1. Data controller
The controller (Verantwortlicher) responsible for processing your personal data on TrustForge is [TODO: legal entity], [TODO: registered address]. Contact via support or by email at [TODO: data-protection@yourdomain].
2. What we collect, why, and on what legal basis
We process the following categories of personal data:
| Category | Fields | Purpose | Legal basis |
|---|---|---|---|
| Account data | email, password (hashed), display name, avatar URL | Provide the user account; authenticate logins. | Contract performance (Art. 6(1)(b) GDPR) |
| Identity verification (KYC) | government ID image, selfie, name, date of birth, country | Verify buyer identity per our anti-fraud / anti-money-laundering obligations. | Legal obligation under the German Geldwäschegesetz (Art. 6(1)(c) GDPR); legitimate interest in fraud prevention for elements beyond the statutory minimum |
| Trade data | order history, chat messages, delivery proofs, reviews, dispute records | Operate the escrow marketplace; resolve disputes; provide trade history; calculate reputation scores. | Contract performance (Art. 6(1)(b) GDPR) |
| Payment data | Stripe customer/account IDs, payout method preference, transaction history (we do NOT see card numbers) | Process payments and seller payouts via Stripe. | Contract performance + legitimate interest in payment integrity |
| Technical data | IP address, browser user-agent, language preferences, cookies for session/auth | Operate the website, prevent abuse, debug errors, detect duplicate accounts. | Legitimate interest (Art. 6(1)(f) GDPR) |
| Communications | support ticket content, transactional emails received, opt-in marketing where applicable | Respond to support requests; send order-related notifications. | Contract performance for transactional; consent for marketing |
3. Third-party processors
We share data only with processors who help us operate the Platform, under contracts that meet GDPR Art. 28 requirements. Current processors:
- Supabase Inc. (US, EU data residency) — database and authentication infrastructure.
- Stripe Payments Europe Ltd.(Ireland) — payment processing, escrow holding, and Connect Express payouts. Stripe is itself the controller for some payment data; see Stripe's privacy notice.
- Vercel Inc. (US) — application hosting and edge networking.
- Resend Inc. (US) — transactional email delivery.
- [TODO if used] — KYC provider (e.g. Stripe Identity / Persona / Veriff). To be filled when integrated.
International transfers (e.g. to US-based processors) rely on Standard Contractual Clauses (SCCs) and, where applicable, the EU-US Data Privacy Framework.
4. Retention
We retain data only as long as needed for the purposes above, plus any statutory retention periods (notably the German tax code & commercial code, which require keeping financial records for up to 10 years). After retention expires, data is deleted or anonymised.
Closed accounts: most personal data is deleted within 30 days of account closure. Trade records and financial documents are retained for the statutory periods even after closure, pseudonymised where possible.
5. Your rights
You have the right to:
- Access — request a copy of the personal data we hold about you (Art. 15 GDPR).
- Rectification — correct inaccurate data (Art. 16). Most fields are editable yourself in profile / settings.
- Erasure— "right to be forgotten" (Art. 17), subject to retention obligations above. Delete your account →
- Restriction — limit processing in certain cases (Art. 18).
- Portability — receive your data in a machine-readable format (Art. 20).
- Objection — object to processing based on legitimate interest (Art. 21).
- Withdraw consent at any time, where processing is based on consent (Art. 7(3)).
- Complaint — lodge a complaint with a supervisory authority. The competent authority in Germany is determined by the state of your residence; a directory is at bfdi.bund.de.
6. Cookies
We use a minimal set of cookies, none for marketing or cross-site tracking. See the Cookie Policy for a full inventory.
7. Security
Passwords are stored hashed (never in plaintext). Data in transit is encrypted (HTTPS/TLS). KYC documents are stored encrypted at rest. Access to production data is logged and limited to authorised personnel. We regularly review our processors' security postures.
8. Changes
We may update this Privacy Policy. Material changes are communicated by email to active accounts at least 30 days before they take effect. The "last updated" date at the top of this page always reflects the current version.