e. ad and marketing tech companies, to process their child’s data at any point in time within a contractual relationship with an app or platform.

What information we collect

We collect your data when you use: 

  • The TrustElevate AUA app.

  • The TrustElevate Zonk app.

  • The TrustElevate Zinc app.

  • The Veripass app.

 

We collect the following data: 

 
 
 

For businesses that rely on our service, such as banks, social media, gaming platforms and partners that also rely on our service but also offer our service to their enterprise customers, we collect:

  • business name; 

  • first name;

  • last name;

  • business email;

  • business telephone.

Professional information (for businesses and partners only)

We collect information you provide to us, such as: 

  • registration information when setting up an account on our website, for example, your name, child’s date of birth; email address, login data; 

  • form submission information including queries and competitions;

  • customer service queries information.

Information provided to us by you

Device, location and usage information

We collect and use the data generated  when you interact with our app. For analytical and improvement purposes, we collect technical information such as app version device data and IP address.

We collect information so that we can: 

  • deliver our services to you;

  • run and improve operation of our app to ensure a good user experience;

  • fix technical issues and bugs;

  • conduct research on our products and services.

 

Information provided to us by third parties

TrustElevate may need to use information from third parties such as mobile number data, data from fraud prevention and credit checks agencies. This is only used for data matching with your own data that you have provided to us and have stored on your mobile.

Under our Terms and Conditions, we may collect and process personal data in order to deliver services to businesses that partner with us:

  • for internal record keeping;

  • to allow us to monitor usage statistics as a basis for future improvements to relevant app  processes;

  • to enable us to track system use by user - with explicit and informed consent;

  • to restrict access; 

  • to build a database of anonymised data based on your use of the platform for further statistical analysis and product development;

  • to publish anonymous statistics under the condition that no personally identifiable information can be derived from such statistics;

  • to improve our products and services;

  • where you have given your consent for us to send you information and newsletters relating to our products and services using the contact details which you have provided.

 

We will not use this information to contact you with marketing promotions without your permission, and we never share your information with other organisations for marketing purposes. Please see the section How we share your data for more information. ​

How we use your information 

We will only use your personal information for the purpose it was collected. Most commonly, this will include the following circumstances:

  1. Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests. Usually, this will include:

    • for internal record keeping;

    • to monitor and evaluate the effectiveness of our products (KYCYouth, MyFamily, AgeCheck, Veripass, i-Approov), programmes, events, and activities, through data tracking, research, statistical analysis and surveys;

    • to contact you with updates and information about our services, events, programmes and activities that may be relevant to you where you have not objected to us doing so.

  2. Where you have given us your consent to provide you with information about TrustElevate services, updates, programmes, events, and activities that we think may be relevant to you. We will only send electronic marketing messages in the following circumstances:

    • when you have consented to this by completing the relevant field on our web forms;

    • you are a teacher/parent/carer/advisor with whom we have an existing contractual relationship.

If you do not want us to use your data in this way, you do not need to provide your consent, and you can use the unsubscribe link in our email communications at any time to opt out.

We may also use your personal information in the following situations:

  • Where we need to comply with a legal obligation.

  • Where we need to protect your interests (or someone else's interests).

  • Where it is required in the public interest or for official purposes.

How we store and protect your data

Your information is held securely in the UK.  If your information is transferred outside the UK for these purposes, then we take measures to ensure that your data remains protected at all times to the standard imposed by the Data Protection Act 2018, UK and EU General Data Protection Regulation. In certain circumstances, courts, law enforcement agencies, regulatory agencies and/or security authorities in those other countries may be entitled to access your personal data.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. TrustElevate websites are maintained on a secure server. All our suppliers and contractors meet the standards we require. Staff training is undertaken regularly, and checks are made by IT staff to ensure data quality is maintained.

TrustElevate operates a stringent Security Policy. The safeguards use encrypted transfer and storage and security protocols and procedures.

When using the TrustElevate app for Verifying Parental relationship, Verifying Parental ID, Verifying Child ID, TrustElevate does not store any Personal Data that has been provided by the Data Subject, this data is stored locally on your device.

Unfortunately, no data transmission or storage system is completely secure. If you feel that the security of your account or interaction with us has been compromised, please contact us immediately at privacy@trustelevate.com. If such a disclosure does occur, we will contact you as soon as possible to explain what has happened and take all steps required of us to meet our legal obligations.

How we share your data

 

We check the data you provide against multiple authoritative data sources to verify the data you provide, and we receive a yes/no response. We do not hold or share your data with other businesses. See relevant sections in the privacy policies on the websites of the companies that use our service.

Concerning your use of this website, data you provide and permission will be used for the  following purposes:

  • Delivering and improving our services - age and identity check, verifying parental responsibility and consent.

  • Monitoring and evaluation in line with this policy.

  • Due diligence checks. 

  • Law enforcement. TrustElevate might disclose the data for legal purposes such as legal proceedings, search warrant, court order. 

Analytics and marketing tools 

We use tracking tools to evaluate the effectiveness of our app performance and product.

Third parties service providers and business partners

We are using third parties to help us with improving our services and business performance. We rely on third parties for services including email communications, SMS messages tools and call tracking tools. 

All third-party processors we use are legally obliged to safeguard your information to the same standards in this Policy. 

Data will only be shared using secure data transfer methods and stored by us and our partners on secure systems. We and our partners will not use your personal data in any way that would affect you individually.

Any data released into the public domain will only appear in aggregate form and will be fully anonymised to prevent identification at an individual level.

How long do we keep your data?

TrustElevate has a range of obligations to keep the data that you provide. These include ensuring that transactions are processed correctly, identifying fraud, and complying with any laws and rules that apply to us and to our service providers. TrustElevate has a Data Retention Policy - per product - to ensure that your data is not held for longer than is necessary. We hold the information that you provide to us while you are an active, registered user and subscriber, and when you register for our services. Therefore, even if you close your account or membership with us, we may keep certain data to meet our obligations but for no longer than required or permitted by law.

This retention policy will be reviewed each year to ensure it remains fit for purpose and compliant with relevant legislation.

The retention policy will align as much as possible with any partner’s requirements and obligations.

TrustElevate will store trial data that you have provided for the length of the trial plus 30 days, after that TrustElevate will delete the data.

Your rights in controlling your personal data

We will not sell, share, distribute or rent your personal information to third parties unless we have your permission, or are required by law to do so. We may publish anonymous statistics under the condition that no personally identifiable information can be derived by third parties from such statistics. 

You can ask us to make changes in how your data is handled and we will respond promptly should a request be made.  You have the following rights over the personal data about you that we are holding and processing:

Right to be informed. This Policy provides you with information in relation to how your data is processed.  This ensures that we are transparent about what we will do with the information you supply to us.

Right of access. You may request details of personal information which we hold about you under the Data Protection Act 2018 and UK General Data Protection Regulation. This is called a Subject Access Request. Further information on this process and how to apply will be accessible from each of the businesses that rely on our service.

Right to request information held is accurate and how to update it. If you believe that any information we are holding on you is incorrect or incomplete, please email us at privacy@trustelevate.com and we will respond as quickly as possible.

Right to erasure. In certain circumstances, you may ask us to delete information about you and stop processing or publishing it (often called the Right to be Forgotten).

Right to object to the processing that is likely to cause you damage or distress. Where you challenge the accuracy or lawful processing of your information, we will consider this.

Right to receive an electronic copy of any information you have consented to us holding (also known as data portability).  You can ask us to provide the personal data about you that you have provided to us and that we hold, securely and in a machine-readable format, so it can be moved, copied or transferred to be used across different services or for you to give to another organisation.

Right to object. We will ensure that we have the right consents in place for sending you information. You can unsubscribe from our mailings and remove your details at any time. If you wish to stop receiving communications from us, you will be able to do so by contacting us at privacy@trustelevate.com

Rights related to automated decision making. If there is additional profiling based on the information we hold, then you can object to us making decisions about you based on such processing. 

Links to other websites

 

Our app may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you may provide while visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy statement applicable to the website in question.

 

Complaints

If you are dissatisfied with the way TrustElevate has processed your personal data, or if you have any questions or concerns about your data please contact privacy@trustelevate.com. If we are not able to resolve the issue to your satisfaction, you have the right to escalate to the Information Commissioner’s Office (ICO). They can be contacted at https://ico.org.uk/make-a-complaint/ or:

The Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

www.ico.gov.uk

Changes to this Policy

 

We keep the Privacy Policy under regular review. We will inform you if we have your details or please check this page from time to time to ensure that you are aware of any changes.

This privacy notice was last updated on September 20, 2021.