Privacy Policy

C/O Arthur G Mead Ltd, 4th Floor, Fitzrovia House, 153-157 Cleveland Street, London, W1T 6QW, United Kingdom 

1 INTRODUCTION

1.1 Important information and who we are 

Welcome to Trigg Digital Ltd’s Privacy and Data Protection Policy (“Privacy Policy”). 

At Trigg Digital Ltd (“we”, “us”, or “our”), a company incorporated in England and Wales with company number 12095839, whose registered office is C/O Arthur G Mead Ltd, 4th Floor, Fitzrovia House, 153-157 Cleveland Street, London W1T 6QW, we are committed to protecting and respecting your  privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and  regulations of the United Kingdom. 

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy  Policy will tell you about your privacy rights, how the law protects you, and inform our  employees and staff members of all their obligations and protocols when processing data. 

The individuals from which we may gather and use data can include: 

• Customers 
• Suppliers 
• Business contacts 
• Employees/Staff Members 
• Third parties connected to your customers 
• and any other people that the organisation has a relationship with or may need to contact. 

This Privacy Policy applies to all our employees and staff members and all Personal Data  processed at any time by us.

1.2 Who is Your Data Controller 

Trigg Digital Ltd is your Data Controller and responsible for your Personal Data. We are not  obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed  one at this time. Therefore, any inquiries about your data should either be sent to us on email at privacy@triggdigital.com or sent in a letter to Trigg Digital C/O Arthur G Mead Ltd, 4th Floor, Fitzrovia House, 153-157 Cleveland Street, London W1T 6QW, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office  (ICO), the UK supervisory authority 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. 

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you 

In discharging our responsibilities as a Data Controller we have employees who will deal with  your data on our behalf (known as “Processors”). Therefore, the responsibilities described  below may be assigned to an individual, or may be taken to apply to the organisation as a  whole. The Data Controller and our Processors have the following responsibilities: 

Ensure that all processing of Personal Data is governed by one of the legal bases laid  out in the GDPR (see 2.2 below for more information on those bases); 

Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of  confidentiality; 

Implement appropriate technical and organisational measures to ensure a level of  security appropriate to the risk associated with the processing of Personal Data; 

Obtain the prior specific or general authorisation of the Controller before engaging  another Processor; 

Assist the Controller in the fulfilment of the Controller’s obligation to respond to  requests for exercising the data subject’s rights; 

Make available to the Controller all information necessary to demonstrate compliance  with the obligations laid down in the GDPR and allow for and contribute to audits,  including inspections, conducted by the Controller or another auditor mandated by the  Controller; 

Maintain a record of all categories of processing activities carried out on behalf of a  Controller; 

Cooperate, on request, with the supervisory authority in the performance of its tasks; 

Ensure that any person acting under the authority of the Processor who has access to  Personal Data does not process Personal Data except on instructions from the Controller; and 

Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2 LEGAL BASIS FOR DATA COLLECTION 

2.1 Types of Data / Privacy Policy Scope 

“Personal Data” 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). 

We may collect, use, store and transfer different kinds of Personal Data about you which we  have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from  you: 

Profile/Identity Data: This is data relating to your first name, last name, gender, date of  birth. 

Contact Data: This is data relating to your phone number, addresses, email addresses,  phone numbers. 

Marketing and Communications Data: This is your preferences in receiving marketing  information and other information from us. 

We do not collect any Special Categories of Personal Data about you (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). Nor do we collect any information about criminal convictions and offences. 

2.2 The Legal Basis for Collecting That Data 

There are a number of justifiable reasons under the GDPR that allow collection and processing  of Personal Data. The main avenues we rely on are: 

“Consent”: Certain situations allow us to collect your Personal Data, such as when you  tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’  to a service. 

“Contractual Obligations”: We may require certain information from you in order to  fulfil our contractual obligations and provide you with the promised service. 

“Legal Compliance”: We’re required by law to collect and process certain types of data,  such as fraudulent activity or other illegal actions. 

“Legitimate Interest”: We might need to collect certain information from you to be  able to meet our legitimate interests – this covers aspects that can be reasonably  

expected as part of running our business, that will not have a material impact on your  rights, freedom or interests. Examples could be your address, so that we know where to  deliver something to, or your name, so that we have a record of who to contact moving  forwards.

3 HOW WE USE YOUR PERSONAL DATA 

3.1 Our Uses 

We will only use your Personal Data when the law allows us to. Set out below is a table  containing the different types of Personal Data we collect and the lawful basis for processing  that data. Please refer to section 2.2 for more information on the lawful basis listed in the  table below. 

Examples provided in the table below are indicative in nature and the purposes for which we  use your data may be broader than described but we will never process your data without a  legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

3.2 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. 

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 How Does Trigg Digital Ltd Protect Customers’ Personal Data? 

We are concerned with keeping your data secure and protecting it from inappropriate  disclosure. Any Personal Data collected by us is only accessible by a limited number of  employees who have special access rights to such systems and are bound by obligations of  confidentiality. If and when we use subcontractors to store your data, we will not relinquish  control of your Personal Data or expose it to security risks that would not have arisen had the  data remained in our possession. However, unfortunately no transmission of data over the  internet is guaranteed to be completely secure. It may be possible for third parties not under  the control of Trigg Digital Ltd to intercept or access transmissions or private communications  unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the  security of any Personal Data you transmit to us. Any such transmission is done at your own  risk. If you believe that your interaction with us is no longer secure, please contact us. 

4.2 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other  rights). However, if your request is clearly unfounded, we could refuse to comply with your  request. 

We may need to request specific information from you to help us confirm your identity and  ensure you have the 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. 

4.3 Correcting, updating, accessing or deleting your information

Trigg Digital may retain your information for a period of time consistent with the original purpose of collection and during the time needed to pursue our legitimate business interests, conduct audits or comply with our legal obligations.

By emailing privacy@triggdigital.com, you may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the Company’s website and services.  Requests to access, change or delete your information will be addressed within a reasonable timeframe.

5 YOUR DATA AND THIRD PARTIES 

5.1 Will We Share Your Data With Third Parties? 

We may also share Personal Data with interested parties in the event that Trigg Digital Ltd  anticipates a change in control or the acquisition of all or part of our business or assets or with  interested parties in connection with the licensing of our technology. 

If Trigg Digital Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer,  sell or assign your Personal Data to a third party as part of or in connection with that  transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the  further use of your Personal Data. In all other situations your data will still remain protected in  accordance with this Privacy Policy (as amended from time to time). 

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy. 

5.2 Cookies and other technologies we use

We use the following types of cookies:

• Essential cookies: These cookies are essential to enable you to view the site.
• Google Analytics: We use Google Analytics to measure the number of visitors to our site. The cookies that Google Analytics uses store information about when a visit occurred, which pages were visited and for how long. None of the information provided by Google Analytics is personally identifiable. It is provided to us as anonymous data.
• Social Media: Social Media share buttons are used throughout the site to enable you to share our content through multiple social media channels. We also cookies to track behaviour on our website for Linkedin and Facebook. This data is not personally identifiable. 

6 HOW LONG WILL WE RETAIN YOUR DATA FOR? 

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we  collected it for. We may retain your Personal Data for a longer period than usual in the event of a  complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship  with you.

7 INTERNATIONAL TRANSFER OF DATA 

Your information may be stored and processed in the US or other countries or jurisdictions outside  the US where Trigg Digital Ltd has facilities. We are currently storing data in the EU and so, by using  Trigg Digital Ltd, you are permitting and consenting to the transfer of information, including Personal  Data, outside of the US.

8 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY 

We keep our Privacy Policy under review and will place any updates on this webpage. This version is  dated 12 October 2021. By using Trigg Digital Ltd, you consent to the collection and use of data by us  as set out in this Privacy Policy. Continued access or use of Trigg Digital Ltd will constitute your  express acceptance of any modifications to this Privacy Policy. 

9 INTERPRETATION

All uses of the word “including” mean “including but not limited to” and the enumerated examples  are not intended to in any way limit the term which they serve to illustrate. Any email addresses set  out in this policy may be used solely for the purpose for which they are stated to be provided, and  any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the  right to not respond to emails, even if they relate to a legitimate subject matter for which we have  provided an email address. As a matter of common sense, you are more likely to get a reply if your  request or question is polite, reasonable and there is no relatively obvious other way to deal with or  answer your concern or question (e.g. FAQs, other areas of our website etc.). 

Our staff are not authorised to contract on behalf of Trigg Digital Ltd, waive rights or make  representations (whether contractual or otherwise). If anything contained in an email from a Trigg  Digital Ltd address contradicts anything in this policy, our terms or any official public announcement  on our website, or is inconsistent with or amounts to a waiver of any Trigg Digital Ltd rights, the  email content will be read down to grant precedence to the latter. The only exception to this is  genuine correspondence expressed to be from the Trigg Digital Ltd legal department.