Privacy Policy
Last Modified: July 26, 2023
PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT WILL HELP YOU MAKE INFORMED DECISIONS ABOUT SHARING YOUR PERSONAL INFORMATION WITH US.
Thank you for choosing to be part of our community at TRBL Ltd and Tribal Finance, Ltd. (“TRBL”, “Tribal Finance”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our Policy, or our practices with regards to your personal information, please contact us at legal@trbl.ltd or at our registered office Floor 4, Banco Popular Building, Road Town, Tortola, VG 1110 British Virgin Islands.
When you visit our websites (e.g., https://www.trbl.ltd and https://www.Tribal Finance), and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our Privacy Policy. We seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. This Privacy Policy applies to all information collected through our websites (such as https://www.trbl.ltd and https://www.Tribal Finance), and/or any related services, sales, marketing or events (we refer to them collectively in this Privacy Policy as the "Sites").
This policy describes:
The types of information we may collect or that you may provide.
The types of information we may collect or that you may provide when you visit our Sites, when you access or use the interface for interacting with the Tribal Finance Protocol (the “Protocol”) available at https://www.Tribal Finance (the "Platform"), or when you contact us via electronic media.
Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies only to information we collect on our Website, on the Platform, and in email, and other electronic communications sent through or in connection with the Website or the Platform. This policy DOES NOT apply to information that:
We collect offline or on any other Company apps or websites, including websites you may access through our Platform.
We collect through any electronic messaging service besides through the Website or email (such as apps like Telegram, Discord, Instagram, etc.).
You provide to or is collected by any third party (see Third-Party Information Collection below).
Our Website and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not access our Website or use our Platform. By accessing our Website, using or Platform, or communicating with us via email, you agree to this privacy policy. This policy may change from occasionally. Your continued use of the Website and the Platform after we revise this policy means you accept those changes, so please check the policy periodically for updates.
If you have any questions about this Privacy Policy, or would like to exercise your rights, please contact us at legal@trbl.ltd.
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.
The personal data we collect may include the following:
By automatically storing the data of the users who access the Tribal Finance platform using cookies. Some of the data that can be stored automatically are the URL, the browser used, IP address among others.
By exchanging emails.
Through access to our Sites.
Through access to the mobile application, creating the username and password.
Through telephone calls.
Through events held by Tribal Finance.
Through the transmission or transfer by strategic allies.
Through forms.
Through service offers.
Through the cooperation contract.
Through the service provision contract.
Through service portfolios.
Through meetings, regardless of the medium used (in person, video conference, telephone, etc.).
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:
Identifying Data
name — any combination of given, middle, and surname(s)
tax identification number (e.g., RFC or Social Security Number)
CURP &/or CIF &/or CIEC &/or proof of tax situation
photo identification (e.g., passport, driver’s license, INE)
e-signature / FIEL (e.firma) location data (e.g., residential address, work address)
date of birth, birthplace
Contact details
email address(es)
telephone number(s)
Employment data
employer’s name
employer’s economic activity
title at employer, employment details
employer’s details, including financial data, location(s), size, tax data, and contact details
Academic data
Not applicable
Sensitive data
Not applicable
Biometric data
government-issued photo identification
liveness video(s)
Credentials
user ID(s)
password(s)
password hint(s)
authentication data
account access data
When you use the Platform, we may ask you provide information. This information includes:
Information that you provide by filling in forms in the Platform. This includes information provided at the time of submitting any transactions through the Platform or solicitations of certain types of interactions with other users, and your MetaMask or similar Web3 software or service (including any information typically transmitted by such) (“Web3 Service”). We may also ask you for information when you report a problem with the Platform.
Records and copies of your correspondence (including email addresses and phone numbers) if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions with the Protocol you carry out through the Platform.
Available information on an underlying blockchain, including, without limitation, your public blockchain address (but excluding any private keys), account balances, crypto-asset holdings, blockchain transaction history, interaction history with smart contracts or “decentralized applications,” or any data included in a data field associated with your public blockchain address transactions (“Blockchain Identifiers”). For more information about blockchain information in general, see the subsection titled “Important Note About Public Blockchains” below.
Aside from Blockchain Identifiers and IP Addresses, we do not collect any information by which you may be individually identified through our Website or Platform.
You may also provide information for publication or display ("Posted") on public areas of the Website or Platform (collectively, "User Contributions"). Your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
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.
We automatically collect certain data when you visit, use, or navigate our Sites. This data does not reveal your specific identity (like your name or contact data) but may include device and usage data, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, data about how and when you use our Sites and other technical data. In some countries and/or regions, this data is considered personal data under applicable data protection and/or privacy laws or regulations.
Like many businesses, we also collect data about how your device has interacted with our Sites, including the pages and products and services accessed, time spent on Sites, and links clicked through cookies and similar technologies. This data is primarily needed to maintain the security and operation of our Sites, your account security, anti-fraud measures, and for our internal analytics and reporting purposes. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including traffic data, generalized location data, logs, and other communication data and the resources that you access and use on or through the Platform. We may collect Blockchain Identifiers and information provided by your Web3 Service (as is standard according to its typical behavior).
If you do not want us to collect this information, do not access the Website or use the Platform. For more information, see the section titled “Your Choices About Our Collection, Use and Disclosure of Your Information” below.
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.
We use the data we collect or receive to:
The personal data that Tribal Finance collects are included in a database to which the authorized personnel of Tribal Finance have access in the exercise of their functions, noting that in no case is the processing of the data authorized for purposes other than those described herein, and they are communicated to the Holder directly at the latest at the time of collection.
Principal purposes of treatment:
Facilitate account creation and logon processes. If you choose to link your third-party account (such as your Securitze account), we use the data you allowed us to collect from those third parties to facilitate and/or expedite account creation and logon processes.
Send marketing and promotional communications. We and/or our third-party marketing partners may use the data you give to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
Send administrative information. We may use your data to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
Fulfill and manage requests. We may use your data to fulfill and manage your requests, payments, returns, and exchanges made through our Sites.
Post testimonials. We post testimonials on our Sites that may contain your data. Prior to posting a testimonial, we will obtain your consent to use your data. If you wish to update or delete your testimonial, please contact us at legal@trbl.ltd and be sure to include your name, testimonial location, and contact information.
Deliver targeted advertising. We may use your data to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
Request feedback. We may use your data to request feedback and to contact you about your use of our Sites.
Protect our Sites. We may use your data as part of our efforts to keep our Sites safe and secure (e.g., for fraud monitoring and fraud prevention).
Enforce our agreements, contracts, terms, conditions, and policies.
Respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
Fulfill other business purposes. We may use your data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Sites, products, services, marketing, and user experience.
Secondary purpose of treatment:
Collect or collect personal data and incorporate and store them in our database.
Sort, catalog, classify, divide, or separate the data provided.
Use the data provided in communication, disclosure and promotion campaigns or offer of products, activities and / or services developed as part of Tribal Finance's internal strategies.
Maintained in historical records of Tribal Finance and maintain contact with the Holders.
Verify or validate the data provided.
Study and analyze the data provided to monitor and improve products, service, and care.
Deliver the data collected to third parties with whom Tribal Finance contracts the storage and / or administration of personal data, under the security and confidentiality standards to which Tribal Finance is bound according to what is contained in the pertinent laws.
Transfer personal data to any country or server in another country.
Communicate and allow access to personal data provided to third party providers of general support services and to natural or legal persons shareholders of Tribal Finance.
Collect, have, manage, and use the data to control and prevent fraud, control, and prevent money laundering and financing of terrorism.
Realization, execution, and management of business proposals and contracts for the services provided.
Sending communications through any channel including, but not limited to, social networks, text messages, push notifications, email, phone call, etc., related to Tribal Finance's corporate purpose such as marketing activities and / or any request made by the owner to Tribal Finance, among others.
Provide the services offered and / or contracted adequately and with excellent quality.
Creation and administration of the customer’s account.
Provide the maintenance, development and / or control of the commercial relationship between the user and Tribal Finance.
Provide users with the necessary information, through the website and / or mobile application, on the products of the bidders, to formalize the relationship of consumption of said products.
Carry out processes within Tribal Finance, for operational development and / or systems administration purposes.
Provide the services of Tribal Finance and carry out follow-up according to the needs of the customer, to provide the appropriate services and products to cover their specific needs.
Keep a historical record of the data, for the purposes of user satisfaction, developing analysis of interests and needs; thus, providing better service.
Carry out market strategies by studying user behavior towards offers and thereby improve content, personalizing presentations and services.
Preparation of commercial prospects and market segmentation.
Carry out satisfaction surveys and offer or recognition of benefits inherent to our loyalty program and after-sales service, to rate the service and attention through the channels provided for it.
Carry out the activities necessary to manage the requests, complaints and claims of the users of the customer or third parties; and direct them to the areas responsible for issuing the corresponding responses.
Present reports to the authorities and process the requirements made by administrative or judicial entities.
Accounting, economic, tax and administrative management of customers.
Conservation of data by the terms established in the Law.
Transfer or transmission of personal data nationally or internationally to third parties with whom Tribal Finance develops activities in compliance with its corporate purpose. Likewise, transmission or transfer may be made to Tribal Finance’s strategic allies to carry out marketing, advertising and promotional activities associated with the corporate purpose.
Send data to the data processors to facilitate and improve the quality of Tribal Finance's products and services.
Request the authorization of collection from the entities defined and authorized to do so.
Transfer and transmit your personal data to third-party commercial partners of Tribal Finance that offer their products and services on the Tribal Finance Platform to make efficient contact between the Holder and the commercial partner, in the terms of the legislation.
Access and consult your personal data in the credit and financial data centers, collect relevant data on credit behavior, and preserve, store, and use personal data to send commercial and advertising guidelines, and to contact in relation to matters of the Tribal Finance business activity. It is clarified that this purpose corresponds to those users who expressly accept the financial services offered.
Request or carry out consultancies, audits, or related services.
Comply with the internal processes of Tribal Finance in matters of administration.
Advance processes within Tribal Finance, for operational development and / or systems administration purposes.
Make tax declarations or management of tax and collection data.
Carry out, in accordance with the law, reports to credit bureaus for non-compliance with financial obligations derived from the business relationships.
Carry out operations and procedures related to the generation and payment of invoices, issuance of certifications, accounting, etc.
Compliance with legal duties and obligations.
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.
We may process or share data based on the following legal bases:
Consent: We may process your data if you have given us consent to use your data in a specific purpose.
Legitimate business interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a contract: Where we have entered into a contract with you, we may process your data to fulfill the terms of that contract.
Legal obligations: We may disclose your data where we are legally required to do so in order to comply with applicable law, governmental requests, regulatory requests, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Anonymized: We may disclose your data if it is anonymized. Meaning subjecting it to a procedure whereby personal data is decoupled from the data subject rendering the data shared incapable of being used or combined to identify the data subject.
Vital interests: We may disclose your data where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our agreements, contracts, policies, applicable laws and rules and regulations, suspected fraud, situations involving potential threats to the health or safety of any person, illegal activities, or as evidence in litigation in which we are involved and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our entities, the Protocol, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and scam deterrents.
We may also need to process and/or share your data in the following situations:
Vendors, consultants, and other third-party service providers. We may share your data with vendors, third-party service providers, contractors, or agents who perform services for us or on our behalf and require access to such data to do that work. Examples include account onboarding, identity verification, legal requirements and legal obligations, payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you access and interact with the Sites over time. This data may be used to, among other things, analyze and track data, fraud prevention, determine the popularity of certain content, or better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your data with third parties for their promotional purposes.
Business transfers. We may share or transfer your data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business partners. We may share your data with our business partners in order to offer you certain products, services, or promotions.
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.
When the receiving country does not comply with the appropriate data protection standards, the transmission or transfer will be prohibited unless one of the following legal exceptions is configured:
That the Holder has given express and unequivocal authorization for the transfer or transmission of data.
Exchange of medical data when required by the Holder's treatment for health and public hygiene reasons.
Bank or stock transfers, in accordance with the applicable legislation.
Transfers agreed in the framework of international treaties to which Colombia is a party, based on the principle of reciprocity.
Transfers necessary for the execution of a contract between the Holder and the person responsible for the treatment, or the execution of pre-contractual measures if there is authorization from the Holder.
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.
Can you control cookies?
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.
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.
Third-Party Information Collection
When you access the Website or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
Analytics companies.
Your device manufacturer.
Your service provider.
When you use the Platform, certain third parties may use automatic information technologies to collect information about your on-chain activities. These third parties may include:
Blockchain explorers.
Decentralized infrastructure providers.
Your Web3 Service.
Any DAO or other entity that controls, interacts with, or provides services related to the Protocol (including pool delegates and other members of the Tribal Finance ecosystem).
Any other party with access to the underlying blockchain.
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 We Use Your Information
We use information that we collect about you or that you provide to us, including Blockchain Identifiers and IP Addresses, to:
Provide you with the Platform and its contents, and any other information, products, or services that you request from us.
Fulfill any other purpose for which you provide it.
Carry out our obligations, such as legal and regulatory requirements, and enforce our rights arising from any contracts entered into between you and us.
Provide technical support.
Detect, prevent, and address fraud, breach of Terms, and threats or harm. Protect the security and integrity of the Website and Protocol.
Notify you when Platform updates are available, and of changes to any products or services we offer or provide though it.
Contribute to the facilitation and operation of the Protocol.
The usage information we collect helps us to improve our Website and Platform and to deliver a better and more personalized experience by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Platform according to your individual interests.
Recognize you when you use the Platform.
HOW DO WE HANDLE YOUR THIRD-PARTY ACCOUNT LOGINS?
In Short: If you choose to share access to your social media accounts and/or other third-party accounts, we may have access to certain data about you.
Our Sites may offer you the ability to share access to your third-party social media account details (like your Facebook or LinkedIn logins) and/or other third-party accounts (like Securitize). Where you choose to do this, the providers will send us certain profile data about you, not access into your account. The profile data we receive will vary depending on the provider, but will often include your name, date of birth, email address, friends list, profile picture, as well as other data you choose to make public and/or is contained within that account.
We will use the data we receive only for the purposes that are described in this Policy or that are otherwise made clear to you on our Sites. Please note that we do not control, and are not responsible for, other uses of your data by your third-party social media providers or other third-party accounts. We recommend that you review their respective privacy policy to understand how they collect, use and share your data, and how you can set your privacy preferences on their sites and apps.
HOW LONG AND WHERE DO WE KEEP YOUR DATA?
In Short: We only keep your data on our servers for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Our retention requirements vary, depending on jurisdictional requirements.
We will only keep your data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legal requirements or legitimate business need to process your data, we will either delete or anonymize it, or, if this is not possible (for example, because your data has been stored in backup archives), then we will securely store your data and isolate it from any further processing until deletion is possible. Our group companies, third-party service providers, and partners, with whom we may share your data as outlined in this Policy, are located in and transfer data to various jurisdictions around the world. This means that your data may be transferred and processed in countries other than the country in which you reside. The data protection laws may be different in these countries versus your own country and, in some cases, may be less protective. Be assured, we take appropriate measures to ensure that your data is protected in accordance with this Policy.
For further information about retention time periods or international data transfers, contact us at legal@trbl.ltd.
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 legal@trbl.ltd.
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 comunications 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 legal@trbl.ltd.
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 comunications methods provided herein
At any time, you can exercise the rights enumerated therein (your ARCO rights) by sending such a request through the comunications 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 comunications 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 comunications 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 comunications 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 comunications methods provided herein.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
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:
Electronic attention: The Holder may make a request to the following email: legal@trbl.ltd
Written attention: The Holder may make a request to the following address of our registered office at: Floor 4, Banco Popular Building, Road Town, Tortola, VG 1110 British Virgin Islands.
If you have questions or comments about this Policy, you may contact our General Counsel, Jordan Magazine, who is the head of our Privacy team by email to the address already provided.