trutap

TRUTAP PRIVACY POLICY

Trutap Limited takes the privacy rights of customers and users of its websites and services very seriously and seeks to ensure the highest standards of compliance with UK Data Protection Laws and Regulations. We have an up-to-date entry on the Data Protection Register. This can be seen at http://www.informationcommissioner.gov.uk/.

This Privacy Policy is incorporated in and subject to the trutap Site Terms of Use and the trutap Service Terms. This Privacy Policy explains to you how trutap may use Your Data (as defined in 1.1 below).

By accessing or using trutap's websites and services, or subscribing for a service or opening an account with trutap, you expressly consent to the use of Your Data in accordance with this Privacy Policy.

1. Your Data

1.1 "Your Data" means any information about you which is personally identifiable or otherwise relates to you, including, without limitation, your name, address, date of birth, telephone number, email address, other contact details, financial details, log-in password, personal code, comments, personal descriptions, photos, transactions, call requests and other information from which you can be identified and which you may disclose to us or otherwise via a trutap service at any time.

2. When do We collect Your data?

2.1 We collect Your Data from you when you:

2.1.1 register with trutap and/or create an online profile to receive a trutap service and/or participate in any trutap promotion;

2.1.2 use our services (including sending, storing and presentation of messages, posting entries or making payments);

2.1.3 make a complaint or enquiry to trutap; or

2.1.4 otherwise disclose Your Data to trutap or via a trutap service at any other point.

2.2 We may also receive Your Data from third parties including mobile operators in connection with your use of any trutap service.

3. How do We use Your Data?

3.1 We use Your Data to:

3.1.1 process any application for any services including the administration of messages and accounts that you may have;

3.1.2 carry out relevant security checks;

3.1.3 confirm and investigate any transactions or transfers of monies or credits that may occur in respect of your account and use of our services;

3.1.4 monitor, develop and improve our websites and services;

3.1.5 provide the services to you including enabling storage, presentation, receipt and sending of messages and posting of entries on our websites;

3.1.6 process and deal with any complaints or enquiries made by you;

3.1.7 at our discretion, monitor and investigate any suspected breach of the Site Terms of Use and/or Service Terms or the terms of any Promotion made by or otherwise relating to you or any suspected unlawful activity; and

3.1.8 only where you have given your consent, to send you direct marketing messages containing offers or promotions from trutap and its affiliates or allow carefully selected third parties to do so (in addition to those general advertisements that appear on pages viewed and messages sent and received via our services as discussed in 3.2).

3.2 We may use traffic, location along with elements of Your Data that You choose to provide to us (for example regarding the area in which you live, age or gender and other demographics) for the purpose of tailoring the general advertisements that appear on pages viewed and messages sent and received via our services. You consent to the use of such information and Your Data and to the receipt of such advertising as part of the trutap service since it is the basis on which We are able to make the services available to You at no cost. However, trutap:

3.2.1 allows you to select the elements of Your Data which you give to us for such purposes on registration and via Your Account which you can update via Your Account at any time;

3.2.2 will not pass or sell this data to third parties; and

3.2.3 gives you the option of terminating Your Account and use of the service at any time without charge.

4. Will we pass on Your Data to third parties?

4.1 We may pass Your Data to other parties as follows:

4.1.1 to our employees and agents and partners and affiliates to process your applications and orders and to administer your accounts, transactions, messages and the services provided to you by us now or in the future or any correspondence entered into between you and us, including any marketing activities to which you have consented under paragraph 3.1.8 above;

4.1.2 to carefully selected third parties for any marketing activities to which you have consented under paragraph 3.1.8 above;

4.1.3 in some cases we may use a technical partner to conduct some processing of Your Data on our behalf, including for research purposes, but this is always subject to strict contractual control and subject to UK Data Protection Legislation restrictions;

4.1.4 some general statistical information about visitors and users of our websites and services, sales patterns, traffic volumes and related matters may be passed on to reputable third parties for research and reporting purposes or otherwise but these details will not include information personally identifying you;

4.1.5 in the event that our business is sold or restructured, to the acquiring companies or persons;

4.1.6 we may disclose Your Data to the police, regulatory bodies, enforcement authorities or legal advisers in connection with any alleged criminal offence or unlawful activity or suspected breach of the Site Terms of Use, Service Terms or the terms of any promotion by you;

4.1.7 to third parties in conjunction with carrying out credit and security checks and verifying or investigating any payments or transactions in relation to your accounts.

4.2 Other than in the circumstances outlined in paragraph 4.1 above, we will not provide Your Data to any third party except our group companies without your consent or unless we are required to do so by law. Please note that we will not pass Your Data to third parties for marketing purposes without your consent.

4.3 Always think carefully before disclosing Your Data or other information to other trutap users or otherwise posting Your Data on our websites. It is important that you are aware that any of Your Data or other information which you disclose to another trutap user may then be disclosed on a trutap website by that user. As stated in Clause 8.1 of the Service Terms, we have no responsibility or control over the contents of communications made between trutap users although you can make a complaint about another trutap user as set out in our Code of Practice.

4.4 The trutap Service includes applications, software and other content provided by third parties. We are not responsible for any such applications, software or other content nor are We responsible for the use of Your Data by those third parties. Such use is likely to be governed by independent third party privacy policies and therefore, before you submit any of Your Data using any third party content, We advise to You to read any such privacy policies carefully.

5. Data Security and Transfers

5.1 We endeavour to take all reasonable steps to protect Your Data. All the data collected by us is stored on a secure server. Data held on our servers is encrypted.

5.2 We will not knowingly transfer Your Data outside of the EEA for any purpose other than in connection with the potential storage of data and systems on servers that may be located elsewhere and then always subject to required restrictions in accordance with relevant data protection laws.

5.3 You are responsible for the consequences of you making any of Your Data available to any other users of our services. Please note that if you make Your Data so available, it may be accessible from anywhere in the world.

6. Cookies

6.1 This section only applies to your use of our websites.

6.2 Cookies are small pieces of information stored by your browser on your computer's hard drive. We use cookies on our websites to allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our websites and services. Most web browsers automatically accept cookies, though you do not have to. We do not control the use of cookies by third parties. If you wish to disable cookies then you can do so by readjusting Your browser settings although please note that by disabling cookies you may not be able to register with or use all features of the websites and services.

6.3 For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.

7. Other links

7.1 Please be aware that we may link to other sites that may be accessed by you through any of our web or WAP sites. We are not responsible for the data policies, content or security of these linked sites.

8. Contact Us

8.1 If you have any comments or queries in connection with our privacy policy, please contact us by email at legal@trutap.net, or write to us at Trutap Limited, PO Box 545, Cambridge, CB1 0DG.