Privacy Policy
Data Collection
Trixfer.com undertakes to collect Your Data by means that are:
fair;
legal; and
transparent.
If you visit Trixfer.com's web-site, your web-browser automatically discloses, and Trixfer.com's web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.
Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.
Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a web-page within a particular domain (such as Trixfer.com). This data may or may not be sufficient to identify you.
If you disclose personal data to Trixfer.com in conjunction with an identifier such as your name or your credit-card details, Trixfer.com will collect Your Data. Moreover, any data that becomes available to Trixfer.com through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, Trixfer.com undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:
where Trixfer.com reasonably considers that the protection of its financial interests requires that it gather YourData from other sources, or from additional sources. This applies in particular where Trixfer.com has a lending exposure to you, and seeks information about your creditworthiness;
where Trixfer.com reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering YourData from other sources. This applies in particular to consumer profile data.
Where Trixfer.com collects Your Data from sources other than you, it undertakes:
to do so only by legal means;
to do so only with your Consent; and
to declare to you what sources it uses, and under what circumstances.
Trixfer.com undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.
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Data Security
Trixfer.com undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Trixfer.com undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
Trixfer.com undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Trixfer.com undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by ThisCompany's staff-members and contractors. These include:
training for staff in relation to privacy;
access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it;
particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour;
declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
clear communication of policies and sanctions; and
processes to audit, to investigate and to impose sanctions.
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Data Use
Use refers to the application of Your Data by any part of Trixfer.com, or any staff-member or contractor of Trixfer.com in the course of their work.
Trixfer.com undertakes to use Your Data only for:
the purposes for which it was collected;
such other purposes as are subsequently agreed between Trixfer.com and You;
such additional purposes as may be required by law. In these circumstances, Trixfer.com will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
such additional purposes as are authorised by law (in particular to protect Trixfer.com's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Trixfer.com or have committed a breach of the criminal law).
Trixfer.com undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.
Trixfer.com undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
Data Collection
Trixfer.com undertakes to collect Your Data by means that are:
fair;
legal; and
transparent.
If you visit Trixfer.com's web-site, your web-browser automatically discloses, and Trixfer.com's web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.
Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.
Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a web-page within a particular domain (such as Trixfer.com). This data may or may not be sufficient to identify you.
If you disclose personal data to Trixfer.com in conjunction with an identifier such as your name or your credit-card details, Trixfer.com will collect Your Data. Moreover, any data that becomes available to Trixfer.com through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, Trixfer.com undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:
where Trixfer.com reasonably considers that the protection of its financial interests requires that it gather YourData from other sources, or from additional sources. This applies in particular where Trixfer.com has a lending exposure to you, and seeks information about your creditworthiness;
where Trixfer.com reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering YourData from other sources. This applies in particular to consumer profile data.
Where Trixfer.com collects Your Data from sources other than you, it undertakes:
to do so only by legal means;
to do so only with your Consent; and
to declare to you what sources it uses, and under what circumstances.
Trixfer.com undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.
--------------------------------------------------------------------------------
Data Security
Trixfer.com undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Trixfer.com undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
Trixfer.com undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Trixfer.com undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by ThisCompany's staff-members and contractors. These include:
training for staff in relation to privacy;
access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it;
particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour;
declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
clear communication of policies and sanctions; and
processes to audit, to investigate and to impose sanctions.
--------------------------------------------------------------------------------
Data Use
Use refers to the application of Your Data by any part of Trixfer.com, or any staff-member or contractor of Trixfer.com in the course of their work.
Trixfer.com undertakes to use Your Data only for:
the purposes for which it was collected;
such other purposes as are subsequently agreed between Trixfer.com and You;
such additional purposes as may be required by law. In these circumstances, Trixfer.com will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
such additional purposes as are authorised by law (in particular to protect Trixfer.com's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Trixfer.com or have committed a breach of the criminal law).
Trixfer.com undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.
Trixfer.com undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
