Trustr Privacy Policy

Introduction

Trustr takes your privacy seriously and understands the importance of protecting your personal information.

Trustr is all about sharing information, recommendations, property listings, etc. within carefully curated and controlled networks of Trustr members. More importantly, Trustr is all about trust. A fundamental part of earning and maintaining that trust means being clear about how we use your personal data and protecting your human right to privacy.

This Privacy Policy describes the privacy practices of Network Travel, Inc., DBA as ‘Trustr’ (“we,” “us,” or “Trustr”) regarding its collection and use of your personal data, and sets forth your privacy rights. The Privacy Policy applies when (i) you visit the Trustr website at https://trustr.com or use any of the online services provided by Trustr at https://trustr.com or related websites where this Privacy Policy appears (the “Services”). (ii) you consent to receive online communications through or directly from us. and (iii) you provide personal information to us in offline communications.

Notification of Changes

We will update this Privacy Policy from time to time. When we post changes, we will revise the “Last Updated” date at the top of the Privacy Policy. We recommend that you check our Services from time to time to inform yourself of any changes in this Privacy Policy.

Accessibility of this Privacy Policy

We will update this Privacy Policy from time to time. When we post changes, we will revise the “Last Updated” date at the top of the Privacy Policy. We recommend that you check our Services from time to time to inform yourself of any changes in this Privacy Policy.

Data Protection Officer

Trustr is headquartered in California, in the United States. If you have questions or concerns about Trustr‘s personal data policies or practices, or would like to exercise any of your privacy rights, you can contact our designated data protection officer:

• Bill Cummings
• 295 Cascade Dr., Mill Valley, CA. 94941
• dpo@trustr.com
• 415-269-7616

Supplemental Privacy Notices

Depending on where you live, some of the following supplemental information may apply to you. Please follow the links and review this information.

Note for United States residents: Please see the Privacy Notice for United States Residents later in this Privacy Policy for more information.

Note for residents of the EEA OR UK: Please see the Privacy Notice for Residents of the EEA or UK later in this Privacy Policy for more information. later in this Privacy Policy for more information.

Scope of Privacy Policy

This Privacy Policy does not apply to third-party websites, online services, or systems to which our Services may link or through which our Services may be accessed, and you accept that Trustr is not responsible for the security or privacy practices of any third-party websites, services, or systems. Sometimes, we may direct you to a website operated by a vendor or partner. Even though the page where you provide information may have the look and feel of the Services, a different privacy policy may govern that information collection by our vendor or partner.

This Privacy Policy does not cover Information provided when you apply for a job at Trustr.

Personal Data We Collect, Use, and Share

Information We Collect

Trustr collects personal information about its members and other customers, including first name, last name, email, and phone number. We use this information to provide you with services, including membership services.

We do not sell personal information to anyone and only share any necessary parts of it with third parties who are facilitating the delivery of our services.

Information You Provide to Create a Trustr Account and Use the Trustr Platform

We collect the following categories of information directly from you to provide the Trustr Services, and enable you to create an account and access membership functions such as joining a network:

• Contact information, including name, username, email address, phone number.
• Age range, geographic location, profile details you supply, and profile photo.

This information is required in order for Trustr to provide its services and to conduct general business operations to support the provision of Services.  If you choose not to provide it, you cannot create a Trustr account and access services available to Trustr members.

Other Information You Provide to Us

If you become a Trustr member, we ask members to voluntarily provide additional information in their membership profile. Some of this information may be publicly visible within the Trustr platform. Members may edit their profile at any time to change, add, or remove personal information. Depending on how you interact with Trustr and your personal choices, you may also provide the following additional personal information directly to us:

• Information you provide by interacting with our services and the Trustr networks you join. Comments you make may be visible to other Trustr members.
• Demographic information such as gender, age, or family status.
• Information you provide when you join Trustr or a Trustr network, including if you link a third-party account to your Trustr account.
• Information contained in any communications with us, including customer service information.
• Your marketing preferences.
• Information about your interests in, reviews of, recommendations for, and use of properties located through Trustr.
• Information about any property and its attributes, location, photos, fees or booking information.
• Payment card information necessary to purchase Services from Trustr. Typically, payment card information is provided directly by users, via the Trustr website, into a PCI/DSS-compliant payment processing service to which Trustr subscribes, and Trustr, itself , does not process or store the card information.

Information Collected Automatically

We collect information that is sent to us automatically by your web browser, which may be collected using cookies. Please see the section on Cookies and Other Technologies for details. This information typically includes:

• Websites visited before and after you use Trustr
• Browser type and language
• IP address
• Hardware and software information
• Communications (including text, chat, or voice)
• Usage data
• Mobile advertising IDs, non-personal identifiers, and other information from your mobile device
• Purchase histories
• Date and time of visit
• Region or location where a computer or device accesses our Services

The information we receive depends on the settings on your web browser. We also collect information regarding customer traffic patterns and usage and mobile application usage data. We may use this information in combination with other information we have about you. We may collect this information by monitoring or recording on your device.

Information Collected from Third Parties

Trustr also collects information from third parties, including:

• Contact information from third-party services such as Google or Facebook when you other people invite you to join a Trustr network.
• Information linking you to properties you rent from third-party services such as Airbnb or VRBO.
• Information that may identify you if you make a referral or identify people who travel with you.

How We Use Information

We may use your personal information to:

• Provide you with and personalize the Services you access. For example, we may offer you recommendations based on your preferences.
• Improve Trustr Services. Trustr has a business interest in understanding how members, customers and potential customers use its Services. We use personal information to help us design our Services to better suit our users‘ needs. We may use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track usage, and gather demographic information that assists us in identifying the preferences of our members and other visitors to our website.
• Optimize our business operations.Trustr processes personal information to better understand and respond to the needs, concerns, and interests of members who use our Services.
• Maintain our internal records and otherwise manage our business.
• Send newsletters, emails and otherwise correspond with you about products, services, and other organizations that we think may interest you.
• Ask for reviews and testimonials, and send you surveys and questionnaires.
• Detect, prevent, or investigate illegal activity or misuse of our products or services and enforce our legal rights.For example, if we suspect criminal activity, we might share our server logs, which contain visitors‘ IP addresses, with the appropriate investigate authorities who could use that information to trace and identify individuals.

In addition to the foregoing uses, Trustr uses emails, phone numbers, and users' full names received from Google APIs and adheres to Google API Services User Data Policy, including the Limited Use requirements.

How We May Share Your information

Trustr may share your personal information:

• With service providers who perform services, such as operation of our Services, management of customer accounts, payment processing and authorization, fraud protection, marketing and promotional activities and communications. Vendors and partners provide services (such as platform providers, billing, consulting, or software) to Trustr to support, operate, and develop the Trustr service. Vendors use your personal information to deliver and/or occasionally to improve the services they provide. For example, the personal information Trustr collects from you is stored in one or more cloud-based services hosted by third parties located in the United States. These third parties do not use or have access to your personal information for any purpose other than providing the cloud-based services that Trustr relies on for its operations.
• With members of Trustr networks you are invited to join.Information about your activity and your membership in Trustr networks is maintained in your Trustr account.Trustr makes member information available through Trustr Member Directory to other Trustr members in the network(s) to which you belong. Members are invited to opt -in to share their information in the networks they are invited to join.
• With other third parties who are under obligations of confidentiality with Trustr.
• Where permitted or required by law.For example, we may disclose personal information to law enforcement or government officials in connection with investigations of fraud, intellectual property infringement, or other illegal activity that may expose you or Trustr to legal liability.
• To enforce legal rights.For example, we will review your history, communications, and other account information to investigate an alleged breach of any applicable Terms of Use or this Privacy Policy. We may disclose your personal information, including communications, to our legal advisors, consultants and law enforcement or other government officials.
• To protect others.We disclose your Information with third parties where we believe this is necessary to protect the rights, property or safety of any person.For example, we disclose Information relating to an account if we in good faith believe the user of that account is using it in ways that are harmful to others.
• In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, Trustr‘s customer information including Information and communications may be transferred to our successor or assign.
• As otherwise set forth in this Privacy Policy.

We may also gather aggregated data about our members and website visitors and disclose the results of such aggregated(but not personally identifiable) information to our partners, service providers, advertisers, and / or other third parties for marketing or promotional purposes.

We use cookies, which are small data files created by a Web server and stored by your browser. We also use pixel tags, which are tiny graphic images, also known as web beacons, action tags, or transparent GIF files. Cookies and pixel tags permit the Services to function properly. For example, they help us to optimize the log- in, account management, and browsing experience. In addition, we may use cookies and other technologies to store your preferences and provide a personalized experience while using the Services. Most browsers accept cookies by default but allow you to block or delete them. If you restrict cookies, you may not be able to use some features of the Services.

Do Not Track Signals

Trustr does not track users when they link from trustr.com to to subsequent sites and does not serve targeted advertising to them. Trustr does not, therefore, respond to Do Not Track (DNT) signals.

Analytics

We also use cookies and other technologies in connection with analytics tools, including Google Analytics, to better understand how the Services are performing, how you engage with the Site, and how you interact with our advertisements and communications. The information we collect using Google Analytics, which may be shared with Google, does not include any names, or contact information but may include your IP address and activity on the Site. You can learn more about your privacy choices in connection with Google Analytics on the Google website: https://policies.google.com.

If you have opted-in to analytics cookies, we may use this information in the aggregate to understand what content our members find useful or interesting.

Social Media

You can invite people to join your Trustr network(s) by accessing their contact information through social networking sites, such as Facebook and LinkedIn (or social media plug-ins and applications) (“Social Media”). Whether your contact information is accessible to Trustr depends on what information you make visible to your networks on the Social Media platform. If you do not want your contact information to be available to Trustr through your Social Media accounts, you can control how that information is shared using the Social Media privacy settings. For more information about how your Social Media uses and protects your personal information, please refer to their privacy policies and terms of use.

Data Storage, Retention, and Security

Your personal data is stored by Trustr on its servers, and on the servers of the cloud-based service providers Trustr engages, located in the United States.

Security

The information you provide is transmitted through the Internet using SSL (Secure Socket Layer) technology. SSL technology is the standard technology for keeping an internet connection secure and safeguarding any sensitive data that is being sent between two systems, preventing criminals from reading, and modifying and information transferred, including personal details.

To help protect the privacy of data and personally identifiable information you transmit through use of the Services, we maintain physical, technical, and administrative safeguards.We update and test our security technology on an ongoing basis.We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you.In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.

While we are committed to use industry standard to protect our Services and your information, the Internet itself is not 100 % secure.We cannot promise that your use of our Services will be completely safe.We encourage you to be cautious when using the Internet.

Use Caution When Sharing Information

When you contribute to a public area or feature of our Services, such as reviewing a property, the information that you submit may be made available to the public. Therefore, we recommend that you do not submit any sensitive information when using our Services, including your name, home address, phone number, financial information or any type of other information that would enable other users to locate you or contact you. We strongly recommend that you do not share any passwords or login information with others.

Data Retention

Trustr retains data for the duration of a customer“s relationship with Trustr and for a period of time thereafter to allow members to recover accounts if they decide to reactivate, to analyze the data for Trustr“s own operations, and for backup purposes for a limited time. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact Trustr“s data protection officer at dpo@trustr.com

Note that if you correspond with us, we may retain such correspondence and the information contained in it and use it to respond to your inquiry; to notify you of services; or to keep a record of your complaint, request, or other concern. If you ask Trustr not to contact you by email at a certain email address, Trustr will retain a copy of that email address in its “master do not send” list in order to comply with your no-contact request.

Other Websites

When you use our Services, you may be able to visit or link to other websites not operated by us. We do not control such websites and are not responsible for the privacy practices of these websites. We encourage you to read the posted privacy policies of such websites before you take any actions.

Details Regarding Disclosure of Personal Information

In addition to other details provided in this Privacy Policy, some U.S. state laws require the following disclosures.

We obtain the categories of personal information from the sources described above in the Privacy Policy.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

Sharing Personal Information

We may disclose your personal information to service providers for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve(12) months, we have not disclosed personal information for a business purpose.As we launch the Trustr Services, we anticipate disclosing the following personal information:

• Identifiers.
• Personal information categories.
• Commercial information.
• Internet or other electronic activity information.
• Geolocation data.

In the preceding twelve(12) months, we have not sold any personal information.

Privacy Rights Under U.S. Laws

Residents of some states have specific rights related to their personal information. This includes California residents who have these rights under the California Consumer Privacy Act (“CCPA”). This section describes those rights and explains how to exercise those rights.

Right to Access Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you(also called a data portability request).

Right to Request Correction

You may have the right to request in certain circumstances that we correct personal information we have collected about you. Some information may be exempt from such requests under law.

Right to Request Deletion

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. If you request that we delete your personal information, you may no longer be able to access or use our Services.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Comply with the California Electronic Communications Privacy Act(Cal.Penal Code § 1546 seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Limit Use of Your Sensitive Personal Information

Residents of California have the right to limit our use of sensitive personal information if we use that information to infer certain characteristics about them. We do not currently use sensitive personal information for such purposes. In some states, we may be required to obtain your consent before collecting sensitive personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, correction, and deletion rights described above, please submit a request to us by either:

• Calling us at 415-269-7616
• Sending an email to us at dpo@trustr.com

You may only make a request for access or data portability twice within a 12-month period. Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will only use personal information provided in a request to verify the requestor‘s identity or authority to make the request.

We attempt to respond to a consumer request within 45 days of its receipt.If we require more time(up to 90 days), we will inform you of the reason and extension period in writing.

Non-Discrimination

We will not discriminate against you for exercising any of your rights related to your personal information. For example, we will not:

• Deny you goods or services.
• Charge you different prices, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of services based on your decision to exercise your rights.

Profiling

We do not engage in “profiling” to further any decision-making that has legal or other similarly significant consequences. For example, we do not use profiling to deny or grant access to our Services or to further employment decisions.

Right to Control Information

You may opt out of any future contacts from us at any time. To do so, or to express any other concerns over our use of your data, please contact us at the email address or phone number provided below, and on our website.

Right to Appeal

Some states allow residents to appeal our decision regarding how they may exercise their rights regarding their personal information. You may do so by contacting us as described in the written notice we provide you in response to your request.

Privacy Notice for Residents of the EEA and UK

Trustr has its headquarters in the United States. By using the Trustr’s services, you acknowledge that your personal information will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR.

Depending on the circumstance, Trustr collects and transfers to the U.S.personal data with your consent or to perform a contract with you, including to operate the Trustr platform and provide services to you as described in this Privacy Policy.

No matter where you are located, Trustr endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Trustr and the practices described in this Privacy Statement.Trustr also enters into appropriate agreements with its vendors and subprocessors. Since it was founded in 2022, Trustr has received no government requests for information.

Data Subject Rights

The European Union‘s General Data Protection Regulation and other countries‘ privacy laws provide certain rights for data subjects. An explanation of these rights (in English) is available on the website of the United Kingdom‘s Information Commissioner‘s Office.

This Privacy Policy is intended to provide you with information about what personal data Trustr collects about you and how it is used. If you have any questions or want to exercise any of your rights, please contact us at dpo@trustr.com

You may also request information about:

• The purpose of the processing; the categories of personal data concerned; who else outside Trustr might have received the data from Trustr;
• The source of the information (if you didn‘t provide it directly to Trustr).
• How long it will be stored.

You also have the right to:

• Correct (rectify) the record of your personal data maintained by Trustr if it is inaccurate.
• Request that Trustr erase that data or cease processing it, subject to certain exceptions.
• Request that Trustr stop using your data for direct marketing purposes.

In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Trustr processes your personal data. When technically feasible, Trustr will — at your request — provide your personal data to you or transmit it directly to another controller.

Reasonable access to your personal data will be provided at no cost to individuals with a Trustr account, upon request made to Trustr at dpo@trustr.com If access cannot be provided within a reasonable time frame, Trustr will provide you with a date when the information will be provided. If for some reason access is denied, Trustr will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email Trustr at dpo@trustr.com If you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation‘s data protection authority.

How to Contact Us

If you have any concerns, questions, or comments regarding this Privacy Policy or our privacy practices, please contact us via telephone at 415-269-7616 or via email at dpo@trustr.com