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Privacy Policy

Effective Date: 6 March 2024

Last updated: 4 July 2024

This Privacy Policy ("Policy") outlines the practices and procedures of Tromero Ltd ("we," "our," or "us") concerning the collection, use, and disclosure of personal data from users of our website, mobile applications, and any other online services we provide (collectively referred to as the "Services").

Legal Basis of Processing

We use your personal information only as permitted by law. Applicable data protection law requires us to have a "legal basis" for each purpose for which we collect your personal information. However, we will normally process personal information from you when:

  • We have your consent to do so (you can withdraw your consent at any time by contacting us at dpo@tromero.ai);
  • We have a contract with you and it is necessary to process your personal information to perform our contract with you, including to provide you with the benefits of the Intuit Platform and operate our business;
  • The processing is in our legitimate business interests, such as operating our businesses, improving and developing the Intuit Platform, communicating with you, marketing our offerings and services and personalizing your experience, and to detect illegal activities; and/or
  • To comply with legal requirements, including applicable laws and regulations.

1. What is Personal Data?

When we use the term "personal data" in this Policy, we mean any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. How We Collect Personal Data:

Personal data you provide:

  • Account Information: including first and last name, company name, business email address, user ID and password, and any other information you provide to us. We use this information to administer your account, provide you with the relevant Services and information, communicate with you regarding your account and your use of the Service, and for customer support purposes. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
  • Payment Information: If you sign up for one of our Services requiring payment (i.e., the Tromero GPU marketplace or Tromero Tailor), we collect the information provided in connection with such payment. Please note that we use third-party payment processors, including Stripe, to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor's use of your personal data is governed by their privacy notice.
  • Inquiry and Communications Information: such as your name, company name, or email address, and including information provided in custom messages sent through, our "Contact Us" feature, or to one of our email addresses. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
  • Newsletter, Marketing Emails, and Blog Information: including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the "unsubscribe link" provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
  • Business Representative Contact Information: If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g. email, phone, address), job title, and any other information related to the performance of the agreement with us.
  • Employment Application Information: including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.

Personal data we receive automatically from your use of our Services:

  • Log Data: Information that your browser or device automatically sends when you use our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our Services.
  • Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
  • Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Cookies and Similar Technologies: We use cookies and similar technologies to operate and administer our Services, and improve your experience. Cookies are managed by a third party provider, Cookiebot. For details about our use of cookies, please visit our Cookie Notice. You can manage your cookie preferences through your browser settings.

For more information about data, privacy and security when using our Services, please click here.

3. How We Use Personal Data

We may use the data we collect to:

  • Provide you with products or services that you request or in which you express interest;
  • Communicate with you, via email;
  • Customize the advertising and content you see;
  • For marketing and advertising purposes, including to market to you or offer you through email, direct mail, phone or text message, information and updates on products or services we think you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
  • Process payment for our Services;
  • Respond to your emails, comments, questions, or requests for client services;
  • Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
  • Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
  • Enforce our Terms of Service, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties;
  • Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
  • For any other purpose we may describe when you provide the information; and
  • For any other lawful purpose, or other purposes that you consent to.

4. Sharing Your Personal Data

We do not sell, trade, or rent your personal data to third parties. However, we may share your personal data with third parties under the following circumstances:

  • Service Providers: We may share your data with third-party service providers who assist us in operating and improving our Services.
  • Legal Compliance: We may disclose your data when required by law or in response to legal requests.
  • With Your Consent: We may disclose personal data about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual's consent or direction we may post their testimonial on our Sites or service-related publications.
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.

5. Your Rights

You have the right to:

  • Access and update your personal data: You may access, rectify, erase, restrict processing, object to processing, and request data portability of your personal data by contacting us at dpo@tromero.ai.
  • Opt-Out: You can opt-out of receiving promotional emails by following the instructions provided in those emails. However, you may still receive non-promotional communications.

6. Security

We take reasonable measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. However, no method of data transmission over the internet or electronic storage is entirely secure.

7. Children's Privacy

Our Services are not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe that a child under 13 has provided us with personal data, please contact us, and we will take appropriate steps to promptly remove that data.

8. Changes to this Privacy Policy

We may update this Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The updated Policy will be posted on our website with the last updated date.

9. Keeping Personal Data

We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.

10. Making a Complaint

You have the right to make a complaint about how we process your personal data to the Information Commissioner at https://ico.org.uk/make-a-complaint/.

11. Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or your personal data, please contact our Data Protection Officer at dpo@tromero.ai.

If you would like to sign a Data Processing Agreement, you can request one from us at dpo@tromero.ai.