Privacy Policy

 

TTMF Limited ("TTMF," "we" or "us") is the data controller responsible for your personal data and is the sole owner of the TTMF website ("Website"), TTMF services (each, a "Service") and all of the information collected on it.

This privacy policy applies to personal data that we collect from you when you visit this Website, create an account, use our applications or services ("you" or "your" being interpreted accordingly). It provides information on what personal data we collect, why we collect 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" means any information that relates to you from which you can be identified.

By using our Service or submitting your personal data, you are agreeing to accept the terms of this privacy policy, so please read it carefully. If you disagree with this privacy policy at any point or time, you should stop using our Services .

We may update this privacy policy at our discretion from time to time by posting a new version on our Website. You should check our Website occasionally to ensure any changes made are suitable for you. If required by applicable law, you will be informed of any significant changes made to the privacy policy.

The current version of this privacy policy was modified on December 31, 2021.

Personal data that 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 we receive from 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:

  • your user name (TTMFID or other identifier), password, profile picture;
  • your account information with thedesignated social Internet services; and
  • if you want to buy a subscription, we will need your full name, postal address and billing information.

In some cases, you may need to provide and verify your phone number. You can also add additional information about yourself in the profile settings, however, this is not mandatory.

The following information will be publicly displayed:

  • the image you have elected to provide as your user avatar, signature, “about me,” location, social media and website.

The following information will not be publicly displayed:

  • your first and last name, phone number, email, company, address, and ID.

If you register to be a user of any subscription service, our third party payment processor will also process information about your debit/credit card and bank account information that we require for the purpose of recording and processing your account registration.

Contact data

We also process any personal data you choose to give when corresponding with us by phone, email, or otherwise visiting and interacting with this Website or any other services we operate.

Cookies and other technologies

A cookie is a small text file created by a website server and saved on a user's browser, and when a user visits a web site server, the web site can access cookie information. In addition to being used to identify users, cookies can also be used to store user information and track user access behavior.

We do not use cookies to collect and track any information or behavior about a user, other than to verify the user's identity and login status.

You can manage and delete cookies according to your preferences, and most browsers have the ability to disable or delete cookies from your system. Note that blocking cookies can cause some features on our Website or system to not work or work effectively, which can affect your experience.

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. Records in our log files include login time, browsing history, language used, date and time of access, network requests, etc. We use web server log files to administer the site, provide broad traffic information for site planning purposes, and to ensure that our terms of service agreement is being adhered to.

We receive and record 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, including language settings, browser type and version, software name and version. This is used:

  • to ensure the integrity and consistent operation of the Services;
  • to protect our Services against cyberattacks, criminal activity, identity theft, or investigation of suspicious activity;
  • to comply with our legal obligations, including as part of conducting routine audits of our Services;
  • to enforce our terms and policies;
  • to protect our users;
  • to determine effectiveness of features and campaigns;
  • to improve our Services; and
  • for security and verification purposes.

Social Media Data

We receive and record account identifier, log data, email address (if you choose to disclose your email), details of request to respond to your support request.

We receive and record social account ID, name, email address, photo, contacts, and any other information that may be or that you make accessible to us when you connect your social media account to your TTMF account.

Forum Data

We receive and record messages, images, videos posted to facilitate your use of the forum to communicate with the community.

Analytics

When you are using our Website, mobile and desktop applications, or widgets we provide to another site, we may collect analytics information automatically. This information may include your general device information, information in log files , device identifiers, 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 this purpose we may use internal analytic as well as third party service providers. For further details about our use of third party service providers, please refer to the Analytics providers section below.

Data we receive from third parties

When you sign in to your account using your social internet service credentials , these  service sends us your username and the email address associated with the credentials you've used. We neither control nor take any responsibility for the way third parties provide information about you and/or process your personal data.

How personal information is used

We use personal data in various ways that are necessary to provide the services you intend to use, certain legitimate interests, and as a necessity in order to comply with applicable law, as further described below.

We do not generally rely on your consent to allow us to process your personal data if there is another lawful ground available. If we do rely on your consent, we will make this clear to you at that time.

Profile

A profile is a set of information for each individual user that details his/her viewing preferences. User settings (chart settings, toolbars, buttons, etc.) are kept solely for the purpose of customizing the user’s experience when using the Website, applications or user accounts. We do not share private profile settings with any third parties.

Note that when you create an account, other users or visitors may access your public profile and see any information you have made publicly available about yourself.

User account and profile operations

We use your contact details, such as username, email address, or phone number, in the following ways:

  • to authenticate your user account, ensure its security along with the security of our services, and to prevent spam, fraud, and abuse;
  • to acknowledge, confirm, and deal with your user account;
  • to send all new users a welcome activation email to verify their email address;
  • to provide you with subscription services and contact you regarding your use of such services. This is necessary for us to implement your requests.

User account deleting

Please note that if you have requested your account to be deleted, we will delete the subsequent personal data you have supplied us. However some data, such as published ideas/scripts and messages sent to other users, will be saved as they have already integrated into our system. This data must be stored to maintain the integrity of the platform, as well as for legitimate business processes, including audits and security purposes.

Note that search engines, as well as third parties, can keep copies of your publicly available information once your account has been deleted. It should also be noted that published ideas will remain on the site and messages sent to other users cannot be deleted.

Marketing

We may send you marketing emails about our products or services that are similar to the products or services you are 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.

Social Notifications

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.

Service-Related Announcements

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

When you open a support ticket, we use your contact details as well as information about your device, server logs, a description of the problem, along with any other supporting materials (videos, screenshots, etc.) to help resolve the issue(s).

Legitimate interests

We will process your personal data as necessary for certain legitimate business interests, which include the following:

  • where we are asked to respond to any of your inquiries, comments, or grievances;
  • 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;
  • to develop and improve our mobile applications;
  • 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;
  • 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;
  • 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 analyse patterns among groups of people and conducting research on demographics, interests, and behavior;
  • 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
  • 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. 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.

When would we share personal information

To the extent required for the supply of the Services, we will share certain personal information with the following:

  • our affiliates– these entities process personal information as part of providing the Services and for the purposes described in this Privacy Policy;
  • third party service providers– these include website hosting, data analysis, payment processing, trade process, information technology and related infrastructure provision, customer service, email delivery, auditing, targeted advertising identification and delivery, mailing service, tax and accounting services, contest fulfillment and other services in connection with the overall delivery of the Services;
  • other users or members of the public– if you post content to the forum or other message boards, within chat, on a profile page, to a blog, or any other services to which you are able to post information and content (including, without limitation, social media pages), then the information you post will be available to any person who can view that page or service. If you choose to share using your connected social media account, then your shared content will be visible to your friends, other users of the platform, and the social media account provider. If you choose to share information using the share function, you authorize us to facilitate the sharing of the information you have selected, and you understand that the use of shared information will be governed by the social media provider’s privacy policy;
  • judicial authorities, law enforcement, regulators, courts, government authorities, and other parties where required for compliance with legal obligations– there may be circumstances where we are legally required to disclose personal information to these entities, whether it be to comply with applicable law and regulations, to cooperate with an inquiry or investigation, to respond to subpoenas, court orders, legal process, law enforcement requests, and legal claims, to enforce our terms and conditions; or to protect our rights, privacy, safety or property, and/or that of our affiliates, users or the public.

Public information on our Website

Public Profile

When you create your profile on our Website, other users or visitors may access your public profile and see any information you have made available about yourself. When browsing for trading ideas, they will only be able to view your market information (i.e. published ideas and scripts, markets allocation, top mentioned Symbols, etc.), social information (i.e. followers and following lists along with the ideas that you follow and comment on), contact information (i.e. your About section, location, website, etc.), your community status (i.e. Moderator or badges, statistical information such as reputation points, views, likes, followers, registration date, as well your last visit date). Your email address, however, will not be visible (unless you choose to make it visible).

Public content

Our Service allows those with a registered user account to share their charts with indicators and comments that can be added, their ideas, scripts, streams and other content, with the rest of the internet via our publish features.

By using a publish features, you grant us an irrevocable, perpetual, and royalty-free license to publish and disclose the content, as well as the username of the author, which makes you identifiable.

You can also publish your content as "private". This means that the content will not be displayed in your profile or your lists of ideas, scripts, streams, etc., nor will it be indexed by search engines. However, users who have a direct link to your content will be able to view it. Note that you will control over who/which users have access to a link.

When you comment on any content, we also publish certain information about your comment: including date, time and application (such as "TTMF for iOS" if you commented on it from one of our applications).

Chats and Private Messages

When you communicate with other users in public and private chats, we store and process your messages and any related information. We check links to make sure there is no malicious software or content as well as to detect spam and prohibited images/text. When you use private messages to communicate, please keep in mind that the recipients have a copy of your correspondence as well. This will continue to be the case even if you delete such correspondence from your account. Recipients can copy, store and/or reshare these messages. Be constantly vigilant of this.

Security of personal data

We use technical and organizational safeguards to protect your personal data and require third parties with whom we work to do the same.

We use Transport Layer Security (TLS) encryption technology in order to protect certain information that you submit to us. This technology protects you from having your information intercepted by anyone while it is being transmitted to TTMF. While on a secure page, such as our order form, the "lock" icon in the browser window is displayed, confirming that a secure and encrypted connection has been established with the Website. We work hard to ensure that our Service is secure and that we meet industry standards. We also use other safeguards, such as firewalls, authentication systems (i.e. passwords, and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data. If you have chosen to create an account, you are responsible for doing everything you reasonably can to keep your access details secret. You must not share these details with anyone else.

We also do our best to protect user information offline. All of our users' personal information is restricted to our offices. Only employees who need to see the information to perform their jobs are allowed to access it.

The servers that store personal data are located in a secure environment in a locked facility.

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.

Children and sensitive personal data

This Website is not directed to wards children who are under the age of 18. We do not knowingly contact or collect personal information from children below the age of 18 years, or sensitive personal data ("racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural person’s sex life or sexual orientation," etc.). Please consult Art. 9 GDPR for more information. If you believe we have inadvertently collected such information, please contact us immediately so that we can either obtain special consent or delete the information.

Third Party Sites

Links to other sites

At our discretion we may add links (web links) to other websites from our Website. These websites can be run by third parties with separate and independent privacy policies. We, therefore, have no responsibility nor are we liable for any content, activities or privacy policies of these linked sites. We suggest you read the privacy policy of each and every site that you visit.

Use of content from our Website

Some business partners use content from our Website on their own sites. Such sites may display messages such as "Powered by TTMF" or similar. We do not control the privacy policies of these sites, regardless of whether or not these messages are displayed. Again, we suggest you read the privacy policy of each and every site that you visit.

Accessing data

If prompted, we will confirm whether or not we are processing your personal data and if so, we will provide you with a copy of that personal data along with any other pertinent details. If you require additional copies, we may need to charge a reasonable fee, but this can be discussed and depends on the situation.

Restricting the processing of personal data

You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, for example, if you contest the accuracy of the data or object to us processing it. We will notify you before we lift any restriction on processing. If we share your personal data with others, we will notify them of the restriction wherever possible. If prompted, and if it is possible and lawful to do so, we will also notify you with whom we have shared or will share your personal data so you can contact them directly.

Objections

You may:

  • ask us to stop processing your personal data at any time, and we will do so. If we are relying on a legitimate interest to process your personal data, then it should not be a problem unless we demonstrate compelling legitimate grounds for processing;
  • object to our processing of your data for the purposes of direct marketing at any time. This can be done by clicking the "unsubscribe" button in our marketing emails; and
  • refuse to receive service notifications via email (for example, when a user you are subscribed to publishes a chart, idea, etc.). This can be adjusted in the User Setting

Withdrawal of consent

If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness with which we process your data before receiving notice of your wish to withdraw your consent. We emphasize that we do not generally rely on your consent to allow us to process your personal data if there is another lawful ground available. If we do rely on your consent, we will make this clear to you at that time.

Viewing and correcting data

You have the right to have inaccurate personal data rectified or completed if it is incomplete. In order to do so, each user can view, manage and/or update his/her personal data in the Profile Settings.

If we share your personal data with others, we will notify them of any corrections made whenever possible. If prompted, and where possible and lawful to do so, we will also notify you with whom we have shared your personal data so you can contact them directly if need be.

Deleting data

You have the right to refuse to use our Services and may ask us to delete or remove your personal data in certain circumstances. If we share your data with others, we will notify them of the edits wherever possible. If prompted, and wherever possible and lawful to do so, we will also notify you with whom we have shared your personal data so you can contact them directly if need be.

Data retention

We will keep your personal data (1) until you decide to delete your account (upon request), or (2) as required by law or as necessary for legitimate business purposes (i.e. for tax, legal, accounting, fraud, or abuse prevention, and/or other purposes). This data can be stored even after an account is deleted.

Upon expiration of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you. In this case, such data is no longer considered personal.

If you consent to receive marketing communications, we will keep your data until you unsubscribe, which is possible via the ‘unsubscribe’ button at the end of our marketing emails. Additional methods to unsubscribe may be added in the future.

Data portability

You have the right to obtain your personal data from us, which that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used, and machine-readable format. You may reuse it elsewhere if you so wish.

Lodge a complaint with the data protection authority

If you have concerns about our privacy practices, including the way we handle or have your personal data, you can report it to any competent data protection authority. If you wish to exercise any of these rights, please contact us. Note that we may need to ask you for further information to verify your identity before we can respond to any request.

International data transfers

The information collected through Services will be stored on servers located in the United States to our service providers and affiliated businesses for the purposes described above. This is necessary to enable you to navigate and use our Services. The data may be transmitted to our service providers and affiliates supporting our business operations (described above).

Note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the United States. If we transfer your personal data to countries outside of your country, we will take the necessary steps to ensure your information receives an adequate level of security protection where it is processed and that your rights continue to be protected.

If you would like to receive more information on the safeguards that we implement, please contact us.

California users' specific rights

If you are an eligible California resident, the California Consumer Privacy Act ("CCPA") provides you with specific rights with respect to our collection and use of your personal information. You have the following rights under the CCPA:

  • Right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. The list of categories of personal information collected and disclosed about consumers are enlisted in the section 'Personal data that we collect' and the list of categories of third parties to whom the personal information may be disclosed are enlisted in the section 'When would we share personal information'. Please contact us to exercise a data portability request. Separately, we do not sell your personal information.
  • Right to request delete personal information we have collected from you. Please see the “User account deleting” section for more details.
  • Right not to be discriminated against regarding pricing and services as you exercise any of your rights under the CCPA. We do not offer consumers financial incentives, price differentials, or services in exchange for selling a consumer's personal information.

Contact information

If you have any questions or suggestions regarding personal data processing, please contact us at uservice@ttm.financial or via post at:

TTMF Limited 
Sertus Chambers, P.O. Box 905, Quastisky Building, Road Town, Tortola, British Virgin Islands.