This privacy policy applies between you, the User of this Website and Trustist Ltd, the owner and provider of these Websites (see below). TRUSTist Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

2. In this privacy policy, unless the context requires a different interpretation:

• a. the singular includes the plural and vice versa;
• b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
• c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
• d. "including" is understood to mean "including without limitation";
• e. reference to any statutory provision includes any modification or amendment of it;
• f. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Trustist Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

Data collected

4. We may collect the following Data, which includes personal Data, from you:

• a. Name
• b. Job Title;
• c. Profession;
• d. Contact Information such as email addresses and telephone numbers;
• e. IP address (automatically collected);
• f. Web browser type and version (automatically collected);
• g. Operating system (automatically collected);
• h. A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
• i. in each case, in accordance with this privacy policy.

We collect a limited, separate, amount of data for marketing purposes and this is limited to:

• Name
• Company
• Email Address
• Telephone Number

We comply with the Legitimate Interest section of GDPR, further information is given below.

Our use of Data

5. For purposes of the Data Protection Act 1998 and GDPR Trustist Ltd is the "data controller".:

6. We will retain any Data you submit for 12 months.:

7. Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.:

8. All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the clause below (Security).:

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

• a. internal record keeping;
• b. improvement of our products / services;
• c. transmission by email of promotional materials that may be of interest to you;
• d. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;

in each case, in accordance with this privacy policy.

Third party websites and services

10. Trustist Ltd may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain personal Data provided by Users of this Website.

11. Any Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the Data Protection Act 1998.

Links to other websites

12. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

13. Trustist Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of TRUSTist Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

14. We may also disclose Data to a prospective purchaser of our business or any part of it.

15. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Controlling use of your Data

16. Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

17. use of Data for direct marketing purposes; and

18. sharing Data with third parties.

Functionality of the Website

19. To use all features and functions available on the Website, you may be required to submit certain Data.

20. You may restrict your internet browser's use of Cookies. For more information see the clause below (Cookies).

Accessing your own Data

21. You have the right to ask for a copy of any of your personal Data held by Trustist Ltd (where such Data is held). This is known as a Subject Access Request under GDPR.

Security

22. Data security is of great importance to Trustist Ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.

23. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.

24. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

Cookies

25. This Website may place and access certain Cookies on your computer. Trustist Ltd uses Cookies to improve your experience of using the Website and to improve our range of services. TRUSTist Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

26. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.v

27. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Trustist Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

28. This Website may place the following Cookies:

Type of Cookie Purpose

• Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

29. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

30. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

31. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

General

32. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

33. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

34. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

35. This privacy policy is governed by and interpreted according to English law. All disputes arising under this privacy policy are subject to the exclusive jurisdiction of the English courts.

Changes to this privacy policy

36. Trustist Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

Legitimate Interest (GDPR)

37. The Information Commissioners Office (ICO) have produced a checklist for companies like Trustist who wish to market to other companies using the Legitimate Interest section of GDPR. This is reproduced here and includes any notes which are helpful or relevant:

• We have checked that legitimate interests is the most appropriate basis.
• We are satisfied that legitimate interest is the most appropriate basis as gaining opt in is not practical, yet we provide a platform which benefits potential clients and it is in their interests to receive marketing emails from Trustist
• We understand our responsibility to protect the individual’s interests.
• We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision.
• We have completed a legitimate interests assessment (LIA)
• We have identified the relevant legitimate interests.
• The legitimate interests are solely for potential clients, we maintain opt-outs in all our email marketing activity and the data we hold for potential clients is limited and listed above. Legitimate interest does not apply to client data as they have agreed to us holding and processing their data in order for us to provide the services we do.
• We have checked that the processing is necessary and there is no less intrusive way to achieve the same result.
• We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests.
• We only use individuals’ data in ways they would reasonably expect, unless we have a very good reason.
• It is reasonable for individuals who are business owners, marketers and others who are interested in making their marketing activities perform better to receive marketing materials from us in order for them to reach their objectives.
• We are not using people’s data in ways they would find intrusive or which could cause them harm, unless we have a very good reason.
• If we process children’s data, we take extra care to make sure we protect their interests.
• We have considered safeguards to reduce the impact where possible.
• We have considered whether we can offer an opt out.
• We do offer an opt-out in every email that we send to potential clients.
• If our LIA identifies a significant privacy impact, we have considered whether we also need to conduct a DPIA.
• We have considered this and concluded that this is not necessary.
• We keep our LIA under review, and repeat it if circumstances change.
• We include information about our legitimate interests in our privacy information.
• This is the purpose of this section of our Privacy Policy.

Data Captured and Processed When a Review is Left

38. When a client collects a review, there are certain pieces of data which need to be collected in order to prove that the review is a genuine review. This is limited to first name, last name, email address, post code, rating (score), date of the review and comments. When the review is publicly displayed the only information that is shown is the first name, the first letter of the surname and the date of the review, rating and comments. We need to hold this data in case there is any conflict arising from reviews which are left.

39. To request removal of any of your personal data that we might hold about you please email support at [email protected]

You may contact Trustist Ltd by email at [email protected].

22 May 2018