Privacy Policy

Updated April 26, 2024

This Privacy Policy is effective for all users of our services and visitors to the website maintained atwww.trustate.com (the “Site”) operated by Trustate Corporation (“Trustate,” “us,” “we” or “our”). This Privacy Policy pertains to Site visitors (“Visitors” or “you”), users of our services, and any other ways in which you may communicate (e.g., via telephone) or interact with Trustate.

Business to Business

At this time, Trustate offers the Site and its services only to businesses, business owners and their authorized users for business purposes and with written consents required under applicable federal and state laws and regulations and privacy rules and policies.  The Site is not intended for consumers.

When you provide CONTACT information to Trustate, we request that it be business contact information. If you provide personal information instead, this does not make this a consumer transaction.  While we use reasonable measures to secure any personal information disclosed to us, privacy rights associated with a consumer transaction, as a general matter, do not apply to the Site.

Limitation of Storage of Personal Information

Please note that you must limit the amount of personal information uploaded to, transmitted to, stored on, or otherwise disclosed to the Site to the extent required in connection with your appropriate and permitted use of the Site.

Scope

This Privacy Policy describes how we collect, use, process, and disclose the limited (if any) personal information when Visitors access this Site. This Privacy Policy does not apply to Users of our Services, from whom we do receive certain personal information regarding third parties.  For information regarding the processing of personal information in relation to the Services, please see our Terms of Service.  We have adopted this Privacy Policy to inform you of our information gathering practices and the ways in which we may use the limited personal information we receive from Site Visitors. This Policy applies to all personal information submitted to us for use with or in connection with the Site (but again, not in regard to Personal Information processed in relation to the Services we provide).  Your use of the Site is governed by our Terms of Use and this Privacy Policy.  This Privacy Policy is incorporated into our Terms of Use and Terms of Service, only as to users of our services, and therefore governs your use of our services.

THIS PRIVACY POLICY DOES NOT APPLY TO THE DATA PROVIDED IN RESPONSE TO USERS’ REQUESTS;  THIS POLICY RELATES TO OUR COLLECTION AND PROCESSING OF SITE VISITORS AND USERS OF OUR SERVICES.

Acceptance of this Privacy Policy

By accessing the Site, you are agreeing to be bound by this Privacy Policy and the Terms of Use. By using the Site, you consent to the collection, use, processing, and disclosure of that information in accordance with this Privacy Policy. If you have questions or concerns about this Privacy Policy or would like to exercise any of your rights or learn more about how your data is used, you can contact us at privacy@trustate.com. If you have a disability and are having trouble accessing this Privacy Policy, please contact us. Please see Contact Information.

You acknowledge that the Terms of Use contain a binding arbitration clause and class action waiver that impact your rights regarding resolving disputes that are not otherwise waived pursuant to the terms of your agreement with Trustate. If you live in the United States, such provisions are binding on you and Trustate. Please read the arbitration clause and class action waiver contained in the Terms of Use carefully. If you disagree or are uncomfortable with the Terms of Use, or this Privacy Policy, please discontinue your use of the Site, otherwise, you will have consented to arbitrate disputes with Trustate which arise under this Privacy Policy and the Terms of Use.

Changes To This Policy

We may modify or update this Privacy Policy from time to time, which will be indicated by changing the date at the top of this page. If we make any material changes, we  will notify you by means of a notice on the Site or as otherwise required by law. We encourage you to review this page periodically for the latest information on our privacy practices.

Geographic Restrictions

The Site is based in the United States. Access to the Site may not be legal by certain persons outside of the United States. If you access the Site from outside of the United States, you do so on your own initiative and are responsible for compliance with local laws.

Children's Privacy

The Site is not intended for persons under the age of 18 (or the age of majority in your state).  Trustate does not knowingly receive or solicit data from children under 18 years of age (or the age of majority in your jurisdiction). By using the Site, you represent to Trustate, intending for Trustate to rely thereon, that you are at least 18 (or the age of majority in your jurisdiction). If Trustate learns that information is collected from someone who is less than 18 years, Trustate will take reasonable measures to promptly delete such data from its records. If you become aware of any data Trustate may have collected from children under age 18 (or the age of majority), please contact Trustate at privacy@trustate.com.

Types of Information and Data Trustate Collects

This section includes all of the information that we may collect about you, but we will rarely collect all of these types of information about a Site Visitor or Site User.

As used in this Privacy Policy, “Personal Information” means information that relates, and is capable of being linked, toa particular person. For purposes of this Privacy Policy, Personal Information includes but is not limited to the following:

The Personal Information we collect depends on

For purposes of the Site, we only collect limited information as noted above.  We do not, through the Site, collect social security numbers, birthdates and/or other sensitive personal information about a Visitor or user.  Should you purchase Trustate services that require the collection and use of sensitive personal information, at that time, you will be advised as to the information we collect, and we will ask you at that time to confirm your consent and agreement therewith.

As stated above, we are a business-to-business service provider.  While we use reasonable efforts to protect the information you provide to us, as discussed further below, we cannot guarantee your privacy.  Accordingly, we ask that you not share with us Personal Information, and instead limit the information you share with us to your business contact information.  

How Trustate Collects Your Information

In this section of the Privacy Policy, we explain where and how we collect data from you. When you provide information upon request or submission, please provide business points of contact, rather than personal (home) points of contact.

                      o   name

                      o   email address

                      o   company name and location

                      o   name

                      o   email address

                      o   company name and address

                      o   title

                      o   telephone contact information

                      o   Online Identifiers

                                    §  geo location/tracking details

                                    §  browser fingerprint

                                    §  operating system

                                    §  browser name and version

                                    §  IP addresses for the device from which you access the Site

                      o   Usage Data

                                    §  authentication data

                                    §  security questions

                                    §  click-stream data

                      o   Information Captured via Server Logs

                                    §  how you visited to the Site and how you interact online

                                    §  your device type and unique device identification numbers

                                    §  your device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL)

                                    §  how your device interacts with the Site, including pages accessed and links clicked

                                    §  geographic location

                                    §  other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser

                      o   Information Captured via External Links

                      o   Information Captured via Log Files

                                    §  IP addresses

                                    §  browser type

                                    §  Internet service provider (ISP)

                                    §  referring/exit pages

                                    §  platform type

                                    §  date/time stamp

                                    §  number of clicks

                      o   See section Cookies and Similar Technologies

How Trustate Uses Your Information

In this section of the Privacy Policy, we explain our commercial and business purposes for collecting information from you.

We gather Personal Information about you in order to respond to your requests and provide you with appropriate information about our services and resources.  However, in some instances, we may combine information that we have collected from multiple sources in order to fulfill these purposes. Trustate potentially uses each category of information that we collect for each of these purposes.

(1) Providing Services. Trustate uses information for the purpose of providing services. We may also use information to respond to inquiries from potential customers who are interested in learning more about our services. Examples of the types of uses of your information for these purposes include is not limited to the following:

o   producing and delivering documents purchased by you

o   administering the Site

o   displaying content based on your preferences

(2) Communicating with You. Trustate uses information for the purpose of sending information to you to keep you updated about our services, informing you of relevant updates, addressing any questions or to troubleshoot problems. Based on your communication preferences, we may also send you marketing communications (e.g., emails or mobile notifications) to inform you of new services.  You can always opt out of receiving these materials by clicking on the opt out link in each such marketing communication you may receive.  

(3) Security. We may collect information for the purposes of detecting fraud or other suspicious activities.

(4) Meeting Legal Requirements. Trustate collects information in order to meet our legal obligations. These obligations may include satisfying screening requirements prior to assisting with estate administration related service work and information requests.  We also may use your contact information to notify you of incidents relating to our processing of your Personal Information.

(5) Marketing. Trustate collects information for use in marketing to current and prospective customers according to your indicated preferences. You can opt-out of receiving marketing materials and/or change your preferences at any time by emailing privacy@trustate.com.  

(6) Development. Trustate collects information for researching and improving our existing services and developing new services.

(7) Analytics. Trustate collects information for use in performing various types of analytics. For example, Trustate uses information to analyze how you interact with the Site, where you arrive from and exit to, and gaining insights into the types of Visitors that may be interested in our services. We may also use information to develop inferences from the information we collect regarding your preferences, characteristics, predispositions, behaviors, and attitudes.

(8) Operational Purposes. Trustate collects information for use for our operational purposes, and the operational purposes of our service/data providers and business partners. For instance, Trustate may use information for maintaining the Site and other infrastructure, training and quality assurance, for conducting surveys or sweepstakes, to promote our brand, and to use in connection with our relationships with service/data providers and business partners.

(9) Financial Reporting. Trustate collects information for use in various types of financial reporting and other similar internal uses. Examples of the types of financial reporting that Trustate may use your information in connection with our internal budgets and projections, calculation of compensation, and reporting to investors. This information is on an aggregated basis and will never mention any one individual from a corporate entity customer of Trustate.

(10) De-Identified or Aggregate Data. In addition to the purposes listed above, Trustate may also use de-identifiedor aggregate data that is not capable of being linked to any Visitor or user for additional purposes not listedabove.

In addition to the above, Trustate may disclose your Personal Information for any purpose for which you provide consent. We will not use your Personal Information for purposes other than those purposes disclosed in this Privacy Policy and the Terms of Use or Terms of Service, at the time the information is collected without your permission. From time to time, and as required under the applicable law, we may request your permission to allow it to share your contact information (including any Personal Information provided) with third parties.

Cookies and Similar Technologies

This section expands on how Trustate uses Internet technologies, such as cookies, to collect information about you.

·      Cookies. Trustate and its service providers may use the standard cookie feature of major browser applications and third-party service/data providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration and Google Analytics Demographics and Interest Reporting), or employ internally developed cookies and tracking codes, that allow Trustate to store a small piece of data on a your computer, or any other device a you use to access the Site, about your visit to the Site or use of other plug-ins exchanging information with Trustate. We also use similar technologies, such as JavaScripts or ETags, to analyze trends, administer the Site, track users’ movements around the Site, and to gather demographic information about our user-base. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. You may also control which cookies are placed on your browser when you visit the Site through our cookie preference center. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as order forms, will be limited.

·      Web Beacons. “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize the Site and to collect a limited set of information about you.

·      Third Party Tracking. The use of tracking technologies by our service/data providers, technology partners or other third party assets (such as social media links) on the site is not covered by our Privacy Policy. These third parties may use cookies, clear gifs, images, and scripts to help them better manage their content on theSite. We do not have access or control over these technologies.

·      Partner and Affiliate Tracking. Our partners and affiliates, including Google Analytics (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics and Interest Reporting), may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may show our ads on sites across the Internet based upon your previous visitsto the Site. Together with our partners and affiliates, we may use these cookies and web beacons to report howyour ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to the Site.

If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://aboutads.info/choices.

If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. You may also learn more about how Google Analytics uses your information by visiting Google’s page https://policies.google.com/technologies/partner-sites. You may also visit Google Analytics’ Ads Settings at https://adssettings.google.com/u/0/authenticated?hl=en to opt out of Google’s use of cookies and customize Google Display Network ads, and Google Analytics’ Opt Out Browser Add-on for the web - https://tools.google.com/dlpage/gaoptout/.

Third Party Sites, Resources and Services

Trustate may maintain links to other websites and other websites may maintain links to the Site. This Privacy Policy applies only to www.trustate.com and not to other websites accessible from Trustate or that you use to access Trustate, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites, Trustate is not responsible for the privacy practices or content of those websites. It is your responsibility to review the privacy policies of non-Trustate websites to confirm that you understand and agree with them.

Disclosure of Your Information to Third Parties

In this section of the Privacy Policy, we explain who we share your information with and under which circumstances we may do so.

·      Service/Data Providers. Trustate contracts with its service providers which help it to maintain and operate the Site, requiring those service providers to only use your information in connection with the services they perform for Trustate, and contractually proscribe them from selling your information to anyone for any purpose.  Examples of the types of service providers Trustate may share personal information with (other than those mentioned above) include but are not limited to the following:

·      Our Business Partners. Trustate collects information in order to provide business partners information inconnection with Visitors or users who have either expressed interest in hearing from the business partner or who have purchased a bundled service through Trustate. Trustate may share information with business partners in limited circumstances, including but not limited to the following:

·      Public Postings. Trustate may publicly share information about Visitors, such as by displaying the information on the Site or having the information published in publicly available media, in a limited number of circumstances. For example, at some point in the future, the Site may include areas where Visitors may voluntarily interact with each other, including a question and answer section. Any information that is provided in this area of the Site may be publicly available. You should use caution when deciding whether to disclose your Personal Information in these areas of the site. To request removal of your information from our community forums, contact us at privacy@trustate.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

·      Required by Law. Trustate may disclose your information as required by law

·      Business Transfers and Related Parties. If Trustate undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including information related to Visitors and users in connection with the transaction or in contemplation of the transaction (such as conducting due diligence). If such an event occurs, your information may be treated like any other Trustate asset and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

·      De-Identified or Aggregate Data. In addition to the circumstances listed above, Trustate may also share de-identified or aggregate data that is not capable of being linked to any Visitor with additional entities not listed above.

Privacy Rights and Requests

This Site is only for business purposes, and Trustate offers business-to-business services only. Therefore, the collection of your Personal Information is in the context of, and in support of, a business transaction, not a consumer transaction.  As such, this transaction, and your rights are not governed by consumer privacy laws to the fullest extent allowed in your jurisdiction.

Nevertheless, where doing so does not interfere with, or impede Trustate’s administration of the Site, or compliance with applicable laws, we will endeavor to comply with your requests.  

Further, your rights to Personal Information are not absolute. Depending upon the applicable law, access may be denied as follows:

·      when denial of access is required or authorized by law

·      you are a resident of a state that does not provide for this right

·      when granting access would have a negative impact on another’s privacy

·      to protect our rights and properties

·      where the request is frivolous or vexatious, or for other reasons

Nevertheless, Trustate will accommodate reasonable requests where possible and not excessive.  

·      Submitting a Request. You can make privacy rights requests relating to your Personal information by contacting Trustate at email us at privacy@trustate.com or call 618-437-8283 (618-4-ESTATE). When we receive an individual rights request via other intake methods, we may, or where required by law, will take steps to verify your identity before complying with the request to protect your privacy and security. You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide Trustate with written permission for the agent to make the request on your behalf or provide us with an executed power of attorney.

·      Verification of a Request. After you submit the request, you will be asked to verify your email address and may also be asked to provide additional information to verify your identity, including potentially providing a declaration under penalty of perjury. Trustate will attempt to verify your identity by asking for information that correlates with the information that we have previously collected about you. Where this is not possible, Trustate may request you submit additional information for verification, such as proof of residency or redacted government-issued identification. Please note that we will be unable to satisfy your request until we have verified your identity.

·      Trustate’s Response to a Request. Upon a verified request, and subject to the privacy interests of others and technical limitations, Trustate will provide you with information about whether we hold any information related to you, information about your orders and similar information. This may include information about the nature and status of your order, information you provided to process your order, payment information, and contact information. If you want someone to have access to your order, you must list him or her as an authorized contact or they may not obtain information. You can confirm who is listed as an authorized contact for your account, add new authorized contacts, or remove authorized contacts by clicking first on "My Account," and then on "Account Information". We may send a confirmation email to your authorizedcontact(s), alerting them that they have been added as an authorized contact. For some services, we may provide information about your order to other individuals named in the order, such as executors named in a last will. For service-specific information about who may request information about your order, please contact us at privacy@trustate.com.

If you believe that Trustate has infringed your rights, please contact Trustate at privacy@trustate.com.

Accessing, Updating, and Storing Your Information;  Account Termination

·      Access and Update to Account. You may access your account profile at any time by logging into the portal and clicking on the "My Account" link. Through My Account, you may review and update basic information about you. You may also update your information at any time by contacting Trustate’s support team atinfo@trustate.com or call 618-437-8283 (618-4-ESTATE).

·      Deletion. You may request deletion of your information. We may, however, be required to maintain certain information by law. Certain federal and state regulations require that we maintain a record of your information for certain periods of time. Due to these regulations, we may be unable to completely delete your information from its database until the time requirements of these regulations have expired.  In these cases, your information will not be used for any purpose (other than compliance with regulatory or legal obligations) and will be deleted in accordance with applicable data destruction laws or Trustate’s data destruction policies.

·      Retention. At minimum, we will retain your information for as long as needed to provide services to you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Trustate may maintain some or all of this data in its archives even after it has been removed from the Site. While retention requirements vary by jurisdiction, information about Trustate’s typical retention periods for different aspects of your personal information are described as follows:

Security

We have implemented reasonable technological, administrative and operational controls intended to protect information collected through the Site from loss, misuse, unauthorized access, exfiltration and/or alteration. Credit card and Personal Information are transmitted by secure servers (TLS). Documents are delivered to you via UPS or similar delivery services, the United States Postal Service, or electronically, including through online storage platforms oremail. In all cases, we will exercise reasonable care to endeavor to provide secure transmission of information between your computer and our servers but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot guaranty or warrant the security of any information transmitted to Trustate over the Internet.

YOU MUST CAREFULLY CONSIDER WHAT INFORMATION YOU SHARE WITH US, AS WE CANNOT GUARANTEE THAT WE WILL BE ABLE TO BLOCK ALL ATTEMPTED ATTACKS TO THE SECURITY OF THE SITE. HENCE, YOU PROVIDE THIS INFORMATION AT YOUR OWN RISK. ALTHOUGH WE USE REASONABLE SECURITY PRECAUTIONS WITH RESPECT TO THE LIMITED PERSONAL INFORMATION WE MAY COLLECT THROUGH THIS SITE, WE CANNOT GUARANTEE THAT ANY OF YOUR PERSONAL INFORMATION STORED ON OUR SERVERS WILL BE FREE FROM UNAUTHORIZED ACCESS.  TO THE FULLEST EXTENT NOT PROHIBITED BY LAW, WE DISCLAIM AND SHALL HAVE NO LIABILITY FOR ANY LOSS OF, UNAUTHORIZED ACCESS OR DAMAGE TO, OR INTERCEPTION OF ANY OF YOUR PERSONAL INFORMATION STORED ON OUR SERVERS WHEN YOU ACCESS THE SITE.  

IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED, PLEASE CONTACT US IMMEDIATELY BY EMAILING PRIVACY@TRUSTATE.COM.

For further information, please see Trustate’s Terms of Use.

Choice/Opt-Out

We send promotional emails and newsletters from time to time to Visitors who have provided us with their email address or whose email addresses we have obtained through other sources. You can opt-out of promotional communications by using the “Unsubscribe” link and following the unsubscribe instructions in an email you receivefrom us or by emailing us at info@trustate.com. We may also send service-related or transactional communications, which are not promotional. Generally, you may not opt-out of these communications. If you do not wish to receive service-related communications, you may terminate your account by contacting us at info@trustate.com.

Contact information

You can contact Trustate about this Privacy Policy by writing or email Trustate at the address below:

Attn: Trustate Privacy Team

802 E. Whiting Street

Tampa, FL 33602

privacy@trustate.com

This Privacy Policy is effective for all users of our services and visitors to the website maintained atwww.trustate.com (the “Site”) operated by Trustate Corporation (“Trustate,” “us,” “we” or “our”). This Privacy Policy pertains to Site visitors (“Visitors” or “you”), users of our services, and any other ways in which you may communicate (e.g., via telephone) or interact with Trustate.

Business to Business

At this time, Trustate offers the Site and its services only to businesses, business owners and their authorized users for business purposes and with written consents required under applicable federal and state laws and regulations and privacy rules and policies.  The Site is not intended for consumers.

When you provide CONTACT information to Trustate, we request that it be business contact information. If you provide personal information instead, this does not make this a consumer transaction.  While we use reasonable measures to secure any personal information disclosed to us, privacy rights associated with a consumer transaction, as a general matter, do not apply to the Site.

Scope

This Privacy Policy describes how we collect, use, process, and disclose the limited (if any) personal information when Visitors access this Site. This Privacy Policy does not apply to Users of our Services, from whom we do receive certain personal information regarding third parties.  For information regarding the processing of personal information in relation to the Services, please see our Terms of Service.  We have adopted this Privacy Policy to inform you of our information gathering practices and the ways in which we may use the limited personal information we receive from Site Visitors. This Policy applies to all personal information submitted to us for use with or in connection with the Site (but again, not in regard to Personal Information processed in relation to the Services we provide).  Your use of the Site is governed by our Terms of Use and this Privacy Policy.  This Privacy Policy is incorporated into our Terms of Use and Terms of Service, only as to users of our services, and therefore governs your use of our services.

THIS PRIVACY POLICY DOES NOT APPLY TO THE DATA PROVIDED IN RESPONSE TO USERS’ REQUESTS;  THIS POLICY RELATES TO OUR COLLECTION AND PROCESSING OF SITE VISITORS AND USERS OF OUR SERVICES.

Acceptance of this Privacy Policy

By accessing the Site, you are agreeing to be bound by this Privacy Policy and the Terms of Use. By using the Site, you consent to the collection, use, processing, and disclosure of that information in accordance with this Privacy Policy. If you have questions or concerns about this Privacy Policy or would like to exercise any of your rights or learn more about how your data is used, you can contact us at privacy@trustate.com. If you have a disability and are having trouble accessing this Privacy Policy, please contact us. Please see Contact Information.

You acknowledge that the Terms of Use contain a binding arbitration clause and class action waiver that impact your rights regarding resolving disputes that are not otherwise waived pursuant to the terms of your agreement with Trustate. If you live in the United States, such provisions are binding on you and Trustate. Please read the arbitration clause and class action waiver contained in the Terms of Use carefully. If you disagree or are uncomfortable with the Terms of Use, or this Privacy Policy, please discontinue your use of the Site, otherwise, you will have consented to arbitrate disputes with Trustate which arise under this Privacy Policy and the Terms of Use.

Changes To This Policy

We may modify or update this Privacy Policy from time to time, which will be indicated by changing the date at the top of this page. If we make any material changes, we  will notify you by means of a notice on the Site or as otherwise required by law. We encourage you to review this page periodically for the latest information on our privacy practices.

Geographic Restrictions

The Site is based in the United States. Access to the Site may not be legal by certain persons outside of the United States. If you access the Site from outside of the United States, you do so on your own initiative and are responsible for compliance with local laws.

Children's Privacy

The Site is not intended for persons under the age of 18 (or the age of majority in your state).  Trustate does not knowingly receive or solicit data from children under 18 years of age (or the age of majority in your jurisdiction). By using the Site, you represent to Trustate, intending for Trustate to rely thereon, that you are at least 18 (or the age of majority in your jurisdiction). If Trustate learns that information is collected from someone who is less than 18 years, Trustate will take reasonable measures to promptly delete such data from its records. If you become aware of any data Trustate may have collected from children under age 18 (or the age of majority), please contact Trustate at privacy@trustate.com.

Types of Information and Data Trustate Collects

This section includes all of the information that we may collect about you, but we will rarely collect all of these types of information about a Site Visitor or Site User.

As used in this Privacy Policy, “Personal Information” means information that relates, and is capable of being linked, toa particular person. For purposes of this Privacy Policy, Personal Information includes but is not limited to the following:

The Personal Information we collect depends on

For purposes of the Site, we only collect limited information as noted above.  We do not, through the Site, collect social security numbers, birthdates and/or other sensitive personal information about a Visitor or user.  Should you purchase Trustate services that require the collection and use of sensitive personal information, at that time, you will be advised as to the information we collect, and we will ask you at that time to confirm your consent and agreement therewith.

As stated above, we are a business-to-business service provider.  While we use reasonable efforts to protect the information you provide to us, as discussed further below, we cannot guarantee your privacy.  Accordingly, we ask that you not share with us Personal Information, and instead limit the information you share with us to your business contact information.  

How Trustate Collects Your Information

In this section of the Privacy Policy, we explain where and how we collect data from you. When you provide information upon request or submission, please provide business points of contact, rather than personal (home) points of contact.

                      o   name

                      o   email address

                      o   company name and location

                      o   name

                      o   email address

                      o   company name and address

                      o   title

                      o   telephone contact information

                      o   Online Identifiers

                                    §  geo location/tracking details

                                    §  browser fingerprint

                                    §  operating system

                                    §  browser name and version

                                    §  IP addresses for the device from which you access the Site

                      o   Usage Data

                                    §  authentication data

                                    §  security questions

                                    §  click-stream data

                      o   Information Captured via Server Logs

                                    §  how you visited to the Site and how you interact online

                                    §  your device type and unique device identification numbers

                                    §  your device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL)

                                    §  how your device interacts with the Site, including pages accessed and links clicked

                                    §  geographic location

                                    §  other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser

                      o   Information Captured via External Links

                      o   Information Captured via Log Files

                                    §  IP addresses

                                    §  browser type

                                    §  Internet service provider (ISP)

                                    §  referring/exit pages

                                    §  platform type

                                    §  date/time stamp

                                    §  number of clicks

                      o   See section Cookies and Similar Technologies

How Trustate Uses Your Information

In this section of the Privacy Policy, we explain our commercial and business purposes for collecting information from you.

We gather Personal Information about you in order to respond to your requests and provide you with appropriate information about our services and resources.  However, in some instances, we may combine information that we have collected from multiple sources in order to fulfill these purposes. Trustate potentially uses each category of information that we collect for each of these purposes.

(1) Providing Services. Trustate uses information for the purpose of providing services. We may also use information to respond to inquiries from potential customers who are interested in learning more about our services. Examples of the types of uses of your information for these purposes include is not limited to the following:

o   producing and delivering documents purchased by you

o   administering the Site

o   displaying content based on your preferences

(2) Communicating with You. Trustate uses information for the purpose of sending information to you to keep you updated about our services, informing you of relevant updates, addressing any questions or to troubleshoot problems. Based on your communication preferences, we may also send you marketing communications (e.g., emails or mobile notifications) to inform you of new services.  You can always opt out of receiving these materials by clicking on the opt out link in each such marketing communication you may receive.  

(3) Security. We may collect information for the purposes of detecting fraud or other suspicious activities.

(4) Meeting Legal Requirements. Trustate collects information in order to meet our legal obligations. These obligations may include satisfying screening requirements prior to assisting with estate administration related service work and information requests.  We also may use your contact information to notify you of incidents relating to our processing of your Personal Information.

(5) Marketing. Trustate collects information for use in marketing to current and prospective customers according to your indicated preferences. You can opt-out of receiving marketing materials and/or change your preferences at any time by emailing privacy@trustate.com.  

(6) Development. Trustate collects information for researching and improving our existing services and developing new services.

(7) Analytics. Trustate collects information for use in performing various types of analytics. For example, Trustate uses information to analyze how you interact with the Site, where you arrive from and exit to, and gaining insights into the types of Visitors that may be interested in our services. We may also use information to develop inferences from the information we collect regarding your preferences, characteristics, predispositions, behaviors, and attitudes.

(8) Operational Purposes. Trustate collects information for use for our operational purposes, and the operational purposes of our service/data providers and business partners. For instance, Trustate may use information for maintaining the Site and other infrastructure, training and quality assurance, for conducting surveys or sweepstakes, to promote our brand, and to use in connection with our relationships with service/data providers and business partners.

(9) Financial Reporting. Trustate collects information for use in various types of financial reporting and other similar internal uses. Examples of the types of financial reporting that Trustate may use your information in connection with our internal budgets and projections, calculation of compensation, and reporting to investors. This information is on an aggregated basis and will never mention any one individual from a corporate entity customer of Trustate.

(10) De-Identified or Aggregate Data. In addition to the purposes listed above, Trustate may also use de-identifiedor aggregate data that is not capable of being linked to any Visitor or user for additional purposes not listedabove.

In addition to the above, Trustate may disclose your Personal Information for any purpose for which you provide consent. We will not use your Personal Information for purposes other than those purposes disclosed in this Privacy Policy and the Terms of Use or Terms of Service, at the time the information is collected without your permission. From time to time, and as required under the applicable law, we may request your permission to allow it to share your contact information (including any Personal Information provided) with third parties.

Cookies and Similar Technologies

This section expands on how Trustate uses Internet technologies, such as cookies, to collect information about you.

·      Cookies. Trustate and its service providers may use the standard cookie feature of major browser applications and third-party service/data providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration and Google Analytics Demographics and Interest Reporting), or employ internally developed cookies and tracking codes, that allow Trustate to store a small piece of data on a your computer, or any other device a you use to access the Site, about your visit to the Site or use of other plug-ins exchanging information with Trustate. We also use similar technologies, such as JavaScripts or ETags, to analyze trends, administer the Site, track users’ movements around the Site, and to gather demographic information about our user-base. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. You may also control which cookies are placed on your browser when you visit the Site through our cookie preference center. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as order forms, will be limited.

·      Web Beacons. “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize the Site and to collect a limited set of information about you.

·      Third Party Tracking. The use of tracking technologies by our service/data providers, technology partners or other third party assets (such as social media links) on the site is not covered by our Privacy Policy. These third parties may use cookies, clear gifs, images, and scripts to help them better manage their content on theSite. We do not have access or control over these technologies.

·      Partner and Affiliate Tracking. Our partners and affiliates, including Google Analytics (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics and Interest Reporting), may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may show our ads on sites across the Internet based upon your previous visitsto the Site. Together with our partners and affiliates, we may use these cookies and web beacons to report howyour ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to the Site.

If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://aboutads.info/choices.

If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. You may also learn more about how Google Analytics uses your information by visiting Google’s page https://policies.google.com/technologies/partner-sites. You may also visit Google Analytics’ Ads Settings at https://adssettings.google.com/u/0/authenticated?hl=en to opt out of Google’s use of cookies and customize Google Display Network ads, and Google Analytics’ Opt Out Browser Add-on for the web - https://tools.google.com/dlpage/gaoptout/.

Third Party Sites, Resources and Services

Trustate may maintain links to other websites and other websites may maintain links to the Site. This Privacy Policy applies only to www.trustate.com and not to other websites accessible from Trustate or that you use to access Trustate, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites, Trustate is not responsible for the privacy practices or content of those websites. It is your responsibility to review the privacy policies of non-Trustate websites to confirm that you understand and agree with them.

Disclosure of Your Information to Third Parties

In this section of the Privacy Policy, we explain who we share your information with and under which circumstances we may do so.

·      Service/Data Providers. Trustate contracts with its service providers which help it to maintain and operate the Site, requiring those service providers to only use your information in connection with the services they perform for Trustate, and contractually proscribe them from selling your information to anyone for any purpose.  Examples of the types of service providers Trustate may share personal information with (other than those mentioned above) include but are not limited to the following:

·      Our Business Partners. Trustate collects information in order to provide business partners information inconnection with Visitors or users who have either expressed interest in hearing from the business partner or who have purchased a bundled service through Trustate. Trustate may share information with business partners in limited circumstances, including but not limited to the following:

·      Public Postings. Trustate may publicly share information about Visitors, such as by displaying the information on the Site or having the information published in publicly available media, in a limited number of circumstances. For example, at some point in the future, the Site may include areas where Visitors may voluntarily interact with each other, including a question and answer section. Any information that is provided in this area of the Site may be publicly available. You should use caution when deciding whether to disclose your Personal Information in these areas of the site. To request removal of your information from our community forums, contact us at privacy@trustate.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

·      Required by Law. Trustate may disclose your information as required by law

·      Business Transfers and Related Parties. If Trustate undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including information related to Visitors and users in connection with the transaction or in contemplation of the transaction (such as conducting due diligence). If such an event occurs, your information may be treated like any other Trustate asset and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

·      De-Identified or Aggregate Data. In addition to the circumstances listed above, Trustate may also share de-identified or aggregate data that is not capable of being linked to any Visitor with additional entities not listed above.

Privacy Rights and Requests

This Site is only for business purposes, and Trustate offers business-to-business services only. Therefore, the collection of your Personal Information is in the context of, and in support of, a business transaction, not a consumer transaction.  As such, this transaction, and your rights are not governed by consumer privacy laws to the fullest extent allowed in your jurisdiction.

Nevertheless, where doing so does not interfere with, or impede Trustate’s administration of the Site, or compliance with applicable laws, we will endeavor to comply with your requests.  

Further, your rights to Personal Information are not absolute. Depending upon the applicable law, access may be denied as follows:

·      when denial of access is required or authorized by law

·      you are a resident of a state that does not provide for this right

·      when granting access would have a negative impact on another’s privacy

·      to protect our rights and properties

·      where the request is frivolous or vexatious, or for other reasons

Nevertheless, Trustate will accommodate reasonable requests where possible and not excessive.  

·      Submitting a Request. You can make privacy rights requests relating to your Personal information by contacting Trustate at email us at privacy@trustate.com or call 618-437-8283 (618-4-ESTATE). When we receive an individual rights request via other intake methods, we may, or where required by law, will take steps to verify your identity before complying with the request to protect your privacy and security. You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide Trustate with written permission for the agent to make the request on your behalf or provide us with an executed power of attorney.

·      Verification of a Request. After you submit the request, you will be asked to verify your email address and may also be asked to provide additional information to verify your identity, including potentially providing a declaration under penalty of perjury. Trustate will attempt to verify your identity by asking for information that correlates with the information that we have previously collected about you. Where this is not possible, Trustate may request you submit additional information for verification, such as proof of residency or redacted government-issued identification. Please note that we will be unable to satisfy your request until we have verified your identity.

·      Trustate’s Response to a Request. Upon a verified request, and subject to the privacy interests of others and technical limitations, Trustate will provide you with information about whether we hold any information related to you, information about your orders and similar information. This may include information about the nature and status of your order, information you provided to process your order, payment information, and contact information. If you want someone to have access to your order, you must list him or her as an authorized contact or they may not obtain information. You can confirm who is listed as an authorized contact for your account, add new authorized contacts, or remove authorized contacts by clicking first on "My Account," and then on "Account Information". We may send a confirmation email to your authorizedcontact(s), alerting them that they have been added as an authorized contact. For some services, we may provide information about your order to other individuals named in the order, such as executors named in a last will. For service-specific information about who may request information about your order, please contact us at privacy@trustate.com.

If you believe that Trustate has infringed your rights, please contact Trustate at privacy@trustate.com.

Accessing, Updating, and Storing Your Information;  Account Termination

·      Access and Update to Account. You may access your account profile at any time by logging into the portal and clicking on the "My Account" link. Through My Account, you may review and update basic information about you. You may also update your information at any time by contacting Trustate’s support team atinfo@trustate.com or call 618-437-8283 (618-4-ESTATE).

·      Deletion. You may request deletion of your information. We may, however, be required to maintain certain information by law. Certain federal and state regulations require that we maintain a record of your information for certain periods of time. Due to these regulations, we may be unable to completely delete your information from its database until the time requirements of these regulations have expired.  In these cases, your information will not be used for any purpose (other than compliance with regulatory or legal obligations) and will be deleted in accordance with applicable data destruction laws or Trustate’s data destruction policies.

·      Retention. At minimum, we will retain your information for as long as needed to provide services to you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Trustate may maintain some or all of this data in its archives even after it has been removed from the Site. While retention requirements vary by jurisdiction, information about Trustate’s typical retention periods for different aspects of your personal information are described as follows:

Security

We have implemented reasonable technological, administrative and operational controls intended to protect information collected through the Site from loss, misuse, unauthorized access, exfiltration and/or alteration. Credit card and Personal Information are transmitted by secure servers (TLS). Documents are delivered to you via UPS or similar delivery services, the United States Postal Service, or electronically, including through online storage platforms oremail. In all cases, we will exercise reasonable care to endeavor to provide secure transmission of information between your computer and our servers but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot guaranty or warrant the security of any information transmitted to Trustate over the Internet.

YOU MUST CAREFULLY CONSIDER WHAT INFORMATION YOU SHARE WITH US, AS WE CANNOT GUARANTEE THAT WE WILL BE ABLE TO BLOCK ALL ATTEMPTED ATTACKS TO THE SECURITY OF THE SITE. HENCE, YOU PROVIDE THIS INFORMATION AT YOUR OWN RISK. ALTHOUGH WE USE REASONABLE SECURITY PRECAUTIONS WITH RESPECT TO THE LIMITED PERSONAL INFORMATION WE MAY COLLECT THROUGH THIS SITE, WE CANNOT GUARANTEE THAT ANY OF YOUR PERSONAL INFORMATION STORED ON OUR SERVERS WILL BE FREE FROM UNAUTHORIZED ACCESS.  TO THE FULLEST EXTENT NOT PROHIBITED BY LAW, WE DISCLAIM AND SHALL HAVE NO LIABILITY FOR ANY LOSS OF, UNAUTHORIZED ACCESS OR DAMAGE TO, OR INTERCEPTION OF ANY OF YOUR PERSONAL INFORMATION STORED ON OUR SERVERS WHEN YOU ACCESS THE SITE.  

IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED, PLEASE CONTACT US IMMEDIATELY BY EMAILING PRIVACY@TRUSTATE.COM.

For further information, please see Trustate’s Terms of Use.

Choice/Opt-Out

We send promotional emails and newsletters from time to time to Visitors who have provided us with their email address or whose email addresses we have obtained through other sources. You can opt-out of promotional communications by using the “Unsubscribe” link and following the unsubscribe instructions in an email you receivefrom us or by emailing us at info@trustate.com. We may also send service-related or transactional communications, which are not promotional. Generally, you may not opt-out of these communications. If you do not wish to receive service-related communications, you may terminate your account by contacting us at info@trustate.com.

Contact information

You can contact Trustate about this Privacy Policy by writing or email Trustate at the address below:

Attn: Trustate Privacy Team

802 E. Whiting Street

Tampa, FL 33602

privacy@trustate.com

This Privacy Policy is effective for all users of our services and visitors to the website maintained atwww.trustate.com (the “Site”) operated by Trustate Corporation (“Trustate,” “us,” “we” or “our”). This Privacy Policy pertains to Site visitors (“Visitors” or “you”), users of our services, and any other ways in which you may communicate (e.g., via telephone) or interact with Trustate.

Business to Business

At this time, Trustate offers the Site and its services only to businesses, business owners and their authorized users for business purposes and with written consents required under applicable federal and state laws and regulations and privacy rules and policies.  The Site is not intended for consumers.

When you provide CONTACT information to Trustate, we request that it be business contact information. If you provide personal information instead, this does not make this a consumer transaction.  While we use reasonable measures to secure any personal information disclosed to us, privacy rights associated with a consumer transaction, as a general matter, do not apply to the Site.

Scope

This Privacy Policy describes how we collect, use, process, and disclose the limited (if any) personal information when Visitors access this Site. This Privacy Policy does not apply to Users of our Services, from whom we do receive certain personal information regarding third parties.  For information regarding the processing of personal information in relation to the Services, please see our Terms of Service.  We have adopted this Privacy Policy to inform you of our information gathering practices and the ways in which we may use the limited personal information we receive from Site Visitors. This Policy applies to all personal information submitted to us for use with or in connection with the Site (but again, not in regard to Personal Information processed in relation to the Services we provide).  Your use of the Site is governed by our Terms of Use and this Privacy Policy.  This Privacy Policy is incorporated into our Terms of Use and Terms of Service, only as to users of our services, and therefore governs your use of our services.

THIS PRIVACY POLICY DOES NOT APPLY TO THE DATA PROVIDED IN RESPONSE TO USERS’ REQUESTS;  THIS POLICY RELATES TO OUR COLLECTION AND PROCESSING OF SITE VISITORS AND USERS OF OUR SERVICES.

Acceptance of this Privacy Policy

By accessing the Site, you are agreeing to be bound by this Privacy Policy and the Terms of Use. By using the Site, you consent to the collection, use, processing, and disclosure of that information in accordance with this Privacy Policy. If you have questions or concerns about this Privacy Policy or would like to exercise any of your rights or learn more about how your data is used, you can contact us at privacy@trustate.com. If you have a disability and are having trouble accessing this Privacy Policy, please contact us. Please see Contact Information.

You acknowledge that the Terms of Use contain a binding arbitration clause and class action waiver that impact your rights regarding resolving disputes that are not otherwise waived pursuant to the terms of your agreement with Trustate. If you live in the United States, such provisions are binding on you and Trustate. Please read the arbitration clause and class action waiver contained in the Terms of Use carefully. If you disagree or are uncomfortable with the Terms of Use, or this Privacy Policy, please discontinue your use of the Site, otherwise, you will have consented to arbitrate disputes with Trustate which arise under this Privacy Policy and the Terms of Use.

Changes To This Policy

We may modify or update this Privacy Policy from time to time, which will be indicated by changing the date at the top of this page. If we make any material changes, we  will notify you by means of a notice on the Site or as otherwise required by law. We encourage you to review this page periodically for the latest information on our privacy practices.

Geographic Restrictions

The Site is based in the United States. Access to the Site may not be legal by certain persons outside of the United States. If you access the Site from outside of the United States, you do so on your own initiative and are responsible for compliance with local laws.

Children's Privacy

The Site is not intended for persons under the age of 18 (or the age of majority in your state).  Trustate does not knowingly receive or solicit data from children under 18 years of age (or the age of majority in your jurisdiction). By using the Site, you represent to Trustate, intending for Trustate to rely thereon, that you are at least 18 (or the age of majority in your jurisdiction). If Trustate learns that information is collected from someone who is less than 18 years, Trustate will take reasonable measures to promptly delete such data from its records. If you become aware of any data Trustate may have collected from children under age 18 (or the age of majority), please contact Trustate at privacy@trustate.com.

Types of Information and Data Trustate Collects

This section includes all of the information that we may collect about you, but we will rarely collect all of these types of information about a Site Visitor or Site User.

As used in this Privacy Policy, “Personal Information” means information that relates, and is capable of being linked, toa particular person. For purposes of this Privacy Policy, Personal Information includes but is not limited to the following:

The Personal Information we collect depends on

For purposes of the Site, we only collect limited information as noted above.  We do not, through the Site, collect social security numbers, birthdates and/or other sensitive personal information about a Visitor or user.  Should you purchase Trustate services that require the collection and use of sensitive personal information, at that time, you will be advised as to the information we collect, and we will ask you at that time to confirm your consent and agreement therewith.

As stated above, we are a business-to-business service provider.  While we use reasonable efforts to protect the information you provide to us, as discussed further below, we cannot guarantee your privacy.  Accordingly, we ask that you not share with us Personal Information, and instead limit the information you share with us to your business contact information.  

How Trustate Collects Your Information

In this section of the Privacy Policy, we explain where and how we collect data from you. When you provide information upon request or submission, please provide business points of contact, rather than personal (home) points of contact.

                      o   name

                      o   email address

                      o   company name and location

                      o   name

                      o   email address

                      o   company name and address

                      o   title

                      o   telephone contact information

                      o   Online Identifiers

                                    §  geo location/tracking details

                                    §  browser fingerprint

                                    §  operating system

                                    §  browser name and version

                                    §  IP addresses for the device from which you access the Site

                      o   Usage Data

                                    §  authentication data

                                    §  security questions

                                    §  click-stream data

                      o   Information Captured via Server Logs

                                    §  how you visited to the Site and how you interact online

                                    §  your device type and unique device identification numbers

                                    §  your device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL)

                                    §  how your device interacts with the Site, including pages accessed and links clicked

                                    §  geographic location

                                    §  other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser

                      o   Information Captured via External Links

                      o   Information Captured via Log Files

                                    §  IP addresses

                                    §  browser type

                                    §  Internet service provider (ISP)

                                    §  referring/exit pages

                                    §  platform type

                                    §  date/time stamp

                                    §  number of clicks

                      o   See section Cookies and Similar Technologies

How Trustate Uses Your Information

In this section of the Privacy Policy, we explain our commercial and business purposes for collecting information from you.

We gather Personal Information about you in order to respond to your requests and provide you with appropriate information about our services and resources.  However, in some instances, we may combine information that we have collected from multiple sources in order to fulfill these purposes. Trustate potentially uses each category of information that we collect for each of these purposes.

(1) Providing Services. Trustate uses information for the purpose of providing services. We may also use information to respond to inquiries from potential customers who are interested in learning more about our services. Examples of the types of uses of your information for these purposes include is not limited to the following:

o   producing and delivering documents purchased by you

o   administering the Site

o   displaying content based on your preferences

(2) Communicating with You. Trustate uses information for the purpose of sending information to you to keep you updated about our services, informing you of relevant updates, addressing any questions or to troubleshoot problems. Based on your communication preferences, we may also send you marketing communications (e.g., emails or mobile notifications) to inform you of new services.  You can always opt out of receiving these materials by clicking on the opt out link in each such marketing communication you may receive.  

(3) Security. We may collect information for the purposes of detecting fraud or other suspicious activities.

(4) Meeting Legal Requirements. Trustate collects information in order to meet our legal obligations. These obligations may include satisfying screening requirements prior to assisting with estate administration related service work and information requests.  We also may use your contact information to notify you of incidents relating to our processing of your Personal Information.

(5) Marketing. Trustate collects information for use in marketing to current and prospective customers according to your indicated preferences. You can opt-out of receiving marketing materials and/or change your preferences at any time by emailing privacy@trustate.com.  

(6) Development. Trustate collects information for researching and improving our existing services and developing new services.

(7) Analytics. Trustate collects information for use in performing various types of analytics. For example, Trustate uses information to analyze how you interact with the Site, where you arrive from and exit to, and gaining insights into the types of Visitors that may be interested in our services. We may also use information to develop inferences from the information we collect regarding your preferences, characteristics, predispositions, behaviors, and attitudes.

(8) Operational Purposes. Trustate collects information for use for our operational purposes, and the operational purposes of our service/data providers and business partners. For instance, Trustate may use information for maintaining the Site and other infrastructure, training and quality assurance, for conducting surveys or sweepstakes, to promote our brand, and to use in connection with our relationships with service/data providers and business partners.

(9) Financial Reporting. Trustate collects information for use in various types of financial reporting and other similar internal uses. Examples of the types of financial reporting that Trustate may use your information in connection with our internal budgets and projections, calculation of compensation, and reporting to investors. This information is on an aggregated basis and will never mention any one individual from a corporate entity customer of Trustate.

(10) De-Identified or Aggregate Data. In addition to the purposes listed above, Trustate may also use de-identifiedor aggregate data that is not capable of being linked to any Visitor or user for additional purposes not listedabove.

In addition to the above, Trustate may disclose your Personal Information for any purpose for which you provide consent. We will not use your Personal Information for purposes other than those purposes disclosed in this Privacy Policy and the Terms of Use or Terms of Service, at the time the information is collected without your permission. From time to time, and as required under the applicable law, we may request your permission to allow it to share your contact information (including any Personal Information provided) with third parties.

Cookies and Similar Technologies

This section expands on how Trustate uses Internet technologies, such as cookies, to collect information about you.

·      Cookies. Trustate and its service providers may use the standard cookie feature of major browser applications and third-party service/data providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration and Google Analytics Demographics and Interest Reporting), or employ internally developed cookies and tracking codes, that allow Trustate to store a small piece of data on a your computer, or any other device a you use to access the Site, about your visit to the Site or use of other plug-ins exchanging information with Trustate. We also use similar technologies, such as JavaScripts or ETags, to analyze trends, administer the Site, track users’ movements around the Site, and to gather demographic information about our user-base. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. You may also control which cookies are placed on your browser when you visit the Site through our cookie preference center. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as order forms, will be limited.

·      Web Beacons. “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize the Site and to collect a limited set of information about you.

·      Third Party Tracking. The use of tracking technologies by our service/data providers, technology partners or other third party assets (such as social media links) on the site is not covered by our Privacy Policy. These third parties may use cookies, clear gifs, images, and scripts to help them better manage their content on theSite. We do not have access or control over these technologies.

·      Partner and Affiliate Tracking. Our partners and affiliates, including Google Analytics (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics and Interest Reporting), may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may show our ads on sites across the Internet based upon your previous visitsto the Site. Together with our partners and affiliates, we may use these cookies and web beacons to report howyour ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to the Site.

If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://aboutads.info/choices.

If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. You may also learn more about how Google Analytics uses your information by visiting Google’s page https://policies.google.com/technologies/partner-sites. You may also visit Google Analytics’ Ads Settings at https://adssettings.google.com/u/0/authenticated?hl=en to opt out of Google’s use of cookies and customize Google Display Network ads, and Google Analytics’ Opt Out Browser Add-on for the web - https://tools.google.com/dlpage/gaoptout/.

Third Party Sites, Resources and Services

Trustate may maintain links to other websites and other websites may maintain links to the Site. This Privacy Policy applies only to www.trustate.com and not to other websites accessible from Trustate or that you use to access Trustate, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites, Trustate is not responsible for the privacy practices or content of those websites. It is your responsibility to review the privacy policies of non-Trustate websites to confirm that you understand and agree with them.

Disclosure of Your Information to Third Parties

In this section of the Privacy Policy, we explain who we share your information with and under which circumstances we may do so.

·      Service/Data Providers. Trustate contracts with its service providers which help it to maintain and operate the Site, requiring those service providers to only use your information in connection with the services they perform for Trustate, and contractually proscribe them from selling your information to anyone for any purpose.  Examples of the types of service providers Trustate may share personal information with (other than those mentioned above) include but are not limited to the following:

·      Our Business Partners. Trustate collects information in order to provide business partners information inconnection with Visitors or users who have either expressed interest in hearing from the business partner or who have purchased a bundled service through Trustate. Trustate may share information with business partners in limited circumstances, including but not limited to the following:

·      Public Postings. Trustate may publicly share information about Visitors, such as by displaying the information on the Site or having the information published in publicly available media, in a limited number of circumstances. For example, at some point in the future, the Site may include areas where Visitors may voluntarily interact with each other, including a question and answer section. Any information that is provided in this area of the Site may be publicly available. You should use caution when deciding whether to disclose your Personal Information in these areas of the site. To request removal of your information from our community forums, contact us at privacy@trustate.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

·      Required by Law. Trustate may disclose your information as required by law

·      Business Transfers and Related Parties. If Trustate undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including information related to Visitors and users in connection with the transaction or in contemplation of the transaction (such as conducting due diligence). If such an event occurs, your information may be treated like any other Trustate asset and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

·      De-Identified or Aggregate Data. In addition to the circumstances listed above, Trustate may also share de-identified or aggregate data that is not capable of being linked to any Visitor with additional entities not listed above.

Privacy Rights and Requests

This Site is only for business purposes, and Trustate offers business-to-business services only. Therefore, the collection of your Personal Information is in the context of, and in support of, a business transaction, not a consumer transaction.  As such, this transaction, and your rights are not governed by consumer privacy laws to the fullest extent allowed in your jurisdiction.

Nevertheless, where doing so does not interfere with, or impede Trustate’s administration of the Site, or compliance with applicable laws, we will endeavor to comply with your requests.  

Further, your rights to Personal Information are not absolute. Depending upon the applicable law, access may be denied as follows:

·      when denial of access is required or authorized by law

·      you are a resident of a state that does not provide for this right

·      when granting access would have a negative impact on another’s privacy

·      to protect our rights and properties

·      where the request is frivolous or vexatious, or for other reasons

Nevertheless, Trustate will accommodate reasonable requests where possible and not excessive.  

·      Submitting a Request. You can make privacy rights requests relating to your Personal information by contacting Trustate at email us at privacy@trustate.com or call 618-437-8283 (618-4-ESTATE). When we receive an individual rights request via other intake methods, we may, or where required by law, will take steps to verify your identity before complying with the request to protect your privacy and security. You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide Trustate with written permission for the agent to make the request on your behalf or provide us with an executed power of attorney.

·      Verification of a Request. After you submit the request, you will be asked to verify your email address and may also be asked to provide additional information to verify your identity, including potentially providing a declaration under penalty of perjury. Trustate will attempt to verify your identity by asking for information that correlates with the information that we have previously collected about you. Where this is not possible, Trustate may request you submit additional information for verification, such as proof of residency or redacted government-issued identification. Please note that we will be unable to satisfy your request until we have verified your identity.

·      Trustate’s Response to a Request. Upon a verified request, and subject to the privacy interests of others and technical limitations, Trustate will provide you with information about whether we hold any information related to you, information about your orders and similar information. This may include information about the nature and status of your order, information you provided to process your order, payment information, and contact information. If you want someone to have access to your order, you must list him or her as an authorized contact or they may not obtain information. You can confirm who is listed as an authorized contact for your account, add new authorized contacts, or remove authorized contacts by clicking first on "My Account," and then on "Account Information". We may send a confirmation email to your authorizedcontact(s), alerting them that they have been added as an authorized contact. For some services, we may provide information about your order to other individuals named in the order, such as executors named in a last will. For service-specific information about who may request information about your order, please contact us at privacy@trustate.com.

If you believe that Trustate has infringed your rights, please contact Trustate at privacy@trustate.com.

Accessing, Updating, and Storing Your Information;  Account Termination

·      Access and Update to Account. You may access your account profile at any time by logging into the portal and clicking on the "My Account" link. Through My Account, you may review and update basic information about you. You may also update your information at any time by contacting Trustate’s support team atinfo@trustate.com or call 618-437-8283 (618-4-ESTATE).

·      Deletion. You may request deletion of your information. We may, however, be required to maintain certain information by law. Certain federal and state regulations require that we maintain a record of your information for certain periods of time. Due to these regulations, we may be unable to completely delete your information from its database until the time requirements of these regulations have expired.  In these cases, your information will not be used for any purpose (other than compliance with regulatory or legal obligations) and will be deleted in accordance with applicable data destruction laws or Trustate’s data destruction policies.

·      Retention. At minimum, we will retain your information for as long as needed to provide services to you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Trustate may maintain some or all of this data in its archives even after it has been removed from the Site. While retention requirements vary by jurisdiction, information about Trustate’s typical retention periods for different aspects of your personal information are described as follows:

Security

We have implemented reasonable technological, administrative and operational controls intended to protect information collected through the Site from loss, misuse, unauthorized access, exfiltration and/or alteration. Credit card and Personal Information are transmitted by secure servers (TLS). Documents are delivered to you via UPS or similar delivery services, the United States Postal Service, or electronically, including through online storage platforms oremail. In all cases, we will exercise reasonable care to endeavor to provide secure transmission of information between your computer and our servers but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot guaranty or warrant the security of any information transmitted to Trustate over the Internet.

YOU MUST CAREFULLY CONSIDER WHAT INFORMATION YOU SHARE WITH US, AS WE CANNOT GUARANTEE THAT WE WILL BE ABLE TO BLOCK ALL ATTEMPTED ATTACKS TO THE SECURITY OF THE SITE. HENCE, YOU PROVIDE THIS INFORMATION AT YOUR OWN RISK. ALTHOUGH WE USE REASONABLE SECURITY PRECAUTIONS WITH RESPECT TO THE LIMITED PERSONAL INFORMATION WE MAY COLLECT THROUGH THIS SITE, WE CANNOT GUARANTEE THAT ANY OF YOUR PERSONAL INFORMATION STORED ON OUR SERVERS WILL BE FREE FROM UNAUTHORIZED ACCESS.  TO THE FULLEST EXTENT NOT PROHIBITED BY LAW, WE DISCLAIM AND SHALL HAVE NO LIABILITY FOR ANY LOSS OF, UNAUTHORIZED ACCESS OR DAMAGE TO, OR INTERCEPTION OF ANY OF YOUR PERSONAL INFORMATION STORED ON OUR SERVERS WHEN YOU ACCESS THE SITE.  

IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED, PLEASE CONTACT US IMMEDIATELY BY EMAILING PRIVACY@TRUSTATE.COM.

For further information, please see Trustate’s Terms of Use.

Choice/Opt-Out

We send promotional emails and newsletters from time to time to Visitors who have provided us with their email address or whose email addresses we have obtained through other sources. You can opt-out of promotional communications by using the “Unsubscribe” link and following the unsubscribe instructions in an email you receivefrom us or by emailing us at info@trustate.com. We may also send service-related or transactional communications, which are not promotional. Generally, you may not opt-out of these communications. If you do not wish to receive service-related communications, you may terminate your account by contacting us at info@trustate.com.

Contact information

You can contact Trustate about this Privacy Policy by writing or email Trustate at the address below:

Attn: Trustate Privacy Team

802 E. Whiting Street

Tampa, FL 33602

privacy@trustate.com

This Privacy Policy is effective for all users of our services and visitors to the website maintained atwww.trustate.com (the “Site”) operated by Trustate Corporation (“Trustate,” “us,” “we” or “our”). This Privacy Policy pertains to Site visitors (“Visitors” or “you”), users of our services, and any other ways in which you may communicate (e.g., via telephone) or interact with Trustate.

Business to Business

At this time, Trustate offers the Site and its services only to businesses, business owners and their authorized users for business purposes and with written consents required under applicable federal and state laws and regulations and privacy rules and policies.  The Site is not intended for consumers.

When you provide CONTACT information to Trustate, we request that it be business contact information. If you provide personal information instead, this does not make this a consumer transaction.  While we use reasonable measures to secure any personal information disclosed to us, privacy rights associated with a consumer transaction, as a general matter, do not apply to the Site.

Scope

This Privacy Policy describes how we collect, use, process, and disclose the limited (if any) personal information when Visitors access this Site. This Privacy Policy does not apply to Users of our Services, from whom we do receive certain personal information regarding third parties.  For information regarding the processing of personal information in relation to the Services, please see our Terms of Service.  We have adopted this Privacy Policy to inform you of our information gathering practices and the ways in which we may use the limited personal information we receive from Site Visitors. This Policy applies to all personal information submitted to us for use with or in connection with the Site (but again, not in regard to Personal Information processed in relation to the Services we provide).  Your use of the Site is governed by our Terms of Use and this Privacy Policy.  This Privacy Policy is incorporated into our Terms of Use and Terms of Service, only as to users of our services, and therefore governs your use of our services.

THIS PRIVACY POLICY DOES NOT APPLY TO THE DATA PROVIDED IN RESPONSE TO USERS’ REQUESTS;  THIS POLICY RELATES TO OUR COLLECTION AND PROCESSING OF SITE VISITORS AND USERS OF OUR SERVICES.

Acceptance of this Privacy Policy

By accessing the Site, you are agreeing to be bound by this Privacy Policy and the Terms of Use. By using the Site, you consent to the collection, use, processing, and disclosure of that information in accordance with this Privacy Policy. If you have questions or concerns about this Privacy Policy or would like to exercise any of your rights or learn more about how your data is used, you can contact us at privacy@trustate.com. If you have a disability and are having trouble accessing this Privacy Policy, please contact us. Please see Contact Information.

You acknowledge that the Terms of Use contain a binding arbitration clause and class action waiver that impact your rights regarding resolving disputes that are not otherwise waived pursuant to the terms of your agreement with Trustate. If you live in the United States, such provisions are binding on you and Trustate. Please read the arbitration clause and class action waiver contained in the Terms of Use carefully. If you disagree or are uncomfortable with the Terms of Use, or this Privacy Policy, please discontinue your use of the Site, otherwise, you will have consented to arbitrate disputes with Trustate which arise under this Privacy Policy and the Terms of Use.

Changes To This Policy

We may modify or update this Privacy Policy from time to time, which will be indicated by changing the date at the top of this page. If we make any material changes, we  will notify you by means of a notice on the Site or as otherwise required by law. We encourage you to review this page periodically for the latest information on our privacy practices.

Geographic Restrictions

The Site is based in the United States. Access to the Site may not be legal by certain persons outside of the United States. If you access the Site from outside of the United States, you do so on your own initiative and are responsible for compliance with local laws.

Children's Privacy

The Site is not intended for persons under the age of 18 (or the age of majority in your state).  Trustate does not knowingly receive or solicit data from children under 18 years of age (or the age of majority in your jurisdiction). By using the Site, you represent to Trustate, intending for Trustate to rely thereon, that you are at least 18 (or the age of majority in your jurisdiction). If Trustate learns that information is collected from someone who is less than 18 years, Trustate will take reasonable measures to promptly delete such data from its records. If you become aware of any data Trustate may have collected from children under age 18 (or the age of majority), please contact Trustate at privacy@trustate.com.

Types of Information and Data Trustate Collects

This section includes all of the information that we may collect about you, but we will rarely collect all of these types of information about a Site Visitor or Site User.

As used in this Privacy Policy, “Personal Information” means information that relates, and is capable of being linked, toa particular person. For purposes of this Privacy Policy, Personal Information includes but is not limited to the following:

The Personal Information we collect depends on

For purposes of the Site, we only collect limited information as noted above.  We do not, through the Site, collect social security numbers, birthdates and/or other sensitive personal information about a Visitor or user.  Should you purchase Trustate services that require the collection and use of sensitive personal information, at that time, you will be advised as to the information we collect, and we will ask you at that time to confirm your consent and agreement therewith.

As stated above, we are a business-to-business service provider.  While we use reasonable efforts to protect the information you provide to us, as discussed further below, we cannot guarantee your privacy.  Accordingly, we ask that you not share with us Personal Information, and instead limit the information you share with us to your business contact information.  

How Trustate Collects Your Information

In this section of the Privacy Policy, we explain where and how we collect data from you. When you provide information upon request or submission, please provide business points of contact, rather than personal (home) points of contact.

                      o   name

                      o   email address

                      o   company name and location

                      o   name

                      o   email address

                      o   company name and address

                      o   title

                      o   telephone contact information

                      o   Online Identifiers

                                    §  geo location/tracking details

                                    §  browser fingerprint

                                    §  operating system

                                    §  browser name and version

                                    §  IP addresses for the device from which you access the Site

                      o   Usage Data

                                    §  authentication data

                                    §  security questions

                                    §  click-stream data

                      o   Information Captured via Server Logs

                                    §  how you visited to the Site and how you interact online

                                    §  your device type and unique device identification numbers

                                    §  your device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL)

                                    §  how your device interacts with the Site, including pages accessed and links clicked

                                    §  geographic location

                                    §  other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser

                      o   Information Captured via External Links

                      o   Information Captured via Log Files

                                    §  IP addresses

                                    §  browser type

                                    §  Internet service provider (ISP)

                                    §  referring/exit pages

                                    §  platform type

                                    §  date/time stamp

                                    §  number of clicks

                      o   See section Cookies and Similar Technologies

How Trustate Uses Your Information

In this section of the Privacy Policy, we explain our commercial and business purposes for collecting information from you.

We gather Personal Information about you in order to respond to your requests and provide you with appropriate information about our services and resources.  However, in some instances, we may combine information that we have collected from multiple sources in order to fulfill these purposes. Trustate potentially uses each category of information that we collect for each of these purposes.

(1) Providing Services. Trustate uses information for the purpose of providing services. We may also use information to respond to inquiries from potential customers who are interested in learning more about our services. Examples of the types of uses of your information for these purposes include is not limited to the following:

o   producing and delivering documents purchased by you

o   administering the Site

o   displaying content based on your preferences

(2) Communicating with You. Trustate uses information for the purpose of sending information to you to keep you updated about our services, informing you of relevant updates, addressing any questions or to troubleshoot problems. Based on your communication preferences, we may also send you marketing communications (e.g., emails or mobile notifications) to inform you of new services.  You can always opt out of receiving these materials by clicking on the opt out link in each such marketing communication you may receive.  

(3) Security. We may collect information for the purposes of detecting fraud or other suspicious activities.

(4) Meeting Legal Requirements. Trustate collects information in order to meet our legal obligations. These obligations may include satisfying screening requirements prior to assisting with estate administration related service work and information requests.  We also may use your contact information to notify you of incidents relating to our processing of your Personal Information.

(5) Marketing. Trustate collects information for use in marketing to current and prospective customers according to your indicated preferences. You can opt-out of receiving marketing materials and/or change your preferences at any time by emailing privacy@trustate.com.  

(6) Development. Trustate collects information for researching and improving our existing services and developing new services.

(7) Analytics. Trustate collects information for use in performing various types of analytics. For example, Trustate uses information to analyze how you interact with the Site, where you arrive from and exit to, and gaining insights into the types of Visitors that may be interested in our services. We may also use information to develop inferences from the information we collect regarding your preferences, characteristics, predispositions, behaviors, and attitudes.

(8) Operational Purposes. Trustate collects information for use for our operational purposes, and the operational purposes of our service/data providers and business partners. For instance, Trustate may use information for maintaining the Site and other infrastructure, training and quality assurance, for conducting surveys or sweepstakes, to promote our brand, and to use in connection with our relationships with service/data providers and business partners.

(9) Financial Reporting. Trustate collects information for use in various types of financial reporting and other similar internal uses. Examples of the types of financial reporting that Trustate may use your information in connection with our internal budgets and projections, calculation of compensation, and reporting to investors. This information is on an aggregated basis and will never mention any one individual from a corporate entity customer of Trustate.

(10) De-Identified or Aggregate Data. In addition to the purposes listed above, Trustate may also use de-identifiedor aggregate data that is not capable of being linked to any Visitor or user for additional purposes not listedabove.

In addition to the above, Trustate may disclose your Personal Information for any purpose for which you provide consent. We will not use your Personal Information for purposes other than those purposes disclosed in this Privacy Policy and the Terms of Use or Terms of Service, at the time the information is collected without your permission. From time to time, and as required under the applicable law, we may request your permission to allow it to share your contact information (including any Personal Information provided) with third parties.

Cookies and Similar Technologies

This section expands on how Trustate uses Internet technologies, such as cookies, to collect information about you.

·      Cookies. Trustate and its service providers may use the standard cookie feature of major browser applications and third-party service/data providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration and Google Analytics Demographics and Interest Reporting), or employ internally developed cookies and tracking codes, that allow Trustate to store a small piece of data on a your computer, or any other device a you use to access the Site, about your visit to the Site or use of other plug-ins exchanging information with Trustate. We also use similar technologies, such as JavaScripts or ETags, to analyze trends, administer the Site, track users’ movements around the Site, and to gather demographic information about our user-base. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. You may also control which cookies are placed on your browser when you visit the Site through our cookie preference center. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as order forms, will be limited.

·      Web Beacons. “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize the Site and to collect a limited set of information about you.

·      Third Party Tracking. The use of tracking technologies by our service/data providers, technology partners or other third party assets (such as social media links) on the site is not covered by our Privacy Policy. These third parties may use cookies, clear gifs, images, and scripts to help them better manage their content on theSite. We do not have access or control over these technologies.

·      Partner and Affiliate Tracking. Our partners and affiliates, including Google Analytics (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics and Interest Reporting), may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may show our ads on sites across the Internet based upon your previous visitsto the Site. Together with our partners and affiliates, we may use these cookies and web beacons to report howyour ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to the Site.

If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://aboutads.info/choices.

If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. You may also learn more about how Google Analytics uses your information by visiting Google’s page https://policies.google.com/technologies/partner-sites. You may also visit Google Analytics’ Ads Settings at https://adssettings.google.com/u/0/authenticated?hl=en to opt out of Google’s use of cookies and customize Google Display Network ads, and Google Analytics’ Opt Out Browser Add-on for the web - https://tools.google.com/dlpage/gaoptout/.

Third Party Sites, Resources and Services

Trustate may maintain links to other websites and other websites may maintain links to the Site. This Privacy Policy applies only to www.trustate.com and not to other websites accessible from Trustate or that you use to access Trustate, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites, Trustate is not responsible for the privacy practices or content of those websites. It is your responsibility to review the privacy policies of non-Trustate websites to confirm that you understand and agree with them.

Disclosure of Your Information to Third Parties

In this section of the Privacy Policy, we explain who we share your information with and under which circumstances we may do so.

·      Service/Data Providers. Trustate contracts with its service providers which help it to maintain and operate the Site, requiring those service providers to only use your information in connection with the services they perform for Trustate, and contractually proscribe them from selling your information to anyone for any purpose.  Examples of the types of service providers Trustate may share personal information with (other than those mentioned above) include but are not limited to the following:

·      Our Business Partners. Trustate collects information in order to provide business partners information inconnection with Visitors or users who have either expressed interest in hearing from the business partner or who have purchased a bundled service through Trustate. Trustate may share information with business partners in limited circumstances, including but not limited to the following:

·      Public Postings. Trustate may publicly share information about Visitors, such as by displaying the information on the Site or having the information published in publicly available media, in a limited number of circumstances. For example, at some point in the future, the Site may include areas where Visitors may voluntarily interact with each other, including a question and answer section. Any information that is provided in this area of the Site may be publicly available. You should use caution when deciding whether to disclose your Personal Information in these areas of the site. To request removal of your information from our community forums, contact us at privacy@trustate.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

·      Required by Law. Trustate may disclose your information as required by law

·      Business Transfers and Related Parties. If Trustate undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including information related to Visitors and users in connection with the transaction or in contemplation of the transaction (such as conducting due diligence). If such an event occurs, your information may be treated like any other Trustate asset and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

·      De-Identified or Aggregate Data. In addition to the circumstances listed above, Trustate may also share de-identified or aggregate data that is not capable of being linked to any Visitor with additional entities not listed above.

Privacy Rights and Requests

This Site is only for business purposes, and Trustate offers business-to-business services only. Therefore, the collection of your Personal Information is in the context of, and in support of, a business transaction, not a consumer transaction.  As such, this transaction, and your rights are not governed by consumer privacy laws to the fullest extent allowed in your jurisdiction.

Nevertheless, where doing so does not interfere with, or impede Trustate’s administration of the Site, or compliance with applicable laws, we will endeavor to comply with your requests.  

Further, your rights to Personal Information are not absolute. Depending upon the applicable law, access may be denied as follows:

·      when denial of access is required or authorized by law

·      you are a resident of a state that does not provide for this right

·      when granting access would have a negative impact on another’s privacy

·      to protect our rights and properties

·      where the request is frivolous or vexatious, or for other reasons

Nevertheless, Trustate will accommodate reasonable requests where possible and not excessive.  

·      Submitting a Request. You can make privacy rights requests relating to your Personal information by contacting Trustate at email us at privacy@trustate.com or call 618-437-8283 (618-4-ESTATE). When we receive an individual rights request via other intake methods, we may, or where required by law, will take steps to verify your identity before complying with the request to protect your privacy and security. You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide Trustate with written permission for the agent to make the request on your behalf or provide us with an executed power of attorney.

·      Verification of a Request. After you submit the request, you will be asked to verify your email address and may also be asked to provide additional information to verify your identity, including potentially providing a declaration under penalty of perjury. Trustate will attempt to verify your identity by asking for information that correlates with the information that we have previously collected about you. Where this is not possible, Trustate may request you submit additional information for verification, such as proof of residency or redacted government-issued identification. Please note that we will be unable to satisfy your request until we have verified your identity.

·      Trustate’s Response to a Request. Upon a verified request, and subject to the privacy interests of others and technical limitations, Trustate will provide you with information about whether we hold any information related to you, information about your orders and similar information. This may include information about the nature and status of your order, information you provided to process your order, payment information, and contact information. If you want someone to have access to your order, you must list him or her as an authorized contact or they may not obtain information. You can confirm who is listed as an authorized contact for your account, add new authorized contacts, or remove authorized contacts by clicking first on "My Account," and then on "Account Information". We may send a confirmation email to your authorizedcontact(s), alerting them that they have been added as an authorized contact. For some services, we may provide information about your order to other individuals named in the order, such as executors named in a last will. For service-specific information about who may request information about your order, please contact us at privacy@trustate.com.

If you believe that Trustate has infringed your rights, please contact Trustate at privacy@trustate.com.

Accessing, Updating, and Storing Your Information;  Account Termination

·      Access and Update to Account. You may access your account profile at any time by logging into the portal and clicking on the "My Account" link. Through My Account, you may review and update basic information about you. You may also update your information at any time by contacting Trustate’s support team atinfo@trustate.com or call 618-437-8283 (618-4-ESTATE).

·      Deletion. You may request deletion of your information. We may, however, be required to maintain certain information by law. Certain federal and state regulations require that we maintain a record of your information for certain periods of time. Due to these regulations, we may be unable to completely delete your information from its database until the time requirements of these regulations have expired.  In these cases, your information will not be used for any purpose (other than compliance with regulatory or legal obligations) and will be deleted in accordance with applicable data destruction laws or Trustate’s data destruction policies.

·      Retention. At minimum, we will retain your information for as long as needed to provide services to you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Trustate may maintain some or all of this data in its archives even after it has been removed from the Site. While retention requirements vary by jurisdiction, information about Trustate’s typical retention periods for different aspects of your personal information are described as follows:

Security

We have implemented reasonable technological, administrative and operational controls intended to protect information collected through the Site from loss, misuse, unauthorized access, exfiltration and/or alteration. Credit card and Personal Information are transmitted by secure servers (TLS). Documents are delivered to you via UPS or similar delivery services, the United States Postal Service, or electronically, including through online storage platforms oremail. In all cases, we will exercise reasonable care to endeavor to provide secure transmission of information between your computer and our servers but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot guaranty or warrant the security of any information transmitted to Trustate over the Internet.

YOU MUST CAREFULLY CONSIDER WHAT INFORMATION YOU SHARE WITH US, AS WE CANNOT GUARANTEE THAT WE WILL BE ABLE TO BLOCK ALL ATTEMPTED ATTACKS TO THE SECURITY OF THE SITE. HENCE, YOU PROVIDE THIS INFORMATION AT YOUR OWN RISK. ALTHOUGH WE USE REASONABLE SECURITY PRECAUTIONS WITH RESPECT TO THE LIMITED PERSONAL INFORMATION WE MAY COLLECT THROUGH THIS SITE, WE CANNOT GUARANTEE THAT ANY OF YOUR PERSONAL INFORMATION STORED ON OUR SERVERS WILL BE FREE FROM UNAUTHORIZED ACCESS.  TO THE FULLEST EXTENT NOT PROHIBITED BY LAW, WE DISCLAIM AND SHALL HAVE NO LIABILITY FOR ANY LOSS OF, UNAUTHORIZED ACCESS OR DAMAGE TO, OR INTERCEPTION OF ANY OF YOUR PERSONAL INFORMATION STORED ON OUR SERVERS WHEN YOU ACCESS THE SITE.  

IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED, PLEASE CONTACT US IMMEDIATELY BY EMAILING PRIVACY@TRUSTATE.COM.

For further information, please see Trustate’s Terms of Use.

Choice/Opt-Out

We send promotional emails and newsletters from time to time to Visitors who have provided us with their email address or whose email addresses we have obtained through other sources. You can opt-out of promotional communications by using the “Unsubscribe” link and following the unsubscribe instructions in an email you receivefrom us or by emailing us at info@trustate.com. We may also send service-related or transactional communications, which are not promotional. Generally, you may not opt-out of these communications. If you do not wish to receive service-related communications, you may terminate your account by contacting us at info@trustate.com.

Contact information

You can contact Trustate about this Privacy Policy by writing or email Trustate at the address below:

Attn: Trustate Privacy Team

802 E. Whiting Street

Tampa, FL 33602

privacy@trustate.com