GDPR Compliance

General Data Protection Regulation Policy

Introduction

Trustiry (operated by Bolrach Technologies Limited) is committed to protecting and respecting your privacy in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679.

This GDPR Compliance Policy explains how we collect, use, store, and protect your personal data, and your rights under GDPR.

Data Controller

Bolrach Technologies Limited
Email: privacy@trustiry.com
Data Protection Officer: dpo@trustiry.com

Legal Basis for Processing

We process personal data under the following legal bases:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contract: Processing is necessary for a contract you have with us
• Legal Obligation: Processing is necessary for compliance with the law
• Legitimate Interests: Processing is necessary for our legitimate interests or the legitimate interests of a third party

Your Rights Under GDPR

Under GDPR, you have the following rights:

1. Right to Access

You have the right to request copies of your personal data. We may charge a small fee for this service.

2. Right to Rectification

You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

3. Right to Erasure

You have the right to request that we erase your personal data, under certain conditions.

4. Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data, under certain conditions.

5. Right to Object to Processing

You have the right to object to our processing of your personal data, under certain conditions.

6. Right to Data Portability

You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.

Data We Collect

• Personal identification information (Name, email address, phone number)
• Account credentials
• Review content and ratings
• Technical data (IP address, browser type, device information)
• Usage data (how you use our website)
• Marketing and communications preferences

How We Use Your Data

We use your personal data for:

• Providing and maintaining our service
• Managing your account and registration
• Authenticating reviews and preventing fraud
• Communicating with you about our services
• Improving our platform and user experience
• Complying with legal obligations
• Sending marketing communications (with your consent)

Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Regular security assessments
• Access controls and authentication
• Staff training on data protection
• Incident response procedures

Data Retention

We retain personal data only for as long as necessary for the purposes set out in this policy, unless a longer retention period is required or permitted by law.

Account Data: Retained while your account is active and for 30 days after account deletion
Review Data: Retained indefinitely for platform integrity unless deletion is requested
Transaction Data: Retained for 7 years as required by law

International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Compliance with GDPR requirements

Cookies and Tracking

We use cookies and similar tracking technologies. You can control cookies through your browser settings. For more information, see our Cookies Policy.

Third-Party Services

We may share your data with third-party service providers who assist us in operating our platform, conducting our business, or serving our users. These parties are contractually obligated to protect your data.

Children's Privacy

Our service is not intended for individuals under 16 years of age. We do not knowingly collect personal data from children under 16.

Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware of the breach.

How to Exercise Your Rights

To exercise any of your GDPR rights, please contact us at:

• Email: privacy@trustiry.com
• Data Protection Officer: dpo@trustiry.com

We will respond to your request within one month. If your request is complex or we receive multiple requests, we may extend this period by two further months.

Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local supervisory authority.

For the UK: Information Commissioner's Office (ICO) - https://ico.org.uk
For EU: Your national data protection authority

Changes to This Policy

We may update this GDPR Compliance Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last Updated" date.

Last Updated: November 1, 2025

Contact Us

If you have any questions about this GDPR Compliance Policy, please contact us:

• Email: privacy@trustiry.com
• Data Protection Officer: dpo@trustiry.com
• Website: https://trustiry.com/contact-us