Privacy Policy

Last updated on April 30th, 2021

Swin Technologies AB, a Swedish corporation bearing corporate registration number 5559122-3796 (“TrusTrace”, “we”, “us”, “our”) values your privacy and is committed to ensuring that your privacy is protected. The purpose of this privacy policy (“Privacy Policy”) is to describe what information we collect about you (“User” or “your” or “you”) while you use and access the trustrace.com website and mobile application (collectively, the “Site”); why we collect this information; how we use your information; how we protect and share your information; the choices we offer you, including your ability to access and update your information and make certain choices about how your information is used.

A) By interacting with us, submitting information to us or accessing the Site, you agree and consent to TrusTrace, and its affiliates, as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your personal data, and disclosing such personal data to TrusTrace’s authorised service providers, suppliers, brand and third parties in the manner set forth in this Privacy Policy.

B) This Privacy Policy supplements but does not supersede nor replace any other consent you may have previously provided to TrusTrace nor does it affect any rights which TrusTrace may have at law in connection with collection, use or disclosure of your personal data. TrusTrace may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on the Site. Please check regularly for updated information on the handling of your personal data.

C) For avoidance of doubt, this Privacy Policy forms part of the terms and conditions of the site available at trustrace.com (“Terms”). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Terms, the Privacy Policy shall prevail. All defined terms contained in the Terms shall apply to this Privacy Policy unless otherwise specifically stated.

D) The Privacy Policy covers both ‘online’ (e.g., the Site, however accessed and/or used, whether via personal computers, mobile devices or otherwise) and ‘offline’ (e.g., collection of data through mailings, telephone, or in person) activities owned, operated, provided, or made available by TrusTrace.

Please read and understand this Privacy Policy carefully, and its applicability to your usage of the Site. BY ACCEPTING THE TERMS OF THE SITE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. Please review the following carefully so that you understand our privacy practices. If you do not agree to this Privacy Policy, do not accept the Terms or use the Site. This Privacy Policy is incorporated by reference into the Terms.

In the event you have any queries or need any clarifications about this Privacy Policy, please feel free to contact us through email address provided on the Site.

1. Applicability

We may ask for and collect certain information (specified in Clause 2 below) from you when you use the Site. This information is necessary for the adequate performance of our obligations towards you and to allow us to comply with our legal obligations. Without this information, we may not be able to provide you access to and allow the use of the Site.

2. Information we collect

There are three categories of information that we collect: 

a) Personally Identifiable Information

This is the information that tells us who you are and lets us identify, contact or locate you (“Personally Identifiable Information”). We will ask for your Personally Identifiable Information when you register with us, fill in the form to contact us, book a demo with us, participate in our surveys, correspond with us or otherwise volunteer information. Personally Identifiable Information includes your name, telephone number, email address.

We collect Personally Identifiable Information about you when you fill your contact information for us on the Site or deliver such information to us through any offline means. We also collect other content that you submit through any social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events undertaken by us.

b) Non-Personally Identifiable Information

This is the information that does not identify you as a specific individual on its own or in combination with other information (“Non-Personally Identifiable Information”). We may gather certain demographic information about you such as age, date of birth, gender, as well as consumer preference information based upon how you navigate the Site.

This information may be compiled and analysed on both a personal and an aggregated basis. This information includes a website’s Uniform Resource Locator (“URL”) that you just came from; landing pages and referring pages and URLs; which URL you next go to; what browser you are using; date and time of your usage of the Site; search terms; domain names; device information such as hardware configuration and operating system; number of clicks; time you spend viewing each page of the Site; name of and information about any advertisement or other third party website that brought you to us; and your anonymised Internet Protocol (“IP”) address, which in turn would enable us to infer your city, region/state, country, continent, longitude/latitude co-ordinates of location and internet service provider.

If you email us, we may store copies of such email or similar communications between you and us. This can result in the collection of your email address or other personally identifiable information you may have in your email text, addresses, or other fields, as well as the collection of your IP address, or other routing of your communication, and the date and time of your communication. All transmissions between you and us, including emails, URLs, cookie identification numbers, usage paths, and any personally identifiable information they might contain, pass through many third party machines, operating systems, programs, browsers, web servers, networks, routers, ethernet switches, internet service providers, proxy servers, intranets, the public telephone systems, or other devices, any of which may create activity logs containing such transmissions, and many of which we cannot control. When you send email, feedback, comments or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests, improve our services, and may post or use such communications without any obligation to you. 

c) Third-party information

On a need-to-know basis, we may, from time to time, collect such relevant information about you as may be necessary from third parties, subject to the privacy and confidentiality terms of such third party. The Site includes links to other third-party websites whose privacy practices may differ from those of TrusTrace. TrusTrace has no control over the policies, actions or omissions of third-party websites and is not responsible or liable for any such policies, acts or omissions.  If you submit personal information to any of those websites, your information is governed by the applicable third-party privacy policies and not by this Privacy Policy. This Privacy Policy does not apply to, nor do we take any responsibility for any information that is collected by any third party through any third-party links made available to you during your use of the Site or through any of the advertisements or through BOTS. We urge you to carefully review the privacy policy of any website you link to, visit or share information with prior to doing so. Further, we cannot control the use of cookies (or the resulting information) by third parties, and use of third-party cookies is not covered by our Privacy Policy.

d) Cookies

We collect information from you by way of cookies. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. For more information, please see our Cookie Policy available at https://trustrace.com/cookie-policy. The terms of the Cookie Policy are herein incorporated into this Privacy Policy by reference.

3. How we use the information we collect

We will use the information collected from you only as permitted by law, and subject to the terms of our Privacy Policy, for the following purposes: 

  1. Ensuring the services we provide and/or the content on the Site is presented in an effective manner for your use.

  2. To provide you with information pertaining to the Site and our services and business.

  3. To notify you about any changes and improvements to the Site; or for analytical purposes, including but not limited to assessing usage data, usage patterns, and other similar activities.

  4. To process transactions and billing, for identification and authentication purposes, to communicate with you concerning transactions, security, privacy, and administrative issues relating to your use of the Site, to do something you have asked us to do, or to tell you of services that we think may be of interest to you.

  5. To contact and record communication with you to help solve any issues you might be facing.

  6. We use information collected from cookies and other tracking technologies to improve your user experience.

  7. To conduct analysis to ensure that the Site is functioning in an efficient manner.

  8. In any other way that we may specifically describe to you at the time you provide the information.

  9. We use IP addresses to diagnose problems with our servers and to administer the Site. IP addresses are further used to help determine the number of our users to maintain efficient administration of our services. This demographic information we determine basis your IP address may also be used by us to analyze aggregate usage behavior.

  10. We may use Non-Personally Identifiable Information to analyse request usage patterns, and other user behaviour to enable us to enhance the Site, and services, and for our marketing purposes. We reserve the right to use and disclose Non-Personally Identifiable Information to any third party at our sole discretion.

  11. In the course of operating our business, it may be necessary or appropriate for us to provide access to your Personally Identifiable Information to others such as our service providers, contractors, select vendors and affiliates so that we can operate the Site and our business. Except as otherwise provided herein, we will not disclose, publish, sell, rent, market or share with any third party your Personally Identifiable Information without your express consent. Where practical, we will seek to obtain confidentiality agreements consistent with this Privacy Policy from such third parties.

  12. If we become involved in a merger, acquisition, or any form of sale of some or all of our assets, we will provide notice if such a transaction results in your information being subject to a different privacy policy.

  13. We may share your Personally Identifiable Information if we are required to do so by law or we in good faith believe that such action is necessary to: (i) comply with the law or with legal process (such as pursuant to court order, or instructions by governmental authority, or a request by law enforcement officials); (ii) to protect, enforce, and defend our Terms, rights and property; (iii) protect against the misuse or unauthorized use of the Site; or (iv) protect the personal safety or property of our Users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

4. Information we share and disclose

We share information about you for the operating and maintaining of our business and for providing our services to you, in the following manner:

  1. To conduct analytics
    We are always looking for ways to make the Site and services smarter, faster, secure, integrated, and useful to you.  We use collective learnings about how people use the Site and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Site.  We may test and analyze certain new features with some users before rolling the feature out to all users.  We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other pseudonymized information for compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

  2. For customer support
    We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Site.

  3. For legal reasons
    We will also share information including personal information with individuals or entities to the extent it believes in good faith it is required to:

    1. Ensure compliance with law/ regulations and/or pursuant to enforceable orders of government, law enforcement or regulatory authorities;

    2. Address fraud, security or technical issues;

    3. Protect against harm to the rights, property or safety of the Site, its other users or the public as required or permitted by law.

    4. For effective provision of services and for the conduct of our business

We may share your personal information to our employees, contractors, brands, partners and agents or to our affiliates (and their employees, contractors and agents) who need to know the information in order for us to provide you with our services and for you to be able to access the Site; and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

5. How we store and protect your information

  1. The data that we collect from you and process as a result of your use of the Site and of our services may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our affiliates or suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this third-party transfer, storing or processing of personal data. In particular, your data may be stored by TrusTrace’s hosting service provider on servers in the Republic of India as well as in the European Union. The Republic of India does not have the same data protection laws as the EEA. An agreement has been signed between TrusTrace and each of its data processors. These agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data. We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information in this regard, please do contact us in accordance with the contact details provided at Clause 7 below.

  2. The security and confidentiality of your data is extremely important to us. We have implemented technical, administrative and physical security measures to protect your information from unauthorized access and improper use. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect and impenetrable, and no data transmissions over the web can be guaranteed 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. If you send us an email, you should know that email is not necessarily secured against interception. Therefore, if your communication will include sensitive information like your bank account, charge card, or social security number, and you prefer not to transmit it electronically, please contact us by postal mail or telephone rather than email.

  3. If we collect information from your computer, we encrypt it while it’s being transferred to us. Once the information reaches our secure servers, as part of our security program, we employ standard procedures and safeguards, such as maintaining firewalls and having an intrusion detection system, to protect the confidentiality, security and integrity of the information we maintain.

  4. When we work with third parties, we require that they maintain the confidentiality, security and integrity of the information and commit that the information is not used for any prohibited purpose.

  5. We use industry standard physical, technical and administrative security measures; and commercially reasonable computer security safeguards in order to safeguard all personal information, confidential and secure. Additionally, we protect our databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data, which includes by internally reviewing our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

  6. Given the nature of internet transactions, TrusTrace does not take any responsibility for the transmission of information including user information shared by you. Any transmission of user information on the internet is done at your risk and TrusTrace shall not be responsible for the circumvention of the privacy settings or security measures either by you or any third party.

  7. Please do not include or provide any personal information unless specifically requested as part of the registration or other applicable processes. If any information you have provided or uploaded violates the terms of this Privacy Policy, TrusTrace may be required to delete such information upon informing you of the same and revoke your access if required without incurring any liability to you.

6. Your rights

  1. Data Access
    You shall have the right access and receive your personal data which you have provided to us under the terms of this Privacy Policy, in a structured, commonly used and machine -readable format.

  2. Data Retention and Data Deletion
    TrusTrace shall retain information that it collects for as long as is necessary for your continued access to the Site, TrusTrace’s performance of its services and for us to comply with our legal obligations. If you no longer want to use the Site and want your data and information to be deleted, you may contact us at sales@trustrace.com to request that your data and information be deleted. Upon such request TrusTrace shall delete all your information within one month from the date of receipt of the request, provided that this period may be extended by two further months where necessary, by giving you due notice, taking into account the complexity of the request. 

  3. Rectification of Inaccurate or Incomplete Information
    You can change, alter, modify your contact information at any time by e-mailing us at sales@trustrace.com. However, please note that in the event you alter, or update or delete your information, we cannot ensure the continuity or quality of the services being provided to you or your use of the Site. TrusTrace may permit or deny modification of any information, to the extent such information is required by it order to be compliant with and observe applicable laws. You have the right to ask us to correct inaccurate or incomplete Personally Identifiable Information concerning you. Please note that if your data has been provided to us by a third party, you should contact such party directly to make queries, obtain feedback, and communicate access and correction requests to TrusTrace on your behalf.

  4. Data Portability
    Data portability is the ability to obtain some of your information in a format you can move from one service provider to another. Depending on the context, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

  5. Withdrawing Consent and Restriction of Collecting Data.
    Where you have provided your consent to the collecting of your information by TrusTrace, you may withdraw your consent at any time by sending a communication to TrusTrace at sales@trustrace.com specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. However, please note that in the event you withdraw your consent, we cannot ensure the continuity or quality of the Site or of the services being provided to you; and this may also result in: (i) the termination of any agreements you may have with TrusTrace; and (ii) your being in breach of your contractual obligations or undertakings, and TrusTrace’s legal rights and remedies in such event are expressly reserved.

7. Grievances and Complaints

TrusTrace hereby appoints Prasad Asokan as the Data Protection Officer for the purposes of the GDPR (General Data Protection Regulation) of the European Union, who may be contacted at prasad.asokan@trustrace.com. The Data Protection Officer shall monitor compliance with the law and with the internal policies of TrusTrace including assigning responsibilities, awareness raising and training staff, amongst other tasks. You may address any grievances you may have in respect of this Privacy Policy or usage of your information or personal data or other data or any other questions or complaints you may have, to the Data Protection Officer. 

8. Restrictions

The Site is only intended for Users who are of 18 (Eighteen) years of age or older. If you are not of the requisite age you are not to provide any User information to us. TrusTrace shall have the right to revoke the provision of services and delete all information of Users below the age of 18 without notice.

9. Amendments

This Privacy Policy is subject to change from time to time. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on trustrace.com and update the ‘Last Updated’ date at the top of this Privacy Policy. If you disagree with the revised Privacy Policy, you may refrain from using the Site. 

10. Governing Law and Jurisdiction

This Privacy Policy shall be governed in all respects by the laws of Sweden without application of Swedish conflict of law rules. If you use the Site outside Sweden, you are responsible for complying with the legislation wherever you are located. The courts of Sweden shall have exclusive jurisdiction over any matters arising out or in relation to these Terms. It is clarified that to the extent this Privacy Policy conflicts with any applicable provisions of law, such provisions of law shall supersede the Privacy Policy.