Privacy Policy

1. Introduction

Welcome to Trustoe ("Trustoe", "we", "us", or "our"). Trustoe is a global human-first platform enabling local professionals — such as guides, drivers, hosts, and other local experts — to share trusted local recommendations with travelers through personal public pages and QR codes.

We respect your privacy and are committed to protecting your personal data in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK Data Protection Act 2018 ("UK GDPR"), the California Consumer Privacy Act and California Privacy Rights Act ("CCPA/CPRA"), and other applicable international privacy laws.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you interact with our services.

2. Data Controller and Contact Information

Trustoe acts as the Data Controller for personal data collected from professionals, visitors, and other users of the Trustoe platform.

If you have any questions about this Policy or wish to exercise your rights, please contact us:

If you are based in the EU/EEA or UK, you may also contact our appointed Data Protection Representative or DPO (Data Protection Officer) once designated.

3. Categories of Personal Information We Collect

We collect and process limited personal information necessary to deliver our services effectively and responsibly.

A. For Local Professionals

We may collect:

• Identity details: name, photo, biography, and city or region
• Professional information: area(s) of expertise, role (e.g., driver, guide, fixer), and languages spoken
• Profile content: local tips, images, recommendations, activities, references, and reviews you submit
• Contact information: email address, phone number (optional), or links to social profiles (if provided)
• Account and communication data: messages and correspondence with Trustoe (e.g., onboarding or support requests)

B. For Travelers

We collect minimal, non-intrusive data:

• Device and access information (approximate location, browser type, and device identifiers)
• Page visit metrics (analytics, engagement time, referrer URLs)
• Optional feedback or review content you voluntarily provide

C. Sensitive Data

We do not intentionally collect sensitive data (e.g., ethnic origin, health data, political beliefs). In exceptional cases where such data is submitted voluntarily, it will be processed only with explicit consent and safeguarded appropriately.

4. Legal Bases for Processing (GDPR / UK GDPR)

We process your personal data under one or more of the following lawful bases:

• Performance of a contract – to create and manage your professional profile and provide services you request.
• Consent – when you voluntarily provide information or allow publication of your profile.
• Legitimate interests – to operate and improve our platform securely and efficiently.
• Legal obligation – to comply with applicable laws, regulations, or legal processes.

5. How We Use Personal Data

We use your information for the following purposes:

• To create, review, and publish public profiles for local professionals
• To facilitate onboarding, translation, and quality control
• To provide users with functional access via QR codes and shareable links
• To communicate regarding profile updates, service improvements, and feedback requests
• To maintain the security and integrity of the Trustoe platform
• To perform analytics for service optimization (without profiling individuals)

We do not sell, rent, or trade your personal data for advertising or marketing purposes.

6. Disclosure and International Data Transfers

We may share personal data with trusted service providers (e.g., web hosting, analytics, translation tools, communication platforms) strictly under confidentiality and data processing agreements, with business partners when you explicitly opt in to collaborations or promotions, and with regulatory authorities or law enforcement, when required by law.

When data is transferred internationally (including to countries outside the EU/EEA/UK), we ensure use of Standard Contractual Clauses (SCCs) or equivalent safeguards approved by the European Commission, and diligent assessment of partner compliance with privacy protections.

7. Data Retention

We retain personal information only as long as necessary for the purposes described, including legal, accounting, or reporting obligations. You may request deletion of your data or closure of your profile at any time by contacting [email protected], after which we will securely erase or anonymize your information.

8. Data Security

We employ industry-standard administrative, technical, and physical safeguards to protect your personal data against unauthorized access, loss, or misuse. Although no system is completely secure, Trustoe continuously evaluates and upgrades its practices in line with modern cybersecurity and data protection standards.

9. Your Rights (Under GDPR and Global Privacy Laws)

Depending on your location, you have the following rights:

• Access – to request a copy of your personal data
• Rectification – to correct inaccuracies
• Erasure ("Right to be Forgotten") – to delete your data
• Restriction of Processing – to limit how we use your data
• Data Portability – to receive your data in a structured, machine-readable format
• Objection – to object to processing based on legitimate interest
• Withdrawal of Consent – at any time, without affecting prior lawful processing

To exercise these rights, contact us at [email protected]. We will respond within the timeframes required by applicable law.

10. California and U.S. Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know what personal information we collect and how we use it
• Request deletion of your personal data
• Opt out of the sale or sharing of your data (Trustoe does not sell personal data)
• Exercise your rights free from discrimination

To make a CCPA request, contact us at [email protected] and indicate "California Privacy Rights" in the subject line.

11. Cookies and Similar Technologies

Trustoe uses essential local storage and analytics technologies to operate and improve the platform.

• Essential Local Storage (Device Variables): We use AsyncStorage (a local storage technology) to store "Device Variables" directly on your mobile device. These are strictly necessary for the technical operation of the application, such as maintaining your authentication session, remembering your user preferences, and ensuring account security.
• Data Retention and Control: Information stored via these variables persists on your device's physical storage. While signing out may clear the content of certain variables, the underlying data remains until you manually clear the application's cache through your device settings or uninstall the application.
• Analytics: We may use analytics tools that collect aggregated usage data (e.g., Google Analytics) to improve design and usability.

By continuing to use the site or application, you acknowledge the use of these strictly necessary local storage technologies.

12. Children's Privacy

Trustoe is not directed at individuals under 18 years of age. We do not knowingly collect or process personal data from minors. If you believe we have collected data from a minor, please contact us immediately at [email protected].

13. Changes to this Privacy Policy

We may update this Privacy Policy to reflect operational, legal, or technical changes. When updates occur, we will revise the "Last updated" date at the top and, when required, notify users directly of material changes.

14. Contact and Complaints

To contact our Privacy Office or Data Protection Officer (once appointed):

Email: [email protected]

If you are located in the EU/EEA, you may file a complaint with your local Data Protection Authority (DPA). For UK users, you may contact the Information Commissioner's Office (ICO).

In Summary

Trustoe is built on human trust — that same principle extends to how we handle your personal data. We collect only what's necessary, protect it diligently, and give you full control over it.