These documents are template-level information for transparency. They are not certified legal translations or lawyer-approved equivalents in every language. For binding advice, consult qualified counsel. Enterprise customers receive executed MSA, Order Form, and counter-signed DPA — see Enterprise contracting.

Policy version: 2026-07-13 · EN

Privacy Policy

Version: 2026-07-13 · Controller: Soluzyn OÜ (Registry code 17387492), Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551, Estonia

1. Scope

Applies to trustoriginality.ai, panel, APIs, SDKs, mobile apps.

2. Data we collect

Category Examples
Account Name, email, password hash, company
Verification Text, images, audio, video
Technical IP, browser, device, logs
KYC/biometric Selfie, voice, ID — special category
Cookies Cookie Policy
Purpose Basis
Services Contract Art. 6(1)(b)
Security Legitimate interests
Analytics cookies Consent
Marketing Consent
Legal Legal obligation

4. Website analytics (marketing site)

On trustoriginality.ai we use the tools below only after you consent to performance/analytics cookies in our cookie banner (legal basis: GDPR Art. 6(1)(a) consent; ePrivacy opt-in).

Tool Processor Purpose Typical data
Web analytics Google LLC Usage statistics, pages viewed Pseudonymous identifiers, IP (may be truncated), browser/device, referrer
Session analytics Microsoft Corporation Session analytics, heatmaps Interaction events, page snapshots (masking where configured), device/browser

Default: analytics cookies and scripts are off until you click Accept all or enable Performance / analytics in Cookie Settings. Withdraw consent anytime via footer Cookie Settings.

See Cookie Policy and Sub-processor List. Google Privacy Policy · Microsoft Privacy Statement.

5. Automated analysis & profiling (Art. 22)

Outputs are decision-support only and are not used as sole automated decisions with legal or similarly significant effects under GDPR Art. 22(1). Deployers must ensure human oversight.

Trust Score and detection signals are decision-support only. They are not used as the sole automated decision-making mechanism producing legal or similarly significant effects about you. If you use our Service to evaluate individuals (as data controller), you are responsible for human oversight and a valid legal basis.

6. Sharing & subprocessors

Service providers. We do not sell personal data.

7. International transfers

International transfers use SCCs or adequacy decisions.

8. Retention

Data Period
Account Until deletion + 2 years billing
Verification 48 hours default
Logs 1–3 years

9. Security

TLS 1.3, AES-256, RBAC, MFA.

10. Your rights

Under GDPR (and, where applicable, KVKK) you may request:

  • Access and a copy of your personal data
  • Rectification of inaccurate data
  • Erasure (“right to be forgotten”)
  • Restriction of processing
  • Portability (structured export where applicable)
  • Objection to certain processing
  • Withdrawal of consent where processing is based on consent

How to exercise these rights

Request Self-service Alternative
Export / portability Sign in to the panel and download a JSON export (also linked from Data deletion) Email info@trustoriginality.ai
Erasure of personal data Data deletion → sign in, optional export, then confirm with password and type DELETE Email info@trustoriginality.ai with your registered email
Close account (same erasure flow) Account deletion → sign in and confirm deletion Email info@trustoriginality.ai
Restriction / objection / other DSAR — Email info@trustoriginality.ai

Notes: Self-service erasure permanently removes personal data tied to the panel account (profile, analysis history, stored reports, API keys) and closes the account. Billing identifiers may be anonymised and some invoices retained where tax or accounting law requires it. Security logs may be anonymised and kept for a limited period. We may need to verify your identity before acting on email requests.

Public instructions: Account deletion · Data deletion · Data retention & deletion

11. Supervisory authority

Complaint: AKI — https://www.aki.ee or your local EU authority.

12. Children

Not directed at under-16s.

13. DPO

Uğur Seçginli — info@trustoriginality.ai

14. Company details