This document is a working draft prepared for launch. Have your counsel review it against your final data-processing arrangements before you publish it.
01

Who we are and what this covers

TryTrustable ("we", "us") provides the TryTrustable compliance, security and consent platform, the trytrustable.com website, the TryTrustable SDK and the consent banner our customers place on their own websites and apps. TryTrustable is based in India.

This policy explains what personal data we handle, why, who we share it with, how long we keep it and the rights you have. It is written to meet India's Digital Personal Data Protection Act, 2023 and the DPDP Rules, 2025, the EU and UK GDPR, and US state privacy laws including the CCPA.

Our two roles. For our website, your account, billing and our own communications, we decide why and how personal data is used, so we are the Data Fiduciary (DPDP) or controller (GDPR). For the data our customers put into the platform, including the consent records of visitors to a customer's website, the customer decides, and we act as their Data Processor or processor under our agreement with them. If you are a visitor to a customer's site or an employee of a customer, contact that organisation first; we will help them answer you.

02

The personal data we collect

CategoryExamplesWhere it comes from
Account and contactName, work email, company, job role, sign-in and MFA settingsYou, when you sign up, book a demo or contact us
Support and correspondenceMessages, call notes, attachments you send usYou
BillingBilling contact, company tax details, plan and invoices. Card details go directly to the payment processor and never reach usYou, and our payment processors once paid checkout is enabled
Product usage and securityActions in the platform and their timestamps, the audit trail, sign-in events, IP address and browser of a sessionGenerated when you use the platform
WebsitePages viewed, referring page, device and browser type; analytics identifiers only if you accept analytics cookiesYour browser, our website host and, with consent, Google Analytics
Data from your connected systemsConfiguration and user lists from GitHub, AWS, Google Cloud, Okta or Google Workspace, such as staff names, emails, MFA status and admin rolesIntegrations a customer connects (we act as processor)
SDK findingsA finding with the single code line it points to (credentials redacted), file paths, line numbers; consent discovery sends paths, lines and the matched fragment, never file contentsThe SDK running in a customer's own pipeline (processor)
Consent recordsThe choice made, purposes, notice version, language, regime, timestamp and a salted hash prefix of the IP address, never the address itselfThe consent banner on a customer's site (processor)
03

Cookies and similar technologies

The platform uses one strictly necessary session cookie to keep you signed in, protected against cross-site requests. Our website and the consent banner store your consent choice (trytrustable_consent) and your language so you are not asked again; these are strictly necessary.

Website analytics, only with consent. If you accept analytics cookies, we load Google Analytics 4 to understand which pages are read and how visitors find us. It is not loaded at all until you agree. It sets cookies such as _ga and _ga_*, which last up to two years, and Google may process the data outside your country, including in the United States. We do not use advertising cookies, and we keep analytics event data for no longer than 14 months.

You can change or withdraw your choice at any time from the Cookie settings link in the footer. Withdrawing is as easy as consenting was.

04

How we use personal data, and on what basis

PurposeBasis (GDPR)Basis (DPDP)
Provide the platform, your account and supportContractConsent given when you sign up, or the s.7(a) voluntary-provision use
Keep the service secure: authentication, abuse and fraud prevention, loggingLegitimate interestsLegitimate use and the security duty in s.8(5)
Bill for paid plans and keep tax recordsContract and legal obligationLegal obligation
Improve the product from aggregated, de-identified usageLegitimate interestsConsent, where personal data is involved
Website analyticsConsentConsent
Product news and marketing emailsConsent (or legitimate interests for existing customers, with an easy opt-out)Consent
Meet legal obligations, such as CERT-In log retention and responding to authoritiesLegal obligationLegal obligation
05

AI and machine learning

We do not use customer data, consent records or your personal data to train AI models, ours or anyone else's.

No AI model provider is connected to the production platform today, so no customer data is sent to one. If we enable an AI-assisted feature, we will list the provider in this policy first, send it only the snippets the feature needs, and let customers switch the feature off.

06

Who we share it with

We do not sell personal data, and we do not share it for cross-context behavioural advertising. We share it only with the service providers below, each under a written agreement that limits them to processing on our instructions, and where the law requires it.

ProviderWhat it does for usLocation
Google CloudHosts the platform and its databaseIndia (Mumbai)
ResendSends transactional email: sign-in, invitations, alertsUnited States
HostingerHosts the trytrustable.com website and keeps its server logsData centre used for the website
Google AnalyticsWebsite analytics, only if you consentUnited States and other locations
Stripe; Razorpay (rupee payments)Payment processing, once paid checkout is enabledUnited States / India

We may also disclose personal data to professional advisers under confidentiality, to a buyer or successor if the business is sold or merged (with this policy continuing to apply), and to authorities when a law, court order or regulator requires it. We tell you about such a request when the law allows us to.

07

Where your data is stored

The platform and its database run on Google Cloud in Mumbai, India, for every customer. We are expanding to Singapore, the US and the EU.

Some providers above are outside India, so data reaches them through a transfer. Transfers out of India are permitted under s.16 of the DPDP Act except to countries the Government restricts. For data covered by the EU or UK GDPR, we rely on an adequacy decision where one exists, or on Standard Contractual Clauses with additional safeguards.

08

How long we keep it

DataHow long
Account dataFor the life of the account, then 12 months, unless the law requires longer
Customer data in the platformAs the customer configures it; deleted after the 30-day export window that follows termination
Consent recordsFor the period the customer configures, which needs to cover how long they must be able to prove consent
Security, access and audit logsAt least one year, as the DPDP Rules require, and longer where an investigation needs it
Billing and tax recordsAs long as tax law requires
Website analyticsNo more than 14 months
BackupsA limited rolling period; deleted data leaves backups as they expire
09

How we protect it

  • Encryption in transit (TLS) and at rest
  • Credentials for connected systems encrypted with AES-256-GCM; integrations read-only by default
  • Multi-factor authentication, single sign-on (OIDC) and role-based access in the platform
  • Access to production limited to the people who need it, and logged
  • A tamper-evident audit trail, and consent records that store a salted hash of the IP, not the address
  • Credentials removed from SDK findings before they leave your environment

No system is perfectly secure. If a personal data breach affects you, we tell the affected customers and people without undue delay, and the authorities within the time the law sets: the Data Protection Board of India under the DPDP Rules, CERT-In within six hours for reportable incidents, and the supervisory authority within 72 hours under the GDPR.

10

Your rights

Under the DPDP Act you can ask for a summary of your personal data and who it was shared with, ask us to correct, complete, update or erase it, withdraw consent, have a grievance answered, and nominate someone to exercise these rights if you die or become unable to.

Under the GDPR and UK GDPR you can ask for access, rectification, erasure, restriction and portability, object to processing based on legitimate interests or for direct marketing, withdraw consent, and complain to your data protection authority.

Under US state laws such as the CCPA you can ask to know, correct and delete your personal data, and to opt out of its sale or sharing, which we do not do. We will not treat you differently for using these rights.

How to ask. Email privacy@trytrustable.com. We may ask you to confirm your identity so we do not disclose your data to someone else, and we answer within 30 days. Where we hold your data for a customer, we pass the request to them and help them answer it.

11

Make a privacy request

Use this form to ask for a summary of your personal data, to correct or erase it, to withdraw consent, to raise a grievance, or to nominate someone to exercise your rights if you die or become unable to. It goes straight into our request queue, which records when it arrived and when it is due. We reply by email and may ask you to confirm it is you before we disclose or erase anything.

12

Children

The platform is a business service and is not directed at anyone under 18. We do not knowingly collect personal data from children. If you believe a child has given us personal data, write to privacy@trytrustable.com and we will delete it.

13

Grievances and contact

Questions, requests and complaints about personal data: privacy@trytrustable.com. Our Grievance Officer and Data Protection Officer can be reached at the same address. We acknowledge a grievance promptly and resolve it within 30 days.

If you are not satisfied with our answer, you can complain to the Data Protection Board of India, or to your data protection authority in the EU or the UK.

14

Changes to this policy

When we change this policy we update the date at the top. If a change materially affects how we use your personal data, we tell you by email or in the platform before it takes effect and, where the law requires it, ask for your consent again.