T Tauri Ltd. Privacy Policy

Last Updated: March 15, 2022

T Tauri Ltd. and its controlled and controlling entities (“T Tauri,” “we,” “us,” or “our”) respect your privacy. This Privacy Policy describes the processing of Personal Information (defined below) that is provided, collected, or shared in connection with your relationship with us (collectively, the “Services”). It also describes your choices about the collection, sharing, and use of your Personal Information.

1. Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we collect may include:

• Contact and Personal Information – If you submit an inquiry, offer to purchase anything from us, or provide information in connection with the Services, we may collect your contact information. This may include your name, email address, demographic information, phone number, birthdate, tax identification number, and other information we reasonably believe to be needed to comply with “know your customer” and other legal, regulatory, or contractual obligations. 
• Financial Information – If you make any purchases or offer to make any purchases in connection with the Services, we will collect your financial information, including your name, suitability information, credit check, tax forms, and payment information, and for purposes of verifying accredited investor status may collect other financial information we reasonably believe could be used to verify your accredited investor status. 
• Communication Information – We may collect audio, electronic, or visual information, which includes screen sharing views; any data in any files uploaded, emailed or otherwise provided by you; the contents of your communications with us, whether via e-mail, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect.

2. How We Collect Your Personal Information

• We May Collect Your Personal Information Directly From You - For example, if you request or purchase tokens, products, services, or information from us.

• We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, “know your customer” and accredited investor verification services, anti-money laundering service providers, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.

3. How We Use Personal Information

To the extent permitted by applicable law, we may use Personal Information:

• to provide and operate our Services and provide support to our business functions;
• to comply with our legal obligations, including detecting and preventing fraud, spam, abuse, security incidents and other illegal or harmful activity, complying with exemptions from applicable laws, and conducting risk and security assessments;
• to enable us to provide representations to and continue to or start to work with our service providers, including banks and money transmitters;
• to process your applications and transactions, and to verify information you provide to us, including background and other checks as permitted by applicable law;
• to communicate with you for transactional purposes;
• to meet our contractual requirements
• to improve our Services, for example, by using your Personal Information to customize your experience with us;
• for the security of the Services and our company, our customers, and other third parties;
• for our marketing purposes, to send you information about new features on the Services, new services we offer, and to tell you about information we think you might find interesting;
• to resolve any disputes and enforce our agreements with you or third parties; and
• for other purposes, as permitted by applicable law. 

4. Sharing of Personal Information

We may share your Personal Information in the following circumstances:

• With Our Affiliates – We may share your Personal Information with our affiliates and across our organization.
• For Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any legal agreement, including any terms of use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of T Tauri, its users, or the public against harm.
• In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
• To Service Providers – When we hire a service provider to help operate the Services or our business, we may give access to Personal Information as necessary to perform the applicable service for T Tauri. This may include service providers that operate our Services, send our communications, or run our promotions.
• To Business Partners – We may share Personal Information with our trusted business partners.  For example, we may share your Personal Information with a company when we co-sponsor a promotion or service.  These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.

5. How Long We Keep Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Policy, or any longer retention period required by law.

6. How We Protect Your Personal Information

We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.

7. Your Choices and Controls

Depending on where you live, you may have the right to exercise certain controls and choices regarding our collection, use, and sharing of your Personal Information. To opt-out of marketing communications please email us at privacy@t-tauri.org or by following any relevant instructions included in the email or text correspondence.

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.  Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our services to you.

To exercise other rights with respect to your Personal Information, please contact us using the information in Section 13 below.

8. International use of the Services

The Services may be hosted throughout the world, including in and from United States. If you are using our Services from outside of the United States, please note that by providing your Personal Information it may be transferred to, stored, collected, or processed in the United States, where certain data centers and servers may be located or operated.

9. Children’s privacy

We do not knowingly collect or solicit any Personal Information from children under the age of 16.  In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at privacy@t-tauri.org or contact us using the information listed in Section 13.

10. Links to third-party websites

We are not responsible for the practices employed by any websites or services linked to or from our Services, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy policy.

11. Information for Individuals in the EU and UK

In accordance with European and UK law (collectively, the “GDPR”), individuals in the EU and UK may have additional rights relating to the collection and processing of Personal Information.

a. Basis for Processing

Our legal basis for processing the personal information described in this Privacy Policy will depend on the Personal Information concerned and the context in which we process it.  We process Personal Information from you:

• where we need it to perform a contract with you;
• where the processing is in our legitimate interests (including the purposes described, above, in How We Use Personal Information);
• where the processing is necessary for us to meet our applicable legal obligations; or
• if we otherwise have your consent.

b. Your Privacy Rights

Depending on applicable law, you may have the right to:

• Request access to your Personal Information.
• Request correction of your Personal Information.
• Request erasure of your Personal Information. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Information.
• Request restriction of processing of your Personal Information.
• Request the transfer of your Personal Information to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your Personal Information.

If you wish to exercise any of these rights or would like further information, please contact us at privacy@t-tauri.org or write to us using the address in the “Contact us” section below.  Depending on the nature of your request, we may need to verify your identity.

Depending on where you are located, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning your Personal Information.  We encourage you to first reach out to us at privacy@t-tauri.org or using the address in the “Contact us” section below, so we have an opportunity to address your concerns directly before you do so.

12. Changes to this Privacy Policy  

Please note that we may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with an updated Privacy Policy if material changes are made. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately.

13. Contact us

If you have any questions about our practices or this Privacy Policy, please contact us at privacy@t-tauri.org.