Privacy Policy

Privacy policy

Effective Date: 16 May 2025
ICO Registration Number: ZB558189


This Privacy Policy ("Policy") outlines how Trusty Digital Ltd ("we", "us", "our") collects, uses, and protects personal data of individuals ("Users", "you", "your") who access our website at https://trusty.digital ("Site") or utilise our services ("Services"). By using our Site or Services, you acknowledge that you have read and understood this Policy and agree to the processing of your personal data as described herein.


1. Data Controller

1.1. Trusty Digital Ltd is registered in England and Wales under company number 14672896.
1.2. Our registered office is located at 124 City Road, London, United Kingdom, EC1V 2NX Kingdom.
1.3. We are registered with the Information Commissioner's Office (ICO) under registration number ZB558189.
1.4. Our appointed Data Protection Officer (DPO) is Mr. Andrei Perjan. He can be contacted via email at [email protected] or by telephone at +44 7458 149643.


2. Scope of this Policy

2.1. This Policy applies to all personal data collected by us through the Site and Services.
2.2. It encompasses data collected when you browse our Site, create an account, complete Know Your Customer (KYC) verification, and use our Services, including but not limited to token-related functions and communications with us.
2.3. Our Services may provide tools enabling Users to independently generate non-custodial wallets. Such wallets are under the sole control of Users; we do not hold, manage, or have access to the private keys or contents of these wallets. Users are solely responsible for their use.


3. Types of Personal Data Collected

  • Identity Data: Full name, date of birth, nationality.
  • Contact Data: Email address, telephone number, residential address.
  • KYC Data: Government-issued identification documents (e.g., passport, driving licence), facial recognition data (if applicable), and other verification information required by our KYC provider, Withpersona.
  • Technical Data: IP address, browser type and version, operating system, and other technology on the devices you use to access our Site.
  • Usage Data: Information about how you use our Site and Services.
  • Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

4. Legal Bases for Processing

4.1. We process your personal data based on the following legal grounds:

  • Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
  • Contractual Necessity: Processing is necessary for the performance of a contract with you or to take steps at your request before entering into such a contract.
  • Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject.
  • Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests.

5. How We Use Your Personal Data

5.1. We use your personal data for the following purposes:

  • To register you as a new User and manage your account.
  • To facilitate KYC verification through our provider, Withpersona.
  • To provide and manage access to our Services.
  • To communicate with you regarding your account and our Services.
  • To comply with legal and regulatory obligations.
  • To improve our Site and Services through analysis and research.
  • To send you marketing communications, where you have opted in to receive them.

6. Disclosure of Your Personal Data

6.1. We may share your personal data with the following third parties:

  • Service Providers: Including our KYC provider, Withpersona, who process your data on our behalf under strict contractual obligations.
  • Regulatory and Legal Authorities: Where required by law or to enforce our legal rights.
  • Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

7. International Transfers

7.1. Where we transfer your personal data outside the United Kingdom or European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

  • Transferring to countries deemed to provide an adequate level of data protection by the UK government or European Commission.
  • Using Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner's Office.

8. Data Security

  • 8.1. We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.
  • 8.2. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.

9. Data Retention

9.1. We retain your personal data only for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data, and whether we can achieve those purposes through other means.


10. Your Legal Rights

10.1. Under data protection laws, you have rights in relation to your personal data, including:

  • Access: The right to request access to your personal data.
  • Correction: The right to request correction of inaccurate or incomplete data.
  • Erasure: The right to request deletion of your personal data.
  • Objection: The right to object to processing of your personal data.
  • Restriction: The right to request restriction of processing your personal data.
  • Data Portability: The right to request transfer of your personal data to you or a third party.
  • Withdraw Consent: The right to withdraw consent at any time where we are relying on consent to process your personal data.

10.2. To exercise any of these rights, please contact our Data Protection Officer at [email protected].


11. Complaints

11.1. If you have any concerns about our use of your personal data, you can make a complaint to us at [email protected].
11.2. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. Contact details are available at https://ico.org.uk.


12. Changes to This Policy

12.1. We may update this Policy from time to time. Any changes will be posted on this page with an updated revision date.


13. Contact Us

13.1. For any questions or concerns about this Policy or our data practices, please contact:
Data Protection Officer: Mr. Andrei Perjan
Email: [email protected]
Telephone: +44 7458 149643


14. Specific Provisions for United States Residents

14.1. If you are a resident of certain U.S. states, including California, Virginia, or Colorado, you may have additional rights regarding your personal data under applicable state privacy laws such as the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), and the Colorado Privacy Act (CPA).
14.2. These rights may include:

  • The right to know what personal data we collect, use, and disclose.
  • The right to access a copy of your personal data.
  • The right to request deletion of your personal data.
  • The right to correct inaccurate personal data.
  • The right to opt out of the sale or sharing of your personal data (including for cross-context behavioural advertising).
  • The right to limit the use of sensitive personal data (where applicable).
  • The right not to be discriminated against for exercising any of the above rights.

14.3. To exercise any of these rights, please contact us using the contact details set out in Section 13. Only you, or someone legally authorised to act on your behalf, may make such a request.
14.4. We honour recognised universal opt-out mechanisms, including the Global Privacy Control (GPC) signal. If your browser or device sends a GPC signal, we treat this as a request to opt out of the sale or sharing of personal data for that browser or device.
14.5. We do not knowingly collect personal data from children under the age of 13. If we become aware that such data has been inadvertently collected, we will delete it as soon as possible.


15. Cookie Preferences and Tracking

15.1. We use cookies and similar tracking technologies to enhance your experience on our Site, analyse usage patterns, and deliver targeted content.
15.2. You can manage your cookie preferences through our Cookie Management Tool, accessible on our Site. This tool allows you to:
• Accept or reject non-essential cookies.
• Set preferences for different categories of cookies.
• Withdraw consent at any time.
15.3. We respect browser-based opt-out signals, including the Global Privacy Control (GPC). If your browser sends a GPC signal, we will treat this as a valid request to opt out of the sale or sharing of your personal data for that browser or device.



General Disclaimer

THE INFORMATION, CONTENT, AND DOCUMENTS ACCESSED FROM OR THROUGH THE SITE ARE PROVIDED "AS IS," "AS AVAILABLE," WITH "ALL FAULTS," AND ALL WARRANTIES, EXPRESS OR IMPLIED, ARE DISCLAIMED (INCLUDING BUT NOT LIMITED TO THE DISCLAIMER OF ANY IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE). THE INFORMATION AND SERVICES MAY CONTAIN BUGS, ERRORS, PROBLEMS, OR OTHER LIMITATIONS. WE AND OUR AFFILIATED PARTIES HAVE NO LIABILITY WHATSOEVER FOR YOUR USE OF ANY INFORMATION OR SERVICE, EXCEPT AS PROVIDED IN THE USER AGREEMENT. IN PARTICULAR, BUT NOT AS A LIMITATION THEREOF, WE AND OUR AFFILIATED PARTIES ARE NOT LIABLE FOR ANY INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES (INCLUDING DAMAGES FOR LOSS OF BUSINESS, LOSS OF PROFITS, LITIGATION, OR THE LIKE), WHETHER BASED ON BREACH OF CONTRACT, TORT, OR OTHERWISE.