Privacy Policy

Last Updated: December 20, 2023

TrustCo LLC and its affiliated companies (“we,” “us,” “our”) works hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) on which this Privacy Policy is linked (collectively, “Sites”), and any transactions, interactions, or other engagements you might have with us (collectively, “Services”).  

This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use. This Privacy Policy does not apply to our collection, use, or disclosure of Personal Information (as defined below) when acting as a data processor performing services on behalf of our clients. For information about the privacy practices of our clients, please consult their privacy policies.

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Sites and/or Services. If you do not agree with our Terms of Use or this Privacy Policy, you must refrain from using our Sites/Services. By accessing or using our Sites or Services, you agree to our use of your information consistent with our Terms of Use and this Privacy Policy.

ABOUT THIS PRIVACY POLICY

Privacy Policy Changes

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. If we make any material changes to this Privacy Policy, the revised policy will be posted on the Sites with the date of revision. Changes will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide notice, such as by a posting on the Sites or an email to your last known email address, before using your Personal Information in the new way.

Conflict Between this Policy and Laws and Regulations

When federal, state, or local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. The specific requirements of this Privacy Policy apply unless disallowed by applicable laws or regulations. Please be aware that the Sites and Services are subject to the laws of the United States of America and that your Personal Information will be processed in the United States and other jurisdictions. The Sites and Services are intended for use by individuals in the United States.

INFORMATION WE COLLECT

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Unique Identifiers and Contact Information such as name, social media identifiers, mailing address, billing address, email address, phone number;
• Financial Information such as credit card or bank account information;
• Characteristics of Protected Classifications such as age, gender, race, ethnicity, national origin, military or veteran status;
• Commercial Information such as the type of real estate you own, whether you rent or own real estate,dwelling age, size and type, mapping information, photos and satellite imagery, details about the home or building’s structure, information related to the financing of properties that your own;
• Internet and Network Information such as IP address, device ID, browsing/search history, browser type, device type and settings;
• Audio/Visual Information such as images, call recordings;
• Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., consumer response models, propensity to purchase models).

The specific Personal Information we collect about you may vary based on how you use the Sites and/or Services and your relationship with us.

Usage Data and Sites Activity

We automatically collect information in connection with the actions you take on the Sites (“Usage Data”). For example, each time you visit our website, we may automatically collect the type of web browser you use, the type of device you use, the type of your operating system, the name of your Internet Service Provider, the pages you view on our Sites, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites. If this information is reasonably capable of being associated with you, we treat it as Personal Information under the category Internet and Network Information. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you explicitly consent to our recording and retention of communications.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, and credit card or bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact. 

HOW WE COLLECT INFORMATION

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us (online or offline), use the Sites or Services, enter into a relationship with us, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or Services or we may not be able to fulfill your requested interaction.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as data brokers, marketing/advertising agencies, financial institutions, and government agencies.

Social Media

If you engage with us via social media, use your social media credentials to access the Site or Services, or interact with social media buttons or widgets embedded in our Sites or Services, we may collect Personal Information available on your social media profile and Usage Data. For information about privacy controls available through your social media provider, please visit their website.

Cookies and Other Automated Tools

We use cookies (a small text file placed on your computer) and other automated tools such as tracking pixels to improve the experience of the Sites and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can change your web browser to refuse all cookies or to indicate when a cookie is being sent. Please consult your web browser’s help section or similar resource for Instructions on how to manage cookies in your browser. However, certain features of the Sites and Services may not work properly if you delete or disable cookies.

We use the following types of cookies:

• Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Sites and Services and are typically deleted once you close your browser. 
• Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Sites and Services. For example, persistent cookies may allow us to remember your preferences and provide you with personalized content.
• Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
• Analytics Cookies: Analytics cookies help us understand how our Sites and Services work and who is visiting our Sites or using our Services. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Policy.
• Functional Cookies:Functional cookies allow our Sites and Services to work as intended such as by allowing us to recognize and honor your login and take other actions for authentication and security. 

We also employ web beacons, local shared objects (sometimes referred to as “flash cookies”), and other technologies that enable us to track certain aspects of a user’s visit to the Sites and use of the Services. For example, web beacons generally consist of an object embedded on a webpage or in an email that is invisible to the user but allows us to understand whether a user has viewed a particular webpage or email and to deliver certain Services. Web bacons typically help us collect Usage Data such as the time and date of a page or email view and a description of the page or email viewed. 

If you arrive at the Sites or Services by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching that led you to our Sites, may be transmitted to us and we may use it. You should review the privacy policy of any website from which you reached the Sites or Services to determine what information was collected by that website and for what purposes you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Interest-Based Advertising

We work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you our ads or other of our content that we believe would be relevant to you. Advertisers may also show you third-party ads or content when you engage with our Sites. Advertisers may collect and use information about your use of the Sites or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information, including across time, devices, and websites. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Sites, on third-party websites, or on social media properties. Using a tool created by the Network Advertising Initiated, you can opt out of several Advertisers’ activities. For more information, please visit the Network Advertising Initiative or the Digital Advertising Alliance (“DAA”) Consumer Choice Page. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Please note that opt-outs only apply to interest-based advertising and not all advertising networks participate. You may still receive other types of online advertising.

Information from Advertisements

If you arrive at the Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date, and time).

THIRD PARTIES THAT COLLECT INFORMATION ON OUR SITES

Certain third parties, including but not limited to those identified below, collect Personal Information and/or Usage Data from users of our Sites using automatic information collection tools such as APIs, cookies, and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their respective privacy policies. 

Session Replay Software

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. This information may also include recording of a user’s interaction with the website such as mouse and keyboard inputs and mobile gestures. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

HOW WE USE AND SHARE INFORMATION 

Generally

We use Personal Information for internal purposes, including:

• Provide the Sites and Services;
• Account creation, fulfillment, servicing and customer support: such as to create user accounts, provide products or services, keep users informed about the status of products and services, respond to questions and address user concerns, and deliver updates, upgrades, and product improvement information; 
• Marketing and market research: such as to send communications and offers and place advertisements, perform analytics for market research, trend analysis, and financial analysis;
• Other company communications: such as to provide individuals and organizations with information that may be of interest such as company newsletters and announcements;
• Sites and Services use and analytics: such as to provide you with access to and use of our Sites and Services, and to analyze use of our Sites and Services including through use of third-party web analytics services which may utilize automated technologies to collect data (such as email and IP addresses);
• Product research: such as to conduct research and analysis for maintaining, protecting, and developing our products and services, increase and maintain the effectiveness of our products and services, and prevent misuse;
• Business operations: such as to evaluate, develop, and improve business operations, products and services offered, and perform business administration and other normal business activities;
• Compliance: such as to comply with applicable legal requirements, government requests, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights or the rights of others; and
• Information security and fraud prevention: such as to operate information security and anti-fraud programs.

Text Message Registration 

We may use your Personal Information and other information such as Usage Data to register your text message campaigns with third parties in accordance with industry standards, carrier requirements, and/or legal requirements. By signing-up for our Services, you direct us to disclose your Personal Information and other information to third parties for the purpose of registering your text message campaigns.

Testimonials 

If you provide a testimonial, we may post it publicly on the Sites or in other advertising material. By providing a testimonial, you give us permission to use it and your likeness in any manner and for any purpose, including in marketing and advertising communications, without any compensation or notice to you. 

Service Providers

We may establish a relationship with other businesses to provide services to us which may include corporate affiliates (“Service Providers”), including for:

• Provision of the Sites and Services;
• Facilitating marketing, non-marketing, and internal communications;
• Marketing design, development, and management;
• Business analytics (both marketing and non-marketing related);
• Project management and collaboration;
• IT and network administration such as data storage and management, website hosting, data security, mobile application development; 
• Payment processing;
• Professional services such as legal and accounting; 
• Obtaining legal records;
• Collection of accounts; and
• Day-to-day business operations such as courier services, facilities management, electronic signatures, and document destruction.

We only provide our Service Providers with the Personal Information reasonably necessary for them to perform these services on our behalf. You may also be asked to provide Personal Information directly to a Service Provider. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified or permitted by us. 

We may share any of the types of Personal Information collected with one or more Service Providers.

Your California Privacy Rights

We may share Personal Information with third parties such as our clients for their direct marketing purposes. If you are a resident of California, you may opt-out of having your Personal Information shared with third parties for their direct marketing purposes by letting us know by sending us an email at support@trustco.ai.  

OTHER PRIVACY AND SECURITY PROVISIONS

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use, both in transit and at rest. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.

Other Websites 

Please be aware that third-party websites accessible through the Sites or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties before providing information.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our sole discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands, and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. 

How Long We Retain Your Data

We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes but is not limited to retention to comply with our legal, regulatory, tax, and/or accounting obligations. 

Children’s Privacy 

The Sites and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records. 

California “Do Not Track” Disclosure

“Do Not Track” is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “Do Not Track” signals.

Messaging Privacy Policy

This Messaging Program Privacy Policy explains how TrustCo LLC collects and uses information about you in relation to its text message marketing program (the “Messaging Service”). We use a third-party service to provide the Messaging Service to you. For the purposes of the Messaging Service, Launch Control acts as our service provider and data processor of your information.

Collection of Information

We collect various information on our behalf from and about you, including information you directly provide when you use the Messaging Service. For example, we collect the phone number and email address you provided when signing up for the Messaging Service. When you send messages via the Messaging Service, we will also collect your messaging history and any information included in those messages. We may also collect information about you using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your device. Cookies enable personalization of your experience on the Messaging Service (e.g., sending you personalized text messages such as shopping cart reminders). If you participate in a contest, sweepstakes, research study, or email survey associated with the Messaging Service, we will collect basic contact information and any other information you choose to provide in connection with these activities. We will also collect your contact information if you contact us with questions about the Messaging Service or for customer service.

Use of Information

We use your information to deliver, analyze, maintain, and support the Messaging Service. We may also use your information to enhance the Messaging Service features and customize and personalize your experiences on the Messaging Service.

Sharing of Information

We may share, transfer, or disclose your information, if you consent to us doing so, as well as in the following circumstances:

• Service Providers. We may share your information with third parties to help us provide the Messaging Service to you.
• Legal Requirement and Protection of TrustCo LLC and Others. We may disclose your information as we believe such disclosure is necessary or appropriate to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce a contract with us; (iv) protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain.
• From time to time, we may share aggregate or de-identified information about the use of the Messaging Service and such aggregated or de-identified information may be shared with any third party, including advertisers, promotional partners, and sponsors.
• No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties.

Protection of Information

We take a variety of physical, technical, administrative, and organizational security measures based on the sensitivity of the information we collect to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. Unfortunately, no online activity can be guaranteed to be 100% secure. While we strive to protect your information against unauthorized use or disclosure, we cannot ensure or warrant the security of any information you provide. We do not accept liability for unintentional disclosure.

Retention of Information

We retain your information for as long as you participate in the Messaging Service or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect us and our customers, and enforce our agreements.

Choices and Controls

Consent to receive automated marketing text messages is not a condition of any purchase. You can opt-out of receiving further commercial text messages via the Messaging Service by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT.

Text Message Campaign Data Selling

If you sign up to receive text messages from us, we will not sell Personal Information collected specifically in connection with such service, including your mobile telephone number or consent data, to any third party, and we will not share such Personal Information with any third party for cross-context behavioral advertising or targeted advertising purposes.

CONTACT US

If you have any questions about our Sites, Services, or this Privacy Policy, please contact us using the information below. 

TrustCo LLC 

101 S 12th St. #102

Tampa, FL 33602

Email address: support@trustco.ai