vrtYou Application - Privacy Policy

Last updated March 26, 2025

This Privacy Notice for TrustGrid LLC (doing business as vrtYou) (“we,” “us,” or “our“), describes how and why we might access, collect, store, use, and/or share (“process“) your personal information when you use our services (“Services“) This includes:

  • Downloading and using our mobile application (vrtYou), or any other application of ours that links to this Privacy Notice
  • Engaging with us in other related ways, including any sales, marketing, or events
 

Questions or concerns? If you have any questions about this Privacy Policy, please contact us at privacy@trustgrid.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. This may include identifiers (e.g., email, phone number), geolocation data, device information, and data collected via AI-powered features where applicable. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information we process may be considered sensitive in certain jurisdictions, such as biometric data, geolocation data, or information processed through AI-powered features. We do not process sensitive information without explicit consent, and where applicable, users may opt out of certain data processing activities. Learn more about how we process sensitive information.

Do we collect any information from third parties? We collect limited data from third-party services, such as Google APIs and analytics providers to enhance the functionality of our Services. We do not sell or share personal information for marketing purposes. Learn more about third-party data collection.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, enhance security and fraud prevention, and comply with legal obligations. In certain cases, we may process data using AI-powered tools (e.g., image analysis), with safeguards in place. Users may opt out of certain AI processing where applicable. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share your information in specific situations, such as business transfers, compliance with legal obligations, and integrations with third-party services like Google Maps API. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We use industry-standard Trusted Execution Environment and Hardware Root of Trust, AES-256 encryptions, role-based access controls, and regular security audits to protect your personal information. However, no system is 100% secure, and we encourage users to take precautions when sharing sensitive data online. Learn more about how we keep your information safe.

What are your rights? Depending on your location, you may have rights under laws such as GDPR, CCPA, and other US state laws. These rights may include accessing, correcting, deleting, or restricting the processing of your data, as well as opting out of AI processing and targeted advertising. Learn more  about your privacy rights.

How do you exercise your rights? You can review, update, or delete your data, as well as exercise your rights, by contacting us at privacy@trustgrid.com. We will verify your identity before processing any requests in accordance with applicable laws. Learn more about how to exercise your rights.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full for more details on how we collect, process, and protect your personal data.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Identifiers: Email addresses, usernames, passwords, and phone numbers.
  • Geolocation Data: To deliver location-based services, we collect geolocation data from your device. This data collection is required for the app to function as intended, and cannot be opted out of. The location data we collect will be stored securely in our database. If you wish to change or revoke location permissions, you can do so in your device’s settings.
  • Device & Usage Information: IP addresses, browser type, operating system, and interactions with our Services.

 

Sensitive Information. Some of the information we process may be considered sensitive in certain jurisdictions. We do not collect sensitive personal information, such as racial or ethnic origins, religious beliefs, or biometric data, without explicit consent where required by law. If sensitive data is processed (e.g., geolocation data or AI-generated inferences), we ensure strict security measures and provide opt-out options where applicable.

Application Data. If you use our application(s), we may collect additional information with your permission:

  • Face Data:

 

    • Collection of Face Data: Our application temporarily collects face data solely for the purpose of liveness detection and face matching. This data is processed locally within the app and is not permanently stored in any external server or database. Additionally, users may choose to store their own facial image locally within the app as a profile picture, but this data remains on the user’s device.

 

    • Use of Face Data: Face data is used exclusively for liveness detection and face matching to ensure secure authentication. The collected data is transmitted to our cloud-based processing system for validation. However, no face data is stored on our servers; only a response (match/no-match) is returned to the app.

 

    • Disclosure of Face Data: We do not store, share, or disclose face data to any third party. The face data is used only during the active authentication process and is discarded immediately after processing.

 

    • Sharing of Face Data: We do not share any facial data with third parties, advertisers, or external entities. The data is used exclusively for the app’s core functionality.

 

    • Retention of Face Data: We do not retain face data beyond the duration required for liveness detection and authentication. The data is never stored persistently on any server and remains only temporarily in the local storage of the app when used as a profile picture.

 

  • Geolocation Information: In order to provide you with certain location-based services, we require access to your device’s geolocation information. This access may be granted continuously or only while you are using our mobile application(s). Please note that this permission is mandatory for the app’s functionality and cannot be disabled. The collected location data will be securely stored in our database. You may manage or update these permissions at any time in your device’s settings.

 

  • ACCESS_BACKGROUND_LOCATION – To get the location in background so live location tracking can be possible.

 

  • Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, camera, microphone, storage, sms messages, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

 

  • MANAGE_EXTERNAL_STORAGE – As we need to import and export the files (.json file) in addition with media files.

 

  • DocumentPicker and ImagePicker – in place of MediaStore API (Suggested by Play console error), we have to get access on both Media as well as Documents so using DocumentPicker and ImagePicker.

 

  • Push Notifications: We may send push notifications related to your account or certain app features. You can opt out in your device settings.

 

This information is primarily used to maintain security, troubleshoot issues, and improve app performance.

Google API & Third-Party Integrations

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Additionally, we may collect data from third-party integrations (e.g., analytics tools) to enhance user experience while ensuring compliance with privacy laws.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, enhance security and fraud prevention, comply with legal obligations, and, where applicable, process data using AI-powered tools.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts.
    • We may process your information to allow you to create and log in to your account and maintain its functionality.
  • To deliver and facilitate the delivery of services to the user.
    • We may process your information to provide you with the requested services, including personalized experiences.
  • To enable user-to-user communications.
    • We may process your information when you use features that allow for direct communication with other users.
  • To process data using AI-powered features.
    • We may process your information through AI tools, such as image analysis, to enhance service functionality. We ensure that AI processing complies with applicable laws, and users may opt out where permitted.
  • To improve, personalize, and develop our Services.
    • We may process your information to analyze usage trends, measure the effectiveness of our content, and improve our offerings.
  • To enhance security, prevent fraud, and ensure service integrity.
    • We process personal data to detect unauthorized access, prevent fraudulent activities, and protect against cyber threats.
  • To comply with legal obligations.
    • We may process your information where required by law, including compliance with regulatory requests, law enforcement inquiries, or obligations related to data protection laws.
  • To save or protect an individual’s vital interest.
    • We may process your information when necessary to prevent harm, protect safety, or respond to emergencies.

We only process personal information when we have a valid legal basis, such as user consent, contractual necessity, legitimate interests, or legal compliance. Learn more  about what legal bases we rely on to process your personal information.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share your information in specific situations described in this section and with certain third parties to provide and improve our Services, comply with legal obligations, and protect our users and business interests.

We do not sell your personal information to third parties for marketing purposes.

We may need to share your personal information in the following situations:

  • Business Transfers.
    • We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Legal and Compliance Obligations.
    • We may disclose your personal information where required by law, such as in response to law enforcement requests, court orders, subpoenas, or legal processes.
    • We may share your information when we believe it is necessary to detect, prevent, or address fraud, security concerns, or violations of our Terms of Service.
  • Third-Party Service Providers.
    • We may share your information with vendors, consultants, and other service providers who help us operate our Services, such as:
      • Cloud hosting and data storage providers.
      • Customer support and communications platforms.
      • Analytics and security monitoring services.
      • Third-party integrations (e.g., Google APIs).
    • These third parties are contractually obligated to protect your data and cannot use it for their own purposes.
  • When We Use Google Maps Platform APIs.
    • If you use features that integrate with Google Maps Platform APIs (e.g., location-based services), your data may be processed in accordance with Google’s privacy policies.
  • AI Processing and Data Sharing.
    • If we use AI-powered tools to process your data (e.g., for image analysis or automated decision-making), we will ensure compliance with privacy laws and provide opt-out options where applicable.
  • User-Requested Sharing.
    • We may share your information when you request or consent to share data with third parties, such as through user-to-user communication features.
  • Aggregated or De-Identified Information.
    • We may share anonymized and aggregated data that does not personally identify individuals for business analysis, research, or statistical purposes.

We take appropriate measures to ensure that your personal information is shared securely and in compliance with applicable privacy laws. If you have questions about how we share your data, contact us at privacy@trustgrid.com.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: No, we do not use cookies or any other tracking technologies.

We do not use cookies, web beacons, tracking pixels, or similar technologies to collect or store information for any purpose.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: Yes, we offer products, features, or tools powered by artificial intelligence (AI), machine learning, or similar technologies. We are committed to ensuring transparency, security, and compliance with applicable privacy laws regarding AI processing.

Our AI-Powered Features

As part of our Services, we offer products, features, or tools powered by artificial intelligence and machine learning (collectively, “AI Products”). These tools are designed to enhance functionality, improve efficiency, and provide innovative solutions to users.

Our AI Products currently include, but are not limited to:

  • Image Analysis: AI tools that process images to improve user experience.

We ensure that all AI processing complies with applicable data protection laws, including GDPR, CCPA, and other relevant regulations.

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in accordance with:
Our Privacy Notice and applicable data protection laws.
Strict security measures to protect user data.
Agreements with third parties to ensure compliance with privacy standards.

Our AI Products do not make fully automated decisions that have a legal or similarly significant effect on users without human oversight.

Your Rights & AI Processing

  • Transparency: We provide clear details on how AI processing is used within our Services.
  • Data Minimization: AI processing is conducted only when necessary, and data is anonymized or de-identified whenever possible.

For further information about our AI-powered products or to manage your AI-related privacy preferences, please contact us at privacy@trustgrid.com.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law.

We will retain your personal information:

  • For as long as your account remains active.
  • As necessary to comply with legal, tax, accounting, or regulatory obligations.
  • To resolve disputes, enforce our agreements, and maintain security.

Data Retention Periods

We follow a data minimization policy, ensuring that personal information is retained no longer than necessary:

Data Type

Retention Period

Account Information

Until the user deletes the account or requests deletion, subject to legal requirements.

Transaction Data

Retained as required by tax and financial regulations.

AI-Processed Data

Retained only for the duration necessary for its intended purpose and anonymized where possible.

Security & Fraud Prevention Data

Retained as necessary to detect and prevent security threats or fraud.

What Happens When Retention Ends?

When we no longer have a legitimate business need to process your personal information, we will:
Delete the data, or
Anonymize it, so it can no longer be linked to an individual.

If deletion is not immediately possible due to technical, security, or compliance reasons (e.g., backup storage), we will securely store and isolate the data until deletion is feasible.

For more details on our data retention practices, or to request data deletion, please contact us at privacy@trustgrid.com.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We implement industry-standard technical and organizational security measures to protect your personal information, but no system is 100% secure.

We have established appropriate security safeguards to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Data Encryption:
    • All data in transit is encrypted using TLS (Transport Layer Security).
    • Sensitive data at rest is encrypted using AES-256 encryption.
  • Access Controls & Authentication:
    • We use role-based access controls (RBAC) to limit data access to authorized personnel only.
    • Multi-factor authentication (MFA) is required for administrative access.
  • Security Monitoring & Threat Detection:
    • Our systems are monitored in real time for anomalies and potential breaches.
    • We conduct regular security audits and vulnerability assessments.
  • Data Minimization & Anonymization:
    • Personal information is retained only as long as necessary (see “How Long Do We Keep Your Information?”).
    • Where feasible, data is anonymized or pseudonymized to minimize risk.

Important Security Considerations

Despite our safeguards, no electronic transmission over the Internet or information storage system can be guaranteed 100% secure.

  • We encourage users to take steps to protect their accounts, such as using strong passwords and enabling multi-factor authentication (MFA) where applicable.
  • If you suspect a security issue or believe your personal data has been compromised, please contact us immediately at privacy@trustgrid.com.

For additional information on our security measures, please review our Security Policy or reach out to our team.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to minors.

The vrtYou app and our Services are intended for users aged 18 and older. By accessing or using the Services, you affirm that you are at least the minimum age required by applicable law in your jurisdiction or that you have obtained verifiable parental consent if required.

Parental Responsibility and Consent

  • If you are a minor (under 18 years old), a parent or legal guardian must review and approve your use of our Services.
  • We may request verifiable parental consent before allowing minors to access certain features, in compliance with applicable laws such as the Children’s Online Privacy Protection Act (COPPA) and the GDPR’s child protection requirements.

What Happens if We Collect Minor Data?

  • If we learn that a minor has provided personal information without verifiable parental consent, we will take immediate steps to delete it.
  • Parents or legal guardians may review, request deletion, or modify a minor’s data by contacting privacy@trustgrid.com.

Parental Guidance on Safe Use

We encourage parents and guardians to:
Monitor their child’s online activity.
Educate minors on safe and responsible internet use.
Use parental control settings on devices and applications.

For concerns regarding minor data collection or to request data removal, please contact us at privacy@trustgrid.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location, you may have certain rights regarding your personal information under applicable privacy laws, including the right to access, correct, delete, or restrict processing of your data.

Your privacy rights vary based on your jurisdiction, and we comply with GDPR (EU/UK), CCPA (California), and other applicable data protection laws. These rights may include:

  • Right to Access – You may request a copy of the personal information we have collected about you.
  • Right to Correct – You may request corrections to any inaccurate or incomplete personal information.
  • Right to Delete – You may request the deletion of your personal information, subject to legal exceptions.
  • Right to Restrict Processing – In some cases, you may request that we restrict processing of your personal information.
  • Right to Object – If we process your information based on legitimate interests, you may object to such processing.
  • Right to Data Portability – In certain cases, you may request to receive your personal information in a structured, commonly used format.
  • Right to Opt-Out of AI Processing – If we process your data using AI-powered tools, you may have the right to opt out, where applicable.
  • Right to Withdraw Consent – If we rely on your consent for data processing, you can withdraw that consent at any time.

How to Exercise Your Rights

To exercise any of these rights, please contact us at privacy@trustgrid.com.

  • We will respond to your request within the timeframe required by law.
  • We may verify your identity before processing your request.
  • Some requests may be subject to legal or contractual restrictions that prevent immediate action.

If you are located in the EEA, UK, or Switzerland, and believe we are unlawfully processing your personal data, you also have the right to file a complaint with your local data protection authority.

If you are located in California, Colorado, Virginia, or other US states with privacy laws, you may have additional rights. See “Do United States Residents Have Specific Privacy Rights?” for more details.

For any questions or to submit a request regarding your privacy rights, please contact us at privacy@trustgrid.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

In Short: We do not currently respond to Do-Not-Track (DNT) signals due to the absence of an industry-wide standard.

Most web browsers, mobile operating systems, and some applications include a Do-Not-Track (“DNT”) feature that allows users to indicate their preference not to be tracked online. However, because no universal standard has been established for recognizing and implementing DNT signals, we do not currently respond to them.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of certain U.S. states, including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, you may have specific rights regarding your personal information.

Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information as defined under U.S. state privacy laws:

Category

Examples

Collected?

A. Identifiers

Name, email address, phone number, IP address, account login credentials

Yes

B. Personal Information (Cal. Civ. Code § 1798.80(e))

Contact details, employment information, payment details

Yes

C. Protected Classification Characteristics

Gender, age, race, ethnicity

No

D. Commercial Information

Purchase history, financial transactions

No

E. Biometric Information

Fingerprints, voiceprints

No

F. Internet or Network Activity

Browsing history, interactions with our Services

No

G. Geolocation Data

Precise location information

Yes

H. Sensory Data

Audio, electronic, or visual recordings

No

I. Professional or Employment-Related Information

Job title, employer details

No

J. Education Information

Academic history

No

K. Inferences from Collected Data

User preferences, behavioral analysis

No

We may also collect other information when you engage with us in person, online, or through customer support interactions.

Your Privacy Rights Under U.S. State Laws

Depending on the state where you reside, you may have the following rights regarding your personal information:

  • Right to Know – Request details about the personal information we collect, how we use it, and who we share it with.
  • Right to Access – Obtain a copy of the personal information we have collected about you.
  • Right to Correct – Request corrections to any inaccurate or incomplete personal information.
  • Right to Delete – Request deletion of your personal information, subject to legal exceptions.
  • Right to Opt-Out – Opt-out of certain processing activities, including:
    • Targeted advertising
    • The sale or sharing of personal information
    • Automated decision-making and profiling (where applicable)
  • Right to Data Portability – Receive your personal data in a structured, commonly used format.
  • Right to Non-Discrimination – We will not deny services, charge different prices, or provide a lower level of service if you exercise your privacy rights.

California Residents: You may also exercise rights under the California “Shine the Light” Law (Cal. Civ. Code § 1798.83), which allows you to request details on our disclosures of personal information for direct marketing purposes.

How to Exercise Your Rights

To submit a privacy request, contact us at privacy@trustgrid.com or refer to the contact details at the bottom of this notice.

  • Verification Process: We may require identity verification before processing your request.
  • Authorized Agents: If you appoint an authorized agent to make a request on your behalf, we may require proof of authorization.
  • Response Time: We will respond within the timeframes required by applicable state laws.

If we decline your request, you may have the right to appeal our decision. Appeals should be submitted via privacy@trustgrid.com.

For more details about your U.S. state-specific privacy rights, please contact us at privacy@trustgrid.com.

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Depending on where you reside, you may have additional privacy rights under applicable data protection laws.

Australia & New Zealand

We collect and process your personal information in compliance with:
Australia’s Privacy Act 1988
New Zealand’s Privacy Act 2020

Under these laws, you have the right to:

  • Request access to the personal information we hold about you.
  • Request correction of inaccurate or incomplete personal data.
  • Withdraw consent to data processing where applicable.

Failure to provide necessary personal information may affect our ability to:

  • Offer products or services you request.
  • Manage your account and verify your identity.

If you believe we have breached Australian Privacy Principles (APPs) or New Zealand Privacy Principles, you may file a complaint with:

  • Office of the Australian Information Commissioner (OAIC)
  • Office of the New Zealand Privacy Commissioner

Republic of South Africa

We comply with the Protection of Personal Information Act (POPIA). You have the right to:

  • Request access to, correction, or deletion of your personal data.
  • Object to certain types of data processing.
  • File complaints regarding non-compliance with the Information Regulator (South Africa).

For inquiries or complaints, contact:
📩 General Inquiries: enquiries@inforegulator.org.za
📩 POPIA Complaints: POPIAComplaints@inforegulator.org.za

Other Countries & Regions

If you are located in a country not specifically mentioned above, you may still have rights under local privacy laws. These may include the right to access, correct, delete, or restrict processing of your personal information.

To learn more about your privacy rights based on your location, or to exercise your rights, please contact us at privacy@trustgrid.com.

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this Privacy Notice as necessary to stay compliant with applicable laws and reflect changes to our practices.

We may update this Privacy Notice from time to time. When we make significant changes, we will:

Update the “Last Updated” date at the top of this notice.
Provide a prominent notice on our Services.
Notify you directly if required by law (e.g., via email or in-app notifications).

We encourage you to review this Privacy Notice periodically to stay informed about how we protect your personal information.

If you continue to use our Services after updates take effect, you are acknowledging and agreeing to the revised Privacy Notice.

If you have any questions about changes to this Privacy Notice, please contact us at privacy@trustgrid.com.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this Privacy Notice, you may contact us by email or postal mail:

📩 Email: privacy@trustgrid.com

📍 Mailing Address:
TGrid, LLC
11600 Sunrise Valley Drive, 4th Floor, Reston, Virginia 20191

If you are a resident of the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you may also have the right to contact your local data protection authority regarding our processing of your personal information.

For any further privacy-related inquiries, please reach out to privacy@trustgrid.com.

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

In Short: Depending on the laws applicable to your jurisdiction, you may have the right to review, update, or delete the personal information we have collected from you.

You can request to:
Access the personal information we have about you.
Update or correct any inaccuracies in your personal information.
Delete your personal information, subject to legal or contractual obligations.
Withdraw consent for certain types of data processing where applicable.

How to Submit a Request

To exercise these rights, you may:
📩 Email us at: privacy@trustgrid.com

Upon receiving your request, we may:

  • Verify your identity before processing your request.
  • Retain certain data if legally required (e.g., tax, fraud prevention, compliance).

If your request is denied, you may have the right to appeal our decision in accordance with applicable laws. For more details on exercising your rights, please contact us at privacy@trustgrid.com.