This Privacy Policy has been updated on July, 2026
WE RESPECT YOUR PRIVACY!
TRILLIONS SOFTWARE UAB, the company with the address: Lithuania, Vilnius, T. Narbuto g. 5-1, LT-08106 and company number: 307723626 (“Company” “Us”, “We” and “Our”) understands that Your privacy is important to You and is committed to being transparent about the technologies it uses.
This Privacy Policy describes how We collect and use the Personal Data You provide. It also describes the choices available to You regarding Our use of Your Personal Data and how You can access the information. We respect Your privacy and We take protecting it seriously.
Please read this Privacy Policy carefully before using Our Application or Website. If You do not agree with Our policies and practices, please do not use Our Services.
1.1. When You visit, use, or navigate Our Application and/or Website, We may process Personal Data depending on how You interact with Us and the Services, the choices You make, and the products and features You use. This Privacy Policy applies to the following people:
1.1.1. people who use the Services (for the purposes of this Privacy Policy, We define the term “User”, “You”, “Your”, “Yours” as a person which has registered through Our Application or Website);
1.1.2. people who express an interest in obtaining information about Us or Our products and Services, when participating in activities on the Services, or otherwise when contact Us;
1.1.3. people who visit Our Website, browse its content, or otherwise interact with it before registration (for the purposes of this Privacy Policy, We define the term “Visitors”);
1.2. The Company does not sell Your Personal Data to third parties.
1.3. We may process sensitive Personal Data (defined as such by the applicable law) when necessary with Your explicit consent or as otherwise permitted by applicable law.
1.4. We may receive Your information from public databases, marketing partners, social media platforms, and other outside sources.
1.5. As a non-custodial Wallet infrastructure provider We do not collect, create, manage or control in any other way Your private keys or seed phrases.
1.6. We process Your Personal Data to provide, improve, and administer Our Services, communicate with You, for security and fraud prevention, and to comply with law. We may also process Your Personal Data for other purposes with Your consent. We process Your Personal Data only when We have a valid legal reason to do so.
1.7. We may share Your Personal Data in specific situations and with specific categories of Third parties as outlined in this Privacy Policy. We may collect and share Your financial, particularly banking information in case You use the according financial service (on-ramp, off-ramp, card payments etc.). In such case Our sharing is limited to the particular Third parties providing such financial services in the scope required for provision of these services.
1.8. We have organizational and technical processes and procedures in place to protect Your Personal Data. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat Our security and improperly collect, access, steal, or modify Your Personal Data.
1.9. Depending on where You are located geographically, the applicable privacy law may mean You have certain rights regarding Your Personal Data.
1.10. The easiest way to exercise Your rights is by submitting a data subject access request, or by contacting Us. We will consider and act upon any request in accordance with applicable data protection laws.
1.11. Please read carefully the following sections of this Privacy Policy to understand in more details the terms provided in this section “General information”.
2.1. We adhere to the following principles in order to protect Your privacy:
2.1.1. principle of lawfulness and purposefulness — We process Personal Data fairly and in a transparent manner only for the achievement of determined and lawful objectives, and they shall not be processed in a manner not conforming to the objectives of data processing;
2.1.2. principle of minimalism — We collect Personal Data only to the extent necessary for the achievement of determined purposes and do not keep Personal Data if it is no longer needed;
2.1.3. principle of restricted use — We use Personal Data for other purposes only with the consent of the data subject or with the permission of a competent authority;
2.1.4. principle of data quality — We update Personal Data in order to be up-to-date, complete, and necessary for the achievement of the purpose of data processing;
2.1.5. principle of security and confidentiality — We apply the security measures in order to protect Personal Data from unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical and organizational measures;
2.1.6. principle of individual participation — We ensure the Users to be notified of data collected concerning them, to have access to the data concerning them and to have the right to demand the correction of inaccurate or misleading data;
2.1.7. principle of performance of a contract — We may process Your Personal Data when We believe it is necessary to fulfill Our contractual obligations to You, including providing Our Services or at Your request prior to entering into a contract with You;
2.1.8. principle of consent — We may process Your Personal Data if You have given Us permission (i.e., consent) to use Your Personal Data for a specific purpose. You can withdraw Your consent at any time;
2.1.9. principle of legitimate interests — We may process Your Personal Data when We believe it is reasonably necessary to achieve Our legitimate business interests and those interests do not outweigh Your interests and fundamental rights and freedoms.
3.1. The following terms shall have the following meaning:
3.1.1. “Application” — software program under the name “Trillions”, URL: https://trillions.com, provided by the Company, accessed via a mobile application that can be downloaded from Google Play, App Store, through which Users interact with the Company’s Services. The URL may differ, depending on the marketplace, please note, that We place this Privacy Policy in Our Application, that is applicable notwithstanding the marketplace.
3.1.2. “Company” — refers to TRILLIONS SOFTWARE UAB, the company with the address: Lithuania, Vilnius, T. Narbuto g. 5-1, LT-08106 and company number: 307723626, the legal entity and/or its affiliate company (including and any subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us) responsible for providing the Application and its related Services, as described in this Privacy Policy.
3.1.3. “Consent” — means a clear, freely given, specific, informed, and unambiguous indication of the Users’ wishes by which they, through a statement or a clear affirmative action, agree to the processing of their Personal Data and other terms of this Privacy Policy.
3.1.4. “Creator” — the User who successfully passed the Know Your Customer (KYC) verification and obtained access to creating and sharing the content via Creator public profile in the Application or Website. Creators are entitled to receive donations from other Users and participate in the Company’s partnership programme.
3.1.5. “GDPR” — the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation.
3.1.6. “IP address” — a unique numerical label assigned to a device connected to the Internet, which can be used to identify the approximate geographic location of the device and track online interactions.
3.1.7. “Personal Account” — a User-created profile within the Application or Website that allows access to certain features, services, and personalized settings, which will include User’s certain Personal Data. Information specified in the Personal Account will not be available for other Users of the Services, except specific information defined in this Privacy Policy.
3.1.8. “Personal Data” — an information that directly or indirectly identifies an individual, including but not limited to name, email address, IP address, as defined under applicable data protection laws, including the GDPR, and other local data protection regulations worldwide.
3.1.9. “Registration” — registration via the Application or Website by filling out the form with the User’s email address, username, password and the other data, which is necessary to create the Personal Account of the User.
3.1.10. “Sensitive data” — Personal Data which includes financial data or biometric data that is defined as a special category of personal data according to the local laws of the applicable states (e.g. in separate states in the USA).
3.1.11. “Service” or “Services” — access to the Wallet via Our Application and/or Website. The Services provided by the Company include the access to the non-custodial Wallet and its functionality to hold and manage Your digital assets. Please note that Our Services are limited to the provision of technical infrastructure only. The User retains all control and ownership either to their assets or to their private key. We do not have any access or control over the User’s assets or keys. The Services are provided by the Company, together with its affiliates, officers, directors, employees, agents, and subsidiaries, please read Our Terms of Service carefully to understand the scope of Our Services. Other services, particularly financial services You may see in Our Application or Website are provided by Our business partners — Third parties.
3.1.12. “Third parties” — any individuals, organizations, or entities that are not part of the Company, its affiliates, officers, directors, employees, agents, or subsidiaries, but may have access to Personal Data as described in this Privacy Policy, such as service providers, business partners, and other external entities with whom the Company may share or receive data under specified circumstances.
3.1.13. “User” — any individual who accesses or uses the Application or Services provided by the Company, including those who have registered for a Personal Account, accessed the Service, or interacted with the features and content available on the Application or Website after the Registration.
3.1.14. “Visitor” — any individual who accesses and browses Our Website without necessarily registering for an account or using Our Services.
3.1.15. “Wallet” — non-custodial crypto wallet created and owned solely by the User.
3.1.16. “Website” — the online platform operated by the Company, accessible via a web browser on various devices, including desktops, laptops, tablets, and mobile phones, that provides information, content, and Services to Users and Visitors. The Website can be accessed at: https://trillions.com.
4.1. To fulfill Our obligations on provision of the Services for You and applicable Terms of Service, We may ask You to provide Us with Your Personal Data. The Personal Data that We collect depends on the context of Your interactions with Us and the Services, the choices You make, and the products and features You use. The Personal Data We collect may include the following:
4.1.1. Data submitted during Registration and contact details: first and last name, age or date of birth, email address, phone number, mailing address;
4.1.2. Card-application data for card Users: name, address, and card issuer-required identifiers (e.g. SSN / tax ID for US residents);
4.1.3. Wallet address read from public ledgers and generated on the User’s side via Third Party software infrastructure;
4.1.4. For the specific financial products and features provided to You through Our Application or Website by the licensed Third parties (Our business partners) We might ask You to provide Us with the information required for the Anti-Money Laundering purposes (full legal name, date of birth, nationality and citizenship, residential address, government-issued ID (passport, national ID, driver’s license) number and image, selfie or facial biometric for liveness check, and where required source-of-funds information). We ask You for this information to ensure the compliance with the AML-requirements in terms of financial services provided by Third parties. The full scope of the required information depends on the personal risk level and is defined by the Third party and presented by Us via Our Application, Website or channels of communication before the access to such financial services. Collecting such information We fulfill Our obligations to Our business partners to ensure You the access to their services. Please read carefully the privacy policy and terms of use of such Third parties before using their services.
4.1.5. We do not collect either private keys, seed phrases or crypto balances (read on-chain, not stored).
4.1.6. All the information is voluntarily provided by You during Registration of the Personal Account or using Our Services. You warranty that all Personal Data that You provide to Us is true, complete, and accurate, and You must notify Us of any changes to such Personal Data.
4.2. Sensitive data. When necessary, with Your consent or as otherwise permitted by applicable law, We process the following category of Sensitive data:
4.2.1. Financial information (credit or debit card number: last 4 digits only, billing address, billing email address).
4.2.2. Biometric data (facial or hand geometry scans, including facial prints) in terms of KYC procedure.
4.3. We always ask Your explicit consent before collecting and processing Your Sensitive data and take all necessary measures to ensure its security.
4.4. We automatically collect certain information when You visit, use, or navigate Our Application and/or Website. This information does not reveal Your specific identity (like Your name or contact information) but may include device and usage information, such as Your:
4.4.1. IP address;
4.4.2. browser and device characteristics: device type, OS, browser, user-agent, device ID;
4.4.3. usage data: pages viewed, actions taken, purchase history, usernames or account IDs;
4.4.4. approximate geolocation from IP;
4.4.5. interactions with web pages;
4.4.6. referring page or source used to access the Services;
4.4.7. non-identifiable requests;
4.4.8. statistics on device or browser interactions with the Services;
4.4.9. information about how and when You use Our Services;
4.4.10. and other technical information, particularly public blockchain data — Wallet addresses and on-chain activity read from public ledgers.
4.5. This information is primarily needed to maintain the security and operation of Our Services, and for Our internal analytics and reporting purposes.
4.6. The information automatically collected on Our Website cannot identify the Visitor’s personal identity. The collection and processing of such data are carried out based on the principle of legitimate interests and does not require explicit consent.
4.7. Data collection for Our Website Visitors: We do not request the provision of the Personal data listed in Section 4.1, Sensitive data specified in Section 4.2, nor do We collect any other Personal data (including from other sources) that may identify an individual.
4.8. In order to enhance Our ability to provide relevant marketing, offers, and Services to You, to provide the access to Our partner’s services and update Our records, particularly for AML purposes, We may obtain information about You from other sources, such as public databases, joint marketing partners, data providers, and from other Third parties. This information may include email addresses, phone numbers, intent data (or User behavior data), Internet Protocol (IP) addresses, social media profiles, custom profiles or other data for purposes of ensuring the User’s Registration, AML-compliance and providing Services.
4.9. In the process of Personal Account registration We may obtain Your Google account profile information (such as name, email) if You choose Google sign-in.
4.10. In case We obtain any other data, which is not indicated in this Privacy Policy, We take all necessary measures to ensure the same level of security as for the Personal Data You provide to Us. We do not collect any data for which We do not have the legal grounds.
5.1. We may use Your Personal Data for a variety of purposes, primarily, relating to providing Our Service and information about Our Service. We may also use the information for such other purposes as otherwise allowed by law. For example, We (or Our affiliates) may use Your Personal Data, including personally identifiable information, for such purposes, including but not limited to:
5.1.1. to provide access to the Services;
5.1.2. to facilitate Personal Account Registration and authentication and otherwise manage Users’ accounts. We may process Your Personal Data so You can create and log in to Your Personal Account, as well as keep Your Personal Account in working order;
5.1.3. to handle Your orders and requests, particularly requests for technical support and assistance, excluding financial orders;
5.1.4. to properly fulfill tax-related and accounting obligations imposed by applicable laws;
5.1.5. to detect, investigate, and prevent illegal activities or conduct that may violate the Terms of Service of the Services and this Privacy Policy;
5.1.6. to ensure fraud prevention, security, and implementing bug fixes;
5.1.7. to personalize Your experience with Our Service based on Your preferences, and display advertisements, including interest-based or online behavioral advertising;
5.1.8. to contact You in relation to Our Services, including marketing and sales-related communications, administrative purposes, changes to this Privacy Policy, dispute resolution;
5.1.9. to conduct internal research and development and to improve, test, and enhance the features and functions of Our Services;
5.1.10. to meet Our internal and external audit and legal requirements, including Our information security obligations and obligations to Our partners;
5.1.11. to request feedback: We may process Your Personal Data when necessary to request feedback and to contact You about Your use of Our Services;
5.1.12. to fulfill Our obligations to Third Parties, which ensure the Users with financial or other licensed services (particularly, obligations of AML compliance and records management);
5.1.13. any other purpose as We determine, in Our sole discretion, to be necessary or required to ensure the safety and/or integrity of Our Users, employees, Third parties, public, and/or Our Services, or to comply with requirements of any applicable law.
6.1. We may share Your data with Third parties, including vendors, service providers (hosting, cybersecurity), licensed partners, contractors, employees or agents who perform services for Us or in cooperation with Us and require access to such information to do that work. We have contracts, particularly Data Processing Agreements (DPAs) or other similar agreements in place with Our Third parties, which are designed to help safeguard Your Personal Data. This means that they cannot do anything with Your Personal Data unless We have instructed them to do it. They will also not share Your Personal Data with any organization apart from Us. We limit the information provided to such Third parties to that which is reasonably necessary for them to perform their functions. However, We can not provide any guarantees for their actions and We do not take the responsibility for such actions. The categories of Third parties We may share personal information with are as follows:
6.1.1. Service providers enabling Us with the services required for the proper business operation;
6.1.2. Advertising partners;
6.1.3. Analytics partners;
6.1.4. Third parties authorized by Users to access or authenticate Personal Data;
6.2. Although We may share Your Personal Data with Third parties, We do not sell such data in the meaning of the applicable laws, in particular:
6.2.1. A “sale” of Personal Data under the California Consumer Privacy Act (CCPA) is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal Data of a User to another business or third party “for monetary or other valuable consideration.”
6.2.2. A “sale” of Personal Data under the Virginia Consumer Data Protection Act (VCDPA) is defined as the exchange of personal data for monetary consideration.
6.2.3. We also consider the other privacy laws, which provide the concept of selling the personal data, however We do not sell the Personal Data within their meaning as well.
6.2.4. If We decide to sell Your Personal Data, We will inform You about this, so You can forbid Us to transfer Your Personal Data together with Our business. If so, We will delete Your data from the databases prior to a business transfer.
6.3. Any transaction or operation via the Application or Website infrastructure that is supported and ensured by the licensed provider or decentralized network is indicated as a Third party service and is processed according to the rules of such Third party. We are not liable for the services provided by such Third parties. Providing consent to Our Services You authorize Us to share Your Personal Data with such Third parties in order to provide You the access to their services. Any other information You provide to such Third parties is not controlled by Us and is the subject of privacy policies of such Third parties. Please read their terms of use and privacy policies carefully before making any transactions, using their services and providing any Your data to them.
6.4. We may share Your Personal Data with Our insurers, Our professional advisors (lawyers, bankers, auditors, corporate financiers) in connection with the services they provide to Us. If We share Your Personal Data with those processors, We will require the recipient to keep it confidential and secure. To provide You (or Your organization) with Our Services, We may provide Personal Data to the courts, to lawyers advising the other parties to a matter, or other professionals (such as overseas law firms, patent agents, forensic accountants, or barristers).
6.5. All data transfers are performed in accordance with the highest security regulations. If You are an EU User, transfer of Personal Data to countries outside of the European Economic Area may be possible only in the case when We have obtained Your consent for it. By accepting this Privacy Policy You provide the consent to such transfer. If You do not agree with such transfer, please do not provide Your consent or contact Us. In case of transfer Your Personal Data outside the European Economic Area, such transfers are conducted in compliance with GDPR regulations, using Standard Contractual Clauses (SCCs) or other legal mechanisms to ensure adequate data protection.
6.6. All data processed by Us is stored exclusively in secure hosting facilities provided by AWS, EU region (Frankfurt eu-central-1 / Ireland eu-west-1); particularly the application data is stored in PostgreSQL and Redis.
6.7. We may share Your Personal Data with such Third parties — service providers to allow You the access to the their specific services:
| Service provider | Service | Location |
|---|---|---|
| Signify Holdings, Inc. (DBA “Rain”) | Blockchain-based card issuing | USA |
| Horkos, Inc. (DBA “Privy”) | Software development and support | USA |
| Ramp Swaps LLC, Ramp Swaps (Ireland) Limited, Ramp Swaps Ltd and other members of the group (DBA “Ramp Network”) | On-ramp and off-ramp services | USA; Europe (Ireland); UK |
| MoonPay (UK), MoonPay USA LLC, MoonPay AUS Pty Ltd, MoonPay Europe B.V., MoonPay Jersey Ltd. and other members of the group (DBA “MoonPay”) | On-ramp and off-ramp services | UK; USA; Australia; EEA (Netherlands); Jersey |
| Transak Inc., Transak Limited, Transak USA LLC, Transak Canada Limited, Transak sp. z o.o., TRANSAK AUSTRALIA PTY LIMITED, Transak Technology India PVT LTD and other members of the group (DBA “Transak”) | On-ramp and off-ramp services | USA; UK; Canada; Australia; Europe (Poland); India; Hong Kong |
| ZeroEx Holdings, Inc. (DBA “0x”) | Assets exchange services (swaps) | USA |
| Sum and Substance Ltd., Sumsub GmbH, Sumsub Inc., Sumsub Technology LLC, Sumsub Brasil LTDA and other members of the group (DBA “Sumsub”) | Know Your Customer (due diligence and verification) services | UK; Europe (Germany); USA; UAE; Brazil |
6.8. Some of Your Personal Data may be visible to the other Users or public. The scope of such Personal Data is limited to the following data:
6.8.1. Creator public profile: displaying name, donation page, and digital products;
6.8.2. In-app transfers: counterpart display name and wallet address may be shown to the other party in a transaction;
6.8.3. Referral: referral links or attribution;
6.8.4. Public blockchain data: wallet addresses and on-chain transactions visible on the public blockchain.
6.9. Such Personal Data as emails, KYC identity documents, biometric data, payment identifiers, private account settings is never visible to the public and other Users.
7.1.1. If You are an EU or UK User to process Your Personal Data We need to receive Your Consent, as it is prescribed by GDPR and UK GDPR accordingly, We will process Your Personal Data only in the case We have received from You a freely given, specific, informed, and unambiguous indication of Your wishes by which You signify agreement to the processing of Your Personal Data (“Consent”).
7.1.2. You give Your Consent by registering in the Application or Website (in particular by checking the checkbox regarding Your consent). In the case of Your Registration with Our Service, You irrevocably and unconditionally consent and agree that Company shall be entitled to process Your Personal Data as it is indicated by Your Consent.
7.1.3. Your Consent covers all processing activities with Your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, Your Consent should be deemed given for all of them.
7.1.4. You have the right to withdraw Your Consent at any time. You can submit such a request by sending Us an email to privacy@trillions.com. Your withdrawal of Consent shall not affect the lawfulness of Your Personal Data processing based on Consent before its withdrawal.
7.1.5. Except as required or enabled by law We will not use or disclose Your Personal Data for any purpose for which You refuse Consent or later withdraw Your Consent. If You withdraw Consent, You agree that in spite of this withdrawal, We may continue to use those Personal Data previously provided to Us to the extent that We are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation You may have towards Company or in any other way permitted by law.
7.2.1. If You are not an EU or UK User, by Registration via the Application or Website, You irrevocably and unconditionally consent and agree that the Company shall be entitled, in accordance with this Policy:
7.2.1.1. to Process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), Your Personal Data so provided to Us, as well as Your Personal Data, collected from Your use of the Services (i.e. Your Personal Data which We collect automatically and/or from other sources); and
7.2.2. In some exceptional cases, We may be legally permitted under applicable law to process Your information without Your consent, for example to:
7.2.2.1. Comply with federal, state, or local laws.
7.2.2.2. Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
7.2.2.3. Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law.
7.2.2.4. Exercise or defend legal claims.
7.2.2.5. Collect, use, retain, sell, or disclose consumer information that is deidentified or in the aggregate consumer information.
7.2.3. You have the right to withdraw Your Consent at any time. You can submit such a request by sending Us an email to privacy@trillions.com. Your withdrawal of Consent shall not affect the lawfulness of Your Personal Data processing based on Consent before its withdrawal.
8.1. If You are located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).
8.1.1. Under Art. 6 of the GDPR, We only process Personal Data, where We have a lawful basis for doing so.
8.1.2. The processing of Personal Data, described in section 5 of this Privacy Policy is based on contract obligations (Art. 6 (1) lit. (b) GDPR) and is performed only for the purposes specified in this Privacy Policy — to meet Your request concerning the Service, to formalize the development of the contractual relationship.
8.1.3. The processing of Personal Data, described in this Privacy Policy is based on a legitimate interest (Art. 6 (1) lit. (f) GDPR) and is performed only for the purposes specified in this Privacy Policy — to contact You about, and conduct, surveys or polls You choose to take part in and to analyze the data collected for market research purposes.
8.1.4. The processing of Personal Data, described in section 5 of this Privacy Policy is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Privacy Policy — to personalize Your experience with Our Service and for marketing and promotion of Our Services or related products, including those of a Third party’s products which are related to Our Services.
8.2. If You are located in the United States of America, all processing of Personal Data is performed in accordance with regulations and rules of the state where You are located, in particular if You are in:
8.2.1. California — the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”) applies; 8.2.2. in Virginia — Virginia Consumer Data Protection Act; 8.2.3. in Colorado — Colorado Privacy Act; 8.2.4. in Connecticut — The Connecticut Data Privacy Act; 8.2.5. in Utah — Utah Consumer Privacy Act; 8.2.6. in Florida — Florida Digital Bill of Rights; 8.2.7. in Oregon — The Oregon Consumer Privacy Act; 8.2.8. in Texas — Texas Data Privacy And Security Act; 8.2.9. in Nevada — Chapter 603A – Security and Privacy of Personal Information; 8.2.10. in Montana — Montana’s Consumer Data Privacy Act; 8.2.11. in Iowa — Iowa Act Relating to Consumer Data Protection; 8.2.12. in Delaware — Delaware Personal Data Privacy Act; 8.2.13. in Nebraska — Nebraska Data Privacy Act; 8.2.14. in New Hampshire — New Hampshire Senate Bill 255; 8.2.15. in New Jersey — New Jersey Senate Bill 332; 8.2.16. in Tennessee — Tennessee Information Protection Act (from 01/07/2025); 8.2.17. in Minnesota — Minnesota Consumer Data Privacy Act (from 31/07/2025); 8.2.18. in Maryland — Maryland Online Data Privacy Act (from 01/10/2025); 8.2.19. in Indiana — Indiana Consumer Data Protection Act (from 01/01/2026); 8.2.20. in Kentucky — Kentucky Consumer Data Protection Act (from 01/01/2026); 8.2.21. in Rhode Island — Rhode Island Data Transparency and Privacy Protection Act (from 01/01/2026).
8.2.22. If You are located in any other state, where the specific privacy law is implemented, all processing of Personal Data is performed in accordance with such local regulations and rules.
8.3. If You are located in Brazil, all processing of Personal Data is performed in accordance with regulations and rules following the Lei Geral de Proteção de Dados (“LGPD”).
8.4. If You are located in the United Kingdom, all processing of Personal Data is performed in accordance with regulations and rules following the Data Protection Act 2018 (“DPA 2018”) and UK General Data Protection Regulation (“UK GDPR”).
8.5. If You are located in Australia, all processing of Personal Data is performed in accordance with regulations and rules following the Privacy Act 1988.
8.6. If You are located in Canada, all processing of Personal Data is performed in accordance with regulations and rules following Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).
8.7. If You are located in New Zealand, all processing of Personal Data is performed in accordance with regulations and rules following Privacy Act 2020.
8.8. In case if You are located in any other jurisdiction, the laws of such jurisdictions are applicable for You and all Personal Data processing is performed in accordance with the regulations and rules of such jurisdiction.
8.9. We process Personal Data as a Controller, as defined in the GDPR.
9.1. In some regions (like the EEA, UK, Switzerland and others), You have certain rights under applicable data protection laws. These may include the right:
9.1.1. to request access and obtain a copy of Your Personal Data; 9.1.2. to request rectification or erasure of Your Personal Data; 9.1.3. to restrict the processing of Your Personal Data; 9.1.4. if applicable, to data portability; 9.1.5. and not to be subject to automated decision-making. 9.1.6. In certain circumstances, You may also have the right to object to the processing of Your Personal Data.
9.2. If You are located in the United States of America, some states (including but not limited to California, Virginia, Colorado, Connecticut, Utah, Florida, Oregon, Texas) introduce local privacy laws. Considering them, You have such rights:
9.2.1. Right to be informed whether or not We are processing Your Personal Data; 9.2.2. Right to access Your Personal Data; 9.2.3. Right to correct inaccuracies in Your Personal Data; 9.2.4. Right to request deletion of Your Personal Data; 9.2.5. Right to obtain a copy of Your Personal Data You previously shared with Us; 9.2.6. Right to opt out of the processing of Your Personal Data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”); 9.2.7. to appeal Our decision and to be informed regarding the taken measures within the terms, established by law.
9.3. If You are located in any other region, We consider the privacy laws applicable in Your jurisdiction and the rights You have.
9.4. Under this Privacy Policy You can access, withdraw consent, object, restrict the processing, receive, correct inaccuracies, request deletion of Your Personal Data. For that, contact Us directly at privacy@trillions.com. We will acknowledge Your request within seventy-two (72) hours and handle it promptly and as required by law.
9.4.1. Right to access and to be informed whether or not We are processing Your Personal Data. You may contact Us to get confirmation as to whether or not We are processing Your Personal Data. When We process Your Personal Data, We inform You (in particular in this Privacy Policy) of what categories of Personal Data We process regarding You, the processing purposes, the categories of recipients to whom Personal Data have been or will be disclosed, and the envisaged storage period or criteria to determine that period.
9.4.2. Right to withdraw consent. In case Our processing is based on the Consent granted, You may withdraw the Consent at any time by contacting Us. You can withdraw Your Consent at any time by replying to the email with Your withdrawal and Your Personal Data will be deleted in 48 (forty eight) hours. Withdrawing Consent may lead to fewer possibilities or the impossibility to use Our Services. Notwithstanding any Consent granted beforehand for direct marketing purposes, You have the right to prohibit Us from using Personal Data for direct marketing purposes, by contacting Us or by using the functionalities of the Services or unsubscribe possibilities in connection with Our direct marketing messages.
9.4.3. Right to object. In case Our processing is based on Our legitimate interest to run, maintain and develop Our business, You have the right to object at any time to Our processing. We shall then no longer process Your Personal Data unless for the provision of Our Services or if We demonstrate other compelling legitimate grounds for Our processing that override Your interests, rights, and freedoms or for legal claims.
9.4.4. Right to restriction of the processing. You have the right to obtain from Us restriction of processing of Your Personal Data, as foreseen by applicable data protection law, e.g. to allow Our verification of the accuracy of Personal Data after Your contesting of accuracy or to prevent Us from erasing Personal Data when Personal Data is no longer necessary for the purposes but still required for Your legal claims or when Our processing is unlawful. Restriction of processing may lead to fewer possibilities or the impossibility to use Our Services.
9.4.5. Right to data portability. You have the right to receive Your Personal Data from Us in a structured, commonly used, and machine-readable format and to independently transmit those data to a third party, in case Our processing is based on Your Consent and carried out by automated means.
9.4.6. Right to correct inaccuracies. If You would at any time like to review or change the information in Your Personal Account or terminate Your account, You can: log in to Your account settings and update Your Personal Account or contact Us using the contact information provided.
9.4.7. Right to request deletion of Your Personal Data. Upon Your request to terminate Your Personal Account and Your Personal Data, We will deactivate or delete Your Personal Account and Your Personal Data and information from Our active databases. However, We may retain some information in Our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce Our legal terms and/or comply with applicable legal requirements.
9.4.8. Right to non-discrimination for the exercise of a Consumer’s Privacy Rights. We will not discriminate against You when You exercise Your privacy rights.
9.4.9. Right to limit use and disclosure of Sensitive Data. You have the right to direct the Company to limit the use of Your Sensitive Data to that use which is necessary to perform the Services. To exercise Your right You should email the Company with such a request. Please note, that Your limitation of Sensitive Data may lead to the restriction of access to the specific services, particularly to the Third parties’ services (on-ramp, off-ramp, card issuing, etc.).
9.4.10. How to use these rights. To exercise any of the above-mentioned rights, You should primarily use the functions offered by Our Services. If such functions are however not sufficient for exercising such rights, You shall send Us a letter or email to the address set out below under Contact, including (but not limited to) the following information: full name, phone number, email address. We may request additional information necessary to confirm Your identity. We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded, but it does not deprive You of the right to retry Your request.
9.4.11. You can designate an authorized agent to make a request under the applicable regulation, for example CCPA, on Your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on Your behalf in accordance with the applicable law.
10.1. When a User or a Visitor visits, navigates or uses the Application or the Website, little text files known as “cookies” are stored on their device. These files provide information that may be used to store login credentials, Users’ or Visitors’ preferences, and other browsing-related data. Cookies are particularly useful for tracking Users’ or Visitors’ activity, optimizing Application and Website performance, and personalizing content.
10.2. Please read Our Cookie Policy carefully to know more about the use of cookies.
11.1. We store Your Personal Data for as long as needed to provide You with Our Services. We may store data longer, if a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements), but only in a way that it cannot be tracked back to You. When Personal Data is no longer needed, We delete it using reasonable measures to protect the data from unauthorized access or use.
11.2. EU Territory. We store Personal Data as long as it is needed for the provision of Our Services. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission or, in the case of payable services, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added services information (including traffic information used for these purposes) are stored as long as the same is necessary for the provision of these activities, or up to the time when a User opts out from such use in accordance with this Privacy Policy. Other information is stored for as long as We consider it to be necessary for the provision of Our Services. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for Us to provide the Service You requested.
11.3. As explained in the GDPR statement, We strive to anonymize the data when possible. If You decide to exercise Your right to erasure We will also inform Our providers to delete all Your data.
11.4. US Territory. We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.
11.5. Other territories. Storing might be different depending on the territory of collecting the information and the applicable legislation, but We always strive to store the information only as long as it is needed for the purposes of providing, improving, or personalizing Our Services.
12.1. Our Services are not intended for children under the age of majority in their jurisdiction of residence. By Registration in the Application, You represent that You are the age of majority in your jurisdiction of residence or that You are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.
12.2. If We determine upon collection that a User is under this age, We will not use or maintain his/her Personal Data without the parent/guardian’s consent. If We become aware that We have unknowingly collected personally identifiable information from a child under the age of majority without the appropriate parent/guardian’s consent, We will make reasonable efforts to delete such information from Our records. If You believe that We might have any information from or about a child under the age of majority please contact Us at privacy@trillions.com.
12.3. We also recommend that parents monitor their children’s Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.
13.1. We care to ensure the security of Personal Data. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once We receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for Your Personal Data. When We or Our contractors process Your information, We also make sure that Your information is protected from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is done through appropriate administrative, technical, and physical measures.
13.2. There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, We cannot guarantee its absolute security. You should only access the Services within a secure environment.
14.1. You can deactivate local notifications by changing the notification settings in accordance with the instructions of the operating system running on the Users’ device.
15.1. This Privacy Policy is applicable to Our Services. Once redirected to another service, website, or app, this Privacy Policy is no longer applicable.
16.1. We assume that all Users have carefully read this document and agree to its content when they provide their Consent to use Our Services during the Registration of the Personal Account in Our Application or Website. If You do not agree with this Privacy Policy, You should refrain from using the Services and do not provide Your consent.
17.1. From time to time, We may update this Privacy Policy. We encourage You to periodically check back and review this Policy so that You always will know what information We collect, how We use it, and with whom We share it.
18.1. If You have any questions, suggestions, or requests, please contact Us at privacy@trillions.com.