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Privacy Policy

This privacy policy (“Policy”) describes Trustin Limited’s (“Trustin Trade” or “Company” or “we” or “our”) policies and procedures on the collection, usage, maintenance, and disclosure of information collected from users (“you” or “User” or “Users”) in accordance with the Abu Dhabi Global Market Data Protection Regulations, 2021 (“Data Protection Regulations”) along with any other applicable rules, guidance, ordinances, circulars issued by the Financial Services Regulatory Authority (FSRA) [together hereinafter referred to as “Applicable Laws”] when you access/ use the electronic platform that is owned and operated by the Company (“Platform”) and to render the services available on our Platform (“Services”).

The protection of your data is a top priority for us and we take pride in taking all the necessary steps to ensure the safety of your data. It is to enable us to improve our standards of service in a safe and secure manner, we process some personal information. In this regard, if you have additional privacy-related questions or require more information about our Privacy Policy, please do not hesitate to contact us at hello@trustin.ae.

By using or accessing our Platform, you hereby consent to our Policy and agree to its terms.

1. Personal Information Required to be Disclosed:

0.1. Personal data under the Applicable Laws has been defined as any data relating to an identified natural person or identifiable natural person (“Personal Data”).

0.2. We will be collecting Personal Data and other relevant information from you only if you voluntarily submit such information to us. You can always refuse to provide personal identification information; however, it may prevent you from accessing our Platform and the use of our Services. We may process and retain any information (including Personal Data) you may provide us with, as may be required under the Applicable Laws. Please check Article 11 – Consent and Withdrawal of Consent to find out how you may change, access or delete your Personal Data.

0.3. We collect, process or host the following Personal Data and relevant information that you may submit on our Platform in order for us to perform a Know-Your-Customer (KYC) check on our Users for rendering the Services:

  1. KYC information
    1. For Individuals:
      1. your full legal name;
      1. date of birth;
      1. front and back copy of address proof;        
      1. your nationality;
      1. country of residence;
      1. front and back copy of valid UAE Resident ID/ UAE ID or passport;
      1. contact details, including an email address and telephone number at which you can be contacted;
      1. bank account details (including IBAN Number) for the purpose of rendering Services through our Platform;
      1. debit card and/or credit card information for the purpose of rendering our Services through our Platform;
      1. other information as may be required to verify your identity and all data provided by you to us; and        
      1. other information as may be required to allow the Company to comply with all legal and regulatory obligations under the Applicable Laws.
    2. For Corporate Entities:
      1. legal name;
      1. date incorporation;
      1. registered address;        
      1. copy of Trade License/ Commercial License containing details including but not limited to the unique entity number;        
      1. front and back copy of valid UAE Resident ID/ UAE ID or passport and address proof of the Registered User, and manager of the corporate entity;
      1. contact details including email address and telephone number of your directors, shareholders, beneficial owners, employees and any other individual authorized to act on your behalf (each a User) includes such information as listed in Article 1.3 - Personal Information Required to be Disclosed above in relation to each User;
      1. bank account details for the purpose of rendering our Services on our Platform;
      1. debit card and/or credit card information for the purpose of rendering our Services on our Platform;
      1. other information as may be required to verify your identity, the identity of the legal entity that you represent, and all data provided by you to us in order for us to be able to render our Services on our Platform; and
      1. other information as may be required to allow the Company to comply with all legal and regulatory obligations under the Applicable Laws.
  2. Preferences: for example, language settings or interests on the type of Service you prefer and whether you wish to receive marketing/ promotional emails.

0.4. Please note that, pursuant to the Data Protection Regulations, we do not collect any form of sensitive personal data which reveals or concerns (directly or indirectly) any racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade-union membership and health or sex life, including but not limited to, any genetic data and biometric data where it is used for the purpose of uniquely identifying a natural person (together referred to as “Special Categories of Personal Data”).

0.5. If you contact us directly, we may receive additional information about you such as the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

2. Purpose of collecting Personal Data and Consent from Users

2.1. The Company collects Personal Data and other relevant information from its users, mainly for the below-mentioned purposes:

  1. Registration of Users: to assess and evaluate your eligibility for registering an account on the Platform (“Account”);
  1. Operating Platform: We collect Personal Data to enable us to operate and maintain our Platform and render Services to our Users, and also to understand and analyze how you use our Platform and Services, in order for us to improve, personalize and expand our Platform and Service functionality for your benefit and for maintaining relationships with our Users;
  1. Marketing and Advertisements: We may use your Personal Data for marketing, promotional activity, and (interest-based) advertising using cookies, and any additional functionalities or new products we may wish to offer to you.
  1. Fraud Prevention: We may use Personal Data collected from you to improve our fraud prevention framework in order for us to detect any fraud at its inception and improve fraud-prevention procedures to efficiently counter any fraudulent activity.
  1. Law Enforcement: We are obliged to share your Personal Data in case of a request from a Court of Law and/or any federal or local government or regulatory authority;
  1. Other Legal Obligations: We may disclose your Personal Data, in good faith belief that such action is necessary to: (i) maintain legal and regulatory compliance where required under any Applicable laws; (ii) protect and defend the rights or property of the Company; (iii) prevent or investigate possible wrongdoing in connection with the Services available on our Platform; (iv) protect the personal safety of Users of our Platform or the public; (v) protect and defend against any legal liability that may arise against the Company and/ or (vi) to enforce the terms and conditions of any agreement between you and the Company (including but not limited to this Policy); or
  1. Consent-based Use: for any other purpose for which you have given the Company your consent in writing.

(Collectively hereinafter referred to as the “Purposes”).

3. Information collected by automated means

We may collect non-personal identification information about you when you use our Platform through automated means. Non-personal identification information may include the following:

  1. Information from Platform: date and time stamp of usage, referring/exiting pages, and possibly the number of clicks.
  1. Browser information: type of browser, language settings, country and time zone.
  1. Cookie or web beacon information: cookie IDs and settings, and other information received through cookies, web beacons or pixel tags.
  1. Device information: the type of device, hardware model and operating system.
  1. Network information: Internet Service Provider (ISP), IP-addresses and mobile network information.
  1. Location data: data on your geo-location. If we use your device based, precise GPS-location, we will make sure we only do so after receiving your consent.
  1. Platform usage: information regarding the way you interact with our Platform.

The above information is not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the Platform, tracking our Users’ activity on the Platform, and gathering demographic information.

4.Information from Third-Party Sources

4.2. From time to time, the Company may obtain information about its Users from third-party sources as required or permitted by Applicable Laws, including from:

  1. Publicly available databases;        
  1. Credit bureaus;
  1. Social media platforms.
  2. The Company’s ID verification partners. Such ID verification partners may use a combination of government records and publicly available information about you to verify your identity, including the following information relating to you:
    1. name;
    1. address;
    1. employment information;
    1. public employment profile (where applicable);
    1. credit history;
    2. status on sanctions lists maintained by public authorities (where applicable).

4.3. The Company obtains such information from third-party sources to comply with its legal obligations, including applicable anti-money laundering laws, and to ensure that the services and/or products of the Company are not used fraudulently or for other illicit activities.

Consent Architecture and User Acknowledgements

5. Consent Architecture

5.4. Unless otherwise permitted or required under the Applicable Laws, the Company generally collects Personal Data in the course of or in connection with the registration of your Account with the Company only after you have agreed to the terms of this Policy through which you acknowledge that:

  1. you have been notified of the Purposes for which the Company collects your Personal Data; and
  1. you have provided the Company with your consent to the collection, use and disclosure of Personal Data or relevant information for the satisfaction of the Purposes.

6. User Acknowledgements

6.5. You acknowledge and agree that any Personal Data or relevant information provided to us (whether electronically or otherwise)

  1. is done knowingly and voluntarily by you;
  1. is complete, true and accurate in all respects; and
  1. does not omit anything that affects or is likely to affect the meaning or significance of such Personal Data in any respect.

6.6. In order to ensure that your Personal Data and other relevant information submitted is complete, true, and accurate in all respects, you acknowledge and agree that it is your sole responsibility to update the Company within a reasonable time if there are any changes to such Personal Data by informing the data protection officer of the Company to their email at compliance@trustintrade.ae.

6.7. In the event that you provide Personal Data relating to any individual who may act as your authorized representative (each such authorized representative a User), you undertake that you have obtained consent from such individual concerned for the disclosure of their Personal Data to the Company and for the Company to collect, use and disclose such Personal Data for the fulfillment of the Purposes.

6.8. The Company reserves the right to request for proof of notification and consent for the disclosure of Personal Data by a User.

6.9. You agree that the Company may disclose Personal Data to:

  1. any governmental agency or regulatory authority of any jurisdiction properly exercising its powers;
  1. professional advisers of the Company;
  1. parties providing services and/or products to the Company (including information technology services, know-your-client and anti-money laundering compliance services providers);
  1. Affiliates of the Company (“Affiliates” means, with respect to a party, any director, employee, agent, subsidiary of the Company those controls, is controlled by, or is under common control with such party. For purposes of this definition, “control” means the legal power to direct or cause the direction of the general management of a company, partnership, or other legal entity), if any, for the satisfaction of the Purposes, provided, the requirements for transferring Personal Data with Affiliates as set out under the Data Protection Regulations are maintained;
  1. entities that the Company is in discussions with for a merger or an acquisition of the Company by such other entities;
  1. entities that acquire the assets of the Company pursuant to the Applicable Law, including the laws of insolvency in United Arab Emirates;
  1. entities, pursuant to any order of the court from a court of competent jurisdiction.

6.10. You acknowledge and agree that the Company may continue to use and disclose Personal Data for a reasonable period following the termination of the relationship between you and the Company for any one or more of the following purposes:

  1. to allow the Company to fulfill its outstanding obligations to you under any agreement between you and the Company, if any;
  1. to allow the Company to enforce its rights under any agreement between you and the Company, if any;
  1. for such purposes to which you have given your consent in writing;
  1. where required under any Applicable Laws;
  1. where required for the satisfaction of the Purposes; or
  1. where required under any order of court from a court of competent jurisdiction.

Data Protection Measures

7. Data Protection Standards

7.11. At Trustin Trade, we ensure that your Personal Data is collected, used, disclosed, copied, modified, disposed and/or processed as per the standards laid down in the Data Protection Regulations. We ensure that your personal information is kept securely, protected from any breach, infringement, or illegal or unauthorized processing by establishing and applying appropriate technical as well as organizational measures and procedures, in accordance with the Data Protection Regulations.

7.12. The Company has introduced appropriate administrative, physical and technical measures (including up-to-date antivirus protection, encryption and use of privacy filters) to secure all data collection, storage, transmission of Personal Data by the Company, and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data, username, password, transaction information and data stored on our Platform.

7.13. Any disclosure of our Users’ Personal Data (whether internally or otherwise) will only be carried out on a need-to-know basis.

7.14. You acknowledge and agree that no method of transmission over the internet or method of electronic storage is completely secure and the Company makes no representation and/or warranty (whether express or implied) that there will be no unauthorized:

  1. access to Personal Data;
  1. copying of Personal Data; and/or
  1. disposal or dissemination of Personal Data.

7.15. You agree that, save for any proven wilful default or fraud on the part of the Company or its directors, officers, employees, representatives, and/or agents (each a “Relevant Person”), no Relevant Person shall be liable to you for any losses, liabilities, damages, costs and/or expenses (including any direct, indirect, incidental, special, consequential or punitive damages or economic loss or any claims for loss of profits or loss of use) arising from or in connection with this Policy.

8. Retention of Personal Data

8.16. Subject to any Applicable Laws, the Company may retain Personal Data of its Users for as long as it is necessary to fulfil the Purposes.

8.17. The Company shall cease to retain Personal Data or otherwise remove the means by which such Personal Data can be associated with Users as soon as, in the opinion of the Company, it is reasonable to assume that such retention no longer services the Purposes for which the Personal Data was collected and is no longer necessary for the Purposes contemplated.

8.18. However, the Company may retain your Personal Data for permissible purposes as set out under the Data Protection Regulations, provided, a data protection impact assessment is conducted in accordance with the Data Protection Regulations. The data or information we collect automatically is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Platform, or we are legally obligated to retain this data for longer time periods.

8.19. We may retain your Personal Data after the completion of purposes set out in the Data Protection Regulations, in an anonymized/ pseudonymized/ encrypted form using an “Anonymization” feature. Anonymization is the processing of your Personal Data in such a way that anonymizes your identity so that such data can no longer be linked and attributed to you and you can no longer be identified in any way whatsoever.

9. Access and Correction of Personal Data

9.20. You may make an access request for access to a copy of the Personal Data or information on the ways in which we use or disclose the Personal Data via email to our data protection officer to their email at  compliance@trustin.ae

9.21. Please note that depending on the request that is being made, the Company may only need to provide you with access to the Personal Data contained in the documents requested, and not to the entire documents themselves, in which case it may be appropriate for the Company to instead provide you with a confirmation of the Personal Data that our organization has on record if the record of the Personal Data forms a negligible part of the document.

9.22. Where the Company is unable to comply with any request under Article 9.1 here above, the Company shall inform you of the reason(s) for being unable to do so.

10. Transfer of Personal Data outside the United Arab Emirates

10.23. In the event that the Company and/or its services providers store, transfer or otherwise process Personal Data outside of United Arab Emirates, the Company shall take steps to ensure that the Personal Data continues to receive a standard of protection that is at least comparable to that provided under the Data Protection Regulations.

10.24. In the event that you provide Personal Data relating to any individual (where such an individual is your authorized representative i.e., being a User of the Platform), you undertake that you have obtained the consent from such individual concerned for the transfer of Personal Data relating to such individual outside of United Arab Emirates.

10.25. The Company reserves the right to request for proof of notification and consent for the disclosure of Personal Data by an individual under Article 10.2 hereinabove.  

11. Consent and Withdrawal of Consent

11.26. In providing any Personal Data, you acknowledge and agree that you have read, understood and agreed to this Policy and consent to the use, disclosure and/or processing of the Personal Data for the Purposes.

11.27. Your consent shall remain valid until such time as withdrawn by you in writing, following the termination of the relationship between you and the Company.

11.28. You may withdraw your consent (whether in part or in whole) at any time in writing or via email to the data protection officer of the Company at the details below (“Withdrawal Request”).        

11.29 Upon receipt of a Withdrawal Request, the Company will inform you of the likely consequences of withdrawing your consent (whether in part or in whole) and the Company will cease collecting, using or disclosing Personal Data save in accordance with this Policy.

12. Changes to Policy        

12.30. This Policy applies in conjunction with any other notices, contractual clauses, and consent clauses that apply in relation to the collection, use and disclosure of Personal Data by the Company.

12.31. The Company may revise this Policy from time to time without any prior notice and you acknowledge and agree that it is your sole responsibility to keep up to date with any revisions to this Policy.

12.32. Your continued use of any service and/or product provided by the Company shall constitute your acknowledgement and acceptance of any revisions to this Policy.

13. Our Advertising Partners

13.33. Some third-party advertisements by our advertising partners on our Platform may use cookies and web beacons. Such third-party ad servers or ad networks use technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on our Platform which are sent directly to your browser. They automatically receive your IP address when this occurs. Such technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on other websites that you visit. Please note that we do not have any access to, or control over these cookies that are used by third-party advertisers.

14. Third Party Privacy Policies

14.34. Each of our advertising partners, have their own privacy policy, for their policies on processing your data. You access the privacy policy for each of our advertising partners on their website. Please note that our Policy does not apply to other advertisers or their websites. Thus, we are advising you to consult the respective privacy policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

14.35. You may also choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.