Trusible
Legal

Privacy Policy

How we collect, use, and protect your personal data.

Last Updated: January 2026

1. Introduction

Trusible Private Limited (UEN: 202557340G) ("Trusible," "we," "us," or "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you access or use the Trusible digital platform, website, mobile applications, and related services (collectively, the "Platform").

This Privacy Policy is issued in accordance with the Personal Data Protection Act 2012 of Singapore ("PDPA") and other applicable data protection laws. By using the Platform, you consent to the collection and use of your personal data as described in this Privacy Policy.

This Privacy Policy should be read together with our Terms of Service and Disclaimer.

2. Personal Data We Collect

2.1 Identity and Verification Data

To comply with regulatory KYC/AML obligations and to operate the Platform, we collect:

  • Full legal name, date of birth, and nationality
  • Government-issued identity documents (e.g., passport, national identity card)
  • Proof of address (e.g., utility bill, bank statement)
  • Photographs or selfies for identity verification purposes
  • Tax identification numbers where required by applicable law

2.2 Contact and Account Data

  • Email address and phone number
  • Account login credentials (stored in encrypted form)
  • Communication preferences and notification settings
  • Correspondence and support communications with Trusible

2.3 Financial and Transaction Data

  • Bank account details and payment information used for funding
  • Transaction history, including acquisitions, disposals, and transfers
  • Digital asset holdings and balance records
  • Source of funds declarations where required

2.4 Technical and Usage Data

  • IP address, device type, browser type, and operating system
  • Platform usage patterns, page views, and session data
  • Log files and error reports
  • Cookies and similar tracking technologies (see Section 8)

2.5 Data You Provide Voluntarily

  • Information submitted through contact forms or support requests
  • Feedback, survey responses, or user research participation
  • Any other information you choose to provide to us

3. How We Use Your Personal Data

We use your personal data for the following purposes:

3.1 Platform Operations

  • Creating, maintaining, and managing your account
  • Processing and recording user-directed transactions
  • Providing access to digital asset services through third-party providers
  • Delivering customer support and responding to inquiries
  • Sending transaction confirmations and account notifications

3.2 Legal and Regulatory Compliance

  • Identity verification and KYC/AML procedures as required by applicable law
  • Screening against sanctions lists and watchlists
  • Transaction monitoring for suspicious activity
  • Reporting to regulatory authorities where legally required
  • Maintaining records as required by law or regulation

3.3 Security and Fraud Prevention

  • Detecting, investigating, and preventing fraud, unauthorized access, and security incidents
  • Verifying the integrity of transactions and account activity
  • Protecting the rights and safety of users and the Platform

3.4 Platform Improvement

  • Analyzing usage patterns to improve Platform functionality and user experience
  • Conducting internal research and analytics (using aggregated or anonymized data where possible)
  • Testing and developing new features

3.5 Communications

  • Sending service-related communications (required notices, policy updates, security alerts)
  • Marketing communications about Platform features and services, where you have provided consent
  • You may opt out of marketing communications at any time via the unsubscribe link in any marketing email or by contacting us

4. Legal Basis for Processing

We process your personal data on the following grounds:

  • Contractual necessity: Processing required to provide the Platform services and fulfill our agreement with you
  • Legal obligation: Processing required to comply with KYC/AML laws, regulatory requirements, and other legal obligations
  • Legitimate interests: Processing for fraud prevention, security, and Platform improvement, where these interests are not overridden by your rights
  • Consent: Processing for marketing communications, where you have given explicit consent

5. Disclosure of Personal Data

5.1 Third-Party Service Providers

We share your personal data with third-party service providers who assist in operating the Platform and delivering services, including:

  • Licensed custodians and execution providers who hold and settle digital assets on your behalf
  • Identity verification and KYC/AML service providers
  • Cloud hosting, infrastructure, and technology providers
  • Customer support platform providers
  • Analytics and fraud prevention service providers

All third-party providers are contractually required to handle your data in accordance with applicable data protection laws and are permitted to use your data only for the specific purposes for which it was shared.

5.2 Regulatory and Legal Disclosure

We may disclose your personal data to regulatory authorities, law enforcement agencies, courts, or other government bodies where we are legally required or permitted to do so, including for AML/CTF reporting, regulatory examination, or court orders.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or part of Trusible's business, your personal data may be transferred to the relevant successor entity. We will notify you of any such transfer and any resulting changes to this Privacy Policy.

5.4 We Do Not Sell Your Data

Trusible does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

6. International Data Transfers

Some of our third-party service providers may process your data outside of Singapore. Where this occurs, we ensure that appropriate safeguards are in place to protect your data, including contractual arrangements that provide equivalent protections to those required under the PDPA. By using the Platform, you acknowledge that your data may be transferred to and processed in countries outside Singapore.

7. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including:

  • For the duration of your account with Trusible
  • As required by applicable AML/KYC laws and regulations (typically a minimum of five (5) years after the end of the business relationship)
  • As required for tax, accounting, or legal compliance purposes
  • As necessary to resolve disputes or enforce our agreements

When personal data is no longer required, we will securely delete or anonymize it in accordance with applicable law.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate and improve the Platform. Cookies are small data files stored on your device.

8.1 Types of Cookies We Use

  • Essential cookies: Required for the Platform to function. These cannot be disabled without affecting core functionality
  • Analytics cookies: Help us understand how users interact with the Platform (e.g., pages visited, session duration)
  • Security cookies: Used for fraud detection and session integrity

8.2 Managing Cookies

You can control and manage cookies through your browser settings. Disabling essential cookies may affect your ability to use the Platform. Note that blocking all cookies may prevent certain features from functioning correctly.

9. Data Security

We implement technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, access controls, and regular security assessments.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

10. Your Data Rights

Subject to applicable law and regulatory requirements, you have the following rights regarding your personal data:

  • Access: You may request a copy of the personal data we hold about you
  • Correction: You may request correction of inaccurate or incomplete personal data
  • Withdrawal of consent: Where processing is based on consent, you may withdraw consent at any time (this does not affect processing already carried out)
  • Objection to marketing: You may opt out of marketing communications at any time

Please note that certain data rights may be limited or overridden by our legal obligations under AML/KYC laws, regulatory requirements, or contractual obligations. For example, we may not be able to delete data that we are legally required to retain.

To exercise your rights, please contact us at dev@trusible.com. We will respond to your request within a reasonable timeframe in accordance with applicable law.

11. Children's Privacy

The Platform is not intended for use by persons under the age of eighteen (18). We do not knowingly collect personal data from minors. If we become aware that we have collected personal data from a person under 18, we will take steps to delete such information promptly. If you believe we may have collected data from a minor, please contact us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Material changes will be communicated through the Platform or via email. Your continued use of the Platform following any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically.

13. Contact and Data Protection Enquiries

For questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact:

Trusible Private Limited
UEN: 202557340G
Singapore
Email: dev@trusible.com

If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commission of Singapore (PDPC) at www.pdpc.gov.sg.