TRULINCO PRIVACY POLICY

Introduction

This privacy policy (the “Privacy Policy”) describes how Trulinco (“Trulinco”, “us”, “we”, “our”) collects, uses, discloses and disposes of personal information relating to users who have an account with Trulinco or use the Trulinco Services through our website, desktop or mobile application (collectively referred to as “you”, “your”).

Trulinco takes your privacy seriously and is committed to respecting and safeguarding your privacy and the confidentiality of your personal information when you use the Trulinco Services.

Trulinco processes personal information in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), and the Data Protection Act (Chapter 586) of the laws of Malta and its subsidiary legislation, where applicable (collectively, the “Applicable Data Protection Laws”).

Trulinco Services

Trulinco is a multilingual cloud application/platform that allows users to translate documents, text and verbal messages, images, voice calls and video calls, and to send and receive text and verbal messages in their preferred language through its website or mobile application (“Trulinco Services”).

Certain translation, image recognition and speech features use third-party AI services. The content processed, the providers receiving it and your permission choices are described in the AI Features and Data Sharing section below.

Data Controller

The data controller is KBJ LTD, bearing company registration number C 94117 and having its registered office situated at Micallef Group, Triq Ic-Cimiterju, Ghaxaq GXQ 2248, Malta (the “Data Controller”).

The designated contact person of the Data Controller is Kurt Micallef, who can be reached at kurt@trulinco.com.

You may contact the Data Controller by mail at the registered office address above or by email at kurt@trulinco.com for questions about this Privacy Policy, the processing of your personal information or the exercise of your data protection rights.

Interpretation

Terms used in this Privacy Policy that are not defined herein shall have the same meaning as in the GDPR.

What Type of Personal Information Do We Process?

Identification information and user account details: your name and surname, address, email address, mobile phone number, age, date of birth, gender, account name and password, and profile name, as provided through the relevant account features. Information relating to gender may be used to select a male or female narration voice.

Social networking account information: account names and information provided when you choose to connect to Trulinco through Facebook or another supported social media service.

Payment information: information relating to the payment method you choose, where applicable, including payment details you provide, transaction information and payment history. Payment information handled by a payment provider is also subject to that provider’s applicable terms and privacy policy.

Preferences: interests, language settings, preferences, feedback and survey responses, where applicable.

Technical and usage data: IP address, login data, browser type and version, device make and model, operating system, hardware version, platform, device settings, browser plug-in information, Bluetooth or WiFi signals, connection information such as your mobile operator or internet service provider, language and time zone, and information about how you use the Trulinco Services, including screens visited, searches and redemption of offers.

Uploaded and shared content: photos, images, videos, voice messages, documents, comments, messages and other information that you upload, submit for processing or choose to share with users or non-users of Trulinco. This content may include personal information about you or other people.

Contacts: where you provide permission, we may access your address book to identify contacts who already use Trulinco. The contacts synchronisation feature may check phone numbers from your address book on a regular basis. These address-book numbers are not stored by Trulinco. Numbers are checked to identify registered Trulinco users, allowing you to communicate with contacts already using the application.

Content used with AI features: depending on the feature you choose, we process text and chat messages, selected documents and images, voice recordings, call audio and transcripts generated from audio. We obtain this content when you enter text, select or upload a file, or activate a voice, image recognition or call translation feature.

Receiving 2FA Text Messages

To enhance account security, we may send a two-factor authentication (2FA) code by SMS when you log in or perform sensitive actions. These messages are used for authentication and not for marketing. Your phone number and the information necessary to deliver the message may be processed by the authentication and messaging service providers involved in sending the SMS.

Purpose and Legal Grounds

Trulinco processes personal information for the following purposes:

Providing the Services: operating, maintaining and improving the Trulinco Services and their features;
Account management: registering, creating, authenticating and managing your account;
Translation and AI processing: translating content and providing image recognition and speech features through the services described below;
Contact synchronisation: identifying contacts who use Trulinco and facilitating communication in your preferred language;
Promotional communications: providing information about our services, activities, offers and discounts, subject to applicable consent requirements;
Usage management: calculating usage quotas, maintaining service availability and identifying excessive or abnormal usage;
Legal compliance: complying with applicable laws, regulations and lawful requests;
Legal claims: establishing, exercising or defending legal claims;
User requests and support: responding to questions, verifying requests and helping you exercise your data protection rights.

The legal grounds for processing your personal information include:

Performance of a contract: processing necessary to provide the Trulinco Services under our Terms of Use;
Legitimate interests: operating the Services efficiently, maintaining accurate records, improving functionality, protecting service security, preventing misuse and defending legal claims, subject to your rights and interests;
Consent: where required for marketing communications, access to contacts or other device information, and sharing content with third-party AI services;
Legal obligations: processing necessary to comply with applicable law.

Who Do We Share Your Personal Data With?

To provide the Trulinco Services, we may share information with the following recipients:

Trulinco personnel: employees who need access to perform their duties;
Suppliers: service providers supporting our software, maintenance, authentication, messaging, email, hosting, servers and cloud infrastructure;
AI service providers: Microsoft Azure and Google, including Gemini and Cloud Vision, for the purposes and data categories described below;
Other users and recipients: people with whom you choose to communicate or share content through the Services;
Social media services: services with which you choose to share information, subject to their privacy policies and your account settings;
Public authorities and courts: where necessary to comply with legal obligations, respond to lawful requests or defend legal claims;
Banks, payment providers and auditors: where necessary to process payments or fulfil financial, statutory or audit obligations;
Professional advisors: accountants and legal, tax or other advisors engaged to provide necessary services.

AI Features and Data Sharing

Trulinco uses third-party AI services to provide translation, image recognition and speech features. When you use these features, the relevant content is transmitted to the applicable provider, directly from the app or through our servers.

What Data Is Sent to AI Services?

Depending on the feature you choose, the content sent may include:

Text you enter or select for translation, including chat messages;
Documents and images you select or upload;
Voice recordings or call audio processed when you activate speech or translated-call features;
Transcripts generated from audio for speech processing and translation.

This content may contain personal information, including information appearing in messages, documents, images or recordings. The content processed depends on the feature you activate.

AI Providers and Processing Purposes

Microsoft Azure: processes text, chat messages, selected documents and images, and voice or call audio for translation, text recognition and speech processing, depending on the feature used.
Google Gemini: processes voice audio and transcripts for speech translation.
Google Cloud Vision: processes selected images for image recognition.

The provider receiving your content depends on the feature you use. The categories listed above do not mean that every provider receives all of your content.

Trulinco uses the paid Gemini API. Under Google’s terms for Paid Services, submitted content and generated responses are not used to improve Google’s products. Google may retain prompts and responses for a limited period for abuse prevention, service security and required legal or regulatory disclosures.

Your Permission and Choices

On iOS, the Data Privacy Consent prompt explains the content shared and identifies the providers before you authorize the relevant AI processing. Selecting “I agree” permits this sharing when you use the relevant features.

If you select “Do not agree” or dismiss the prompt without agreeing, features that require this permission remain unavailable. Attempting to use one of these features again will display the consent prompt again.

You can change or withdraw your permission in Settings → AI data sharing. Withdrawing permission stops active AI processing controlled by the app and blocks further AI requests that require this permission until you agree again.

Withdrawing permission does not itself delete content already processed or stored. You may request deletion as described in this Privacy Policy. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Permission for AI data sharing is separate from cookie preferences and device permissions, such as microphone or photo access.

Protection of Data Shared with AI Providers

Trulinco requires third-party providers that process personal data on its behalf to provide the same or an equivalent level of protection as described in this Privacy Policy. This includes obligations concerning confidentiality, data security, restricted access and the handling of personal data for the agreed purposes.

Microsoft Azure services are subject to the applicable Microsoft Products and Services Data Protection Addendum. Google Cloud Vision is subject to the applicable Google Cloud terms and Cloud Data Processing Addendum. Paid Gemini API processing is subject to the Gemini API Terms and the Google Data Processing Addendum applicable to those services.

You can review the providers’ terms here:

International Data Transfers

Trulinco and its service providers may process personal information in the European Economic Area (EEA) and other countries where the relevant providers or their authorised subprocessors operate. Processing locations depend on the service used and its applicable terms and configuration.

Where personal information is transferred outside the EEA, Trulinco requires an applicable lawful transfer mechanism and safeguards under Applicable Data Protection Laws. These may include an applicable adequacy decision or Standard Contractual Clauses, together with additional safeguards where required.

You may contact kurt@trulinco.com for information about the safeguards relevant to your personal data.

How Long Do We Keep Your Data For?

We retain personal information only for as long as necessary for the purposes described in this Privacy Policy, including providing the Services, maintaining security, meeting legal obligations and resolving disputes.

Account information: we generally retain information needed to provide and manage your account while it remains active. Personal information associated with an account that has been inactive for two (2) years is deleted, subject to the legal and operational exceptions described below.

Account deletion: when you deactivate your account or request deletion, we delete the associated personal information unless continued retention is necessary to comply with legal or statutory obligations, establish or defend legal claims, or respond to lawful enquiries or investigations.

Translation and AI content: submitted text, documents, images, audio, transcripts and results may be processed or temporarily stored as necessary to complete the requested operation and deliver its results. Retention depends on the feature, whether content forms part of a saved conversation or user-requested history, and the applicable provider’s processing arrangements.

Provider processing: third-party providers may retain certain content or processing records for service security, abuse prevention and legal compliance under their applicable terms. For example, the paid Gemini API terms allow limited retention of prompts and responses for these purposes. Completing a translation or withdrawing consent does not necessarily cause immediate deletion of every provider-held record.

Technical records and backups: where information is retained in technical records or backups, the retention period is determined by the need to operate and secure the Services, investigate errors, maintain recovery capabilities and comply with applicable obligations. Such retention does not permit unrelated use of the information.

Copies you save: where available, you may choose to save or back up translations to your email account, iCloud or another service. Copies you save are governed by your settings and the relevant provider’s policies.

The criteria used to determine retention periods include the type and sensitivity of the data, the purpose for which it was collected, whether your account remains active, your deletion requests, technical requirements and applicable legal obligations.

To request deletion or information about retention of your data, contact kurt@trulinco.com.

What Rights Do You Have?

Trulinco maintains technical and organisational measures intended to support the exercise of your rights under Applicable Data Protection Laws.

Depending on the circumstances and applicable law, you have the following rights:

Right to information: you have the right to be informed about who processes your personal information, how and why it is processed, where it is processed and how long it is retained. Please contact us if you require information not provided in this Privacy Policy.

Right to access: you have the right to know what personal data we hold about you and to request access to or a copy of it, subject to applicable restrictions and the rights of other people. You can view and manage information through your Profile section in the app or website. You may also contact us to make an access request.

Right to rectification: you have the right to correct inaccurate or incomplete information. You can update supported account information through Settings → Profile. If you cannot update particular information, including your mobile number, please contact us. A change of mobile number may require creation of a new account.

Right to erasure: you may request deletion of your personal information where the conditions under Applicable Data Protection Laws are met. You can deactivate your profile through the settings menu or contact us to request deletion. Where continued retention is required or otherwise permitted by law, we will explain the relevant reason where legally permitted.

Right to portability: where processing is based on consent or contract and carried out by automated means, you may request a copy of the relevant personal data in a structured, commonly used and machine-readable format, or request its transfer to another provider where technically feasible.

Right to object: you may object to processing based on legitimate interests on grounds relating to your particular situation. You may also object to the processing of your personal information for direct marketing.

Right to restriction: you may request restriction of processing in the circumstances provided by Applicable Data Protection Laws, including certain cases where you contest the accuracy of information or object to its processing.

Right to withdraw consent: where processing is based on consent, you can withdraw it. For AI data sharing on iOS, use Settings → AI data sharing. For other consent-based processing, contact info@trulinco.com. You can unsubscribe from marketing communications through the available unsubscribe function. Withdrawal does not affect the lawfulness of processing before withdrawal.

Right to lodge a complaint: you may contact us with concerns about the processing of your personal data. You also have the right to lodge a complaint with the Information and Data Protection Commissioner in Malta or another competent supervisory authority.

We may need to verify your identity before responding to a request. We will respond within the periods required by Applicable Data Protection Laws and inform you if a permitted extension is necessary.

Privacy requests may be sent to kurt@trulinco.com or info@trulinco.com. Requests concerning payments may be sent to payments@trulinco.com.

Translation and Conversation Usage (Usage Quotas and Limits)

To ensure fair and optimal usage of the Trulinco Services, we apply certain usage quotas to translation and conversational features. These quotas are shared across supported translation formats, including text, audio, video and call translations.

Translation and Conversation Limit

You may use up to 100,000 characters per month, equivalent to approximately 130 minutes of translated conversation using the estimates below. This is a shared quota across translation formats, not a separate allowance for each format.

Approximate Calculation

Estimated speaking rate: 130 words per minute
Estimated word length: 6 characters
1 minute ≈ 780 characters
100,000 characters ≈ 128 minutes of speech, rounded to approximately 130 minutes

These conversions are illustrative. Actual usage depends on the language, speaking rate and amount of text processed.

Example

Using these estimates, 90 minutes of translated conversation would use approximately 70,200 characters, leaving approximately 29,800 characters for other translations. This remaining allowance is equivalent to approximately 38 additional minutes of speech.

Trulinco monitors usage to ensure fair access to all users. Excessive or abnormal usage patterns may result in temporary suspension or limitation of service access in line with our Terms of Use.

Cookies

Our website uses cookies to help provide a useful and reliable experience. Cookies are small text files placed on your computer or mobile device when you browse websites.

Cookies help us to:

Make our website work as expected;
Keep you signed in between visits;
Remember your settings during and between visits;
Improve the speed and security of the website;
Support sharing pages through social networks;
Understand how visitors use the website and improve its functionality;
Measure and improve the relevance of our marketing.

We use the following types of cookies:

Essential: cookies needed to provide services you request, such as maintaining your signed-in session.
Performance: cookies that help measure visits and understand how visitors use the website.
Functionality: cookies that recognise returning visitors and remember preferences or settings.
Advertising: cookies that collect information about visits, content viewed, links followed, and browser or device information, which may include an IP address.

When you use social-media “Like” or “Share” features, the relevant social network may process information according to its own privacy policy and your settings on that network.

Blocking some cookies may affect website functionality. You can manage or block cookies through your browser’s privacy and security settings. Browser cookie settings do not necessarily control data collected by native app services.

Accepting cookies does not constitute permission to share content with third-party AI services.

Updates to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version takes effect when published on our website, unless a different effective date is stated. Please review this page periodically to stay informed about our data practices.

Publishing an updated Privacy Policy does not replace any separate permission required before sharing your personal data.

Last updated: September 11, 2026.