Last Updated: February 29 , 2024
Effective date: February 29 , 2024
Introduction
TTMF Limited ("TTMF", "we" or "us") is the operator of the To The Moon website located at http://ttm.financial ("Website") and provider of TTMF services ("Services"). We attach great importance to your personal information. We are also the data controller responsible for your personal data.
This TTM Privacy Policy ("this Policy") applies to personal data that we collect from you when you visit the Website together with all related sub-domains thereof, mobile and desktop applications operated by or on behalf of TTMF, create an account, use our applications or services. It provides information on what personal data we collect, why we collect such personal data, how it is used, the lawful basis on which your personal data is processed, how it is stored, and how we share information.
As used in this privacy policy, "personal data" is all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding information after anonymization processing.
Please read this Policy carefully. By using our Service or submitting your personal data, you hereby acknowledge and understand that you agree to accept the terms of this Policy. If you disagree with this Policy at any point or time, you should stop using our Services.
This Policy will help you understand the following contents:
I. What information we collect
II. How we use your information
III. How we share your information
IV. Your rights to your information
V. How we protect and store your information
VI. How we protect the information of minors
VII. How we transfer your information across the border
VIII. How this Privacy Policy is updated
IX. How to contact us
X. Special section for certain jurisdictions
I. What information we collect
There is no need to create an account when searching and viewing information from certain markets, such as symbols, quotes, financial data, as well as ideas and publicly available data of TTMF users.
Data provided by you
User accounts
If you decided to create an account, you will need to provide us with some personal data so we can provide you with access to our additional services that users benefit from. You may also elect to provide us with additional information about you, as described below.
During registration you will be required to provide us with either:
1. your email address or your phone number;
2. your user name (TTMF ID or other identifier), password, profile photo;
3. your account information with the designated social Internet services.
You can also add additional information about yourself in the profile settings, however, this is not mandatory.
If you do not provide an email address or phone number, we will be unable to complete the registration process for you. However, it will not affect your ability to browse the Website.
When you log in to your account with your email address or your phone number and password, we collect your browser type and settings, device type and settings, and operating system for human verification operations to prevent interference from malicious programs and protect your login security.
We publicly display the following personal information: (i) the image you have elected to provide as your user avatar；(ii) the nickname and personal introduction you have filled in.
Forum data
We receive and record messages, images, videos you posted to facilitate your use of the forum to communicate with the community. The messages, images, and videos you upload to the forum may contain personal information about yourself or others, including names, photos, voiceprints, or data that, when combined with other information, can identify specific individuals. You should exercise caution when uploading messages, images, and videos to the forum.
Please note that if the information you provide contains personal data of others, you need to ensure that you have the legal authorization of those individuals before providing such personal data to us.
Contact data
When you communicate with us via phone, email, or any other means, or interact with our website or any other services we provide, we may collect any personal data you choose to provide, including the content of your communication with us.
Community data
When you access and use the community features, you can voluntarily post and upload content such as images, audio, or videos. We will collect information related to the content you post during the use of these features, including images, audio, video, and textual content, as well as your community nickname, UUID, friend relationships, medal information, and note information.
TigerGPT
To provide you with the TigerGPT Services, we will collect text dialogue information you input and the evaluation information for the output content. Specific services are detailed at TigerGPT Service Agreement and Privacy Statement.
Data automatically collected by us
Cookies and other technologies
Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the services, pages visited, language preferences and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the services in order to continually improve our design and functionality. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the services. We may also use cookies or other technologies in online advertising to track responses to our ads.
You can manage and delete cookies according to your preferences through the settings of the browser you use. Note that blocking cookies can cause some features on our Website or system to not work or work effectively, which can affect your experience. You also may not receive advertising or other offers from us that are relevant to your interests and needs. However, this does not affect your use of our other services.
In addition to cookies, we use Authorization or Web Beacon and other similar technologies on the web site. Authorization is an HTTP protocol header that is passed behind the browser and the server of the Internet, instead of a cookie use. The Web Beacon can calculate who browses the web or access some cookies. We use Authorization to record your identity and collect information about your web browsing activities through the Web Beacon, such as Internet Protocol (IP) Address, Browser Type, Internet Service Provider (ISP), Visited Pages, Operating System, Date/Time Stamp, Click Data Stream, and so we can learn more about and improve our products and services.
Log files
Like most websites, we use web server log files. Our log files contain records such as account status, login time, browsing history, which also includes browser type, language used, operating system version, date and time of access, network requests etc. We will obtain storage access to your device for the purpose of saving the aforementioned log information. These web server log files are used for administration, generating aggregated traffic information for site planning, and ensuring compliance with our terms of service agreement.
We receive and retain IP address to determine your approximate location. IP addresses may be considered personal data in certain jurisdictions and will be treated in accordance with this privacy policy. Note that IP addresses are not tied to personal data in our web server log files.
Device information
We receive and record information about the device you are using, which includes device information (such as IMEI, IDFA, IDFV, Android ID), IP address, operating system, language settings, browser type and version, software name and version. This information is gathered for the following purposes:
1. to ensure the integrity and consistent operation of the Services;
2. to protect our Services against cyberattacks, criminal activity, identity theft, or investigation of suspicious activity;
3. to comply with our legal obligations, including as part of conducting routine audits of our Services;
4. to enforce our terms and policies;
5. to protect our users;
6. to assess effectiveness of features and campaigns;
7. to improve our Services; and
8. for security and verification purposes.
Analytics data
When you are using our Services, we may collect analytics information automatically. This information may include your general device information, device identifiers (for example, Google Advertising ID, if you are using an Android device, or Advertising Identifier (IDFA), if you are using an iOS device), IP address, information in log files, network information, website, and application interaction events, etc. We collect pseudonymous data only and this analytic information does not include any personal identifiable information from your profile. We use this information to analyze and improve the work of our services and applications, and to develop, test, and improve our service further. For these purposes, we may use internal analytic as well as third party service providers.
II. How we use your information
We need to collect personal information in order to provide you with the requested services. If you do not provide the requested information, we may not be able to provide the services.
Generally, we do not rely on your consent to process your personal data unless there is another legal basis. If we do rely on your consent, we will make this clear to you at that time. The details are as follows:
If we intend to use personal data for purposes other than those specified in this Policy or to collect additional personal data not described herein, we will provide you with a detailed explanation of the purposes, methods, types of information collected and obtain your consent separately through page prompts, interactive processes, website announcements or other means. Once you agree, such additional information or use purpose will be considered part of this Policy and apply to this Policy.
When we collect various types of sensitive personal data from you, we will obtain your consent again, as required by applicable law, through page prompts, interactive processes, website announcements, or other means, and make efforts to minimize the impact on your personal rights.
Profile
We provide you with the functionality to set up and manage your personal profile. A profile is a set of information for you that details your viewing preferences. Your settings (chart settings, toolbars, buttons, etc.) are kept solely for the purpose of customizing the user’s experience when using the Website, applications or your accounts. We do not share private profile settings with any third parties.
We also offer the functionality to display your personal profile. After you set up your personal profile, certain information will be made publicly available.
User account security and profile operations
To ensure the security of your account and verify your true identity, we will use your contact details, such as username, email address, or phone number, for the following purposes:
1. to authenticate your user account, ensure its security along with the security of our services, and to prevent spam, fraud, and abuse;
2. to acknowledge, confirm, and deal with your user account;
3. to send all new users a welcome activation email to verify their email address.
Marketing
To facilitate ad attribution as part of our marketing campaigns, we may send you marketing emails about products or services similar to those you have subscribed to, including information about events and other promotions we feel may interest you. This is unless you have indicated to us that you do not wish to receive communications in this manner. We will send you other promotional information by email only with your consent, which was given at the time you provided us with your personal data.
Sending notifications and announcements
We can notify you via push about new users who have followed you, liked an idea, new ideas of users that you follow, and so on.
On rare occasions, it is necessary to send out service-related announcements. For instance, if our service is interrupted for a prolonged period or a major functionality upgrade is released, we might send all users an email message.
Customer service
To assist you in resolving any inquiries or concerns, we collect your contact information and the details of your communication with us to provide customer service.
Legitimate interests
We will process your personal data as necessary for certain legitimate interests, which include the following:
1. where we are asked to respond to any of your inquiries, comments, or grievances;
2. to administer our services in order to better understand how visitors interact with the Website and application, and ensure that they are presented in the most effective manner for you and your computer/device;
3. to develop and improve our mobile applications;
4. to share personal data among our affiliated businesses for administrative purposes, provide subscription services, and in relation to our sales and marketing activities, except where we require your consent, as described above;
5. to send you information about our products or services that are similar to the products or services you subscribed to (unless you have refused or opted out of receiving these communications). Our legitimate interest is to ensure our marketing is relevant to you, so we may process your data to send you information on our products or services that is specifically tailored to your interests;
6. we may anonymize, pseudonymize, aggregate and de-identify the data that we collect and use this data for our own internal business purposes, including sharing it with our business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes. For example, to allow those parties to analyze patterns among groups of people and conducting research on demographics, interests, and behavior;
7. for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and as part of our efforts to keep our Website, network, and information systems secure; and
8. to (a) comply with legal obligations, (b) respond to requests from competent authorities; (c) enforce our Terms and Conditions; (d) protect our operations or those of any of our affiliated businesses; (e) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f) enforce or defend legal rights, or prevent damage. This means we can store and disclose your information to law enforcement authorities, state, or government agencies if we establish that such disclosure is necessary to comply with the law. This includes responses to court orders or subpoenas, as well as other judicial or regulatory processes.
As used in this privacy policy, “legitimate interests” means the interests of TTMF and our affiliated businesses in conducting and managing our business. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We do not use personal data for activities where our interests override the impact they may have on our users, unless we have their explicit consent or those activities are otherwise required or permitted by law. Where your consent is required by applicable law, we will obtain your consent separately. You have the right to object to the processing of your personal data that is based on our legitimate interests at any time, on grounds relating to your particular situation.
III. How we share your information
To the extent required for the supply of the Services, we will share certain personal information with the following:
Affiliated companies: Currently, we may share your personal information with our affiliated companies. However, we assure you that we will only share the necessary information for legitimate and specific purposes within our affiliated companies. These companies will use your personal information in the same manner as outlined in this policy, including providing partial product functionality, preventing illegal use, and supporting users. If our affiliated companies intend to change the purpose of processing, we will notify you through the corresponding service notice.
Authorized partners: In order to provide certain features or enhance your overall experience, some of our services are provided by authorized partners. We adhere to the principles of minimization, necessity, and legality when sharing information with these partners. Before sharing any information, we require our authorized partners to implement appropriate confidentiality and security measures to process personal information in accordance with this policy and applicable laws in your jurisdiction.
Corporate transactions: In the event of a merger, acquisition, bankruptcy liquidation, or change of operating company or organization due to business development, if there is a transfer of personal information involved, we will ensure that the new company or organization receiving your personal information is bound by this policy. Alternatively, we will seek your authorization and consent again from the new company or organization.
Legal obligations and rights: We will only disclose your personal information publicly when it is mandatory under the law, in compliance with a subpoena, legal proceedings, legal actions, or upon compulsory request by government supervisory departments. Additionally, we may publicly disclose your personal information if we sincerely believe it is necessary to protect our rights, ensure your safety or the safety of others, investigate fraud, or respond to government requests.
IV. Your rights to your information
As the data subject, you have the right to enjoy the rights provided by the applicable laws in your jurisdiction. Your rights may include some or all of the following rights described below:
1. Right to be informed: You have the right to be informed about the personal data that an organization is processing and the purposes of such processing. This information is provided to you in this Policy.
2. Right of access: You can request a copy of your data.
3. Right of rectification: If the held data is inaccurate, you have the right to have it corrected.
4. Right to erasure: You have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: In limited circumstances, you have the right to request us to stop processing the data while it is retained.
6. Right to data portability: You can request a copy of certain data in a machine-readable form that can be transferred to another provider.
7. Right to object: In certain circumstances (including where data is processed based on legitimate interests or for marketing purposes), you may object to that processing.
8. Rights related to automated decision-making, including profiling.
There are several rights in this area where processing carried out solely on an automated basis results in a decision that has legal or significant effects for the individual. In these circumstances, your rights include the right to ensure that there is human intervention in the decision-making process.
V. How we protect and store your information
We employ necessary security measures to safeguard your information from unauthorized access, manipulation, loss, disclosure, destruction, and third-party intrusion.
While it is impossible to guarantee absolute security for websites, internet transmissions, computer systems, and wireless connections, we diligently uphold physical, electronic, and procedural safeguards to protect your information in compliance with applicable data protection requirements.
We will retain and process your personal data only for as long as necessary to fulfill the purposes for which the information was collected. Additionally, we will retain and use your personal data as required to comply with legal obligations, assert our legal rights (for instance, if we are compelled to retain your data to abide by applicable laws), resolve disputes, and enforce our legal agreements and policies. Subject to local laws and regulations, we may also store the collected information in countries or regions outside of the jurisdiction where our business is situated.
Currently, we may store your information in the United States, Hong Kong.
Once we no longer require your personal information for its intended purposes or to fulfill legal obligations related to our legal rights, we will either delete it from our systems and records or take measures to anonymize it in accordance with relevant privacy laws, thereby rendering it unidentifiable and unlinkable to you.
We are constantly improving the ways we secure, store, and process the data we collect, including the addition of physical security measures that help us counter unauthorized access to our systems. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee its absolute security.
VI. How we protect the information of minors
This service is not intended for minors. Our services are only intended for adults, and we do not knowingly collect personally identifiable information from anyone under the age of 18 or the equivalent age as specified by law in your jurisdiction. If you are a parent or guardian and you are aware that your child has provided us with information, please contact us. If we become aware that we have collected personal information from minors without verification of parental consent, we will take steps to remove that information from our servers.
We do not seek to collect any information from or engage in any transactions with persons under the legal age of majority in their respective country. However, due to the inability to always accurately determine a user's age, our databases may contain personal data of minors. We reserve the right to block the services from any individual who is or whom we reasonably suspect to be a minor.
This policy requires that minors do not register or engage in other legal activities on the Website without the consent of a parent or legal guardian, unless otherwise permitted by applicable law. If you are a minor but have obtained the consent of your legal guardian, you must be able to provide proof of such consent upon request.
VII. How we transfer your information across the border
In order to fulfill our contractual obligations to you and for the purposes outlined in this Policy, your information may be processed on servers located in the United States, Hong Kong, subject to applicable local laws and regulations and with your authorized consent.
You acknowledge and understand that the personal information laws in the countries or regions to which the data is transferred may not be as strict as the laws in your country and may not provide the same level of protection or rights. If you object to the transfer or use of your personal information as described in this Policy, please refrain from using the Service.
Regardless of where your information is processed, we apply the same safeguards described in this Policy. We also ensure that this Policy complies with significant legal frameworks pertaining to data transfers. In the event that we receive complaints about data transfers, we will cooperate with the appropriate regulatory authorities when direct resolution is not feasible.
VIII. How this Privacy Policy is updated
We retain the right to update or modify this Policy from time to time. The updates to this Policy will be made by posting a new version on the Website. You shall check our Website occasionally to ensure any changes made are suitable for you. In the event of substantial changes to our Privacy Policy, we will deliver the updated Privacy Policy to you via our device and seek your consent once again.
IX. How to contact us
If you have any questions or suggestions of this Policy, please contact us via: uservice@ttm.financial
Company Address：
Sertus Chambers, P.O. Box 905, Quastisky Building, Road Town, Tortola, British Virgin Islands.
X. Special section for certain jurisdictions
Singapore
This Section applies for users located in Singapore:
We supplement or revise this section in accordance with the applicable data privacy laws, regulations, and regulations of the local data privacy regulatory authorities in Singapore (collectively referred to as "Applicable Laws"). In the event of any inconsistency between the Privacy Policy and this Section, this Section shall take precedence in relation to our processing of your personal information. Please note that, in this context, "processing" includes activities such as collection, recording, organization, storage, updating or modification, retrieval, querying, use, merging, blocking, deletion, or destruction of personal data.
Your right
As a user located in Singapore, you have the following rights:
Right to be informed
Right to access
Right to rectification
Right to withdraw consent
Right to data portability
When you request the correction of your personal information, we will respond to your request within 30 days using written communication.
You can refer to the "How we share your information" section above for more detailed information.
We implement reasonable security measures to prevent unauthorized access, collection, use, disclosure, copying, modification, or disposal, or similar risks. We also take precautions to prevent the loss of personal data storage media or devices. In the event that we become aware of a data breach that may cause or has caused significant harm to affected individuals or is of significant scale, we will notify the relevant authorities within three (3) calendar days and appropriately notify the affected individuals' data in accordance with the requirements of applicable laws.
Minimum age
In Singapore, the minimum age for users is 21. We therefore do not knowingly collect any personal information from children under the age of 21 in Singapore without parental consent, unless permitted by law. If we learn that a child under the age of 21 has provided us with personal information, we will delete it in accordance with applicable law.
Australia
This Section applies for users located in Australia:
When collecting, using, disclosing, and otherwise managing your personal information, we will strictly adhere to the Privacy Act 1988.
We take reasonable measures to ensure that third-party recipients of your personal information located outside of Australia handle your personal information in a manner consistent with Australian privacy laws. However, you hereby acknowledge that we cannot control the actions or omissions of these third-party recipients and we do not assume any responsibility for them. You can refer to the "How we share your information" section above for more detailed information.
Your rights
If you make a request to us regarding your rights to your personal information, and you are not satisfied with our response, you can contact us via uservice@ttm.financial.
Hongkong SAR
This Section applies for users located in Hongkong SAR:
If you are a user located in Hong Kong SAR, this Section applies to our collection, processing, and use of your personal information. Please note that if you refuse to provide us with your personal information, you may not be able to use the Services.
Your right
You have the right to request access to and correction of your personal information held by us. You also have the right to request us to cease using your personal information for direct marketing purposes. You can exercise these rights by contacting us via uservice@ttm.financial.
New Zealand
This Section applies for users located in New Zealand:
We will collect, process, and use your personal information in accordance with the Privacy Act 2020 and relevant data and privacy protection laws.
Your right
You have the right to know how your personal information is being processed. Additionally, you can request access to or correction of your personal information by contacting us via uservice@ttm.financial.