Privacy Policy

Hey there!

We're Trustie Technology Limited (Trustie, we, our, or us), and we take your privacy seriously. This policy is here to explain how we protect and handle your personal data when you use our Trustie Platform and Services.

We want you to feel confident about how your information is collected, used and protected. We want to make sure you are aware of your rights and understand how the law keeps your privacy and data safe. That's why we encourage you to read this policy carefully-along with any updates or related privacy policies-so you know exactly when, how, and why we use your data.

You'll find explanations for specific terms (ones with capital letters) at the end of this policy. We've kept things clear and simple to ensure we're on the same page. If you ever feel unsure about anything, our friendly support team is just an email away at support@trustie.co.uk.

Why This Policy Matters

This policy sets out how we collect and process your personal data when you use Trustie's Platform and Services. This includes:

• Our website
• Gift card services
• Cashback rewards
• Our Trustie App
• When you buy a product or service from us
• When you post in the Trustie forum
• If you provide feedback, take a survey, or enter a competition

Our Services are for adults aged 18+. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, please contact us at privacy@trustie.co.uk and we will take steps to delete it.

This policy explains how we use your personal data for the Trustie Platform and Services. If other Trustie privacy notices apply to a specific feature, we'll point you to them.

Important information and who we are

Trustie Technology Limited is the 'Controller' of your personal data (meaning we decide how and why it is used) for the Trustie Platform and Services.

Trustie Technology Limited is registered in Northern Ireland (company number NI653889) and registered with the ICO under number ZB628293.

Our Data Protection Officer (DPO) is Sukhi Byrne. If you have questions about this policy or want to exercise your rights, email privacy@trustie.co.uk (please include 'For the attention of the DPO' in the subject line).

Our Contact details

• Full name of legal entity: Trustie Technology Limited
• Email address: privacy@trustie.co.uk
• Postal address: Trustie Technology Limited, Omagh Business Complex, Cortrush Industrial Estate, Great Northern Road, Omagh BT 78 5LU Northern Ireland
• Telephone number: +44 28 8230 6422

Changes to the privacy policy

At Trustie we may from time to time update our privacy policy because we regularly review it. Please contact us if you would like a copy of any past policies.

When you must inform us of any changes

If there is a change in your circumstances, the data we hold about you may no longer be accurate. This is why we need you to keep any information you provide to us updated and let us know if anything does change in the relevant section of your personal data that you utilise in the Trustie Platform and Services.

The type of personal information we collect

Personal information (or data) means any information about a person which enables that individual to be identified. The data is anonymous if it does not contain any personal information. We may collect, use, process, store and transfer the following information. We only collect what we need to provide the Services, meet legal requirements, and run our business.

• Your personal information – including your full name, date of birth, gender, contact details, including email address and telephone number and also information you insert on your profile (username, password, interests, preferences, hashtags, comments, goals, posts, targets and responses)
• Any financial information – including any bank account numbers, sort codes, IBAN numbers, payment card details, transactions, and other account information you choose to link to Trustie.
• Any financial information you provide when you link into our account, historical account transactions from all bank accounts that are linked to the Trustie Platform or Services
• Any financial transactions you make when you use our Trustie Platform or Services, including payments that come in and out of your account and purchases that you make (including gift cards)
• Any technical data related to how you use our Trustie Platform or Services – including your login, the ID of the device you use (e.g. mobile, tablet, laptop and any other devices), internet protocol (IP) address, location (approximate location based on IP address, unless you choose to enable precise location on your device), browser type you use and the version, plug-in types, operating system and platform.
• Any information on how you use our Trustie Platform or Services
• Any information we request relating to marketing and communication – including your preferences for marketing purposes, and any third parties and how you would like us to communicate with you
• Identification documents – proof of identification including passport, driving licence, national insurance card and proof of address utility bills, bank statement and Liveness video
• Data from 3rd parties including identity and verification information from fraud prevention agencies, data from partner merchants, basic profile or contact details from social media only if you choose to interact with us on those channels (for example, if you message our support team). We do not automatically pull detailed behavioural data from your private social media accounts.
• Contacts (if you choose to share them). If you choose to enable this feature, we may access and upload contact details from your phone (such as name, email address, and phone number) so you can invite people or connect with others on Trustie. We use this data only for the purpose shown to you at the time. You can turn this off at any time in your device/app settings. Please only share contact details where you have permission to do so.
• We may also process certain special categories of information for specific and limited purposes, such as detecting and preventing fraud and financial crime, if it is in the wider public interest (for example, to protect customers' economic wellbeing); making our services accessible to customers; reporting of complaints for regulatory purposes.
• Special category data (used only in limited cases). In some situations we may process special category data (for example, health or accessibility information) if you choose to share it with our support team so we can support you. Where we do this, we rely on your explicit consent. We may also process special category data for fraud prevention and financial crime controls where the law allows and appropriate safeguards apply under the Data Protection Act 2018. We will only use special category data for the specific purpose it was collected for. This may include information concerning your health or vulnerability (only where you voluntarily disclose this to our support team so we can provide extra assistance).
• Where you have provided your consent for us to process your special category data, such as biometric data, you can withdraw it at any time by contacting us.

We may be unable to provide you with our Trustie Platform or Services if we do not get personal data, we require from you by law or if we require it for contractual purposes. We will make sure we tell you when we need it and let you know that if you don't provide it, why we will have to refuse or cancel any use of the Trustie Platform or Services with you.

Any data that doesn't directly or indirectly reveal your personal identity is not personal information about you and we sometimes will collect, use and share this type of information which we call Aggregated Data. If we connect this data to your personal information and we can identify you from it, then it is personal information which we will use for the purposes of our Privacy Policy.

How we get your personal information and why we have it

Most of the personal information we process is provided to us directly by you (as detailed below) and we have also set out the reasons why we need to collect it.

When you interact with us directly by:

• inputting any information into our systems, including registration, we collect personal information
• inputting any information into the Trustie forum
• fill in any forms and surveys
• connect your accounts (UK bank accounts, saving accounts, credit cards, investment accounts, pensions, financial accounts)
• write to us, contact us via our website, Trustie Platform, email, phone or contact us through any other means
• create any accounts on our Trustie Platform
• apply for our Services, products or anything else we have on our Trustie Platform
• subscribe to our marketing list
• subscribe to our service or publications
• participate in our promotions, competition, or surveys and give any feedback
• Following or subscribed to any of our 3rd party social media accounts

We collect technical data when you directly interact with us through our technology and automated technologies including our Trustie Platform and Services by automatically recording personal data through:

• your browsing history
• the device you are using
• using cookies and we also use cookies to gain data about other websites you are visiting, see our Cookie Policy for more information
• open banking technologies
• any server logs

We collect data on your transactions when you:

• carry out any payment transactions on our Trustie Platform or Services
• carry out any spending transactions
• make any payments into your account
• any transactions made via linked financial accounts (open banking)
• Trustie gift card transactions

We also receive personal information indirectly, from the following sources in the following scenarios, which are from any third parties (which may be based in the UK or and/or outside the UK and the EEA) – and public sources that are available to us and include:

• analytical providers which may give us data (e.g. Google)
• delivery services for open banking and gift cards
• any payment, technical and delivery services
• data from data brokers and aggregators which include anti-money laundering checkers
• public sources which can help us verify your identity including the Electoral Register, address verification at Royal Mail Group Ltd, Communication Provider Databases
• parties who send money to and from you using our Trustie Platform or Services which include their identity, contact and any financial information

If we receive your personal data from a third party, we will tell you what we received and where it came from where required by law (unless a legal exemption applies, for example where providing this information would prejudice the prevention or detection of crime).

We use the information that you have given us in order to:

• provide you with a service(s) and/or when you use our Trustie Platform
• ensure we can enter into a contract with you to provide services
• provide you with our Services on our Trustie Platform which includes financial products, making payments, fees and charges
• ensure we can process and deliver payment requests from your bank accounts
• contact you if we need to provide any information about the Trustie Platform and/or Services
• send you marketing about Trustie where you have opted in, or where 'soft opt-in' applies under PECR (you can opt out anytime). See 'Marketing and cookies' below.
• making recommendations as to how to budget effectively to achieve your goals

We may share anonymised information with the brands we have partnered with to ensure any marketing or promotion is appropriate to any customers.

If we change the reason as to why we are using your personal information, and it is not related to the original reason as to why we collected it, we will notify you and provide you with an explanation of why the law permits us to do so. However, we will not inform you if we reasonably believe the change of purpose is related to our original reason or permitted or required by the law.

Sharing your personal data

There are times when we share your personal data with other parties and the reasons as to why we do (as detailed above). We may need to share your personal information with other companies who will act as processors or joint controllers within our Trustie Group of companies (where joint services are performed for the group of companies e.g. IT and administration services), any agencies and organisations that assist with business functions and running our business (e.g. web hosting, CRM provider) including Tillo for Trustie gift cards and Salt Edge and Nuapay (provider of Open Banking services AIS and PIS), professional advisors (e.g. solicitors, auditors, insurers, consultants and bankers), any organisations assisting in providing checks for Trustie (e.g. anti-money laundering), legal regulators and authorities including HM Revenue & Customs and other authorities. If we decide to restructure, seek funding or sell (part or all of), transfer, or merge our business or any assets, we may need to share your personal information with such companies and we will ensure such companies are bound by confidentiality terms and conditions, which bind them in accordance with this policy and our instructions.

Legal Right to Process Information

Under UK GDPR, we rely on the following lawful bases to process your personal data (details are in Schedule 1):

• (a) Consent (for example, where you opt in to receive marketing). You can withdraw consent at any time (see "Marketing" and "Your rights").
• (b) Contract (we need your data to provide the Services you sign up for).
• (c) Legal obligation (for example, identity checks and anti-fraud controls).
• (d) Legitimate interests (where we have a genuine business reason and it does not override your rights—see below).

When we rely on legitimate interests, we have considered the impact on your privacy rights and balanced them against our business needs. You can object to processing based on legitimate interests at any time (see "Your data protection rights").

Marketing

You can choose whether to receive marketing from Trustie. We will only send you marketing by email or SMS if:

• you have opted in, or
• the "soft opt-in" applies (for example, if you signed up for Trustie and we're marketing our own similar products or services, and you were given a clear chance to opt out when we collected your details and in every message).

You can opt out at any time by using the 'unsubscribe' link in emails, replying STOP to SMS (where available), or updating your settings in the App. Opting out won't affect essential service messages (like important accounts or security updates).

We will not send you third-party/partner marketing by email or SMSunless you have clearly opted in.

Cookies and similar technologies

We use cookies and similar technologies to:

• make our website and app work (for example, to keep you signed in),
• keep them secure, and
• if you choose, help us understand how they're used (analytics) and personalise content.

We only use non-essential cookies (such as analytics, advertising, or personalisation cookies) if you opt in through our cookie banner. You can change your choices at any time using the cookie settings link in the banner (or in our website/app settings, where available).

For more detail and a list of cookies, see our Cookie Policy.

How we store and keep your personal information secure

Your information is securely stored. The measures we have in place ensure that your personal data is not used, given to or accessed by anyone who does not have authority to do so. We also make sure we don't accidentally lose your data, or that it is not changed without us being aware of it. Your personal information is only accessed by those in our organisation who are entitled to view it for business reasons. There are a number of processes and procedures we put in place to limit which other parties can view your personal information for business purposes.

Data Retention

We retain your personal, financial and technical data for as long as you have an account with us, and for a period of 6 years after you close your account. This allows us to comply with our legal, tax, and anti-money laundering reporting requirements. When retention periods expire, we delete or anonymise your data. Some data may remain in secure backups for a limited period. We may also keep certain data for longer where required by law or to establish, exercise, or defend legal claims.

International Transfers

Sometimes we (or our third-party service providers) may process your data outside the UK and the European Economic Area (EEA). When we do this, we ensure your data gets the same level of protection as it does in the UK. We do this by ensuring the recipient country has an 'Adequacy Decision' from the UK Government, or by signing UK Government- approved contracts called the 'International Data Transfer Agreement' (IDTA) or the 'UK Addendum' to the EU Standard Contractual Clauses. You can request a copy of our relevant transfer safeguards (such as the IDTA or UK Addendum) by contacting privacy@trustie.co.uk.

Your data protection rights

You have rights including:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to correct personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to delete your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances including to direct marketing at any time.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
  You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. However, if your request is unreasonable or excessive we may charge a reasonable fee in such circumstances and we may take longer than one month to fulfil such a request, but we will aim to fulfil your request within a reasonable time period.
  Please see our contact details above if you wish to make a request. To help us process your request, please tell us which right you want to use and provide enough information for us to help (for example, the email address linked to your account). We may ask for proof of identity to protect your data.
• Your right to withdraw consent – If we rely on your consent, you can withdraw it at any time. This won't affect the processing we carried out before you withdrew consent.
• Your rights relating to automated decision-making – You have rights if a decision is made about you purely by automated means and it has legal or similarly significant effects (we will tell you if this applies).
• Your Right to Complain – If you have any concerns about our use of your personal information, you can make a complaint to us at:
  • Email: privacy@trustie.co.uk
  • Write to us at: Trustie Technologies, Omagh Business Complex, Cortrush Industrial Estate , Great Northern Road, Omagh BT78 5LU Northern Ireland
  • Phone us: +44 28 8230 6422

We aim to respond to complaints as quickly as possible, and we will keep you updated on progress.

You can also complain to the ICO if you are unhappy with how we have used your data. We would like an opportunity to resolve your complaint in the first instance and would like you to contact us first, if possible.

Information Commissioner's Office (ICO)

The ICO's address:

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Trustie's ICO Registration number is ZB628293

Schedule 1 – Schedule of Purposes of Processing

We would like you to fully understand the legal reasons as to why we use and share your personal information in our business and have set these out in the sections below.

SUMMARY

Special category data (limited cases): If you choose to share health/accessibility information with support, we process it with your explicit consent. We may also process special category data for fraud/financial crime controls where the law allows and safeguards apply under the DPA 2018.

Contractual necessity

We require certain information to enter into a contract with you and to effectively deliver the Trustie Platform and associated services. If you choose not to provide this necessary data, we may be unable to open your account or continue providing our services to you.

• Data Processed: To provide our services, we collect and process information from your application form, transaction and payment data (including transfers between your accounts, sub-accounts, and other accounts), and any necessary documentation required to act on your instructions. We also process records of our communications with you (which may be recorded and monitored) and, where applicable, the age of individuals for whom you open sub-accounts to ensure they are placed on age-appropriate versions of the Trustie Platform.
• Legal Basis: The legal basis for processing this data is contractual necessity. This information is strictly required for us to enter into and perform our contract with you. This includes setting up and managing your accounts, processing your transactions, resolving queries or complaints, keeping you updated on service changes, and managing our ongoing relationship.
• Third-Party Processors: In order to manage, maintain, and continually improve the Trustie Platform and services, we may share your necessary information with other companies within our corporate group, who process this data on our behalf.
• Your Right to Opt-Out: Because the processing of this specific data is necessary to fulfill our contract and operate your account, you generally do not have the right to opt out of this processing while using our services. If you wish to stop this data processing, you would need to close your account(s) and terminate your contract with us.

Legal Obligations

We require certain information from you to comply with strict legal and regulatory requirements. If we do not receive this personal data, we are legally prohibited from opening your account and cannot provide or continue to provide the Trustie Platform and Services to you.

• Data Processed: To meet our legal requirements, we collect and process identity verification information (which may include voice-recognition technology and biometric data), transaction records, and location data. We may also process information regarding criminal convictions, offenses, fraud, and security threats. Furthermore, we process internal reports for risk management, data quality assessments, emergency incident logs, and records of mandatory legal communications sent to you.
• Legal Basis: The primary legal basis for processing this data is compliance with a legal obligation. We are bound by laws relating to fraud prevention, anti-money laundering, terrorist financing, bribery, international sanctions, and corruption. This legal obligation also covers monitoring transactions, correcting service errors, conducting formal internal investigations, managing litigation, and sending mandatory terms and updates. Note: Where we specifically use biometric or voice-recognition data to verify your identity, we do so on the additional legal basis of your explicit consent.
• Third-Party Processors: We are legally required to share your data with specific external organisations and authorities. This includes the police, tax authorities, law enforcement, government agencies, fraud prevention agencies, and regulatory bodies (for example, to report suspicious activity or comply with court orders). We also share necessary data with banks and other relevant third parties to reclaim any money that was incorrectly applied to your account due to an error.
• Your Right to Opt-Out: Because this data processing is mandated by law to prevent financial crime and ensure regulatory compliance, you do not have the right to opt out of it while using our services. However, because we rely on your consent specifically for the use of voice-recognition and biometric data, you may opt out of those specific identity verification methods at any time (though we will still be legally required to verify your identity using alternative documentation).

Legitimate Interests

We process your information when it is necessary to pursue our legitimate business interests, or those of a relevant third party, provided these interests are not overridden by your fundamental rights and freedoms. This processing supports our ability to run our business, improve our services, and proactively manage risk.

• Data Processed: To support these operations, we process a broad range of information. This includes physical and IT security data (such as CCTV footage, network access logs, and disaster recovery logs), operational data (accident and emergency reports), and customer interaction data (recorded communications, feedback, and complaint records). We also analyse your transaction history, financial profile, and data from third-party services you use, alongside screening data (such as checks against external fraud databases, sanctions lists, and registries of Politically Exposed Persons).
• Legal Basis: The legal basis for this processing is our legitimate interests. Specifically, we rely on this basis for the following purposes:
  • Running and Managing Our Business: Ensuring the physical security of our premises and the cybersecurity of our IT networks, maintaining business continuity, facilitating internal accounting and regulatory reporting, and managing business reorganisations, transfers, or sales.
  • Developing and Improving Services: Analysing customer usage, errors, and complaints to improve the Trustie Platform, compensating customers for service failures, identifying new business opportunities, and sending relevant marketing communications (where legally permitted and aligned with your preferences).
  • Managing Risk: Proactively preventing, detecting, and investigating fraud, money laundering, terrorist financing, and other financial crimes, as well as conducting internal financial risk assessments and responding to threats.
• Third-Party Processors: To fulfill these legitimate interests, we may share your information with specific third parties. This includes law enforcement agencies, fraud prevention organisations, banks, and regulatory bodies for intelligence gathering and crime prevention. We may also share data with other companies within our corporate group, carefully selected partner companies (for relevant marketing or service improvements), and prospective buyers or relevant parties in the event of a business sale or reorganisation.
• Your Right to Opt-Out: You have the right to object to our processing of your personal data when it is based on legitimate interests. You have an absolute right to opt out of any processing for direct marketing purposes at any time. For other processing activities (such as network security or fraud prevention), you may submit an objection; however, we may continue to process your data if we can demonstrate compelling legitimate grounds that override your rights, or if the processing is necessary to establish, exercise, or defend legal claims.

Consent or "soft opt-in" - Direct Marketing

We use your personal data to send you updates, exclusive offers, and news regarding Trustie's own products and services.

• Data Processed: We collect and utilise your contact details, marketing preferences, and limited usage data. This allows us to personalise and tailor our communications to your interests.
• Legal Basis: We process this data based on your explicit consent or the "soft opt-in" exemption under the Privacy and Electronic Communications Regulations (PECR). The soft opt-in applies if you are an existing customer or have previously engaged with us, allowing us to promote our own similar products and services to you.
• Third-Party Processors: To deliver these communications securely, we share your information with trusted third-party email and SMS providers. These providers act strictly as data processors on our behalf; they are authorised only to send our messages and are strictly prohibited from using your data for their own purposes.
• Your Right to Opt-Out: You retain full control over your inbox and can opt out of direct marketing at any time. You can do this by clicking the "unsubscribe" link in our emails, replying "STOP" to SMS messages, or updating your notification preferences directly within the Trustie app settings. We never use the soft opt-in rule to send you third-party marketing.

Consent - Partner and Third-Party Marketing

You have the option to receive promotional offers and news from our carefully selected partners via email or SMS.

• Data Processed: If you opt in, we process your contact details and specific marketing preferences to facilitate these communications.
• Legal Basis: Unlike our direct marketing, the legal basis for processing your data for partner marketing relies entirely on your explicit consent. We will never send you partner-related marketing or third-party offers unless you clearly and actively opt in to receive them.
• Third-Party Processors: When you provide consent, your details may be securely shared with designated partners or marketing providers strictly for the purpose of delivering those specific offers.
• Your Right to Opt-Out: You may withdraw your consent for partner and third-party marketing at any point using the same opt-out methods outlined above.

Definitions

• Services: All services we offer on the Trustie Platform including the Ask Service, Rewards Service, Gift Cards Service, Saving & Spending Service and any other services we provide.
• Terms: These terms and conditions outlined in the Terms and Conditions agreement.
• Trustie: Trustie Technology Limited a UK-based company (registration number NI653889)
• Trustie App or App: The Trustie mobile application
• Trustie Platform: The Trustie App and the Website used to access the Services.
• Trustie Profile or Profile: The profile a Trustie User sets up via the Trustie Platform to access the Service
• Trustie User: A registered user of the Trustie Platform
• Website: The Trustie website at www.trustie.co.uk