Trustable Bridge Privacy And Policy
Trustable Bridge B.V ("we" "us" "our") are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Please note that by linking us with third party sites (such as LinkedIn, Twitter, or Google) you will authorise those sites to share personal data held by them with us.
○ 1. Who we are
We are Trustable Bridge B.V at copernicuslaan 5, The Hague, Netherlands. We are the Controller of your personal data for the purposes of the applicable data protection legislation.
○ 2. The Basis On Which We Process Your Data
We process personal data in accordance with this policy on one of the following bases:
● Where necessary for the performance of a contract with you or to take steps to enter into a contract, such as the administration of your account and/or to provide services to you.
● For other purposes not covered above:
○ Where we have sought your consent and you have provided consent, on the basis of that consent; or
○ Where we have not sought your consent, on the basis of our legitimate interests and we have assessed that these are not overridden by your interests. These legitimate interests are:
■ Associated activities with the administration of our business such as finance and accounting, compliance with legal obligations of the company;
○ 3. Why We Collect Information About You
We collect data about you for the following purposes (which are explained in more detail later in this policy):
● To establish a credit rating based on your information and provide that rating to financial service providers selected by you or where you have agreed that we may share your credit score with a particular financial service provider;
● To provide you with a report on and monitoring your financial standing;
● To better understand our customers and to provide our customers with better and personalised experiences with our company.
○ 4. Information We May Collect and Process About You
We may collect and process the following data about you:
● Information you give us.
○ you may give us information about you by filling in forms on our site https://trustablebridge.com or mobile application ("our site") or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product (for example, loan amounts, currency, loan duration), apply for a product such as a loan on our site, your activity levels on boards or other social media functions on the applicable social media sites, the applications you use on social media sites, and when you report a problem with our site.
○ you can allow us to access your information on social media sites (including but not limited to Twitter and LinkedIn) or through your email provider (such as Gmail) (“limited use data”);
○ the information you give us may include your name, address, e-mail address and phone number, login information for social networking sites, financial and credit card information, purchase transaction history, personal description, places and former places of employment and education, names of colleagues, contacts and friends, photographs, and lists of family members;
○ You may also decide to give us the following information via our mobile application where you have expressly agreed to provide the information via the mobile application: GPS co-ordinates, contact lists, SMS log, calendars, events, reminders, and pictures.
● Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
○ technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login Information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
○ information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
○ anonymised repayment data.
● Information we receive from other sources. We may receive information about the following information about you:
○ if you use any of the other websites we operate, the other services we provide and/or the social media sites which you login to via our site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, social media sites, advertising networks, analytics providers, search information providers, credit reference agencies, and financial services and credit providers) and may receive information about you from them;
○ where a third party lender is using our mobile software development kit it may send the following information to us in relation to your mobile data: GPS co-ordinates, contact lists, SMS log, calendars, events, reminders, and pictures.
○ 5. Cookies
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
● Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e- billing services.
● Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
● Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
● Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our website.
Except for essential cookies, all cookies will expire after a period appropriate to their use and no longer than six months after their use.
○ 6. Uses made of the information
We use information held about you in the following ways:
● Information you give to us. We will use this information:
○ to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
○ to establish a credit rating based on your information and provide that rating to third parties selected by you or where you have agreed that we may share your score with;
○ to establish a "Know Your Client rapport";
○ to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
○ to notify you about changes to our service;
○ to ensure that content from our site is presented in the most effective manner for you and for your computer;
○ to improve the accuracy of the assessment that our services make about you including (where you have agreed the that relevant data is sent to us): monitoring your activities and habits using GPS location, calculating the average score of your contacts where those contacts are using our platform, to improve the accuracy of your scoring via an assessment of your SMS logs, assessing your calendars, events and reminders and description of your pictures for scoring purposes.
● Information we collect about you. We will use this information:
○ to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
○ to improve our site to ensure that content is presented in the most effective manner for you and for your computer; o to allow you to participate in interactive features of our service, when you choose to do so;
○ as part of our efforts to keep our site safe and secure.
● Information we receive from other sources (including social media sites).
○ We collect this information to establish a credit rating based on your information and provide that rating to third parties selected by you or where you have agreed that we may share your score with;
○ We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
○ Where a third party lender is using our mobile software development kit we use the information generated to improve the accuracy of the assessment that our services make about you including (where you have provided or agreed the that relevant data is sent to us): monitoring your activities and habits using GPS location, calculating the average score of your contacts where those contacts are using our platform, to improve the accuracy of your scoring via an assessment of your SMS logs, assessing your calendars, events and reminders and description of your pictures for scoring purposes.
● Restrictions on how we use your data We do not:
○ store your contacts after the credit score calculation is made;
○ store your SMS log data after credit score calculations are made;
○ store your calendars, events and reminders data after credit score calculations are made;
○ access any photographs on your device other than those taken in our mobile application or via third party mobile interfaces and we remove pictures from servers and store only the description of the photos.
● Limited use data
We apply additional restrictions to our use of limited use data. Notwithstanding anything else in this policy, if you allow us to access your social media or email data:
○ we will only use our access to access your contracts or read your posts, email content (that is headers, message body and attachments), and metadata to extract information relevant to the calculation of your credit score;
○ we will not transfer limited use data to others;
○ we will not use limited use data for serving advertisements;
○ we will not allow humans to read limited use data, unless we have your explicit consent for specific messages, where doing so is necessary to comply with law, or where doing so is necessary for internal operations but only then if the data is anonymised and aggregated.
○ 7. Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries
We may share your information with the following third parties:
● Financial service providers selected by you or where you have agreed that we may share your credit score with a particular financial service provider. Your credit score information is comprised of the score generated on our site.
● Sub-contractors we use for the performance of any contract we enter into with them or you for the services and activities described in this policy (and we ensure that appropriate safeguards are in place when selecting such subcontractors who may process your personal data).
● Analytics and search engine providers that assist us in the improvement and optimisation of our site.
● We may disclose your personal information to third parties:
○ If Trustable Bridge B.V or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
○ 8. Where we store your personal data
The data that we collect from you is stored within the European Economic Area.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
○ 9. The Period We Store Your Personal Data
We store your personal data for the following periods:
Category of Data
Contact details and details contained on your registration form.
For the period you are using the site.
Specific information provided to complete your credit score (such as contacts or calendars)
Until your credit score calculation is made.
Specific information obtained from limited use data
Until your credit score calculation is made.
Information provided via our mobile application.
For the period you are using the site.
Information received from other third party sources
For the period you are using the site.
Technical information a bout your visits to our website
○ 10. Your rights
You have the following rights:
● The right to object to your data being used for marketing purposes;
● The right to request access to the personal data that we hold about you;
● The right to request rectification of the personal data that we hold about you;
● The right to request erasure of the personal data that we hold about you;
● The right to request restriction of processing about you;
● The right to object to processing; and
● The right to data portability.
If you wish to invoke any of the above rights, please notify us using the contact details set out in Section 14 below.
Where our processing of personal data is based on your having given consent, you have the right to withdraw that consent at any time. If you wish to invoke this right, please notify us using the contact details set out in Section 14 below.
○ 11. Your Preferences
You have the following choices available to you with respect to how we process your personal data:
● You can opt out of receiving any marketing communications by clicking the unsubscribe link in our emails to you, by changing the privacy settings in your profile via the email address below.
○ 12. Third Party Sites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link from or to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
○ 14. Contact