When we refer to “Trevor”, we mean TMD Technology Limited, a company incorporated in England with company number 13856879 whose registered office address is at International House, 142 Cromwell Road, London, United Kingdom, SW7 4EF, which is the entity that acts as the controller or processor of your information.
The UK GDPR merges together two prior sets of data protection regulations namely, the EU GDPR and the DPA 2018. The UK GDPR became effective from 1st January 2021. It is almost identical to the EU GDPR, and sets the same standards as required under the EU GDPR. It has been formally recognised by the EU Commission as providing appropriate data protection. The transfer of personal information from the EU to the UK has been specifically permitted under the ‘EU adequacy provisions’ and, similarly, under UK GDPR, the transfer of data from the UK to the EEA is also permitted.
Information We Collect And Receive
Trevor may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
(1) Customer Data. Customers or individuals granted access to a Datasource by a Customer (“Authorized Users”) may submit Information ("Customer Data") to Trevor while using the Services. For example, if you run a query against your database using Trevor, Customer Data will be submitted to Trevor in the form of the results of your query.
(2) Other Information. Trevor also collects, generates and/or receives Other Information:
How We Use Information
A quick distinction
Data protection law in certain jurisdictions, such as in the UK and the EU, differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, Trevor is the processor of Customer Data and the controller of Other Information.
Customer Data will be used by Trevor in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Customer may, for example, use the Services to grant and remove access to a Datasource, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its own policies to the Services.
In accordance with its obligations under GDPR, Trevor uses Customer Data and Other Information in furtherance of our legitimate interests in operating our Services, Website and business. More specifically, Trevor uses Customer Data and Other Information:
Data Storage and Retention
Trevor stores Customer Data for between 24 and 48 hours for performance reasons, and to protect your database from too much load. It is then permanently deleted.
Customer Data and Other Information are stored on Heroku Postgres or Amazon S3.
How We Share And Disclose Information
This section describes how Trevor may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Trevor does not control how they or any other third parties choose to share or disclose Information.
Trevor takes security of data very seriously. Trevor works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology.
To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Practices. Given the nature of communications and information processing technology, Trevor cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.
International Data Transfers
Trevor may transfer Personal Data between the UK and the European Union or Switzerland and the US. We will protect your personal data when it is transferred outside of the EEA, the UK or Switzerland by processing it in a territory which the European Commission has determined provides an adequate level of protection for personal data; or otherwise ensuring appropriate safeguards are in place to protect your personal data. For transfers of your personal data to the US, following the invalidation of the Privacy Shield, we will rely on the Standard Contractual Clauses approved by the European Commission.
Data Protection Officer
To communicate with our Data Protection Officer, please email email@example.com.
Your principal rights under data protection law are (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
To the extent that the legal basis for our processing of your personal data is (a) consent or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
In addition, individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance.
To the extent that Trevor’s processing of your Personal Data is subject to the General Data Protection Regulation, the legal basis for processing your information will be in order to fulfil the terms of the services you have requested or our legitimate interests, which are the proper administration of our website and business. Trevor may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Trevor’s use of your Personal Data for this purpose at any time.
Data Protection Authority
Subject to applicable law, you also have the right to restrict Trevor’s use of Other Information that constitutes your Personal Data and lodge a complaint with your local data protection authority if you believe that we are misusing your information in any way.
If you have any questions, please contact Trevor on firstname.lastname@example.org.