https://shop.trustpayments.com (our website) is provided by Trust Payments (UK) Ltd (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
• What this policy applies to
• Personal data we collect about you
• How your personal data is collected
• How and why we use your personal data
• Who we share your personal data with
• How long your personal data will be kept
• Transferring your personal data out of the UK
• Your rights
• Keeping your personal data secure
• How to complain
• How to contact us
Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you, or relating to employees, officers, authorised signatories and other associated individuals:
• your name, address, and contact information, job title, including email address and telephone number and company details
• information to check and verify your identity, e.g. date of birth
• location data, if you choose to give this to us
• your billing information, transaction and payment card or other payment method information
• bank account and payment details
• details of any information, feedback or other matters you give us by phone, email, post or via social media
• your account details, such as username and login details
• your activities on, and use of, our website
• information about the services we provide to you
• your contact history, purchase history and saved items
• information about how you use our website and technology systems
• your responses to surveys, competitions, and promotions
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
We collect personal data from you:
• directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website, and
• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies’
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
|What we use your personal data for||Our reasons|
|Create and manage your account with us||To perform our contract with you or to take steps at your request before entering into a contract|
|Providing products and/or services to you||To perform our contract with you or to take steps at your request before entering into a contract|
|Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us||To comply with our legal and regulatory obligations|
|To enforce legal rights or defend or undertake legal proceedings||Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests, and rights or those of others|
|Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website||Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website—see ‘Cookies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price|
|Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended||Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website—see ‘Cookies’ below—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price|
|Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and/or services or other important notices||Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price|
|Protecting the security of systems and data||To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us|
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price|
|Updating and enhancing customer records||Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products|
|Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant.||To comply with our legal and regulatory obligations|
|Marketing our services to existing and former customers||For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information|
|External audits and quality checks, e.g. for the audit of our accounts||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards|
|To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary||Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets|
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We may use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
• contacting us at [email protected]
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts, or
• updating your marketing preferences via the following link Email Preference Center (trustpayments.com). We may ask you to confirm or update your marketing preferences if you purchase products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and whilst it may be shared with the Trust Payments Limited Group for marketing purposes, we will not sell it to other organisations outside the Trust Payments Limited Group for marketing purposes. Trust Payments Group means Trust Payments (UK) Limited and/or Trust Payments (Malta) Limited or such other member as designated by Trust Payments in writing.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
We routinely share personal data with:
• third parties we use to help deliver our products and/or services to you, e.g. payment service providers, warehouses and delivery companies.
• other third parties we use to help us run our business, e.g. website hosts and website analytics providers
• our banks(s)
We only allow those organisations to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data.
We or the third parties mentioned above may occasionally also need to share personal data with:
• external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
• professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
• other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will keep and process your personal data for as long as is necessary for the purposes for which it was collected, and in connection with your relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to share your personal data to countries outside the UK In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA or to an international organisation where:
• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
• a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) [e.g. legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR]. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where such is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law.
For further information about such transfers and the safeguards we employ, including to obtain a copy of the standard data protection clauses, please contact us by sending an email to [email protected]
For further information on cookies, our use of ‘cookies’, when we will request your consent before placing them and how to disable them, please see our https://www.trustpayments.com/cookie-policy/.
You generally have the following rights, which you can usually exercise free of charge:
|Access to a copy of your personal data||The right to be provided with a copy of your personal data A more detailed explanation of this right under UK law is available here|
|Correction (also known as rectification)||The right to require us to correct any mistakes in your personal data A more detailed explanation of this right under UK law is available here|
|Erasure (also known as the right to be forgotten)||The right to require us to delete your personal data—in certain situations A more detailed explanation of this right under UK law is available here|
|Restriction of use||The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data A more detailed explanation of this right under UK law is available here|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations A more detailed explanation of this right under UK law is available here|
|To object to use||The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests. A more detailed explanation of this right under UK law is available here|
|Not to be subject to decisions without human involvement||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website. A more detailed explanation of this right under UK law is available here|
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email us on [email protected] or call us on our support desk at +44 333 240 6000 When contacting us please:
• provide enough information to identify yourself (e.g. your full name, address and customer or invoice or matter reference number) and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
• the Information Commissioner in the UK, and
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
Individuals and businesses in the UK
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).