Privacy Policy

HOW WE COLLECT THE DATA?

The personal data we collect depends on the context of your interactions with us and our Sites, the choices you make, and the products and features you use.

WHAT INFORMATION DO WE COLLECT?

In Short: We collect personal information when you visit our Sites, that you provide to us through forms, or when you communicate with us.

The personal information that we collect depends on the context of your interactions with us and our Sites, the choices you make, and the products and features you use. The personal information we collect can include the following:

Data Automatically Collected

In Short: Some data – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites.

Data Collected From Other Sources

In Short: We may collect data from public databases, marketing partners, social media platforms, and other outside sources to the extent permitted by applicable laws.

We may obtain data about you from other legally permissible sources, such as public databases, governmental databases, joint marketing partners, social media platforms, as well as from other third parties. Examples of the data we receive from other sources include: profile data (your name, gender, birthday, email, current city, state and/or country, user identification numbers for your contacts, profile pictures, URL, employer, employer’s address, employment title, employment contact data, social media followers, business’ size and status, and any other data that you choose to make public or accessible); marketing leads, search results, and links, including paid listings (such as sponsored links).

HOW DO WE USE YOUR DATA?

In Short: The legal bases for using your data are legitimate business interests, the fulfillment of a contract with you, compliance with our legal obligations, and/or your consent.

We use data collected via our Sites or from outside sources for a variety of business purposes that are legally permissible as described below. We process your data for the following purposes — our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on for each purpose listed below.

For other purposes or treatment, prior, express, and informed authorization will be requested from the Holder.

WILL YOUR DATA BE SHARED WITH ANYONE?

In Short: We only share data with your consent, to comply with laws and legal obligations, to protect your rights, or to fulfill contracts and other business obligations.

Tribal Finance may share the information of the personal data with those third parties that are necessary for the development of its activities and corporate purpose, always protecting the rights and data of the data owner. The transmission or transfer of personal data that is carried out will observe the rules that the applicable regulations and the supervisory authority provide for this purpose.

In the case of national transmissions or transfers of personal data, Tribal Finance will ensure compliance with the requirements of current data protection legislation and protection measures by the person in charge or new controller.

If it is an international transfer, we make sure that the country that receives the personal data provides adequate levels of protection.

Your personal data may be transferred to and processed in countries other than the country in which you reside. Data protection laws may be different in these countries than in your own country and, in some cases, may be less protective. Please be assured that we take appropriate steps to ensure that your personal data is protected in accordance with this Policy.

With Whom Will Your Data Be Shared?

In Short: We only share data with the following categories of recipients:

• Our own group of companies, third-party service providers, product content providers, and partners;
• Law enforcement bodies, regulators, governmental agencies, courts and tribunals, legal proceedings, or other regulatory or governmental entities with relevant powers; and
• Any other third parties in which you have provided specific consent.

Do We Use Cookies And Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your data.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store data. Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements that are used to remember your browser and/or device during and across website visits. Cookies are widely used by website owners to make their websites more efficient, as well as to provide reporting data. Pixels, which are also called web beacons, are small blocks of code installed on, or called by, a web page, app, or advertisement which can retrieve certain data about your device and browser, including the device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, advertising identifiers, location, and other similar data that uniquely identifies your device. Pixels enable the ability to recognize when someone has visited a website or opened an email and allows monitoring the traffic patterns of users within websites, delivery or communication with cookies, determining whether a user has come to a website from an online advertisement displayed on a third-party website, to improve website performance, to measure the success of email marketing campaigns, and to set and read browser cookies from third-party domains and collect data about visitors to that domain, typically with the permission of the domain owner.

In Short: Yes, in certain jurisdictions, such as Mexico and the EU data subjects may have the right to choose whether or not to accept cookies and/or pixels. Cookies and pixels may be an important part of how our Sites work. You should be aware that if you choose to refuse or remove cookies and/or pixels, this could affect your ability to access and use our Sites.and store your data.

Most web browsers are configured to accept cookies and/or pixels by default. You can generally configure your browser to remove or reject browser cookies and/or pixels. If interested, follow the instructions provided by your browser, which are usually located in the “help” or “preferences” menu. Some third parties also provide the ability to refuse their cookies and/or pixels directly by clicking on an opt-out link.

Please be aware that removing or rejecting browser cookies or pixels does not necessarily affect third-party cookies or pixels. For mobile users, your device’s operating system provides controls that enable you to choose whether or not to allow cookies or share your unique identifier with companies like us or our third-party providers.

CAN YOU CONTROL DO-NOT-TRACK FEATURES?

In Short: Yes, most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

No uniform technology standard for recognizing and implementing DNT signals has been finalized, however. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.

In Short: Yes, in certain jurisdictions, such as Mexico and the EU data subjects may have the right to choose whether or not to accept cookies and/or pixels. Cookies and pixels may be an important part of how our Sites work. You should be aware that if you choose to refuse or remove cookies and/or pixels, this could affect your ability to access and use our Sites.and store your data.

These third parties may use tracking technologies to collect information about you when you use the Website or the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible party directly.

We do not use your information for advertising purposes beyond that normally and reasonably expected through the use of the Platform. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

IMPORTANT NOTE ABOUT PUBLIC BLOCKCHAINS

Information stored on a blockchain may be public, immutable, and not easily removed or deleted. Your transactions and addresses may reveal information about you, and information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. We do not control how other parties may use this information and cannot provide you any protection related to such information. Use our Platform at your own risk!

HOW DO WE KEEP YOUR DATA SAFE?

In Short: We aim to protect your data through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any data we collect and process, which are designed to provide a level of security appropriate to the level of risk presented; however, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your data, transmission of data to and from our Sites is at your own risk. You should only access our Sites within a secure environment.

DO WE COLLECT DATA FROM MINORS?

In Short: We do not knowingly collect data from or market to individuals under 18 years of age.

We do not knowingly solicit data from, or market to, individuals under 18 years of age. By using our Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to you minor’s use of the Sites . If we learn that data from users less than 18 years of age has been collected without authorization from the parent or guardian, we will deactivate the minor’s access and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from individuals under age 18, please contact us at contact@tribal.finance.

WHAT ARE YOUR DATA PRIVACY & PROTECTION RIGHTS?

In Short: In certain locations you may be a data subject and have some of the following data rights, which can be exercised through the communications methods provided herein

• Right of access: You may have the right to access and receive copies of your data we hold and receive details about how and why we use your data.

• Right to request proof of the authorization granted for the treatment: You may request the person in charge to allow you to know about the record where the consent you granted for the processing of your personal data is recorded.

• Right of portability: You may have a right to obtain your data for your own purposes, including so that you can provide or “port” that data elsewhere.

• Right of erasure: You may have the right to request us to delete the data we hold about you. We may also pass your requests on to other third parties to which we have shared your data.

• Right to exercise your rights without discrimination: You may have the right to exercise these rights without being discriminated against.

• Right to file a complaint: You may have the right to complain to your applicable data protection authority about our collection and use of your data.

• Right to not participate: If you do not agree with us collecting your data, you can inform us of your choice not to participate.

• Right to opt-out and/or revoke: You may have the right to revoke your consent to us collecting and/or processing your data and/or stop marketing communications and/or opt-out of participating and receiving future marketing communications, even if our reasons are based on legitimate business interests. You may also have the right to opt out of other processing activities. For email marketing communications, where applicable, click on the “unsubscribe” link found in those emails. To opt-out of other activities, you may note your preferences when going through the registration process or by accessing your account and updating your preferences.

• Right to correct: You may have the right to have us correct any inaccurate or incomplete personal data.

• Right to restrict: In certain circumstances you may be able to request that we restrict collecting and/or processing your data. Contact us to learn more about the circumstances in which this right exists at contact@tribal.finance.

• Right to appoint others: Certain locations permit you to appoint someone else to act on your behalf. Typically, this is done through a document such as a power of attorney. If your domicile allows this, please understand that we will require this appointed person to provide proof of such appointment, which may include you verifying your identity directly with us and/or our third-party identity verification partner.

• Right to confidentiality: You have the right to have your personal data protected in a manner appropriate to its degree of confidentiality.

• Right to anonymization, blocking or deletion of unnecessary, excessive, or processed data in contravention of the provisions of the Legislation.

• Right to be obtained from the person responsible for the treatment, in relation to the data of the owner processed by him, at any time and upon request, the confirmation of the existence of treatment.

• Updating or editing account data or closing an account: You can review or change the data pertaining to you in your account by logging into your account and updating your user data. If you close your account with us, we will deactivate your account and certain data from our active databases; however, some data will be retained in our systems to prevent fraud, troubleshoot problems, assist with any investigations, enforce our contracts and agreements and policies and procedures, and/or comply with legal requirements.

DO MEXICAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Mexico, you are granted specific rights regarding access to your personal data.

Mexico’s Regulations to the Federal Law on the Protection of Personal Data Held by Private Parties sets forth the rights of Mexican residents regarding their personal data held by private parties such as Tribal Finance. To understand your rights, please review the Regulations via the hyperlink above. If you wish to assert any of your personal data rights, please contact our privacy team through the communications methods provided herein

At any time, you can exercise the rights enumerated therein (your ARCO rights) by sending such a request through the communications methods provided herein. Your request must contain (i) your full name (given, middle, and surname(s)) and contact information (email address, phone number, and/or residential address), (ii) documentary evidence that proves your identity (or we may require you to verify your identity with our third-party identity verification partner), (iii) a clear description of the right(s) you wish to exercise, (iv) any other evidence or details that support your request, and (v) if you’re seeking the Right to correct, evidence that supports your request.

DO EU RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of the EU, you are granted specific rights regarding access to your personal data

The European Commission’s General Data Protection Regulation (GDPR) sets forth the rights of EU residents regarding their personal data held by others, such as Tribal Finance. To understand your rights, please review the information provided via the hyperlink above. If you wish to assert any of your personal data rights, please contact our privacy team through the communications methods provided herein.

DO CANADIAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Canada, you are granted specific rights regarding access to your personal data.

The Personal Information Protection and Electronic Documents Act (PIPEDA) sets forth the rights of Canadian residents regarding their personal data held by private parties such as Tribal Finance. To understand your rights, please review the Regulations in this link https://laws-lois.justice.gc.ca/eng/acts/P-8.6/. If you wish to assert any of your personal data rights, please contact our privacy team through the communications methods provided herein.

DO WE MAKE UPDATES OR MODIFICATE TO THIS POLICY?

In Short: Yes, we update this Policy as necessary to stay compliant with relevant laws

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

Also, Tribal Finance has the right to modify this Privacy Policy. In case of making modifications to this Privacy Policy, we will inform you by email if we have your email address.

DO WE TREAT SENSITIVE PERSONAL DATA?

Tribal Finance Will Not Collect, Store, Or Process Sensitive Data, Unless Strictly Necessary. If Such A Situation Arises, It Will Not Carry Out Any Treatment Without The Due Prior, Informed And Express Authorization Of The Holder Of The Information, And Only If The Owner Or His Legal Guardian Consents, Specifically And Prominently, For Specific Purposes Or Absent Owner Consent Of The Owner, In Cases Where It Is Essential:

• Compliance with a legal or regulatory obligation by the data controller.
• Shared treatment of the data necessary for the execution, by the public administration, of the public policies established in the laws or regulations.
• Carry out studies by a research body, ensuring, whenever possible, the anonymity of sensitive personal data.
• Regular exercise of rights, including in contracts and in judicial, administrative and arbitration processes.
• Protection of the life or physical safety of the owner or a third party.
• Health protection, exclusively, in a procedure performed by health professionals, health services or health authorities.
• Guarantee of fraud prevention and security of the Holder, in the processes of identification and authentication of the record in electronic systems, safeguarding the rights referred to in the Legislation and except in the case in which the fundamental rights and freedoms of the Holder prevail. require the protection of personal data.
• When the treatment is necessary to safeguard the vital interest of the Holder and he is physically or legally incapacitated.
• When an anonymization or disassociation procedure has been applied.
• When the treatment is carried out during legitimate activities and with the due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious, or union, provided that refer exclusively to their members or to people who maintain regular contacts by reason of their purpose, in which cases, the data may not be provided to third parties without the authorization of the Holder.
• When the treatment refers to data that are necessary for the recognition, exercise, or defense of a right in a judicial process.
• When the treatment has a historical, statistical, or scientific purpose. In this event, the measures leading to the suppression of the identity of the Holders must be adopted.

The answers to the questions about sensitive data are optional, therefore, they will not be mandatory. In any case, Tribal Finance will strictly observe the legal limitations on the processing of sensitive data. Tribal Finance, will not condition, in any case, any activity to the delivery of sensitive data. Sensitive data will be treated with the greatest possible diligence and with the highest security standards. Limited access to sensitive data will be a guiding principle to safeguard the Holder’s privacy and, therefore, only authorized personnel may have access to this type of data. Sensitive data may not be processed for purposes other than those expressly authorized by the Holder.

HOW WE TREAT THE PERSONAL DATA OF OUR EMPLOYEES?

Tribal Finance is responsible for the treatment of the personal data that you provide from your selection process, recruitment and, where appropriate, if the selection process is successful, when the employment relationship begins and until it concludes, regardless of the cause. The personal data collected will be processed in order to integrate the file as a candidate or employee at the service of Tribal Finance, prove your identity, location, carry out selection and recruitment, administrative and tax procedures, cover the job profile, pay salaries and benefits, assign and verify travel expenses and national and international tickets, integrate billing, be insured on the Social Security or other similar governmental obligations or benefits and designate beneficiaries in terms of the Labor Law, receive all kinds of legal and extra-legal benefits, control attendance and grant benefits of social security, economic, in-kind and health benefits; and schedule training actions. It is made known to you that Tribal Finance, in addition to the transfers that you make and that do not require your consent, may carry out the transfer of your personal data for the legal purposes that may arise due to the selection and recruitment process to which you are subjected or the individual employment relationship once you have signed the respective agreement; For all extraordinary transfers we will require your consent, therefore, if you do not want your personal data to be transferred for any or all of the purposes indicated, from this moment you can communicate the above, omitting the electronic signature of this notice or using the communications methods provided herein; however, please understand that your refusal to allow such transfers shall also mean that Tribal Finance will be incapable of hiring you or continuing to keep you as an employee depending on the timing of your notification to Tribal Finance. TO BE CLEAR: if you notify Tribal Finance that you do not want your personal data to be transferred while employed by Tribal Finance, this shall be considered as your written voluntary resignation notification from your employment with Tribal Finance. If you do not express your refusal for said transfers, we will understand that you have given us such consent.

Likewise, at any time you can exercise your data protections rights contact our Privacy team through the communications methods provided herein.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

Tribal Finance is responsible for the treatment of the personal data that you provide from your selection process, recruitment and, where appropriate, if the selection process is successful, when the employment relationship begins and until it concludes, regardless of the cause. The personal data collected will be processed in order to integrate the file as a candidate or employee at the service of Tribal Finance, prove your identity, location, carry out selection and recruitment, administrative and tax procedures, cover the job profile, pay salaries and benefits, assign and verify travel expenses and national and international tickets, integrate billing, be insured on the Social Security or other similar governmental obligations or benefits and designate beneficiaries in terms of the Labor Law, receive all kinds of legal and extra-legal benefits, control attendance and grant benefits of social security, economic, in-kind and health benefits; and schedule training actions. It is made known to you that Tribal Finance, in addition to the transfers that you make and that do not require your consent, may carry out the transfer of your personal data for the legal purposes that may arise due to the selection and recruitment process to which you are subjected or the individual employment relationship once you have signed the respective agreement; For all extraordinary transfers we will require your consent, therefore, if you do not want your personal data to be transferred for any or all of the purposes indicated, from this moment you can communicate the above, omitting the electronic signature of this notice or using the communications methods provided herein; however, please understand that your refusal to allow such transfers shall also mean that Tribal Finance will be incapable of hiring you or continuing to keep you as an employee depending on the timing of your notification to Tribal Finance. TO BE CLEAR: if you notify Tribal Finance that you do not want your personal data to be transferred while employed by Tribal Finance, this shall be considered as your written voluntary resignation notification from your employment with Tribal Finance. If you do not express your refusal for said transfers, we will understand that you have given us such consent.

Likewise, at any time you can exercise your data protections rights contact our Privacy team through the communications methods provided herein.

HOW WE TREAT THE PERSONAL DATA OF OUR EMPLOYEES?

Regarding the exercise of your personal data protection rights as Holder (their successors, legal representatives and / or proxies (collectively referred to as the “Holder”)) Tribal Finance will enable access channels for the Holders.

All communications, queries, complaints and / or claims must be directed to Tribal Finance by any of the following means: