Dated March 2022
Welcome to the Truva Corp privacy statement.
Truva Corp is made up of the following different legal entities; Truva Services Limited, Truva Corporate Administration Limited, Truva Legal Services Limited, Truva Trust Corporation Plc and Truva Trustees Limited (“Truva Corp”). This privacy statement is issued on behalf of the Truva Corp group of companies so when we mention “Truva Corp”, “we”, “us” or “our” in this privacy statement, we are referring to the relevant company in the Truva Corp group responsible for processing your data.
Truva Corp respects your privacy and is committed to protecting your personal data. This privacy statement will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy statement is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy statement.
- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
1. Important information and who we are
Purpose of this privacy statement
This privacy statement aims to give you information on how Truva Corp collects and processes your personal data through your use of this website, including any data you may provide through this website, when you sign up to our newsletter, enquire about becoming or become a client of Truva Corp, email an enquiry to us or when we record you as a noteholder or other investor or related adviser in respect of any transaction to which Truva Corp is a party.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy statement together with any other privacy statement or fair processing statement we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements other notices and privacy policies and is not intended to override them.
Truva Services Limited, part of Truva Corp, is the Controller and responsible for this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
If you have any questions about this privacy statement or our privacy practices, please contact our DPO in the following ways:
- Full name of legal entity: Truva Services Limited
- Email address: [email protected]
- Postal address: 1 Northumberland Avenue, London WC2N 5BW
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy statement and your duty to inform us of changes
We keep our privacy statement under regular review. This version was last updated on the date at the beginning of this statement.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.
2. The data that we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The personal data we collect, use, store and transfer will be the information that you provide about yourself and, if appropriate, about persons connected with you such as your officers, employees or advisors, and will include address, phone numbers and email address and may also include further information from the emails, letters and other communications you send and documents you provide to us.
For clarity we have grouped this data together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title and date of birth.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password and feedback.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
In respect of special category data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) about you, we will require your express consent. In other cases any processing by us of special category data will be on one or more of these bases: (a) necessary for the purposes of carrying out obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law; (b) necessary for the establishment, exercise or defence of legal claims; (c) necessary for the assessment of the working capacity of an employee.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- enquire about becoming or become a client of Truva Corp;
- contact Truva Corp for any reason via email or send any correspondence to Truva Corp;
- create a user profile for the Truva Corp client portal;
- subscribe to our publications or newsletters;
- request marketing to be sent to you; and
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie statement on our website for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- (a) analytics providers such as Google based outside the UK;
- (b) Elementor, WordPress site builder to allow for changes to be made to our website in real time;
- (c) Vimeo, tracking information for videos on our website; and
- (d) YouTube, tracking information for videos on our website.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you or with which you are involved.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation or regulatory obligation.
- Where we have your consent to do so.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To respond to any enquiry you send to Truva Corp via email or by other means||(a) Identity(b) Contact||(a) Legitimate Interests (for running our business)(b) Performance of a contract with you or with which you are involved(c) Necessary to comply with a legal obligation|
|To register you as a recipient of our newsletters and publications or to notify you of up coming events that may interest you||(a) Identity(b) Contact(c) Technical(d) Marketing and communications||(a) Legitimate Interests (to undertake direct marketing to promote our business and services)(b) Consent(see your options on direct marketing in the Marketing section below)|
|To register you as a new client of Truva Corp including KYC and AML checks||(a) Identity(b) Contact||(a) Performance of a contract with you(b) Necessary to comply with a legal obligation|
|To record you as a noteholder or other investor or related adviser in respect of any transaction to which Truva Corp is a party.||(a) Identity(b) Contact||(a) Performance of a contract with you or with which you are involved(b) Necessary to comply with a legal obligation|
|To provide our services to you as a client:(a) Manage payments, fees and charges(b) Collect and recover money owed to us(c) Register documents at Companies House||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)(c) Necessary to comply with a legal obligation|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how clients use our website or services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, client relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which or our services may be relevant for you (we call this marketing).
You will receive marketing communications for example newsletter from us if you have requested information from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the services we provide to you as a client.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
Internal Third Parties
Other companies in the Truva Corp group acting as joint controllers or processors and who are based in the UK.
External Third Parties
- Service providers acting as processors who provide IT and system administration services, such as Clio Manage, Trello, Xero.
- Professional advisors acting as processors including lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- We may disclose your details to credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the UK. However, some of our external third parties service providers may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data to such third party service providers, we request a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• your personal data will only be transferred to countries that have been deemed to provide an adequate level of protection for personal data.
- use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact our DPO on the seatiled set out above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.