Privacy policy

TrustyTech.io (“We”, “Us”, “Our”, or the “Company”) respects Your privacy and fully understands how important it is to You. We are committed to transparency and compliance with all applicable laws regarding the confidentiality and security of Personal Data. Celestialwinner – Unipessoal Lda, a company duly incorporated under the laws of Portugal, with its registered office at Rua Moinho Novo 3 Ex Lt 291 C5.2 Quinta da Beloura, 2710-704 Linhó – SINTRA, Lisboa, Portugal, acts as the controller of personal data collected and processed through TrustyTech.io.

This Privacy Policy of TrustyTech.io (the “Policy”) applies to all information published by TrustyTech.io on https://trustytech.io/ (the “Website”) that may be collected from Users (“You”, “Your”) during the use of the Website. The Policy describes the methods of collection, use, and protection of Users’ Personal Data and specifies the cases in which the information collected by Us may be disclosed or shared with third parties.

This Privacy Policy is governed by the laws of Portugal and constitutes an integral part of the Public Offer.

1. 1. DEFINITIONS

   1. 1.1. The following terms shall have the following meanings:

   1. 1.1.1. Cookies – small files, typically consisting of letters and numbers, that are downloaded to a device (computer or mobile device) when a User visits a particular website. These files are stored on Your device (computer or mobile device) and allow Us to collect information about the identifiers of Your device, IP address, web browser used to access the website, pages or features viewed, time spent on the website, and links clicked.

   2. 1.2. Usage Data – data collected automatically or generated through the use of the Service or its infrastructure (for example, page visit duration).

   3. 1.3. Personal Data – means any information that can directly or indirectly identify a User, or information that may directly or indirectly relate to any natural or legal person.

   4. 1.4. Terms used in this Privacy Policy shall have the same meanings as assigned to them in the Agreement unless otherwise defined herein.

2. 2. SCOPE

   1. 2.1. By using the Website, the User agrees to this Policy, any related annexes, and any other documents referenced herein. If You do not agree with the terms of this Policy, or if You are subject to requirements that are not compatible with it, You must not use the Website and must immediately discontinue access.

   2. 2.2. You must comply with the age restrictions established under the laws of Your jurisdiction. If You do not meet the legal criteria of Your jurisdiction, You must immediately stop using Our Website. The Company is not responsible for any use of the Website that violates the laws of Your jurisdiction.

   3. 2.3. Please exercise caution when browsing the Website. It may contain links to other websites. Once You follow a link to another website, this Policy no longer applies. We are not responsible for the content or privacy policies of other websites.

   4. 2.4. This Policy should be read in conjunction with the Company’s Public Offer, which is incorporated into this document by reference.

3. 3. PRINCIPLES OF DATA PROCESSING

   1. 3.1. To safeguard Your privacy, We adhere to the following principles:

   1. 3.1.1. Purpose limitation principle – We process Personal Data solely for the purpose of achieving specific, clear, and lawful objectives;

   2. 3.1.2. Lawfulness, fairness, and transparency principle – We process Personal Data lawfully, fairly, and transparently with respect to the data subject;

   3. 3.1.3. Data minimization and storage limitation principle – We collect Personal Data only to the extent necessary to fulfill specific objectives. We do not retain Personal Data if it is no longer needed or if the purpose for which it was collected has been fulfilled;

   4. 3.1.4. Accuracy principle – We maintain the accuracy and completeness of Personal Data to ensure effective achievement of the data processing objectives;

   5. 3.1.5. Integrity and confidentiality principle – We process Personal Data in a way that ensures appropriate security, particularly protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical and organizational measures;

   6. 3.1.6. Individual participation principle – We inform Users about data collection activities. Users have the right to access their Personal Data and to request correction of inaccuracies or misleading information.

   7. 3.1.7. The Сompany does not sell Your Personal Data to third parties. “Selling” of Personal Data includes selling, renting, releasing, disclosing, disseminating, transferring, or otherwise making available Personal Data of Users to another business or third party for monetary or other valuable consideration.

4. 4. PURPOSE OF THE POLICY

   1. 4.1. The User gives their consent and authorizes the Company to collect, store, process, use, and disclose the User’s Personal Data in accordance with the terms of this Policy by using any aspect of the Website to enable the User to access the Website, as well as to protect the User’s rights and legitimate interests in accordance with applicable law.

   2. 4.2. In order to fulfill Our obligations related to the provision of Services via the Website and under the applicable Public Offer, We have the right to request that You provide Us with Your Personal Data, including (but not limited to): 1) first and last name; 2) email address; 3) Profile name; 4) password; 5) IP address; 6) geolocation.

   3. 4.3. We may collect Your Personal Data in various ways and under various circumstances, including, among others, access to the Website, form submissions, and the provision of feedback. We have the right to combine Personal Data collected throughout Your interaction with different parts of the Service with any available and legally accessible information.

   4. 4.4. We may request additional information from You and documentation confirming such information, at Our discretion and depending on Your country of residence.

5. 5. PURPOSES OF PERSONAL DATA COLLECTION

   1. 5.1. The purposes of processing and collecting Your Personal Data through the Website include (but are not limited to):

   1. 5.1.1. enabling the User to create an account and manage it;

   2. 5.1.2. enabling Users to access the Services We provide through the Website;

   3. 5.1.3. evaluating the popularity of web pages and the effectiveness of the Content provided to the User;

   4. 5.1.4. providing You with feedback, customer support, and responses to Your inquiries;

   5. 5.1.5. ensuring an adequate level of security for Your Profile against unauthorized access;

   6. 5.1.6. collecting analytical or valuable information to help Us optimize the interface and platform functionality for better compatibility with User devices/browsers and to understand popularity;

   7. 5.1.7. enabling Our developers to detect, prevent, and resolve key technical issues using specialized tools;

   8. 5.1.8. monitoring Website usage by the User to improve the web product and enhance the User experience;

   9. 5.1.9. detecting, analyzing, and preventing prohibited actions or behavior that may violate the Public Offer or this Policy;

   10. 5.1.10. fulfilling any other purpose for which You provide Your Personal Data;

   11. 5.1.11. fulfilling Our obligations and ensuring compliance with Our rights arising from any agreements made between You and Us;

   12. 5.1.12. any other purpose We may reasonably deem necessary to protect Our legitimate interests, including the interests of Users, employees, third parties, the public, and/or Our Website, or to comply with the requirements of applicable law.

6. 6. PERSONAL DATA COLLECTED AUTOMATICALLY (USAGE DATA)

   1. 6.1. We may also automatically collect data about the devices You use to interact with Our Website. Personal data automatically collected or transmitted to Us during Your access, interaction, or use of the Website may include, among other things, the following Personal Data:

   1. 6.1.1. IP addresses or domain names of computers used by Users accessing the Website;

   2. 6.1.2. URI addresses (Uniform Resource Identifiers);

   3. 6.1.3. time spent on the request;

   4. 6.1.4. method used to submit the request to the server;

   5. 6.1.5. size of the file received in response;

   6. 6.1.6. numeric code indicating the server response status (successful, error, etc.);

   7. 6.1.7. browser and operating system characteristics used by the User;

   8. 6.1.8. various timing data for each visit (e.g., time spent on each page) and detailed information about the navigation path on the Website, especially the sequence of pages visited;

   9. 6.1.9. other parameters related to the operating system and/or IT environment of the User.

   2. 6.2. We use this information in aggregate to evaluate the popularity of web pages on Our Website and to improve the delivery of content. In combination with other information about You received from previous visits, this data may be used for personal identification, even if You have not logged into Our Website. For data analysis, We use services provided by third parties such as Google Analytics, Google Tag Manager, reCAPTCHA, Cloudflare, and hCaptcha. Data collected in this way is retained for no more than one year.

   3. 6.3. The processing of such data is based on Our legitimate business interests. It is necessary for effective and efficient business management, including maintaining Service quality, customer support, service development, and identifying user groups or parties that may be interested in Our offerings.

   4. 6.4. The data automatically collected on Our Website does not, by itself, allow Us to identify the User. The collection and processing of such data is carried out in compliance with applicable legal requirements and does not require the User’s consent.

7. 7. CONDITIONS FOR PROCESSING PERSONAL DATA

   1. 7.1. The basis for processing the Personal Data of Our Users is their Consent to such processing. We process Personal Data in ways You can reasonably expect and which have minimal impact on Your privacy.

   2. 7.2. The processing of Users’ Personal Data is carried out during the retention period by any lawful means, including in information systems using automation tools or without using such tools.

   3. 7.3. Users’ Personal Data may be transferred to authorized government bodies only on the grounds and in the manner provided for by applicable law.

   4. 7.4. In the event of loss or unauthorized disclosure of Personal Data, We will notify Users about such loss or disclosure.

   5. 7.5. We implement necessary organizational and technical measures to protect Users’ Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, dissemination, and other unlawful actions by third parties.

8. 8. LEGAL BASIS FOR DATA PROCESSING

   1. 8.1. If You are located in the European Economic Area (EEA), You are granted privacy rights, and all processing of Personal Data is carried out in accordance with the provisions and regulations set forth in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation ("GDPR").

   2. 8.2. In accordance with Article 6 of the GDPR, We process Personal Data only where We have a lawful basis for doing so.

   3. 8.3. The processing of Personal Data described in Section 5 of this Policy is based on contractual obligations (Art. 6(1)(b) GDPR) and is carried out solely for the purposes specified in this Policy — to fulfill Your request regarding the Services and to formalize the development of contractual relationships.

   4. 8.4. The processing of Personal Data described in this Policy related to confidentiality is based on legitimate interests (Art. 6(1)(f) GDPR) and is performed only for the purposes specified in this Policy — for communication with You and conducting surveys or questionnaires in which You choose to participate, as well as for analyzing the collected data for marketing research purposes.

   5. 8.5. The processing of Personal Data described in Section 5 of this Policy is based on Your consent (Art. 6(1)(a) GDPR) and is carried out solely for the purposes specified in this Policy — to personalize Your Website experience and for marketing and promotion of Our Services or related third-party products.

   6. 8.6. If You are located in the United States of America, all processing of Personal Data is carried out in accordance with the applicable laws of the state in which You reside, including federal law. If no specific law on confidentiality applies, all processing of Personal Data is carried out in accordance with this Policy and applicable general standards.

   7. 8.7. If You are located in Brazil, all processing of Personal Data is carried out in accordance with the provisions and regulations of the General Data Protection Law ("LGPD").

   8. 8.8. If You are located in the United Kingdom, all processing of Personal Data is carried out in accordance with the provisions of the Data Protection Act 2018 (“DPA 2018”) and the UK General Data Protection Regulation (“UK GDPR”).

   9. 8.9. If You are located in Australia, all processing of Personal Data is carried out in accordance with the provisions of the Privacy Act 1988.

   10. 8.10. If You are located in Canada, all processing of Personal Data is carried out in accordance with the provisions of the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).

   11. 8.11. If You are located in any other jurisdiction, the laws of that jurisdiction apply to You, and all processing of Personal Data is carried out in accordance with the applicable legal provisions of that jurisdiction.

   12. 8.12. We process Personal Data in the capacity of a Controller, as defined under the GDPR.

9. 9. CONSENT TO PERSONAL DATA PROCESSING

   1. 9.1. Consent of EU citizens to the processing of Personal Data:

   1. 9.1.1. If You are an EU citizen and We are required to obtain Your consent for processing Your Personal Data under the GDPR, We will process Your Personal Data only if We have received freely given, specific, informed, and unambiguous consent from You, which clearly indicates Your wishes and grants Us permission to process Your Personal Data ("Consent").

   2. 9.1.2. You may give Your Consent by checking the corresponding box in the form on the Website during Profile creation. By checking this box, You unconditionally agree that We may process Your Personal Data to the extent specified in Your Consent.

   3. 9.1.3. Your Consent applies to all processing operations carried out for the stated purposes. Although processing may serve multiple purposes, Your Consent shall be considered granted separately for each of them.

   2. 9.2. Consent of non-EU citizens to the processing of Personal Data:

   1. 9.2.1. If You are not an EU citizen, by transmitting Your Personal Data to Us via software interfaces or in any other way, You are deemed to have given Us voluntary and unconditional Consent and agreed that We may process Your Personal Data in accordance with this Policy.

   2. 9.2.2. We process Personal Data in various ways, including the collection, storage, recording, use, structuring, combination, use, and transfer (including cross-border transfer) of Your Personal Data provided to Us or received from third parties, as well as Personal Data collected during Your use of the Service (e.g., Your behavior, data that the Company regularly collects from different sources); and

   3. 9.2.3. We use cookies and web beacons (pixel tags) to collect Your Personal Data.

10. 10. USER RIGHTS

    1. 10.1. Users may view, correct, update, delete, and transmit their Personal Data.

    2. 10.2. Subject to applicable limitations under national legislation, You may have the following rights regarding the Personal Data We collect about You:

    1. 10.2.1. Right to object to the processing of Your Personal Data. If Our processing is based on legitimate interest for service provision, improvement, or support of Our business, You have the right to object to such processing. Unless We demonstrate compelling legitimate grounds that override Your interests, rights, and freedoms, or unless such processing is necessary for legal claims, We will stop the processing.

       Notwithstanding any Consent given in the future for direct marketing purposes, You retain the right to prohibit Us from using Your Personal Data for such purposes by contacting Us or using the Website’s functionality to unsubscribe from direct marketing communications.

    2. 10.2.2. Right to access Your Personal Data. You have the right to know whether We are processing Your Personal Data. When We process Your data, We will inform You of the categories of Personal Data processed, the purposes, recipients, and transfer categories, as well as the applicable retention periods or criteria for determining those periods.

    3. 10.2.3. Right to restrict, verify, and rectify. Users have the right to request that inaccurate Personal Data be corrected, or to request restriction of processing, including deletion, if further storage is no longer necessary or the processing is unlawful.

    4. 10.2.4. Right to restrict objectionable processing. Users have the right to object to processing that does not meet data protection requirements and to request the restriction or termination of such processing.

    5. 10.2.5. Right to receive Your Personal Data and transfer it to another Controller. If Our processing is based on Your Consent and is carried out by automated means, You have the right to receive Your Personal Data in a structured, commonly used, and machine-readable format and transmit it to another Controller without hindrance.

    6. 10.2.6. Right to withdraw Consent. If Our processing is based on Your Consent, You may withdraw it at any time by contacting Us at [email protected], and Your Personal Data will be promptly deleted. Withdrawal of Consent may affect Your ability to use certain Website functionality.

    7. 10.2.7. Right to lodge a complaint. Users also have the right to file a complaint with a supervisory authority if they believe that We have violated their rights. However, We ask that You contact Us first so that We can try to help.

    8. 10.2.8. How to exercise these rights. To exercise any of the rights listed above, You should primarily use the Website’s functionality.

    9. 10.2.9. When We receive a request for access, editing, or deletion of personally identifiable information, We reserve the right to first take reasonable steps to verify Your identity, including requesting additional actions. This is necessary to protect Your Personal Data. We may also reject requests that are unreasonably repetitive, excessive, or clearly unfounded.

11. 11. COOKIES

    1. 11.1. When a User or Visitor accesses, views, or uses the Website, small text files known as "cookies" are stored on their device. These cookies contain information that may be used to store login data, User or Visitor preferences, and other data related to Website activity. Cookies are particularly useful for tracking User and Visitor interactions, optimizing Website performance, and personalizing content.

    2. 11.2. Storage duration. Some cookies persist only while the session is active. Information collected via third-party cookies is retained for 2 (two) weeks.

    3. 11.3. Our Website uses only strictly necessary cookies.

    4. 11.4. Strictly necessary cookies. These cookies are essential for the operation of Our Website because, without them, We cannot provide You with the functionality required to use the Website. Strictly necessary cookies are associated with Website settings, security, and fraud prevention. Without these cookies, core functions cannot be provided. These cookies are always active and cannot be disabled.

    5. 11.5. Internal cookies. These cookies are used to recognize You when You return to the Website, to store language and regional settings, and to provide basic functionality such as session storage and navigation memory.

    6. 11.6. Session cookies. These cookies are temporary and expire when You close Your browser and/or end Your session. Session cookies allow the Website to operate consistently during a session.

    7. 11.7. Persistent cookies. These cookies remain on Your device permanently (for the time specified in the cookie file).

    8. 11.8. Purpose of cookies. Cookies are used for various purposes, including facilitating navigation, storing Your preferences, and improving the User experience. We are responsible for processing Your Personal Information and use cookies to enhance Our Website, optimize performance, and improve Our Services.

    9. 11.9. Cookie consent. By selecting "Agree" on the cookie banner, You confirm that You are informed about the use of cookies and that You have read this Section 11.

    10. 11.10. By selecting "Privacy Policy" on the cookie banner, You can review the applicable terms regarding the processing of Your Personal Data and use of cookies on the Website.

    11. 11.11. If You are located in the European Economic Area (EEA), any data processed via cookies qualifies as Personal Data, and the legal basis for such processing is Your Consent (in accordance with Article 6(1)(a) of the GDPR), except for strictly necessary cookies as defined in this Policy.

    12. 11.12. If You are located outside the EEA, all processing of Personal Data is carried out in accordance with the laws and regulations of Your country of residence.

    13. 11.13. Below is a list of strictly necessary cookies used:

        NAME	PURPOSE	DURATION	TYPE
        lang	Stores the user's preferred language for proper interface display	Persistent	Functional, internal, persistent
        remember-me	Enables automatic login during subsequent visits to the site	Persistent	Authentication, persistent
        session	Stores current session data	Current session, 30 minutes	Session-based, technical

    14. 11.14. We use Third-Party Cookies. Third-party cookies are owned and operated by external providers who are subject to appropriate contractual guarantees in accordance with the requirements of the GDPR, the ePrivacy Directive (EPD), and other applicable laws commonly referred to as the “Cookie Law”.

12. 12. STORAGE AND DELETION OF INFORMATION

    1. 12.1. Personal Data shall be processed and stored only for as long as necessary to achieve the purposes for which it was collected and/or for the duration of this Agreement (if applicable), as well as for the period necessary to comply with applicable legal requirements, including bookkeeping and tax retention periods, or until Consent is withdrawn (“Retention Period”).

    2. 12.2. We will retain, collect, and process Your Personal Data only for as long as You remain Our User and We have Your Consent. Personal Data collected and processed based on Your Consent will be retained for as long as We have Your Consent.

    3. 12.3. The User may request deletion of Personal Data at any time. To request deletion, You must send an email to [email protected] with a formal request for deletion of Personal Data, and We will promptly delete Your Personal Data upon receipt of Your request.

    4. 12.4. Upon expiration of the Retention Period, We will delete the Personal Data. Accordingly, rights such as objection to processing, access, deletion, restriction, or portability may not be exercised after the expiration of the Retention Period.

    5. 12.5. We do not provide any User lists to third parties except as expressly provided for in this Policy.

13. 13. DATA SECURITY

    1. 13.1. We care about the security of Your Personal Data. We adhere to generally accepted industry standards for protecting data during transmission, as well as upon receipt. We implement technical, physical, and administrative security measures to ensure the proper protection of Your Personal Data. When We process Your data, We also take measures to protect it from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is achieved through appropriate administrative, technical, and physical safeguards.

    2. 13.2. Unfortunately, the transmission of information via the Internet is not entirely secure. Although We make every effort to protect Your data, We cannot guarantee the security of Your Personal Data transmitted to Our Website. The transmission of Personal Data is carried out at Your own risk. We are not responsible for the security settings or confidentiality of any data stored on the Website.

    3. 13.3. We never process any sensitive information, such as personally identifiable information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, inherited information, biometric data used solely for identification, data related to health or sexual life or orientation, or information concerning criminal convictions.

14. 14. DATA TRANSFER

    1. 14.1. Your information, including Personal Data, may be transferred to and stored on computers located outside of Your province, region, country, or other governmental jurisdiction where data protection laws may differ from those in Your jurisdiction.

    2. 14.2. Your consent to this Privacy Policy, accompanied by the provision of such information, constitutes Your agreement to such transfer.

    3. 14.3. We take all reasonably necessary steps to ensure the secure processing of Your data in accordance with this Privacy Policy. No transfer of Your Personal Data will take place to any organization or country unless there are adequate controls in place, including the security of Your Personal Data.

15. 15. SERVICE PROVIDERS AND CONTRACTORS

    1. 15.1. We may cooperate with third-party service providers who deliver services to Us, including, but not limited to, website development, hosting and maintenance, email communications, marketing, technical support, IT services, cybersecurity, user support, and other services. These providers may have access to and process Your Personal Data on Our behalf and under Our instructions within the scope of their services to Us. We restrict the information shared with them to what is reasonably necessary for the performance of their functions.

    2. 15.2. We may also need to transfer Your Personal Data to third parties who provide services to Us. If Your Personal Data is transferred outside Your country or jurisdiction, We require such third parties to comply with applicable data protection laws and ensure appropriate safeguards.

    3. 15.3. We require all Our service providers and contractors who process Personal Data to comply with data security and confidentiality requirements, including those established by applicable law and Our contractual terms, and to implement appropriate security measures.

16. 16. GOVERNING LAW AND DISPUTE RESOLUTION

    1. 16.1. In the event of any disputes, the Parties shall seek to resolve them through negotiations. The negotiation period shall be 30 days.

    2. 16.2. If a dispute cannot be resolved within 30 days, any dispute arising from the use of the Services, including the collection, storage, processing, use, or disclosure of Users’ Personal Data, shall be governed by the laws of Portugal.

    3. 16.3. If any provision or agreement under this Policy is held to be unenforceable or invalid by competent legal authorities or courts, such unenforceability shall not affect the validity or enforceability of the remaining provisions of this Policy.

    4. 16.4. Any claim or dispute shall be resolved within 30 days of negotiation. If resolution is not possible, the matter shall be referred to a competent authority selected by the Company.

17. 17. CHANGES TO THE PRIVACY POLICY

    1. 17.1. The Company reserves the right to amend this Policy without the User’s consent.

    2. 17.2. We may update or change this Policy from time to time. All amendments and updates to this Policy shall become effective upon their publication on the Website. We reserve the right to modify and update this Policy at any time without prior notice. The User is responsible for regularly reviewing this Policy to stay informed of any changes.

    3. 17.3. If We make changes that, in Our opinion, are material, We will make reasonable efforts to notify You in advance by using Your contact details or by posting the updated information on the Website.

    4. 17.4. The User must regularly review this Policy to remain informed of any changes. Continued use of the Website after such changes indicates acceptance of the updated Policy.

    5. 17.5. Any suggestions or questions regarding this Privacy Policy should be sent to: [email protected].

18. 18. CONTACTING US

    1. 18.1. If You have any questions regarding this Privacy Policy, please contact Us by email at [email protected].