PRIVACY POLICY

TruthLayer® Software

Operated by CheckTransfer Tech B.V.

Last updated: 24-02-2026

1. Identity of the Data Processor

This Privacy Policy describes how personal data is processed within the TruthLayer® software environment.

TruthLayer® is developed and operated by:

CheckTransfer Tech B.V.

The Netherlands

Chamber of Commerce (KvK): 99698277

Email: support@check-transfer.com

Phone: +31 85 040 6311

CheckTransfer Tech B.V. is a software development company and independent SaaS provider.

CheckTransfer Tech B.V.:

is not an Online Travel Agency (OTA)
is not a transport provider
is not a broker or intermediary
does not sell travel or transfer services
is not a contracting party in any transport agreement

TruthLayer® operates exclusively as an independent digital verification infrastructure between booking entities, passengers and transport providers.

2. Role Under GDPR

For purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”):

The booking entity / OTA / transport company acts as Data Controller.
CheckTransfer Tech B.V. acts as Data Processor.

CheckTransfer Tech B.V. processes personal data solely on documented instructions from the Controller.

TruthLayer® does not independently determine the purposes or means of commercial data processing.

3. Purpose of Processing

Personal data within TruthLayer® is processed exclusively for:

Logging booking information as received from Controller
Timestamping operational workflow events
Registering driver and passenger confirmations
Preserving immutable audit records
Providing neutral evidentiary infrastructure

TruthLayer® does not use personal data for:

Marketing
Profiling
Commercial resale
Behavioral analysis
Independent commercial exploitation

Processing is strictly limited to operational verification and digital evidence preservation.

4. Categories of Data Processed

Depending on system configuration by the Controller, data may include:

Passenger name
Phone number
Email address
Flight details
Pickup and drop-off location
Booking reference
Driver identification
Vehicle details
Event timestamps
Digital confirmations
System log data

TruthLayer® does not expand data categories beyond those transmitted by the Controller.

5. Lawful Basis

The lawful basis for processing is determined solely by the Controller.

The Controller is responsible for:

Informing data subjects
Providing privacy notices
Obtaining consent where required
Ensuring lawful data collection

CheckTransfer Tech B.V. processes data strictly under Article 28 GDPR (Processor obligations).

6. Data Minimization & Neutrality

TruthLayer® is architected according to the principles of:

Data minimization
Purpose limitation
Storage limitation
Integrity and confidentiality

CheckTransfer Tech B.V. has no commercial interest in:

The outcome of a transfer
Whether a booking is completed
Whether a dispute arises

TruthLayer® operates as a neutral technological layer.

7. Data Security

CheckTransfer Tech B.V. implements appropriate technical and organizational measures, including:

Encrypted data transmission (TLS/SSL)
Role-based access control
Multi-layer authentication
Secure hosting infrastructure
Continuous monitoring and logging
Access limitation to authorized personnel

TruthLayer® is designed as an event-logging environment to reduce risk of data manipulation.

8. Data Retention

Personal data is retained:

According to Controller instructions
For contractual duration
For legally required evidentiary preservation where applicable

Deletion requests are assessed in light of:

Legal retention requirements
Contractual obligations
Audit trail integrity

9. International Data Transfers

Data is primarily processed within the European Economic Area (EEA).

If transfers outside the EEA occur, appropriate safeguards (such as Standard Contractual Clauses) will be implemented in accordance with GDPR Chapter V.

10. Sub-Processors

CheckTransfer Tech B.V. may use carefully selected infrastructure providers (e.g., hosting providers).

All sub-processors are bound by written agreements ensuring GDPR compliance and equivalent data protection standards.

A sub-processor list is available upon request.

11. Data Subject Rights

Data subjects may exercise their rights under GDPR, including:

Right of access
Right to rectification
Right to erasure
Right to restriction
Right to portability
Right to object

Requests must be directed to the Controller (OTA or booking entity).

CheckTransfer Tech B.V. will assist the Controller where reasonably possible.

12. Data Breach Notification

In the event of a personal data breach, CheckTransfer Tech B.V. will:

Notify the Controller without undue delay
Provide relevant technical details

The Controller remains responsible for supervisory authority notification unless otherwise required by law.

13. Intellectual Property & Use of Software

TruthLayer® and all related software components remain the exclusive intellectual property of CheckTransfer Tech B.V.

Users may not:

Reverse engineer the software
Copy or replicate the system
Modify proprietary elements
Remove trademark or copyright notices
Use the software outside licensed scope

TruthLayer® is protected under applicable copyright, trademark and intellectual property laws.

14. Limitation of Liability

To the maximum extent permitted by law:

CheckTransfer Tech B.V. shall not be liable for:

Transport service failures
Passenger no-shows
Driver non-performance
Commercial disputes
Indirect or consequential damages
Loss of revenue or goodwill

Liability, if any, is limited to the SaaS fees paid in the relevant contractual period.

15. Changes to This Policy

CheckTransfer Tech B.V. reserves the right to update this Privacy Policy.

Material changes will be communicated appropriately.

Continued use of TruthLayer® constitutes acceptance of the updated policy.

16. Contact Information

For privacy or compliance inquiries:

CheckTransfer Tech B.V.

Email: support@check-transfer.com

Phone: +31 85 040 6311