This Privacy Policy explains how ELP Tech Ltd (trading as Trusttle) collects, uses, stores, and shares personal data when you use the TrustBridge platform, visit our website, or contact us. Please read it carefully.
Who We Are
Trusttle is a trading name of ELP Tech Ltd, a company registered in England and Wales.
We operate TrustBridge — an institutional settlement platform that uses smart-contract escrow, multi-party approval flows, and on-chain audit trails to facilitate high-value deal settlements.
For the purposes of UK GDPR and the Data Protection Act 2018, ELP Tech Ltd is the data controller.
Contact: contact@trusttle.com
What Data We Collect
We collect the following categories of personal data:
| Category | Examples | Source |
|---|---|---|
| Identity data | Full name, company name, job title | Provided by you at registration |
| Contact data | Email address, phone number | Provided by you |
| Account credentials | Username, hashed password | Provided by you |
| KYC / verification data | Government-issued ID, proof of address, company documents | Provided by you during onboarding |
| Wallet & blockchain data | Ethereum wallet address, transaction hashes, on-chain activity | Generated when you use the platform |
| Deal & settlement data | Deal terms, parties, commission splits, approval records, escrow amounts | Generated through platform use |
| Usage data | Pages visited, feature interactions, timestamps, IP address, browser type | Automatically collected |
| Communications | Messages sent via deal threads or support requests | Provided by you |
| Early access data | Name, email, firm, interest description submitted via early-access form | Provided by you |
How We Use Your Data
We use your data on the following lawful bases:
| Purpose | Lawful Basis |
|---|---|
| Create and manage your account | Contract performance |
| Facilitate deal creation, approval, escrow funding, and settlement | Contract performance |
| Verify your identity (KYC/AML compliance) | Legal obligation |
| Screen wallet addresses against sanctions lists | Legal obligation / Legitimate interests |
| Prevent fraud, money laundering, and misuse of the platform | Legal obligation / Legitimate interests |
| Send transactional notifications (deal status, approvals, releases) | Contract performance |
| Respond to support queries and communications | Contract performance / Legitimate interests |
| Improve and develop the platform | Legitimate interests |
| Comply with regulatory and legal obligations | Legal obligation |
| Send product updates and relevant communications (you may opt out at any time) | Consent / Legitimate interests |
Blockchain & On-Chain Data
When you participate in a settlement on TrustBridge, certain data is written to a public blockchain (Base mainnet). This includes wallet addresses, transaction hashes, escrow contract interactions, approval signatures, and payout records.
This data cannot be deleted, modified, or erased. Blockchain records are permanent and immutable by design. Once a transaction is confirmed on-chain, it exists on the public ledger indefinitely. Your right to erasure (right to be forgotten) does not apply to data recorded on a public blockchain.
Off-chain data (your account profile, uploaded documents, deal metadata stored in our database) remains subject to your full data rights including erasure.
We minimise the personal data written on-chain. Wallet addresses are pseudonymous identifiers — they do not directly identify you by name. However, in combination with other data, they may constitute personal data under UK GDPR. We treat them accordingly.
By using TrustBridge to participate in an on-chain settlement, you acknowledge and accept that on-chain data is permanent.
Data Sharing
We do not sell your personal data. We share it only as described below:
| Recipient | Purpose | Safeguards |
|---|---|---|
| Other deal parties (buyer, seller, broker, arbiter) | Required to execute the settlement you are party to | Contractual necessity — disclosed deal data only |
| Hiscox (insurance underwriter) | Settlement insurance cover, claims processing | Data processing agreement in place |
| Kleros (dispute resolution) | Arbitration of disputed settlements where activated | Smart contract — on-chain, public |
| Chainalysis (KYT / AML screening) | Wallet screening and transaction monitoring | Data processing agreement; standard contractual clauses |
| Cloud infrastructure providers (Hetzner / VPS) | Hosting and data storage | Servers in EU / EEA |
| Resend (transactional email) | Sending deal notifications and account emails | Data processing agreement; EU data centres |
| Legal and compliance advisors | Regulatory compliance, legal obligations | Bound by professional confidentiality |
| Law enforcement or regulators | Where required by law or court order | Only to the extent legally required |
International Transfers
Our primary infrastructure is hosted in the EU/EEA. However, some third-party processors (including blockchain networks and certain service providers) may process data outside the UK and EEA.
Where we transfer personal data outside the UK or EEA, we ensure appropriate safeguards are in place, including:
- ▸UK International Data Transfer Agreements (IDTAs) or equivalent
- ▸EU Standard Contractual Clauses (SCCs) where applicable
- ▸Adequacy decisions where the destination country is recognised as providing adequate protection
Public blockchain networks (Base mainnet) are global and decentralised. Data written on-chain is replicated across nodes worldwide. This is inherent to blockchain technology and cannot be prevented or reversed.
Data Retention
We retain your data only for as long as necessary for the purposes described in this policy, or as required by law.
| Data Type | Retention Period |
|---|---|
| Account and identity data | Duration of account + 7 years after closure (AML/regulatory requirement) |
| KYC / verification documents | 5–7 years from onboarding or last transaction (regulatory requirement) |
| Settlement and deal records (off-chain) | 7 years from deal completion (financial records obligation) |
| On-chain data (blockchain) | Permanent — cannot be deleted |
| Usage and analytics data | Up to 2 years, then aggregated or deleted |
| Support and communications | 3 years from last contact |
| Early access enquiries | 18 months, unless you become a client |
Your Rights
Under UK GDPR, you have the following rights in relation to your personal data:
To exercise any of your rights, email us at contact@trusttle.com. We will respond within 30 days.
Cookies
We use a minimal set of cookies and local storage to operate the platform:
| Name / Type | Purpose | Duration |
|---|---|---|
| tb-theme (localStorage) | Stores your light/dark mode preference | Persistent until cleared |
| Session cookies | Maintain your authenticated session | Session only |
| Analytics (aggregated, if enabled) | Understand how the platform is used — no individual tracking | Up to 2 years |
We do not use third-party advertising cookies or behavioural tracking. You can clear cookies and local storage at any time via your browser settings.
Security
We implement industry-standard technical and organisational security measures, including:
- ▸TLS 1.3 encryption for all data in transit
- ▸AES-256 encryption for data at rest
- ▸Gnosis Safe multisig escrow — no single party can move funds unilaterally
- ▸Third-party smart contract security audit (pre-mainnet, non-negotiable)
- ▸Ongoing penetration testing and vulnerability monitoring
- ▸Role-based access controls — staff access to personal data is strictly limited
- ▸Hiscox settlement insurance covering disputes and execution failures
No system is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the ICO within 72 hours and inform affected individuals without undue delay.
Children
TrustBridge is a B2B institutional platform intended for professional use only. It is not directed at or designed for use by individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a minor has submitted data to us, please contact us at contact@trusttle.com and we will delete it promptly.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform features.
When we make material changes, we will notify registered users by email and update the effective date at the top of this page. Continued use of the platform after the effective date constitutes acceptance of the updated policy.
We encourage you to review this page periodically.
Contact Us
For any questions about this Privacy Policy, to exercise your data rights, or to raise a concern:
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):
ico.org.uk · 0303 123 1113
ELP Tech Ltd · England & Wales · contact@trusttle.com · Effective April 2026