1. Overview of the Policy

1.1. Introduction and Overview

This privacy policy describes how Trumia (“We”, “Us”, “Our”) collects, uses, discloses, transfers, stores, retains, or otherwise processes personal data from businesses and other organisations (collectively, “Business Customers”) who engage with our services.
When we process personal data as instructed by Business Customers, we act as their service provider and are considered “data processors.” When we process personal data for our own purposes, such as meeting regulatory obligations, we act as “data controllers.”
For individual customers making use of Trumia’s services, please refer to our Data Privacy Notice (Individuals).

2. Collection and Processing of Personal Data

The personal data we collect depends on how you interact with us and the services you use. We may collect information directly from various sources in various ways, including information you provide directly, information collected automatically from third-party sources, and data we may infer or generate from other data.
We can only use your personal data if we have a lawful reason for doing so. In terms of the data protection laws, we process personal data if you have given us your consent, or it is necessary:

1. for our legitimate interests
2. to carry out our contractual obligations,
3. to comply with a legal obligation, or
4. for any other relevant legal basis set out in the GDPR

2.1 Personal Data We Collect Directly From You:

• ‍Registration/Login information: Depending on your use of the Service, we may collect your name, email address, phone number, company name, and mailing/billing addresses.
• Due diligence information: As part of our due diligence procedure and to fulfill our legal obligations, we may collect documents including but not limited to the following: full name, identity documents, date of birth, address, tax information, and other relevant personal data.
• Financial information: We collect credit card numbers, financial account information, and other payment details for fulfillment of financial transactions.

2.2 Personal Data We Collect From Third Parties‍

We may collect personal data, including identification information and commercial information from third parties or publicly available sources.

‍2.3 Personal Data Collected From Your Use Of Our Services

We may collect information about how you use the services, such as the content that you view or engage with, what you click, and so on. We may also collect your IP address and location information.

3. How We Use Your Personal Data

We may use your personal data for the following purposes;

4. Cookies and Data Tracking

We use cookies and similar tracking technologies ("Tracking Technologies") on our websites.
The Tracking Technologies automatically collect information about you, your online behavior on the websites, and your device (for example, your computer or mobile device), for different purposes, including improving and personalizing your navigation on our Services and enhancing our Services’ performance.
For more information about our use of cookies, refer to our Cookie Policy.

5. With Whom We Share Your Data

We may share your personal data with:

• Our affiliates, subsidiaries, or related companies;
• Our service providers and business partners. The processing by such companies will be governed by a written contract with Trumia to ensure adequate protection and security measures are put in place for the protection of personal data;

• Auditors, contractors or advisers of any of our business processes;
• Any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
• Licensing authorities, governmental and regulatory bodies, law enforcement authorities  in accordance with applicable laws and regulations; 
• Third parties in the event of/connection to corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, transfer, divestiture, or sale of all or a portion of our business or assets; and
• Third-party analytics and advertising companies may also collect personal data through our website and mobile application, including marketing and communications data, demographic data, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie ID, device ID, and IP address).

6. Marketing and Advertising

We may use your Personal Data for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing so, or where we have obtained your affirmative consent.

You may, at any time, decline receiving further marketing offers from us or from our business partners and marketing affiliates by either: following the links inserted in the promotional emails (e.g., selecting the opt-out link), by updating the notification preferences in the personal settings of your account or contacting our customer support, or by reaching out to us at contactus@trumia.com. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

7. Transfers of Your Personal Data Outside the EEA

In the event that personal data is stored or transferred outside the EU/EEA, such transfers shall comply with EU/EEA and Maltese data protection laws. Trumia ensures that data is stored or transferred to jurisdictions that provide an adequate level of protection as recognized by the EU/EEA, secured using appropriate technological solutions, and available on a principle of least privilege. Necessary contractual arrangements are in place with third-party providers, in line with the EU Commission’s Standard Contractual Clauses (SCCs) and any additional required measures. Additional information on the transfer mechanisms used can be provided upon request. 

8. Personal Data Retention Period

We retain your personal data only for as long as this is necessary to fulfill the purposes for which we collected it and in compliance with applicable laws or regulations.

Upon expiration of the data retention period, we will delete, erase, or anonymise any personal data we have about you.

Should you require further information or clarifications, please do not hesitate to contact us.

9. Your Rights With Respect to Personal Data

You have the following rights if you reside in the EU:

• Right to be Informed: included by being provided with this notice.
• Right of Access: request a copy of your personal data.
• Right to Rectification: request we correct any inaccurate personal data about you.
• Right to be Forgotten: require us to delete your personal data.
• Right to Restriction of Processing: require us to restrict processing your personal data.
• Right to Data Portability: receive your personal data which you provided to us, in a structured, commonly used, and machine-readable format, and transmit that data to another data controller in certain circumstances. 
• Right to Object: object to the processing of your personal data in certain circumstances, including continued processing carried out for our legitimate interests.
• Right Not to be Subject to Automated Processing: request not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you.

• Right to Complain to a Data Protection Authority: our supervisory authority is the Office of the Information and Data Protection Commissioner, which may be contacted at: 

Information and Data Protection Commissioner 

Floor 2, Airways House, High Street, Sliema, SLM 1549. MALTA. 

Telephone: (+356) 2328 7100 

Email: idpc.info@gov.mt 

Website: https://idpc.org.mt/en/Pages/contact/complaints.aspx

Should you require any further information on each of the above rights or would like to exercise any of them, please contact us on www.trumia.com or by email on dpo@trumia.com.

10. Third Party Websites

Our website and mobile application may contain links to other websites. Please note third party links are not associated with Trumia and we do not have control over how your personal data is collected, stored or used by other websites. Hence, you are advised to refer to their privacy policies prior to providing your data.

11. Protecting Your Personal Data 

We are committed to take all appropriate measures to protect the confidentiality and security of the data you provide to us. Trumia has implemented security measures to protect your personal data that we collect from being used or accessed unlawfully or accidentally lost. We take appropriate organisational and technical measures to secure your personal data and to protect it against unauthorised or unlawful use and accidental loss or destruction, including but not limited to: 

• only sharing and providing access to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis where possible; 
• using secure servers to store your data; 
• verifying the identity of any individual who requests access to information prior to granting them access to information; 
• using Secure Socket Layer (SSL) protocol (or other similar encryption technologies as may be required from time to time) to encrypt communication to / from our servers; and 
• whenever and to the extent possible, we anonymise or pseudonymise the personal data which we hold about you when it is no longer necessary to identify you from such data. 

12. Contact Us 

You can contact our Data Protection Officer by sending an email to dpo@trumia.com.You can reach our support department directly by sending an email to contactus@trumia.com. 

13. Updates to this Notice

We may update this privacy notice occasionally to keep up with changing legislations, best practices, and the way we process your personal data. Any changes will be immediately placed on our website. We recommend that you check this page regularly to keep up to date.

This Privacy Notice is effective as of May 22, 2024. You can request previous versions of this document by sending us an email at contactus@trumia.com.