Privacy Policy

This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information.   The terms “TangoTrade,” “us,” “we,” and “our” refer to TangoTrade, Inc. and its affiliates. The terms “you” and “your” refer to any person or business that applies or signs up for a TangoTrade account, or accesses or uses any TangoTrade application, product, service, feature, technology, content, or website (collectively, “Services”).

Scope and Consent

This Privacy Policy applies to Personal Information that is Processed by TangoTrade in the course of our business, including through our Services.  “Personal Information” is any information relating to an identified or identifiable natural person. “Process” or “Processing” means any operation that we perform on Personal Information.

This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

You accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy (including to contact you), and for all other purposes permitted under applicable personal information privacy statutes, credit bureau reporting rules, anti-spam legislation, and consumer protection laws.

Collection of Personal Information

We collect Personal Information about you to deliver Services.

Personal Information You Provide Directly to Us

We collect information you provide when you apply or sign up for a TangoTrade account or use TangoTrade Services and when you provide information as part of our identity or account verification process.  We may collect information about you, including but not limited to:

  • Identification information, such as your name, email address, mailing address, phone number, photograph, birthdate, passport, driver’s license, Social Security, Taxpayer Identification, or other government-issued identification number;
  • Financial information, including bank account and payment card numbers; and

Other historical, contact, and demographic information.  We may collect Personal Information from you such as email address, phone number or mailing address when you contact us to request information about our Services, register for our newsletter that we may offer, request to receive customer or technical support, or otherwise communicate with us.

We also collect information you upload to or send through our Services, including but not limited to:

  • Information about products and services you purchase or sell;
  • Information you provide about you or your authorized users, representatives, or beneficial owners; and
  • Information you provide to counterparties using our Services (for example, invoice information).

Some of the information we collect is collected to comply with laws and regulations, including anti-money laundering and anti-terrorist financing laws.

Personal Information We Collect from Your Use of our Services

We collect information about you when you use our Services, including but not limited to:

  • Device Information.  We may collect specific information about the computer or mobile device (“device”) used when you access our Services, including your hardware model, operating system and version, unique device identifier, internet service provider, mobile network information, and information about the device’s interaction with our Services.  We may also identify other software running on the device for anti-fraud and malware-prevention purposes, but we will not collect any content from such software.
  • Location Information.  Through our applications, we may collect information about the location of your device.
  • Use Information.  We collect information about how you use our Services, including your access date and time, browser type and language, and Internet Protocol (“IP”) address.
  • Transaction Information.  When you use our Services to make, accept, request, or otherwise participate in a transaction, we may collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.
  • Information Collected by Cookies.  We use various technologies to collect information when you use our Services, including sending cookies to your device.  Cookies are small data files that are stored on your hard drive or in your device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity.  For more information and to learn how to block or delete cookies used in the Services, please see “Your Choices” below.

Personal Information We Collect from Other Sources

We may also collect information about you from third parties, including third-party verification services, credit bureaus, mailing list providers, and publicly available sources.  In some circumstances, where lawful, this information may include your government-issued identification number. By applying or signing up for a TangoTrade account, you authorize and consent to our obtaining from, and disclosing to, third parties, from time to time, any information about you in connection with the processing of any credit investigation, identity or account verification, fraud detection, or collection procedure, or as may otherwise be required by applicable law.  This includes, where lawful, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau.

Third-Party Advertising and Analytics

We may allow third-party service providers to deliver content and advertisements in connection with our Services and to provide anonymous site metrics and other analytics services.  These third parties may use cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Services, webpages viewed, time spent on webpages, links clicked, and conversion information (e.g., transactions entered into).  This information may be used by TangoTrade and third-party service providers on behalf of TangoTrade to analyze and track usage of our Services, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand how you use our Services. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies.  For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.

Third-Party Websites

Our website may contain links to other websites, and other websites may reference or link to our website or other Services.  These other domains and websites are not controlled by us, and TangoTrade does not endorse or make any representations about third-party websites or social media platforms.  We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications.  Visiting these other websites or applications is at your own risk.

Use of Your Personal Information

We acquire, hold, use, and Process Personal Information about you for a variety of business purposes, including:

To Provide Products, Services, or Information Requested

We may use Personal Information about you to provide, maintain, and improve our products, Services, or information, such as:

  • Processing or recording payment transactions;
  • Displaying historical transaction information;
  • Accessing certain areas, functionalities, and features of TangoTradeservices, such as business resources; and
  • Delivering the information and support you request.

We also may contact you to resolve disputes, collect fees, and provide assistance for problems with our Services or your TangoTrade account.

Research and Development

We may use Personal Information about you to improve, personalize and facilitate your use of our Services.  We also may use Personal Information about you to measure, customize, and enhance our Services, including the design, content, and functionality of our applications and websites, or to track and analyze trends and usage in connection with our Services.

Other Uses

We may use Personal Information about you:

  • To protect our rights or property, or the security or integrity of our Services;
  • To enforce the terms of our Terms of Use or other applicable agreements or policies;
  • To verify your identity (e.g., some of the government-issued identification numbers we collect are used for this purpose);
  • To investigate, detect, and prevent fraud, security breaches, and other potentially prohibited or illegal activities;
  • To comply with any applicable law, regulation, legal process, or governmental request;
  • For any other purpose disclosed to you in connection with our Services.

Sharing of Information

We may share Personal Information about you as follows:

  • With our group companies and other affiliates for the purposes outlined above;
  • With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, and other entities in connection with the payment or money transfer process;
  • With other users of our Services with whom you interact through your own use of our Services.  For example, we may share information when you request or accept a transaction using our Services;
  • In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business; or
  • If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from tax authorities), (ii) to enforce or comply with the terms of our Terms of Use or other applicable agreements or policies, (iii) to protect our rights or property, or the security or integrity of our Services, or (iv) to protect us, users of our Services, or the public from harm or potentially prohibited or illegal activities.

We also may share aggregated information with third parties that does not specifically identify you or any individual user of our Services.

International Data Transfers

You agree that all Personal Information collected via or by TangoTrade may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, in the cloud, or on the servers of our service providers.  Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to TangoTrade, you explicitly consent to the storage of your Personal Information in these locations.

Your Choices

Personal Information

You may access, change, correct, or delete Personal Information about you by logging into your TangoTrade account at any time or by contacting us.  We may need to verify your identity before granting access or otherwise changing, correcting, or deleting your information.

Although we will make good faith efforts upon your request to provide you with access to your information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where it is commercially proprietary.  If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.

Deactivating Your Account

You may deactivate your TangoTrade account by logging into your TangoTrade account or by emailing us using the contact details provided below.  We may retain archived copies of Personal Information about you and any transactions or Services you used for a period of time that we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Use or other policies, or to take any other actions consistent with applicable law.

Cookies

When you access or use the Services, to help make your experience simpler, our web server may send a cookie to your device.  Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application.  Other cookies are used to remember you when you return to use the Services and, as such, will last longer.

We may use cookies to:

  • Remember that you have visited us or used the Services before.
  • Customize elements of content of our website or application for your experience.
  • Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Most web and mobile device browsers are set to automatically accept cookies by default.  However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set.

You also can learn more about cookies by visiting  http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices.  Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out.  For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.

Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites.  We currently do not respond to DNT signals. We may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.

Children’s Information

Our website and Services are not targeted or directed at children under the age of 13 and do not knowingly collect or store any personal information about children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at the contact information provided below.  If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.

California Privacy Rights

California law permits residents of California to request and receive once each calendar year certain details about information we have disclosed to third parties for those third parties’ direct marketing purposes during the immediately preceding calendar year.  If you are a California resident and would like to request this information, please contact us at the address listed below.

Security of Your Information

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.  We hold Personal Information about you at our own premises and with the assistance of third-party service providers. We restrict access to Personal Information to those TangoTrade employees, contractors, and agents who need to know that information in order to transmit, store, or Process it, who are subject to contractual confidentiality obligations consistent with this Privacy Policy, and who may be disciplined or terminated if they fail to meet these obligations.  Our third-party service providers store and transmit Personal Information in compliance with this Privacy Policy and other appropriate confidentiality and security measures.

Nevertheless, TangoTrade cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your Personal Information for improper purposes.  If information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

Amendment

We may amend this Privacy Policy from time to time by posting a revised version and updating the “Last updated” date below.  The revised version will be effective at the time we post it. We will provide you with reasonable prior notice of substantial changes in how we use your information, including by email at the email address you provide or as otherwise required by law.  Where these changes would cause material detriment to you, you may of course cancel your account at any time. We encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices and the choices available to you, and to contact us if you have any questions about these changes.  Your continued use of our Services constitutes your acceptance of any amendment of this Privacy Policy.

Contact

If you have any questions or concerns regarding our Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our Compliance Department and we will respond to let you know who will be handling your matter.  We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.

TangoTrade, Inc.
2955 Campus Drive

San Mateo, CA, U.S.A.
compliance@tangotrade.com