DATED: SEPTEMBER 2021
- The types of personal information we collect
- How we use personal information we collect
- How we share personal information we collect
- How we safeguard personal information we collect
- Miscellaneous Privacy Information
1. What Type of Information Is Collected
To provide our Services, and facilitate exchanges between users of the Website, we obtain personal information directly from you and obtain information about you indirectly through electronic communications and third parties.
User Supplied Membership Information: Depending on the Services you seek to access we may require that you provide us with some or all of the following types of personal information:
● Account Data includes your email address and password, as well as your communication preferences and your communication with our support staff.
● Profile Data includes the data collected by us during the application and KYC processes, such as your name, address, mobile phone number, a video recording of your face, citizenship, date of birth, gender and identification numbers such as those contained on your driver’s licence, passport or national identity card.
● Transaction Data includes details about your transactions on the Platform and details of Services you have used.
● Technical Data includes information about the device you are using to access our Services, such as your internet protocol (IP) address, operating system, time zone, country and language setting.
● Usage Data includes information about when and how you use our Services (i.e. logs of interactions with our system).
The account registration process may request that you provide other information that you may, at your option, choose to provide or withhold. Any such information provided shall be subject to this policy.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
Identity Verification (KYC/AML): If required to help us verify your identity, you may provide us a copy of your driver’s license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering, US Treasury department rules or regulations or other legal requirements. If you seek to invest through an entity, you may provide us with documentation relating to the entity’s jurisdiction of formation, legal status and ownership. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship.
Banking Information: In order to make an investment in tokenized real estate offerings made through the Website, you must provide us and/or our financial partners with certain account and other payment information, such as information needed to make payment via ACH, wire, electronic checks, cryptocurrency, foreign currency or any other payment method accepted by us at such time.
“Cookie(s)” are small amounts of data, often including an anonymous unique identifier, sent to your internet browser from a website’s computers and then stored on your computer’s hard drive. Cookies help provide a a unique user experience and to make it easier for you to use the Website over time. Terramint may include cookies on our Website and use them on a limited basis to recognize you when you return to our Website.
Some web browsers transmit “do-not-track” signals to websites. Currently, Terramint Services are not designed to respond to these signals or similar mechanisms from browsers.
We may send email messages that use a “click-through URL” linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. Terramint shall track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click text or graphic links in the email, or notify us at Info@terramint.com.
Information Related to Your use of the Services: We collect certain information about you when you visit the Website and interact with any of our Services. We collect information about when you use Services, the pages within the Website you visit, the links you click on, the type, size and names of files you upload or download, and the search terms you use. If you invite others to use the Website, we retain information about your referral.
Terramint collects transactional information in connection with the transactions you become a party to through the Services, including your participation in primary offerings via the Website and secondary purchase and sale transactions through the secondary marketplace. Transaction data includes, without limitation, the terms on which you purchase or sell securities and information relating to price, size, volume, class of securities, offers, acceptances, transfer restrictions, and any derivative data related thereto.
Third-Party Information: We collect information about you from third-party sources with which we maintain various commercial relationships. If necessary, Terramint utilizes a third-party identity verification service provider to help us confirm your identity, prevent fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating to the Services. We also receive information about you and your activities from third-party service providers, such as Google, LinkedIn and other advertising, social media and market research partners who provide us with information about you, and/or your engagement with and interest in our Services.
Log Information: We collect log files that contain the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our websites.
2. How Collected Personal Information is used by Terramint
We may use your information for the following business and commercial purposes
- To provide, maintain, and improve the Platform and Services;
- To satisfy our record keeping and transfer agency obligations under applicable laws, rules and regulations;
- To verify your identity, and your status as an accredited investor, monitor suspicious activity and prevent fraudulent or other illegal activities;
- Send you technical notices, security alerts, and other support and information messages;
- Respond to your comments and questions and provide customer service;
- Analyze trends and usage;
- To communicate with you about the Services and target our marketing, advertising and sales efforts to enhance your user experience and increase engagement. These communications may alert you to new Services, offerings, features, content and promotional events.
- On an anonymized and aggregated basis, for research and development uses, including to analyze how you use the Services to help us understand usage patterns and understand if there are problems with the Services;
- Contact you via electronic mail, text message, mail service, or telephone, in connection with your relationship with Terramint, including with information and updates about our Servicesl;
- Process and deliver contest entries and rewards;
- Link or combine any information we collect about you; and
- Carry out any other purpose for which you provided the information.
3. Sharing of Personal Information We Collect
Terramint does not share personal information with ANY third parties for sales, direct marketing, or similar purposes without your consent.
The means wherein partners, service providers and others with whom Terramint shares and/or discloses personal information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s). This may include the incorporation of your personal information into databases maintained to validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols.
The most likely situations wherein Terramint may share your personal information are as follows:
Third Party Service Providers: Terramint contracts with other companies to perform functions on our behalf, such as third party service providers that assist in the administration of the Terramint Website, identity verification services, data analytics companies that provide business intelligence. Terramint may need to share your information with these groups.
Internally: Terramint may also share your personal information with companies closely related to or owned by us – our “Affiliates” – for certain purposes under this policy. By “Affiliate,” we mean an entity that controls, is controlled by, or is under common control with Terramint, whether the control results from equity ownership, contract, overlapping or common management or otherwise. In this context, “control” means the ability to replace the officers or directors or otherwise materially influence or control management decisions. Affiliates of Terramint shall be entitled to their rights under this policy and Terramint agrees to be responsible for our Affiliate’s conduct under this policy.
Service Providers: To operate the Services we share information about you as needed with our service providers, including financial institutions, broker-dealer(s), accountants, auditors, lawyers, payment processors, information technology consultants, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Website and the Services.
Governmental Regulators: Terramint may be required to share personal information about you with US, state or international regulators or FINRA where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas.
Financial Institutions. With respect to US residents, we also may share your information with other financial institutions as authorized under Section 314(b) of the US Patriot Act, and with tax authorities, including the US Internal Revenue Service, pursuant to the Foreign Account Tax Compliance Act (“FATCA”), to the extent that this statute is determined to apply to us.
4. Protection of Your Personal Information
Terramint utilizes several security processes to reduce and prevent unauthorized access to or disclosure of Your Personal Information, and we take all reasonable steps to secure and safeguard this Information, including:
- The password-protected areas of the Website requires users to give us unique identifiers such as their user ID and password and authenticate themselves prior to accessing the Services;
- We provide permissions to our databases storing Personal Information only to those with a necessary business need;
- Use of automated cybersecurity tools to analyze network traffic and identify unauthorized access, uploads, changing of information, or otherwise seeking to gain unlawful access to the Terramint network;
- Use of Industry standard encryption technology for any information we store;
- Terramint employees MUST agree to protect the confidentiality of Personal Information and agree to abide by the policy; and
- Where applicable, third-party vendors agree to abide by this policy and apply similar safeguards to Personal Information consistent with the GDPR and CCPA.
Terramint cybersecurity infrastructure is designed and intended to deter and prevent malicious actors and others from accessing the personal information you provide to us. Internet communications and technologies are constantly evolving, and we are unable to provide a warranty for and we also disclaim assurances that the personal information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
Security of Payment Methods: Terramint will safeguard the confidentiality and security of the payment information we obtain from you. This notice describes our policy as it relates to the collection, protection and disclosure of such information resulting from debits, wire transfers, and credit card transactions only. Terramint will collect and use information obtained from debits, wire transfers, and credit card transactions only for business purposes. The debit card, wire transfer, and/or credit card information provided by you to Terramint shall be stored in a confidential manner. Our employees may access such information only when there is an appropriate business reason to do so, such as when a refund must be issued back to the credit card. We maintain physical, electronic and procedural safeguards to protect your personal and payment information, and our employees are required to follow these privacy standards. Transmission of information, including any payment information, is encrypted and protected using TLS/SSL technology. Terramint does not disclose any nonpublic information (such as credit card number and their expiration dates), except as required by law. Terramint shall only disclose payment information only when it is necessary for the conduct of government business, or under circumstances where disclosure is required by law. Information may also be disclosed for audit purposes, to regulatory agencies or for other general administrative services.
5. Miscellaneous Privacy Information
Company Communications Opt-Out: In order to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at info@Terramint.com to opt out. Despite chosen email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt–out of certain communications required to comply with applicable laws, rules and regulations or other legal and related notices concerning your relationship to the Website.
Changing or Deleting Personal Information: All users may review, update, correct or delete the Personal Information furnished by a user by contacting us at info@Terramint.com or, in certain cases, by accessing your member account. If you request, we will take reasonable steps to remove your name and other personal information from our databases. Please understand, however, that:
- it may be impossible to remove this information completely, due to IRS and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions;
- if you request deletion of your information, you will be unable to use certain features of the Website and any associated Services; and
- certain Personal Information may remain in our databases following the deletion of your account pursuant to our data retention policy.
Policies on Data Retention: We retain information we collect for as long as you use the Services (including your ownership of digital tokens in Terramint entities) or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations or otherwise as required by law. We may retain an archived copy of your records as required by law or for other legitimate business purposes.
Lost or Stolen Personal Information: You agree to notify Terramint if you become aware that any personal information provided by or submitted to the Website has been lost, stolen, or used without permission by a third party.
Download or Accesssing Your Personal Information: You may request a copy of your Personal Information, including a copy in machine readable form, by emailing us at info@Terramint.com.
Use by Children and Teenagers: TERRAMINT PROHIBITS INDIVIDUALS WHO WE KNOW ARE UNDER 18 TO PARTICIPATE IN OUR WEBSITE OR SERVICES. YOU MUST BE AT LEAST 18 YEARS OF AGE TO USE OUR WEBSITE AND SERVICES. Please understand that we cannot necessarily confirm whether a user is providing us with his or her true age. If a parent or guardian becomes aware that their minor child has provided us with information without their consent, they should immediately contact us at info@Terramint.com. Upon receipt of a validate report of a minor using the Terramint services, will will restrict access to the account or delete such information from our files within a reasonable time.
United States Operations: Terramint is operated and based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
European Economic Area Residents: If you are an individual residing in the European Economic Area (“EEA”), we collect and process information about you only where we have legal bases for doing so under applicable EU laws, including the General Data Protection Regulation (“GDPR”). The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, perform a contract with you, take necessary steps prior to performing a contract or at your request, provide customer support, and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services, to personalize services you receive, and to protect our legal rights and interests;
You give us consent to do so for a specific purpose; or we need to process your data to comply with a legal requirement. If you have consented to our use of information about you for a specific purpose, you may change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you may object to that use though, in some cases, this may mean no longer using the Services. To do so, please email us at info@Terramint.com.
In the event of a data breach, we will endeavor to notify you within 72 hours of detection of a breach that we conclude poses significant risks to your rights and freedoms under the GDPR. You may also lodge a complaint with a supervisor authority in the EEA member state in which you reside.
California Residents: Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business with which the California resident has an established business relationship what types of personal information, if any, the business shares with third parties for direct marketing purposes by such third parties and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. To access this information, please contact us by email at info@Terramint.com.
Vermont Residents: We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, please contact us for assistance at info@Terramint.com, though we will no longer be able to provide you Services or access to the Website.