Titan Consumer Privacy Notice
Effective: April 2021
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and employment information; bank account information, balances, and history; assets and investment experience and history.
When you are no longer our customer, we continue to share your information as described in this notice.
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Titan chooses to share; and whether you can limit this sharing.
We share your personal information only for the following two purposes: (1) For our everyday business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigation, or report to credit bureaus and (2) For our marketing purposes, to offer our products and services to you
We do not share your information for joint marketing with other financial companies or with any affiliates or non-affiliates.
Please go to email@example.com for further information.
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
We collect your personal information, for example, when you register to become a Titan customer, access and use our services, otherwise provide us your personal information
Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes – information about your creditworthiness, affiliates from using your information to market you, sharing for nonaffiliates to market you. State laws and individual companies may give you additional rights to limit sharing.
Affiliates are defined as companies related by common ownership or control. They can be financial and nonfinancial companies.
Nonaffiliates are defined as companies not related by common ownership or control. They can be financial and nonfinancial companies.
Joint marketing is defined as a formal agreement between nonaffiliated financial companies that together market financial products or services to you.
California residents: Under California law, we will not share information we collect about you with companies outside of Titan, unless the law allows.
Nevada residents: We are providing this notice to you pursuant to Nevada law. Vermont residents: Under Vermont law, we will not share information we collect about
Vermont residents with companies outside of our corporate family, unless the law allows.
Effective Date: April 2021
What types of information do we collect through our Platforms?
We may collect personally identifiable information as well as non-personally identifiable information associated with you, including:
Registration Information. When you register to use the Service, you will be asked to establish a login ID and password, and to provide us with certain personal information, including, but not limited to, your first and last name, email address, mailing address, telephone number, date of birth, and social security number. You may also be asked to provide similar information to us from time to time as you use the Service and/or access any of our Platforms.
Investment Information. When you register to use the Service, you will be asked to provide information regarding your investment preferences, including your risk tolerance, investment objectives and experience, time horizon, liquidity needs, and the like.
Banking Information. To use the Service, you will be asked to provide information regarding your banking relationship, including the bank name and your account number, bank routing number, and bank account login credentials.
Activity and Demographics Information. When you use the Service or otherwise access any of our Platforms, we may record certain details about your computer or mobile phone, the name of your Internet Service Provider (ISP), your IP Address, the website from which you visit us, the pages on our Platforms that you visit and in what sequence, the date and length of your visit and other statistical information about your visit to our Platforms. We may also collect aggregated demographic information regarding users of the Service (e.g., age, gender, and income information). Information Collected Via Cookies, Web Beacons, and Similar Technologies. When you use the Service or otherwise access any of our Platforms, we also may send “cookies” to your computer or device or use similar technologies to enhance your experience. These technologies can identify you as a unique customer and store your personal preferences as well as product preferences, to tell us which webpages you have visited and in what order, and identify your computer or device. On their own, cookies or web beacons do not contain or reveal personally identifiable information; however, if you choose to provide us with such information, it can be linked to the anonymous data stored in the cookies and/or web beacons. We may allow select third parties to place cookies on our Platforms to provide us with better insights into the use of the Platforms or user demographics, or to provide relevant advertising to you. These third parties may collect information about a user’s online activities over time and across different websites when using any of our Platforms.
How do we use information about you collected through our Platforms?
We may use information collected about you through our Platforms for a variety of commercial purposes, including without limitation the following purposes:
- to provide the Service to you, and to conduct our other everyday business purposes (including to process your transactions and maintain your account with us);
- to inform you of changes made to the Service or any of our Platforms;
- to respond to questions that you may have about the Service or any of our Platforms, or about our company;
- to market our products and services to you, and to inform you of certain products or services of third parties which may be of interest to you;
- to organize or carry out promotional activities or other promotional events;
- to develop an online customer profile for you;
- to understand general customer trends and patterns so we can develop and support existing and ongoing marketing strategies for our products and services; and
We may also use information about you that we collect through any of our Platforms for security, administrative, and legal purposes.
How long do we maintain information about you collected through our Platforms?
We will retain information about you collected through any of our Platforms for at least as long as it serves the purposes for which it was initially collected or subsequently authorized, and we may keep such information indefinitely.
To whom do we disclose information about you collected through our Platforms?
- We may disclose information collected about you to third-party service providers or other partners who perform services on our behalf in connection with the Service or any of our Platforms, including without limitation in connection with our service provider or partner completing or confirming a transaction that you conduct with us. When we transfer personally identifiable information about you to such a service provider or partner, that entity will be contractually required to use such information only to carry out those services that we have requested and to provide adequate protection for such information.
- We may also share information collected about you with our auditors, attorneys, and similar advisors in connection with our receiving their professional services, subject to standard confidentiality obligations.
- We may disclose the results of aggregate information or blind data about users of the Service or any of our Platforms to any third party. In such circumstances, we do not disclose to these entities any personally identifiable information about you or other users of the Service or any of our Platforms.
- As noted above, any aggregate information or blind data collected by third-party services integrated with any of our Platforms will be disclosed to such third parties.
- We may transfer and disclose information obtained about you through the Platforms to a third party as part of a merger, acquisition, or other sale or transfer of all or substantially all of our assets or business.
- We may disclose information about you to the government or to third parties under certain circumstances when legally obligated to do so, such as in connection with suspected illegal activity in connection with the Service or any of our Platforms, or to respond to a subpoena, court order or other legal process.
- We reserve the right to release such information to law enforcement or other government officials, as we, in our sole discretion, deem necessary or appropriate.
Do our Platforms support “Do Not Track” signals?
At this time, our websites do not support “Do Not Track” preferences that may be available in your browser. For more information about Do Not Track, visit donottrack.us.
For purposes of understanding your California Privacy Rights, do we share information about you with third parties for their own direct marketing purposes?
No. We do not share information collected about you with our affiliates, or with any unaffiliated third parties, for their direct marketing purposes.
What security measures do we employ for information about you collected through our Platforms?
To help protect the privacy of information collected through our Platforms, we employ reasonable technical, physical, and organizational measures intended to protect such information against accidental or intentional manipulation, loss, misuse, or destruction, and against unauthorized disclosure or access, as well as to protect such information, both during transmission and once it is received, including encrypting the transmission of any sensitive information (such as bank account information or payment card information).
NOTWITHSTANDING THE FOREGOING, PLEASE NOTE THAT DESPITE OUR BEST INTENTIONS NO TECHNOLOGY IS COMPLETELY SECURE. PLEASE BE AWARE THAT OUR PLATFORMS ARE OPERATED ON SOFTWARE, HARDWARE AND NETWORKS, ANY COMPONENT OF WHICH MAY, FROM TIME TO TIME, EXPERIENCE BREACHES OF SECURITY OR OTHER PROBLEMS BEYOND OUR CONTROL. Accordingly we cannot guarantee that any information obtained about you through our Platforms, whether during transmission or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others who do not have your authorization. Any such transmission or sharing of that information is done at your own risk.
You also play a role in protecting your personal information. Please do not share your user name or password with others. If we receive an order or instructions using your information we will consider that you have authorized the transaction.
What are the policies of linked websites and other third parties?
In addition, as noted above, when you are using our Platforms you may be interfacing with third-party integrated services, such as third parties presenting or serving advertisements, third parties providing us with data collection, reporting and ad response measurement, and third parties assisting us with the delivery of relevant marketing messages and advertisements. We prohibit those third parties from collecting any information through our Platforms other than aggregate information and blind data about our users. In any event, please note that Titan is not responsible for the privacy practices of third parties.
How can you correct, update or make choices about the personally identifiable information collected through our Platforms and that we are storing?
You can update, change or delete any personally identifiable information we have collected about you through our Platforms at any time by emailing us at firstname.lastname@example.org.
You can choose not to receive promotional communications from us by following the instructions in any communications you receive from us. Please note that this will not stop us from sending emails to you about your account or your transactions with us.
What is our policy on the use of our Platforms by children?
You must be 18 years or older to register to use the Service. Our Platforms are not designed or intended to be attractive to use by children under 13 years old, and we do not knowingly collect personally identifiable information from anyone under 13 years old. IF YOU ARE UNDER 13 YEARS OLD, PLEASE DO NOT USE ANY OF OUR PLATFORMS AT ANY TIME OR IN ANY MANNER. If you learn that your child under 13 years old has provided us with personal information without your consent, please contact us. We will delete that data from our systems.
How can you contact us?
This notice is being provided by Titan Global Capital Management USA, LLC dba Titan (“Titan”).