Privacy & Cookie Policy

Introduction

Last updated 31st October 2025

Who are we?

We are The Trusted Consultancy Ltd t/a Trusted, a company incorporated in England & Wales, with our registered office at 85 Great Portland Street, First Floor, London, England, W1W 7LT.

Where we decide the means or purpose of processing your personal data, we are the data "controller."

If you would like to access this policy in a different or more accessible format, please write to us at hello@thetrusted.io

When are we the controller?

We are the controller when, as described in this policy, we:

1. collect information through our public website
2. respond to feedback or enquiries about our business
3. collect analytics through our site, products & services
4. process personal data to provide you with an Advocate profile

When are we the processor?

We are a processor on behalf of our customers, and not the controller, for personal data processed by those customers (or us on their behalf) using our products and services.

This means that our customers are the controller where they:

1. upload personal data in the Trusted platform
2. manage data relating to contacts in the Trusted platform
3. record interactions with advocates in the Trusted platform

If this includes your personal data, and you have queries or concerns, you should contact the organisation who is processing your personal data using Trusted.

What's this policy about?

This policy explains how we process your personal data as a data controller.

Other services, our customers and their suppliers, will have separate policies to explain the same information about decisions they make about your personal data.

We update this policy from time to time so please check back in. If we make material changes affecting you, we will notify you either through a notice on our website, our services, by email or otherwise.

How do you contact us?

Regarding questions on this policy, any complaints or concerns, or to exercise your rights, write to us at: hello@thetrusted.io

If we can't resolve your issue, you can also get in touch with the Information Commissioner's Office: https://ico.org.uk/concerns

If you are outside the UK in a European country, you can submit complaints to supervisory authorities in your country, details of which you can find here: European Data Protection Authorities

What are your rights?

You have the following rights, although these rights may be limited in some circumstances:

• Ask us to send a copy of your data to you or someone else
• Ask us to restrict, stop processing, or delete your data
• Object to our processing of your data
• Object to use of your personal data for direct marketing
• Ask us to correct inaccuracies

If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to our address listed above (or, in the case of newsletters, by using the unsubscribe links in our emails).

Your personal data and how we use it

Newsletters

We may collect the following information to send newsletters:

• Name
• Email address
• Subscription status

Retention: We hold this information for as long as you subscribe to our newsletters.

How we use it

We process this information to send newsletters to those who subscribe to receive them through our site.

Our legal basis for this processing is generally consent. However, we may process records of who has subscribed or unsubscribed, as necessary for us to comply with our legal obligation to ensure we record and comply with consents and unsubscribe requests.

If you are a corporate subscriber, we may process this information without consent based on our legitimate interests in promoting our services to you.

Where we get it

We collect this information directly from you.

Enquiry Data

We process some or all the following information so we can collect, record and properly respond to enquiries:

• Name
• Contact information (such as email address and telephone number)
• Other information you submit as part of your enquiry

Retention: We hold onto enquiry data for at least a year after the enquiry has been addressed, for 7 years if you are a customer, and otherwise while we still have a need to do so for purposes set out in this policy.

How we use it

We process this information because it is necessary for the purposes of our (and your) legitimate interests, being our and your legitimate interests in us being able to respond to your queries.

Where we are obliged to respond to your enquiries as part of or in connection with contractual support or similar arrangements, we may also process this data for the purpose of performing or entering a contract with you.

Where we get it

We collect this information directly from you.

Customer Accounts

We may process the following information to administer your customer account:

• Name, username
• Contact information (such as email address and telephone number)
• Administrative user account details and credentials.
• Details of feedback and other correspondence relating to your account.

Retention: We generally hold onto account data for 7 years after you (or the customer you work for) cease using your (or their) account but may continue to retain it where necessary for other purposes set out in this policy.

How we use it

We use this information to administer user accounts, provide our platform and services, and to maintain and improve them.

Our legal basis for processing is legitimate interest, including legitimate interests (of us and our users and customers) in ensuring that our services operate as intended, and maintaining and improving those services.

Where we get it

We collect this information directly from you.

Advocate Accounts

If you have an Advocate account, to the extent you provide it, we process the following to deliver our services:

• Username; name; email address; telephone number.
• Current & past company or employer; job title; dates you changed job.
• Professional networking profile URL (e.g. LinkedIn).
• Languages spoken; country.
• Single Sign-On tokens.
• Connections between you and our customers.

Retention: We generally hold onto account data for 7 years after you cease using your account but may continue to retain it where necessary for other purposes set out in this policy.

How we use it

We process this data to allow you to create and use your Advocate account. We also use this to provide our platform to our customers. For example, if you provide profile information to be shared with customers, we will share that information and may use it for the purpose of matching you with relevant customers.

Legal basis

Our legal basis for this processing is:

1. performance of contractual obligations to you (in particular, our obligation to provide agreed services) or taking steps you request prior to entering a contract;
2. we may also process this personal data to administer user accounts, and provide our services including for matching purposes and by sharing your profile information with customers, on the legal basis of legitimate interest, including interests of you, us, users and customers in facilitating connections with advocates, ensuring that our services operate as intended, and maintaining and improving those services.

Where we get it

We may either:

• collect this information directly from you; or
• collect some of this data initially from our customers who may send you an invite to register (in which case, we will use that information to pre-populate some of your profile).

If you provide profile information and connect with our customers or other users, they will receive your profile information.

Analytics

When you interact with our website or services, we may collect information about that interaction, as follows:

• Browser type and version, IP and MAC address, location and time zone, access logs, device type, the operating system you use, screen size and device capabilities, to the extent provided your device provides this to us.
• Use you make of the pages and features of our website and platform, including the URLs and content you visit, language and other similar preferences, the clickstream to, through and from our pages, date and time, page response times, length of visits to pages, interaction (such as scrolling, clicks and mouseovers) data.
• Error reports generated if there are problems with our website or platform.
• The results of A/B testing (we may present users with different interfaces & record which of those performed more effectively).

Retention: After 25 months underlying data is deleted, but we may retain aggregated statistics generated from that data which are anonymous.

How we use it

We use software to collect analytics data about users of our website and platform, to understand how people use them, where they come from, the devices and operating systems they use, how they interact with our site and platform, and to help improve and maintain our site and services.

Legal basis

We process this analytics data if you have given your consent.

You can withdraw your consent for analytics by using our cookie banner.

Where we get it

We use Piwik PRO and Mixpanel, to collect this data from you.

Notice Dismissal and Consents

We process the following information in connection with operation of our website and services:

• A record of whether you have seen our legal notices and whether you have consented to the use of cookies.

How we use it

We use this information to perform our legal obligations, in particular our obligations to record whether you have been provided with information and given your consent to use of cookies.

Where we get it

We, or the processors acting on our behalf, collect this data directly from you.

Retention Periods

Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. To determine the appropriate period, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.

Cookie, Analytics, and Similar Technologies

Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they’re essential for our sites or services. You can control cookie preferences via our cookie banner.

Most browsers also allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Opera | Apple Safari.

Necessary cookies

These cookies are essential for our website and platform to function properly. They enable core features such as security, network management, accessibility, and your ability to log in or fill out forms. Because they are required for our digital services to operate, these cookies are always active and do not require your consent. You can block them in your browser settings, but some parts of the site may not work as intended.

Statistical (analytics) cookies

These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. We use them to measure and improve the performance of our site and services. For example, by tracking which pages are visited most often or where users might encounter errors. We use Piwik PRO Analytics Suite to collect statistical data about visitors to our website and Mixpanel to analyse usage patterns within our application. Information generated by these cookies or tracking scripts (such as IP address, device type, pages or screens viewed, and usage times) is processed in a way that does not personally identify you.

Data Collection and Retention

Further information, transfers and disclosure

Further information

We do not make decisions based solely on automated processing or profiling that produce legal (or similarly significant) effects for you.

Transfers

Where we use data processors outside the UK and European Economic Area and transfer personal data to a country which does not provide an adequate level of protection, we use contracts approved by the European Commission which give personal data the same protection it has in Europe. For more information drop us a line using the contact details at the start of this policy.

Recipients

We use certain third-party services with whom your personal data may be shared. They only process your personal data for our purposes, unless otherwise indicated. Details of third parties we use are available on our website under the heading “Sub-Processors” here: Trust Vault - Trusted Advocacy Management.

Click on "View All" to see more information about each of them.

Use & disclosure

Other than as set out above, we may use and disclose your personal data:

• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
• With members of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this policy.
• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, users, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.