1. Personal data we collect
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”). Personal data does not include anonymized data.
The types of personal data we collect about you depends on your interactions with us and your use of the Services. We may collect the below categories of personal data from our users:
1. Identifiers such as a real name, alias, postal address, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
2. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
3. Financial information, including, bank account number, credit card number, debit card number, and other financial information.
4. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
5. Geolocation data.
6. Professional or employment information, such as title and employer name.
7. Audio, electronic, visual and similar information, such as calls and messages on our customer service phone line or images from photographs. We will not collect additional categories of personal data other than those categories listed above. If we intend to collect additional categories of personal data, we will provide you with a new notice at or before the time of collection.
2. How we collect personal data
We collect personal data either:
• Directly From You. When you provide it to us directly to perform the Services.
• Automatically or Indirectly From You. For example, through and as a result of your use of and access to the Services. We also collect IP addresses and browser types from the devices you use.
• From our Service Providers. For example, we may collect personal data from service providers to perform know-your-customer (“KYC”) and anti-money laundering (“AML”) checks.
3. How we use personal data
We process personal data described in Section 1 (“Personal Information We Collect”) for the following purposes:
1. To provide the Services, which includes use of our trading platform and brokerage services.
2. Developing, improving, operating, providing, predicting, or performing, including maintaining or servicing accounts, enhancing the Services and your experience with them, providing customer service, processing or fulfilling transactions, verifying your identity, and processing payments.
3. Communicating with you by email about the Services, verifying your identity, responding to support inquiries or, sharing information about the Services.
4. Auditing related to a current interaction with the user and concurrent transactions.
5. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
6. Debugging to identify and repair errors that impair existing intended functionality.
7. Undertaking internal research for technological development and demonstration.
8. Undertaking activities to verify or maintain the quality or safety of the Services owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the Services owned, manufactured, manufactured for, or controlled by us.
9. Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
10. As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third-parties.
We will not use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.
4. Who we share personal data with
We share personal data with the following categories of third-parties:
• Our service providers.
• Our affiliated entities.
• Government agencies or regulators when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.
We may also share your personal data with our legal advisors; auditors; courts and public authorities; and any acquirer or successor in the event of a corporate sale, merger, reorganization, dissolution, or similar event if any of your personal data is part of the assets we transfer or share in preparation for such a transaction.
5. Legal bases for processing personal data
We process personal data for, or based on, one or more of the following legal bases:
• Necessary for performance of a contract. By using the Services, we will process certain personal data to fulfill our contractual obligations to you.
• Legitimate interests. We may process personal data for our legitimate interests, including complying with any applicable law, rule or regulation, investigation or remedy; protecting our, our users' or others' rights, property and safety; and detecting and resolving any fraud or security concerns.
• Compliance with legal obligations and protection of individuals. We may process personal data to comply with our legal obligations, including as required by valid legal process, governmental request, and to protect those individuals who use our Services and others.
• Consent. We may also ask you for your consent to process your personal data. In cases where you provide consent, you may withdraw such consent at any time. However, withdrawing your consent does not affect the lawfulness of any processing based on your consent before your withdrawal.
6. Your rights regarding personal data
You have certain rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Statement, or by following instructions provided in this Privacy Statement or in communications sent to you.
Your rights vary depending on the laws that apply to you. See “Your California Privacy Rights”, “Your Nevada Privacy Rights”, and “Your European Union and UK Privacy Rights”, for more information about certain legal rights.a. Accessing, Modifying, Rectifying, and Correcting Collected Personal Data
We strive to maintain the accuracy of any personal data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us. Please contact us if there are any updates or corrections to your information.
Depending on the laws that apply to you, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, please contact us at the information provided at the end of this Privacy Statement. We reserve the right to deny access as permitted or required by applicable law.
b. Your California privacy rights
California’s “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third-parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third-parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. However, we do not disclose personal data protected under the“Shine the Light” law to third-parties for their own direct marketing purposes.
Please note that we do not “sell” or “share” your personal data as those terms are defined by the California Consumer Privacy Act (the “CCPA”), as amended by the California Privacy Rights Act (“CPRA”).
c. Your Nevada privacy rights
Nevada law permits our users who are Nevada consumers to request that their personal data not be sold (as defined under applicable Nevada law), even if their personal data is not currently being sold. Requests may be sent to
investorsupport@templuminc.com, and are free of charge.
d. Your European Union and UK privacy rights
In addition to the above-listed rights, European Union and UK privacy law provides individuals with enhanced rights in respect of their personal data. These rights may include, depending on the circumstances surrounding the processing of personal data:
• The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;
• The right to request restriction of processing of personal data or object to processing of personal data carried out pursuant to
(i) a legitimate interest (including, but not limited to,processing for direct marketing purposes) or (ii) performance of a task in the public interest;
• In certain circumstances, the right to data portability, which means that you can request that we provide certain personal data we hold about you in a machine-readable format; and
• In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal data we process about you.
• The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.
Note that we may need to request additional information from you to validate your request. To exercise any of the rights above, please contact us at
investorsupport@templuminc.com.