We collect personal data about you in a number of ways including:
where you register for an account or to receive emails from us
when you order products or services from us
when you submit a query or request to us
when you respond to a survey that we run or fill in forms on one of our websites
by tracking your use of our websites and mobile applications
from public sources
from examination of public and private blockchains
from third parties who are entitled to disclose that information to us
In some cases, we may also be required by law to collect certain types of personal data about you. Where we collect personal data from you, we will generally do so ourselves. However, in some cases we may collect personal data from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.
The kinds of personal data that we collect and hold about you may include:
identifying information, such as your name and date of birth
contact information, such as your postal address, email address and telephone numbers
social media handles and other social media profile information that you make available to us or to the public
financial information, such as credit or debit card, bank account or other payment details
online identifiers that may also constitute personal data, such as your MAC address, computer and mobile device unique device ID and IP information based on your internet connection settings ;
blockchain identifiers, such as blockchain addresses and public keys
usernames and passwords that you create when registering for an account with us
details of any products or services that we provide to you
information about how you use the products and services we provide
records of our communications with you, including any messages you send us
identity verification information, such as images of your government issued ID, passport, national ID card, utility bill or driving license.
Without this information, we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services), to respond to queries or requests that you submit to us and to protect against the risks of cybercrime, fraud and money laundering & terrorist financing.
We use personal data that we collect about you for the following purposes:
to verify your identity (including age) when you are dealing with us
to determine your eligibility for any of our products or services
to determine your compliance with the terms and conditions that apply to any of our products or services and applicable law
to enable us to offer our products and services
to provide you with the services, products and information you have requested
to improve our website based on your information and feedback
to answer your queries and requests
to comply with our legal and regulatory obligations
to carry out market analysis and research
to monitor use of our products and services
to assess, maintain, upgrade and improve our products and services
to carry out education and training programs for our staff
to manage and resolve any legal or commercial complaints or issues
to carry out planning and forecasting activities and other internal business processes
to keep you informed about our activities, including by sending out newsletters
We may from time to time use your personal data in order to send you marketing materials about products or services provided by TontineTrust that we think you may be interested in but we shall always give you the opportunity to easily opt-out of any such communications.
You can opt-out of receiving marketing communications from us by contacting us at email@example.com or, in respect of emails, by clicking unsubscribe on the relevant email. We shall not use your personal data for marketing third party products and services unless we have received your consent.
We may share personal data about you with:
your representatives, advisers and others you have authorised to interact with us on your behalf
our staff who need the information to discharge their duties
related entities within our corporate group
our business partners, agents and service providers
payment system operators and financial institutions
identity verification agents
fraud and crime prevention agencies and organisations
prospective purchasers of all or part of our business or a related entity
professional advisers who we engage to provide advice on our business
government authorities and bodies, supra-national authorities and bodies, crime investigation agencies, courts and others who ask us to disclose that information as required by law
Transfer of your personal data
TontineTrust is a global firm, with offices, clients and suppliers located throughout the world. As a result, your personal information may be transferred to other TontineTrust offices, data centers and servers in Europe, Asia, or the United States for the purposes identified above. Any such transfer shall take place only in accordance with and as permitted by the law of your jurisdiction, but please be aware that the laws and practices relating to the protection of personal information are likely to be different and in some cases may be weaker than those within your home jurisdiction. Regardless, in all events, we shall apply the provisions of this Policy to your personal information wherever it is located.
While you will still be able to browse our websites with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly. “Pixel tags” (also called clear GIFs, web beacons, or pixels) are small blocks of code on a webpage that allow websites to do things like read and place cookies. The resulting connection can include information such as the person’s IP address, the time
Storage and security of personal data
We generally store the personal data that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal data in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats that you become aware of.
We also take steps to monitor access to and modification of your information by our staff, and ensure that our staff are aware of and properly trained in their obligations for managing your privacy. If you are a registered user of our services the security of your personal data also relies on your protection of your personal data and particularly any identity information and your secure access credentials (e.g. password and mobile authentication device or service) used to access TontineTrust Services. You must not share your secure access credentials with anyone. If you lose your secure access credentials or share them with a third party for any reason, the third party may have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your secure access credentials, please change them immediately and also contact us at firstname.lastname@example.org immediately.
Retention of personal data
Your personal data will only be kept as long as required to meet our legal obligations and no longer than is necessary. In most cases we will retain your personal data for a period of between 1-6 years. In some cases we may be obliged to retain some of your
personal data for longer periods as are required by law. At our discretion, we shall retain personal data for any period we consider is reasonably necessary to meet our legal or regulatory obligations.
Access and correction
If you want to access any of the personal data that we hold about you or to correct some aspect of it (for example, because you think it is incomplete or incorrect), please contact us at email@example.com To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your request. Even if you do not request access to and/or correct your personal data held by us, if we are satisfied that, having regard to the reasons for which we hold your personal data, that personal data is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.
By using TontineTrust Services, you agree that:
if you have provided personal data to us relating to any other person, you:
have a right to provide that information;
each such person has agreed to those terms.
We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact us using the contact details set out below. We will make a record of your complaint and refer it to our internal complaint resolution department for further investigation. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.
Changes to this policy
Third Party Sites
Some pages made available through TontineTrust Services include links to third-party websites. These sites are governed by their own privacy requirements and policies, and TontineTrust is not responsible for their operations, including but not limited to their data protection practices. Users submitting information to or through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information.
TontineTrust provides the TontineTrust Services to you as is. You use them at your own risk and discretion. That means they don’t come with any warranty. None express, none implied. No implied warranty of merchantability, fitness for a particular purpose, availability, security, title or non-infringement.
Limitation of Liability
TontineTrust won’t be liable to you for any damages that arise from your using TontineTrust Services. This includes if TontineTrust Services are hacked or unavailable as well as all types of damages (indirect, incidental, consequential, special or exemplary). And it includes all kinds of legal claims, such as breach of contract, breach of warranty, tort, or any other loss.
Choice of law and jurisdiction
If you want any further information about our privacy and data protection policies or in respect of our management of your personal data, please contact our privacy compliance team at firstname.lastname@example.org
© 2023 Tontine Trust Advisors LLC ('Tontine Trust'). All rights reserved.
Tontine Trust is a consumer-oriented fintech that provides software and marketing solutions to banks, chartered trust companies and credit unions (each a ‘Bank’) which enables the Banks to offer state of the art retirement income solutions such as the Tontine IRA™.
Banking, trustee and fiduciary services in the US are provided by Bank partner(s) which are regulated in the US to act as fiduciaries on behalf of US Tontine IRA™ accountholders (‘members’).
Tontine Trust provides and operates the TontineIRA™ administration and record-keeping platform on behalf of, and under the supervision of, the Banks.
Tontine Trust is not a Bank or a trust company and does not provide banking & fiduciary services other than certain administrative services in a ministerial capacity as the Trust Advisors to the Tontine IRA™s.
No information on this website or the platforms provided by Tontine Trust should be taken as constituting individual advice to you. The information is informational and of general guidance only. Tontine Trust does not provide investment management services, financial advice, banking or fiduciary services.
The choices you make or do not make around the investment of your retirement account are your own responsibility. Neither Tontine Trust nor the Banks can be held responsible for any financial loss arising from your retirement choices or lack of them.
The amounts and duration of the lifetime income from the Tontine IRA™ are indicative only. By design, neither the amounts nor the duration of retirement income payments from a tontine plan are fixed or guaranteed.
Based upon many years of research and development, the TontineIRA™ platform displays reasonable best estimates of what level of income you can expect to receive over the course of your lifetime. These estimates are constantly reviewed (sometimes nightly) to incorporate any effects on expected incomes caused by changes in interest rates, investment returns, life expectancy and/or the actual mortality experience of members sharing the same tontine.
The Banks we work with are required to manage US trust assets in accordance with the Uniform Prudent Investor Act.
To ensure maximum security of capital and income for members, the Tontine IRA™ assets will be invested by the Banks in a basket of FDIC insured deposits such that each up Tontine IRA™ account can obtain FDIC coverage up to approximately $10m of assets per member.
Note that while the deposits made on behalf of the Tontine IRA™s are FDIC insured, the IRA accounts themselves are not directly insured by the FDIC because they are not a deposit or other obligation of, or guaranteed by a Bank or state chartered trust company and and as such are subject to investment risks, including possible loss of the principal amount invested, particularly if the member passes away before they have receive total income in excess of their original contribution to the TontineIRA™.