TrustX

TrustX Privacy Statement Effective as of 31 January 2012

TrustX is committed to protecting the privacy of your information while using our site www.trustx.com. This Privacy Statement describes our privacy practices as regards the secure services being provided to you.

TrustX has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at support@trustx.com. If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe certification currently only covers information collected on our Web site and not through the login portion of the site or our mobile applications. The login portion of the site and mobile applications are currently under review.

TrustX complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. TrustX has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view TrustX certification, please visit http://www.export.gov/safeharbor.

1. Information Collected

TrustX offers a secure email communications application and service that is collectively referred to as the “Service.” Additional applications may be added in the future and for purposes of this privacy statement would be considered part of the “Service.” Users who register to use the Service are referred to as “Customers”.

When registering to use the Service, TrustX requires customers to provide the Company with personal contact information, such as their name, phone number, and email address (“Required Contact Information”). This information may be used to contact customers with information regarding the service, but will not be shared with third parties unless they are helping to deliver the service or unless required by law.

In addition, TrustX requires customers to provide the Company with certain biometric information, namely voice prints, palm images and a facial image (“Biometric Information”). This information will be collected both during enrolment and whenever required to authenticate a customer’s identity in support of applications such as secure email. Additional biometrics may be collected in the future and would also be considered “Biometric Information”.

Further, as part of the Registration and Authentication processes we may collect information such as your IP address, geographic location and mobile device ID and some related attributes that may be used by the service to assess risk and authenticate identities of persons using the service.

When purchasing the Service, TrustX requires you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number (“Billing Information”). This may be provided indirectly through one of the various app stores in the mobile device market place. Required Contact Information, Biometric Information and Billing Information are referred to collectively as “Data About TrustX Customers.”

We do not collect any personal information on our Web site.

2. Use of Information Collected

The Company uses Data About TrustX Customers solely to perform the services requested. This may include using collected data to test new authentication algorithms or policies to improve the service over time.

3. Sharing of Information Collected

TrustX shall not share Data About TrustX Customers with third parties other than as described in this privacy policy. TrustX does not share, sell, rent, or trade any information provided with third parties for promotional, marketing or any other commercial purposes.

We may provide personal information to companies that provide services to help us with our business activities such as processing payments or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

TrustX reserves the right to use or disclose information provided if required by law, such as to comply with a subpoena or similar legal process or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights, protect your safety or the safety of others and/or to comply with a judicial proceeding, court order, or legal process.

TrustX reserves the right to use or disclose information to third party service providers provided for preventing or addressing service or technical problems, or as may be required by law.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or prominent notice on our Web site of any change in ownership or uses of personal information, as well as any choices you may have regarding your personal information.

4. International Transfer of Information Collected

TrustX is a global company and our Service operates and is provided globally. TrustX may collect, transfer and access Data About TrustX Customers from around the world, including the United States and the European Union. Data About TrustX Customers may be stored in a hosted datacentre in the United States or some other location. This Privacy Statement shall apply even if TrustX transfers Data About TrustX Customers to other countries.

5. Consent

By registering as a Customer and using the TrustX Service you as an individual hereby explicitly consent to our use of the Data About TrustX Customers to be used, transferred and accessed only as set down in this Privacy policy. You certify that this consent is freely given. If you do not so consent then do not register or use the Service.

6. Unsubscribing From the Service or Changing Account Information

You may unsubscribe from the Service or change or delete inaccuracies within your account information by emailing support@trustx.com. We will use a secure protocol to ensure that only the registered owner of an account can request such changes. Some changes to your account, such as changing your email address, may require you to create a new account and result in your losing access to secure information linked to the previous email address. Customers cannot opt out of receiving emails related to their account with TrustX or the Services. Requests to access, change, or delete your information will be handled within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at support@trustx.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7. Security

TrustX uses security measures to protect Customer Data from unauthorized access, maintain data accuracy and to help ensure the appropriate use of Customer Data. These security measures include encrypting the data, digital signatures to ensure the continuing integrity of that data (as well as to evidence any tampering with the data), firewalls, intrusion detection systems, 24 x 7 physical protection of facilities where data is stored, background checks (as permitted by law) for personnel that access physical facilities, and strong security procedures all service operations. These measures help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. Customers are responsible for maintaining the security and confidentiality of their TrustX PINS, passwords, or any other “secret” information used as part of the authentication process.

8. Changes to this Privacy Statement

TrustX reserves the right to change this Privacy Statement. TrustX will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

9. Contacting Us

Questions regarding this Privacy Statement or the information practices of the TrustX Service should be directed to support@trustx.com and TrustX, 11955 Freedom Drive, Suite 16000, Reston VA 20190.

10. Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.

The use of residual cookies by third parties is not covered by our privacy policy. We do not have access or control over the use of these cookies.

11. Clear Gifs (Web Beacons/Web Bugs)

Our third party tracking technology partner employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

12. Links to Other Sites

This Web site contains links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites.

We encourage you to be aware when you leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information.

This privacy statement applies only to information collected by this Web site.