Privacy Policy
VERSION FEBRUARY 10TH, 2024
At TrustPics (“TrustPics”, “We”, “Us” and terms of similar meaning), owned by Outlimit Inc, having its registered address at 3524 Silverside RD STE 35D, Wilmington, Delaware, USA, 19810, we’re committed to protecting the privacy of our users (“You” or “User”) and ensuring the security of any personal data We receive from You. We understand the importance of privacy and have implemented policies and procedures to maintain the confidentiality of your personal data.
At TrustPics (“TrustPics”, “We”, “Us” and terms of similar meaning), we’re committed to protecting the privacy of our users (“You” or “User”) and ensuring the security of any personal data We receive from You. We understand the importance of privacy and have implemented policies and procedures to maintain the confidentiality of your personal data.
This Privacy Policy explains how We collect, use, and disclose Your personal data, and Your rights regarding that data. By using our services, You consent to the collection and use of Your personal data in accordance with this Privacy Policy (“Privacy Policy”), which applies to personal data We process and handle when You use Our products through Our website (the “Services”).
It is important to carefully read and understand both this Privacy Policy and the Terms of Service (the “Term”), as they create a legally binding agreement between You and Us. Therefore, please make sure to review them both thoroughly.
We may update this Privacy Policy from time to time, so We encourage You to review it regularly. If We make changes, We will notify You by email or by posting a notice on our website
https://trust-pics.com (“Site”).
However, notwithstanding the aforementioned clauses, all requests pertaining to personal data may be forwarded to Us via email at:
[email protected]. You are also able to fill out the forms as mentioned in this Privacy Policy.
We appreciate your trust in us and we will continue to work hard to earn it every day.
What personal data do we process, for what purpose and on what legal basis?
Before giving Your consent, we need you to understand what type of data we may collect:
What we process:
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Things you provide to us:
- To access Our Services, you may need to create an account and voluntarily provide us with certain data like your email address and password.
- Some of Our services may require identity verification, and we may collect email addresses, full name, address, and photo, an anonymized scan of passport or ID, for this purpose.
- Your photo.
When you voluntarily use our services, you may choose to upload photos to our Site. We collect and store these photos to provide our services to you, in the manner and timeframe as described in this Privacy Policy.
We will never use your photos for any purpose other than providing our services to you, unless we obtain your explicit consent. We will never sell your photos to third parties, and we will only share them with trusted partners who help us provide our services as described in this Privacy Policy.
We take critical steps to protect your photos from unauthorized access, use, or disclosure. We use encryption to secure your pictures and comply with laws and regulations.
You have the right to access, correct, or delete your images. Contact us if you have any questions or concerns.By uploading, you agree to the terms of this policy and give us consent to collect, use, and share your pictures as described herein. If you disagree with these terms, please do not use TrustPics.
- Payment data like name and location.
To ensure the secure processing of online payments for TrustPics Users, TrustPics engages the services of reputable third-party entities ("Entities"), which act as merchants of records. To understand what data these Entities collect, refer to the Entities' terms and policy. These Entities handle the personal data of Our Users in their own capacity, with the sole purpose of executing the payment process. All of those "Entities" are PCI DSS Compliant.
The merchant of records provides TrustPics with critical data regarding the User's payment, such as the success or failure of the transaction. TrustPics utilizes this data to facilitate payment registration and ultimately provide the requested service to our users.
Entities, in addition to facilitating transactions, also furnish TrustPics with vital data regarding User identification, such as their full name and surname. These specific personal details about the User are essential to TrustPics to establish, exercise, or defend their legal rights and interests. This data is also required for billing purposes to process payment transactions accurately and effectively.
- If you communicate with us through email or by filling out forms placed on TrustPics, we may collect data you provide, like feedback, survey responses, or compliances.
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Data collected when you use our Services:
- Data concerning service usage like activity, results, data usage, and duration.
- Device data about access to our services, such as type, browser type, and operating system.
- Data about your requests to our servers, such as what you request, when, and location.
- Location data, which we may collect using your device's GPS or your IP address.
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Data collected in TrustPics index:
TrustPics, akin to conventional search engines, provides a service to the User by utilizing its index - the search engine indexes "fingerprints" of faces found to facilitate future searches. TrustPics does not engage in targeted searches for any particular individual but rather indexes images available on the Internet, along with corresponding data about their sources. TrustPics doesn't act to confirm the identities of the persons depicted, whom this policy refers to as "unidentified entities."
We're creating an index that relies on publicly available sources; TrustPics processes indexed data to provide a high-quality service to Users. TrustPics employs a secure process, a proxy, to download and display images from external websites. These images are stored temporarily, at most 30 calendar days, and instantaneously deleted upon being exhibited.
Data which is processed in the TrustPics index stems from sources that are publicly accessible. During the collection of such data, TrustPics abides by the distinct regulations of TrustPics automation web robots and only downloads data from sites that officially allow data scraping.
TrustPics presents images from external websites, but the content exhibited is not within its preview. Nevertheless, TrustPics exerts every effort to cull explicit or pornographic content.
Why we process:
- Providing, maintaining, troubleshooting, and supporting services: We collect and use data to deliver the best service possible.
- We use data to respond to requests and keep you informed.
- We have a legitimate interest in enhancing and optimizing our services, so we may use data for improvements.
- Developing new services: We use customer feedback to better understand what new services users may want.
- We use data as demanded by law, legal process, or regulation. We also use data to enforce legal rights and resolve disputes. Please refer to our privacy policy to learn more about how we share data with third parties for legal compliance purposes.
- We use data to enhance our advertising and marketing based on our interest in offering services that may interest you.
- To protect customers and comply with legal obligations, we may use data for security purposes and to deter abuse or fraud.
International transfers
We may collect personal data from, transfer it to, store, and process it in the USA and other countries outside your home. Whenever we share information about EU users outside the EU, we ensure an adequate transfer mechanism is in place, and personal data is shared in limited and specific cases. We provide a level of protection equivalent to that guaranteed within the EU, and you can enforce data protection rights and effective legal remedies.
We're dedicated to protecting the privacy and security of our customers' information. We may collect personal data from, transfer it to, and store and process it in the USA. We take appropriate measures to ensure your personal information receives adequate protection, including using appropriate contractual clauses and other safeguards that comply with applicable data.
Protection laws.
These measures could include but are not limited to, obtaining explicit consent to the transfer of personal information or ensuring that the third-party recipient of your personal information is a trusted third party with whom We have bilateral contractual obligations.
We may transfer personal information for processing, storage, or disaster recovery to service or cloud providers in various countries. We will only transfer personal information to these providers if we've taken steps to ensure that the service provider will adequately protect it.
We also comply with applicable laws and regulations concerning personal information across international borders, including the General Data Protection Regulation (GDPR).
If You have questions about international transfers of information, please contact TrustPics.
Voluntary data providing
We're committed to protecting personal data and being transparent. When you use TrustPics, it's your choice to provide Us with data such as your name, email address, and face image. You do so voluntarily, and we will collect data necessary for Us to provide Our services to You.
We may also collect specific data when You use our services, such as your device, IP address, and browsing history. This helps us understand how Our services are utilized and improved over time.
By using TrustPics, You agree to the terms of this Privacy Policy and give us consent to collect, use, and share your data as described. You have the right to access, correct, or delete your personal data at any time, and you can contact us HERE if you have questions about Our privacy practices.
Does Trustpics share personal data with third parties?
TrustPics is committed to protecting data of its Users, except in cases where access to such data is necessary for the proper performance of services or for the execution of orders. We entrust this data to third-party service providers with whom We form agreements that guarantee confidentiality and terms and limit sharing to the scope of what they are helping Us with.
We may share your data only if:
- You've given instruction or consent (including Takedown service).
- We work with affiliates, partners, and trusted third-party service providers to help us with customer payments and provide analytics, sales, support, marketing, and advertising content.
- We may use generic, non-identifying data for regulatory compliance, research and analysis, marketing activities, and other legitimate business purposes.
- We will comply with the legal process and the law. We may share your data if we are required to do so by applicable law, comply with our legal obligations, comply with legal processes, and respond to valid requests relating to a criminal investigation. We limit the data shared to what is legal and challenge data requests we believe are unlawful, overbroad, or invalid.
- We may share data collected in transaction connection if a corporate transaction occurs.
- We may share limited data to enforce agreements with users, to respond to claims asserted against us, and to protect against fraud and abuse, our affiliates, users, and others.
How long users' data will be stored?
We retain data for as long as is needed to provide the services to You or for as long as You have an account. We may also store personal data for the duration of the service and for some time necessary to establish, exercise, or defend legal claims and comply with legal obligations.
- Regarding processing data only in response to Your inquiry, our policy is to delete the related personal data and any contact forms sent within twelve months after the reaction or the last contact with the individual is initiated. This period helps us analyze and improve our services and modify them according to need.
- Customer data: We retain data for as long as You have an active account. After Your account is closed, we may keep your data for up to a reasonable period, not exceeding 30 days, to comply with legal requirements and archival purposes.
- We will retain the User's search results for 30 calendar days after the User performs the search.
- In the case of Takedown, We retain data for as long as You have an active account or remove it from the User panel. We will keep the form filled in by You, "Personal Data," forever to prove the basis of the relevant assignment requested by You.
- All facial images of Users not having accounts but given explicit affirmative consent while agreeing on thi
- Privacy Policy and Terms of Service are stored for forty-eight hours after You have no account and send the photo to process the search query.
- In case of a breach of this Privacy Policy, Terms of Service, infringement of regulations, for security, fraud and abuse prevention, to comply with regulatory requirements, we reserve the right to retain data for a reasonable period to take appropriate legal action.
When we no longer need to retain Your data or no longer have your consent, we'll immediately start the deletion securely and responsibly. The complete deletion process can take up to 30 calendar days.
You have the right to access, correct, or delete your data, the right to object to processing, restricting processing, and the right to data portability. To exercise such, please get in touch with us at [email protected].
Age registration
Our Services are not intended for use by anyone under eighteen (18).
We do not collect Personal Data from minors (under 18). If you are under eighteen (18), please only provide Personal data if you have the involvement and consent of a parent or guardian. By the GDPR, we do not offer services directly to children.
If We discover We've collected personal data from a minor (under 18) without consent, We may delete the data without notice. Depending on the country, parental consent may be necessary for processing personal data of children under 16. Anyone under 16 cannot use our services without the consent or authorization of their parent or legal guardian. If you suspect that a minor (under 18) has provided us with personal data without parental or guardian consent, please get in touch with us.
Data related to children
TrustPics is committed to the highest standards of privacy - especially regarding minors. We do not collect, search, or permit the searching of data about minors. We have stringent measures to ensure protection. Our systems are designed to identify and exclude data associated with individuals under eighteen (18) or under sixteen (16), depending on applicable legislation. Our commitment extends to using every possible means to safeguard children's well-being online and uphold their rights to a safe and secure digital experience.
We're dedicated to improving our infrastructure to identify better and address any instances where searches or data related to minors may occur. We understand the evolving nature of digital landscapes and the need for constant attention. We are committed to utilizing advanced algorithms and monitoring mechanisms to detect and prevent unauthorized access or usage involving minors—TrustPics pledges to intervene promptly through the ways described in this Privacy Policy. Our ongoing commitment is to comply with and surpass legal requirements, ensuring a secure and responsible platform. We remain committed to providing users with a safe and enriching online experience.
Web browser cookies
We use cookies to provide a better user experience. Cookies can be used to remember Your login data, so you don't have to enter it every time you visit a website. Cookies make navigating a website and finding the data you're looking for faster.
We use cookies to track browsing behavior and to create a profile of interests. This profile is then used to show targeted advertisements.
You're less likely to see irrelevant or annoying ads and more likely to see relevant and useful ads.
Cookies are harmless data bits that enhance the online experience by helping remember preferences. It's crucial to note that cookies do not contain viruses or malware. Your privacy is important to Us, and We want to assure you that cookies are a standard and safe tool used in online environments.
We value consent. You can manage cookie preferences. You can decide whether to accept or reject. You can delete cookies that are stored. We believe in transparency and respect your choices. You must know that rejecting or deleting cookies might impact user experience. We're committed to providing the information and tools you need to make informed decisions. You can always modify Your cookie settings.
By using TrustPics, you acknowledge the terms outlined regarding cookies for personalized ads, understanding that user experience may be tailored based on preferences. Your continued engagement indicates Your acceptance of these terms and consent for Us to utilize Your data for advertising.
Google services
TrustPics employs Google Analytics, a sophisticated web service that leverages data collected from "cookies" to analyze website traffic. This service furnishes TrustPics with extensive reports on Our activity and its users' usage patterns.
Google Analytics facilitates ongoing improvement and ensures services align with Our needs and expectations. Users can exercise their option to turn off Google Analytics services by downloading the available Google plugin. TrustPics utilizes Google's reCAPTCHA system - a cutting-edge risk analysis engine- to authenticate human access to the Site and discern automated ones. This technology typically requires users to rewrite letters or numbers or identify appropriate images.
Information regarding Google Analytics and reCAPTCHA, including processing user data, is available HERE.
How Trust-Pics safeguards services & protects data
We take data privacy seriously. We have implemented organizational measures to comply with applicable laws and regulations. We utilize suitable data gathering, storage, processing practices, and safety safeguards to thwart unauthorized access, modification, revelation, or destruction of the User's personal data, username, password, transaction data, and data stored on the Site. Sensitive data exchanges between the Site and its Users occur through an SSL-secured communication channel, ensuring a professional level of security.
Additionally, various organizational and technical measures are in place to prevent the misuse of our Services and violation of regulations. These measures include, but not limited against:
1. No harm policy:
We are committed to protecting data and strive to maintain its confidentiality, integrity, and availability. We follow best practices to protect data from unauthorized access, disclosure, alteration, or destruction and prevent personal data loss, misuse, or theft.
We've implemented technical, physical, and administrative safeguards to protect data, including encryption, access controls, and security testing. We also restrict access to personal data to authorized personnel with a legitimate business need.
TrustPics doesn't sell or rent personal data to third parties.
We only retain personal data for as long as necessary to fulfill the purposes it was collected - required by law.
We understand no security measures can provide 100% protection against threats, and We cannot guarantee the security of Your data. We're committed to notifying you in the event of a data breach that affects Your data and taking measures to mitigate the impact of a breach.
It's Our responsibility to minimize the risk of a data breach or other privacy-related incident. We have implemented a "no harm" policy, meaning that should a data breach or other privacy-related incident happen, We will take all steps to minimize the risk of harm, including credit monitoring or other remedial measures.
If you believe Your data has been compromised, please get in touch. We will investigate concerns and take appropriate action.
1. Security policy:
2.1 Your data is safe with the TrustPics team:
Everyone on the TrustPics team, including support specialists, PROtect team specialists, and data security officers, must protect personal data.
The employees attending to sensitive cases of Users will be of the same gender as the User to ensure a professional environment. Besides providing legal and technical training who interact directly with users, additional training in managing sensitive/problematic communications (e.g., suicide prevention and behavioral psychology) is also offered professionally.
Candidates with a degree or training in applied psychology are given preferential consideration when recruiting customer support personnel and project team members professionally.
2.2 Data security:
We employ technical measures to protect against unauthorized or unlawful data processing and loss, destruction, or damage. Regular reviews: We review and update our privacy and security practices to ensure they remain up-to-date and effective.
These measures demonstrate TrustPics commitment to protecting the privacy and security of personal data and allow Us to offer Our services in full compliance.
To minimize the risks of infringing copyright regulations, enforce a policy of only scraping data from websites that officially grant permission.
We avoid targeting all known social media and social networking platforms, including:
- Professional networks
- Search engines
- Crawlers
Frequency of product usage - simultaneous and concurrent searches are intercepted and prevented to avert the exploitation of shared accounts, bots, or other unauthorized individuals.
Detect any unauthorized searches – any User whose search goes against our Privacy Policy, Terms of Service, or applicable law will be warned and, in case of repeat, blocked.
We reserve the right to inform government authorities about such a breach, as envisaged in this Privacy Policy.
2.3 TrustPics has developed an AI-based multi-step monitoring system, which helps us to detect:
Frequency of product usage
Simultaneous searches are intercepted to avoid exploiting shared accounts, bots, or other unauthorized individuals.
2.4 No service available for flagged countries or people:
TrustPics does not provide services to anyone located in or subject to sanctions by the United States, the European Union, the United Kingdom, or other applicable laws and regulations.
TrustPics also does not provide services to individuals or entities on any of these lists:
- U.S. Department of Commerce's Denied Persons List
- Entity List
- Unverified List
- U.S. Department of Treasury's Specially Designated Nationals
- Blocked Persons List
- European Union's Consolidated List of Persons,
- Groups and Entities Subject to EU Financial Sanctions
- United Kingdom's Consolidated List of Financial Sanctions Targets
- Any other applicable lists of sanctioned or restricted parties.
TrustPics reserves the right to take any actions TrustPics deems necessary, including but not limited to denying access to services or terminating existing agreements.
TrustPics takes our legal and regulatory obligations seriously and strives to ensure services comply with applicable laws and regulations. TrustPics encourages all Users to comply with applicable laws and regulations and to seek legal advice if they have questions or concerns about legal obligations.
Specific notices to illinois residents
TrustPics does not offer any services in Illinois or for Illinois residents. TrustPics has implemented all technical measures to block data linked to Illinois or Illinois residents (“Illinois Data”), both at the stage of collecting data from publicly available sources as TrustPics as when provided by the data subjects or from a source other than the data subject.
TrustPics may process Illinois Data only in rare cases, i.e., to defend against legal claims or to satisfy the removal request. This Privacy Policy stores such data, including retention periods, based on BIPA. The data above is permanently destroyed no later than when the beginning purpose for collection has been satisfied or within three years of the data subject’s last interaction with TrustPics, whichever occurs first.
Specific notices to nevada residents
TrustPics is conscious of its responsibility under Nevada Statute Chapter 603A - Security and Privacy of Data. TrustPics only delivers search results to users. TrustPics has no intention of selling data in the future.
Specific notices to california residents
As a California resident, it is essential to note that the California Consumer Privacy Act (“CCPA”) provides specific legal guidelines and extra consumer rights. Individuals need to abide by these regulations for the protection of data.
Please note that according to the CCPA:
“ data” means data that identifies relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, for example, real name, alias, postal address, unique identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers, but also biometric data.
A California resident, a natural person, is called a "Consumer."
A "Household" is a collective, identified by residential address, of Consumers who reside together and use shared devices or services.
The Consumer has the following additional rights regarding data:
1. Upon a verifiable consumer request:
a) A Consumer has the right to know what data is collected by TrustPics. A Consumer must make a verifiable request, and upon verifying the request, TrustPics will provide the Consumer with the relevant data:
- Categories of data TrustPics has collected about that Consumer,
- Categories of sources from which data is collected,
- Commercial purpose for collecting, selling, or sharing data,
- Third parties to whom TrustPics discloses data,
- Specific data: TrustPics has collected data about that specific Consumer.
The data supplied by TrustPics will be restricted to the past twelve months.
b) Right to access data.
To fulfill this obligation, the Consumer should submit a verifiable request, and upon successful verification, TrustPics will disclose and provide the data requested to the Consumer at no charge. The data may be delivered by mail or electronically. If provided electronically, the data shall be in a portable, technically feasible, usable format that allows the Consumer to transmit data to another entity without hindrance.
c) Right to request the deletion.
To fulfill consumers' right to delete some or all of the data, after verification of the request, TrustPics will delete the data, with allowances for any exceptions that result from the California Consumer Privacy Act. If an exception applies, FRA informs you about it in writing. According to CCPA, a “Verifiable Consumer Request” is a request made by a Consumer on behalf of the Consumer’s minor child by a natural person or a person registered with the Secretary of State. Authorized by the Consumer to act on the Consumer’s behalf, or by a person who has poTrustPicsr of attorney or is working as a conservator for the Consumer, and that TrustPics can verify, using commercially reasonable methods.
TrustPics shall provide the necessary data to a Consumer without any cost within 45 days of receiving a Verifiable Consumer Request. On legitimate grounds, an extension of 45 additional days can be allotted with the Consumer being duly notified of the delay during the initial 45-day period. When there is a need to address the complexity and quantity of the requests, the duration to respond to any Verified Consumer Request could be extended by a further 90 days. TrustPics will advise the Consumer of such an expansion and the reasons for a hold within 45 days of receipt, all in a professional manner.
Verifiable Consumer Request:
- To ensure accurate identification of the Consumer, it's necessary to collect the Consumer's email address, a face photo, and a copy of the Consumer's identity document with the appropriate image if a request is submitted to access data.
- If you are representing a Consumer, it's in your best interest to provide TrustPics with appropriate documentation verifying your authority to act on behalf of the Consumer. TrustPics has the right to request authorization from the Consumer before proceeding.
- If you act as a household, TrustPics will require all Consumers constituting the household to submit the request.
Verifiable Consumer Request can be made by sending an email containing, respectively, all necessary elements described above to the following email address: [email protected].
1. Right to opt out of the sale of data.
CCPA gives Consumers the right to opt out of the sale of data. TrustPics provides the Users only with the search results, i.e., it does not sell and declares that it does not intend to sell data in the future.
1. Consumers have the right to request the removal of all data from the Trust-Pics system by filling out the contact us form
TrustPics recognizes its responsibility as outlined in the California Code of Civil Procedure (CIV § 1798.83) and asserts that they do not transfer or disclose details to third parties for marketing orders. Therefore, TrustPics has no specific procedure for processing requests about these matters.
Copyrights
All materials on Site, including text, graphics, icons, images, and software, are Our property. You may access and use the materials on this Site solely for Your non-commercial use. Any reproduction, distribution, modification, or publication of the materials on this Site without our prior written permission is strictly prohibited.
TrustPics reserves the right to remove any content alleged to infringe another party's copyright without prior notice, at Our sole discretion, and without liability to You or any other party.
Dmca notification
TrustPics responds to all notifications of copyright infringement by the DMCA. Please be advised that you can send an effective notification only if you are the copyright owner. A person authorized to act on behalf of the copyright owner or a person authorized to act under any exclusive right, according to DMCA.
By Section 512(c)(3)(A) of Title 17 of the DMCA, a notification must be made in writing and must include the following:
I) The written or electronic authorization of a person whose authority has been approved by the proprietor of a unique right that is supposedly violated.
II) Identification of the copyrighted work claimed to have been infringed or, if a single notification covers multiple copyrighted works at a single online site, a representative list of such works.
III) Details of the material claimed to be infringing or subject to infringing activity and allows location, thus enabling TrustPics to remove or restrict access to it.
IV) sufficient data to permit TrustPics to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted.
V) Statement that the complaining party has good faith and belief that the use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.
VI) Statement that the data in the notification is accurate and that the complaining party is authorized, under the penalty of perjury, to act on behalf of the owner of an exclusive right allegedly infringed.
A DMCA notification can be made by filling out a Request Form under this link.
Changes to this privacy policy
TrustPics may change this Privacy Policy at any time and update the "Last Revised" date at the top of this page to reflect the most recent version. It is Your responsibility to review this Privacy Policy periodically for any changes. Your continued use of Our services after any modifications to the Privacy Policy will constitute Your acceptance of such changes.
Contacting Trustpics
TrustPics is committed to maintaining your data's accuracy, confidentiality, and security. If You have any questions or concerns about Our privacy practices, or if You would like to request access to, correction, or deletion of your data, please get in touch with us. TrustPics will respond to your inquiry as soon as possible.
TrustPics may need to verify your identity before fulfilling specific requests, such as providing access to Your data. TrustPics will make reasonable efforts to respond to your request within the timeframes required by law.
It's essential to ensure that the contact information provided is up-to-date and that someone is responsible for promptly responding to inquiries and complaints.