Privacy Policy

Last Updated: November 28, 2025

This Privacy Policy (“Policy”) describes how we collect, use, protect, and handle personal data of users who visit the website support.gettrust.org (the “Site” or “Service”), in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the California Consumer Privacy Act (“CCPA”), and other applicable data protection laws.

1. Data Controller

The Data Controller responsible for processing personal data is:

• Business Name: GetTrust
• European Website: support.gettrust.org
• Parent Company: GetTrust (gettrust.ru)
• Registered Office: Shpakovskaya St. 19, Stavropol, Russia
• Phone: +7 962 400 07 65
• Email: info@gettrust.ru
• EU Representative (if applicable): [Insert EU GDPR Representative details if required] Sergey Novatov 

Note: As a company with its registered office outside the European Union serving EU customers, we may be required to appoint an EU representative under Art. 27 GDPR. For GDPR-related inquiries, EU residents can contact us at the email address above.

2. Nature of Service and Data Intermediation Role

2.1 Affiliate Marketing Business Model

IMPORTANT: This website operates exclusively as a technical intermediary under an affiliate marketing business model.

All products and services reviewed, recommended, or promoted on this Site are sold by third-party commercial partners (“Official Vendors” or “Suppliers”). The Site Owner is NOT the manufacturer, seller, or distributor of any products featured on this Site.

2.2 Data Processing: Collection and Immediate Transfer

The Site Owner acts exclusively as a technical intermediary for transmitting data to third-party Suppliers.

Lead Data Management Process:

• Personal data provided by users (name, surname, phone, address, email) are collected solely for immediate transfer to the selected Official Vendor/Supplier
• NO permanent storage of personal data occurs on the Site Owner’s servers
• Transfer happens in real-time via API integration or automated systems
• Data passes through the Site only for the time strictly necessary for transmission (immediate technical processing)
• Once transfer is complete, data is NOT archived in any database owned by the Site Owner

Site Owner’s Role under GDPR:

In this context, the Site Owner acts as:

• A Data Processor (Art. 28 GDPR) on behalf of third-party Suppliers, limited to the collection and immediate transmission phase
• The actual Data Controller of received data is the Official Vendor/Supplier who processes the order and manages the commercial relationship
• The Supplier becomes responsible for all subsequent processing: order fulfillment, shipping, customer management, data retention for legal/fiscal obligations

2.3 Limitation of Liability

Products, Sales, and Deliveries:

• Responsibility for product quality, compliance, and safety rests exclusively with Official Vendors
• Responsibility for delivery, shipping, courier management, and package integrity rests exclusively with Official Vendors
• For refunds, returns, complaints, damaged products, lost items, or delivery issues, users must contact the Official Vendor directly
• The Site Owner provides only informational support but has no contractual liability for transactions

Data Processing Post-Transfer:

• The Site Owner is NOT responsible for data processing performed by Suppliers after transfer
• Each Supplier applies their own privacy policy and security measures
• Users are encouraged to review the privacy policies of Suppliers where they make purchases
• To exercise GDPR rights (deletion, rectification, access) on data retained by Suppliers, users must contact them directly

3. Types of Data Collected

3.1 Personal Data Provided Voluntarily

When using the Service, we may collect the following categories of personal data provided voluntarily:

• First and last name
• Email address
• Phone number
• Postal address (street, city, state/province, ZIP/postal code, country)
• Any other information provided via contact forms or specific requests

3.2 Navigation Data (Usage Data)

The Site automatically collects certain data during navigation, including:

• IP address
• Browser type and version
• Operating system
• Pages visited and time spent
• Referring URL (referrer)
• Date and time of access
• Unique device identifiers
• Approximate geolocation data

3.3 Cookies and Tracking Technologies

The Site uses cookies and similar technologies (web beacons, pixels, tags) to improve user experience and analyze traffic. For detailed information, please refer to our Cookie Policy.

4. Purpose and Legal Basis for Processing

Personal data is processed for the following purposes:

5. Processing Methods

Personal data processing is performed using computerized and telematic tools, with logic strictly related to the stated purposes and adopting adequate security measures to ensure:

• Data confidentiality and integrity
• Protection from unauthorized access, loss, or destruction
• Use of security protocols (HTTPS, SSL/TLS encryption)
• Backup and disaster recovery procedures
• Training of personnel authorized to process data

Data is collected according to the principle of data minimization: we only request data strictly necessary for the declared purposes.

6. Data Retention

Due to the technical intermediation nature of the service, retention periods are minimal:

6.1 Lead Data (Name, Phone, Address)

• Retention period: ZERO – Data is immediately transferred to the Supplier and NOT stored on our servers
• Possible temporary technical storage only in encrypted system logs for maximum 7 days for security and technical troubleshooting purposes, then automatic deletion

6.2 Aggregated Navigation Data

• Anonymous analytics data: retained for 26 months
• Session cookies: deleted when browser is closed
• Marketing cookies (with consent): maximum duration of 13 months

6.3 Marketing Consents (If Obtained)

• Consent records: retained for 10 years for evidentiary purposes (legal obligation)
• Email addresses for newsletters: retained until consent withdrawal or 24 months from last interaction

6.4 Data for Legal Obligations

• Retained according to terms required by applicable fiscal and legal regulations

7. Data Recipients and Communication

Personal data may be communicated or accessible to the following categories of recipients:

7.1 Third-Party Suppliers (Official Vendors)

Primary and immediate lead data transfer.

When users complete an order form or product request, their personal data (name, surname, phone, address, email) is immediately transferred to the selected Official Vendor/Supplier for order fulfillment.

These entities act as independent Data Controllers for received data and are responsible for its management, storage, and protection according to their own privacy policies.

7.2 Affiliate Networks

For commission tracking and performance monitoring, we share aggregated and anonymous data (e.g., transaction ID, order value) with affiliate networks.

Note: Personally identifiable information is NOT shared with affiliate networks.

7.3 Third-Party Service Providers

• Hosting and cloud infrastructure providers
• Email marketing and CRM service providers
• Analytics platforms (Google Analytics, Facebook Pixel, TikTok Pixel)
• Payment service providers (if applicable)
• Customer support service providers
• Marketing and advertising agencies

These entities act as Data Processors (Art. 28 GDPR) based on specific contracts that guarantee adequate levels of security and compliance.

7.4 Public Authorities and Entities

Data may be communicated to public authorities, law enforcement, or regulatory bodies when required by legal obligations or to protect the Controller’s rights.

8. International Data Transfers

IMPORTANT: Cross-Border Data Transfers

As GetTrust operates with its registered office in Russia (outside the EU/EEA) and serves European customers through support.gettrust.org, personal data may be transferred to Russia for technical processing purposes.

International data transfers are performed in compliance with GDPR Chapter V through one or more of the following safeguards:

• Standard Contractual Clauses (SCCs) approved by the European Commission (Art. 46 GDPR)
• Binding Corporate Rules where applicable
• Additional technical and organizational measures to ensure data protection equivalent to EU standards
• Data encryption during transfer and storage
• Strict access controls and authentication procedures

Additional service providers may transfer data to countries outside the EU/EEA (e.g., United States for cloud or analytics services) using:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Certifications (e.g., EU-US Data Privacy Framework)
• Adequate safeguards in accordance with Arts. 44-49 GDPR

Users can request information about specific safeguards implemented for data transfers by contacting us at info@gettrust.ru.

9. Use of Artificial Intelligence

The Site may use artificial intelligence (AI) systems for the following purposes:

• Content personalization and product recommendations
• Chatbot and automated assistance
• Predictive analytics and marketing campaign optimization
• Automated generation of textual content or product descriptions

AI usage complies with principles of transparency, non-discrimination, and accuracy as required by GDPR and the AI Act (EU Regulation 2024/1689). Users have the right to request human intervention in automated decisions that produce legal or significant effects.

10. Data Subject Rights

Under Arts. 15-22 of GDPR and applicable consumer privacy laws, users have the right to:

• Access (Art. 15): obtain confirmation of data existence and receive a copy (in most cases we do NOT retain personal data)
• Rectification (Art. 16): correct inaccurate or incomplete data – request directly from the Supplier who stores the data
• Erasure (Art. 17 – “right to be forgotten”): request deletion – request from the Supplier, as data is not stored by the Site Owner
• Restriction (Art. 18): restrict processing in case of dispute or rights protection – request from the Supplier
• Data Portability (Art. 20): receive data in structured format and transmit to another controller – request from the Supplier
• Objection (Art. 21): object to processing for direct marketing or based on legitimate interest
• Consent Withdrawal: withdraw marketing consent at any time (without affecting lawfulness of previous processing)
• Complaint (Art. 77): lodge a complaint with the relevant Data Protection Authority

How to Exercise Rights:

For data managed by GetTrust (marketing consents, newsletters):

• Email: info@gettrust.ru
• Phone: +7 962 400 07 65
• Mail: GetTrust, Shpakovskaya St. 19, Stavropol, Russia

For data transferred to Suppliers (orders, deliveries, purchase personal data):

Users must contact the Supplier directly where they made the purchase, using contact information in their privacy policy. GetTrust can provide support to identify the correct Supplier.

California Residents (CCPA Rights):

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information
• Right to opt-out of sale of personal information
• Right to non-discrimination for exercising your rights

To exercise CCPA rights, contact us at info@gettrust.ru or call +7 962 400 07 65.

Supervisory Authorities:

• EU/EEA: Contact your national Data Protection Authority – List of EU DPAs
• UK: Information Commissioner’s Office (ICO) – www.ico.org.uk
• California: California Privacy Protection Agency – www.cppa.ca.gov

11. Cookies and Tracking Technologies

The Site uses various types of cookies:

11.1 Technical Cookies

Necessary for Site functionality. No consent required.

• Session cookies for navigation
• Security and authentication cookies
• Preference cookies (language, layout)

11.2 Analytics Cookies

Used for aggregate statistical traffic analysis. May be treated as technical cookies if properly configured to anonymize IPs.

• Google Analytics (configured for IP anonymization)
• Heatmap and behavioral analysis tools

11.3 Profiling Cookies

Used to track navigation and create user profiles for personalized marketing. Require explicit prior consent.

• Facebook Pixel
• Google Ads
• TikTok Pixel
• Remarketing and retargeting cookies

11.4 Third-Party Cookies

Cookies installed by commercial partners and advertising networks. Please review their respective privacy policies:

• Meta/Facebook: https://www.facebook.com/privacy/policy/
• Google: https://policies.google.com/privacy
• TikTok: https://www.tiktok.com/legal/privacy-policy

Cookie Management: Users can manage cookie preferences through the consent banner displayed on first access to the Site. Browser settings can also be modified to block or delete cookies, which may impact Site functionality.

12. Children’s Privacy

The Service is not directed to minors under 18 years of age. We do not knowingly collect personal data from minors without verified parental or legal guardian consent. If we become aware that we have collected data from minors without authorization, we will proceed with immediate deletion.

Under the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect information from children under 13. If you believe your child under 13 has provided personal information, please contact us immediately at info@gettrust.ru.

13. Links to Third-Party Sites

The Site contains links to websites of commercial partners and third-party vendors. Once users click on such links, they are redirected to external sites not managed by GetTrust. We have no control over and assume no responsibility for the content, privacy policies, or practices of third-party sites or services. Users are encouraged to carefully read the privacy policies of visited sites.

14. Affiliate Marketing Disclosure

IMPORTANT DISCLOSURE: This website participates in affiliate marketing programs and may earn commissions on purchases made through links on this site.

What this means:

• When you click on certain product links and make a purchase, we may receive a commission from the vendor
• This comes at no additional cost to you
• We only recommend products and services we believe will add value to our readers
• Our editorial content is not influenced by affiliate partnerships
• All opinions expressed are our own

This disclosure is made in accordance with the Federal Trade Commission’s 16 CFR, Part 255: “Guides Concerning the Use of Endorsements and Testimonials in Advertising” and applicable EU consumer protection laws.

15. Changes to This Privacy Policy

GetTrust reserves the right to modify or update this Policy at any time to comply with new regulations, improve privacy practices, or reflect changes in offered services.

In case of substantial changes, users will be informed via:

• Prominent notice on the Site
• Email notification (if available)
• Update of the “Last Updated” date at the top of this document

We recommend periodically reviewing this page to stay informed about how we protect personal data.

16. Product and Liability Disclaimer

IMPORTANT NOTICE:

• Products recommended on this Site are sold under an affiliate marketing model
• This Site is NOT the manufacturer or official seller of reviewed products
• For refunds, returns, complaints, delivery issues, defective or damaged products, users must always contact the official vendor where the purchase was made
• Responsibility for delivery, package integrity, and courier management rests exclusively with the official vendor
• GetTrust provides informational support but has no contractual liability for the sales transaction

Products are reviewed for informational purposes. Results cannot be guaranteed; effectiveness varies by customer. Images may be sourced from the web: if you believe they may infringe your rights, contact us at info@gettrust.ru for immediate removal.

17. Social Media Disclaimer

This site is not a part of the Facebook website or Facebook Inc. Additionally, this site is NOT endorsed by Facebook in any way. FACEBOOK is a trademark of META PLATFORMS, INC.

This site is not a part of the TikTok website or TikTok Inc. Additionally, this site is NOT endorsed by TikTok in any way. TIKTOK is a trademark of BYTEDANCE LTD.

This site is not a part of the Google website or Alphabet Inc. Additionally, this site is NOT endorsed by Google in any way. GOOGLE is a trademark of ALPHABET INC.

18. Contact Information

For any questions or requests regarding this Privacy Policy, you can contact GetTrust at:

• Website: support.gettrust.org (European site) | gettrust.ru (Parent company)
• Email: info@gettrust.ru
• Phone: +7 962 400 07 65
• Mailing Address: Shpakovskaya St. 19, Stavropol, Russia

We are available to provide support and clarification regarding personal data processing.

Business Hours: Monday – Friday, 9:00 AM – 6:00 PM (Moscow Time, GMT+3)

19. Clarifications on Intermediation Model

Question: Where is my data stored?

Your personal data (name, phone, address) is NOT stored on support.gettrust.org servers. It is transferred immediately and automatically to the Supplier/Vendor you selected, who becomes the sole entity storing and managing it.

Question: Who should I contact to modify/delete my data?

You must contact the Official Vendor directly where you placed your order, as they are the only entity storing your data.

Question: Who is responsible for delivery?

Responsibility for shipping, couriers, delivery times, and package integrity rests exclusively with the Official Vendor.

Question: Can I trust the data transfer?

Yes. Transfer occurs via encrypted connections (HTTPS/SSL) and Suppliers we partner with are selected for their GDPR compliance.

Question: What if there’s a problem with my order or delivery?

Contact the Official Vendor directly. We can provide their contact information if needed, but all order-related issues (including shipping problems, damaged items, returns, and refunds) must be resolved directly with them.

Question: Why is GetTrust based in Russia but serving EU customers?

GetTrust operates internationally with its headquarters in Stavropol, Russia (gettrust.ru) and a dedicated European service through support.gettrust.org. We comply with GDPR requirements for serving EU customers and implement appropriate safeguards for international data transfers.

© 2025 GetTrust – All Rights Reserved
support.gettrust.org (Europe) | gettrust.ru (Parent Company)