The Tenn Privacy Policy

About TheTenn Inc.

TheTenn Inc., is a company incorporated under the laws of the United States. Our registered office and contact address is: Industrious 9th and Congress, 823 Congress Avenue, Austin, TX, 78701.

You can contact us through the help button in the Thetenn Inc. app or email us at [email protected].

We are here for you

Before getting into the details of our privacy policy, we would just like to say that we are here for you, the customer. Our purpose is to give you better payment services and a better deal. This includes taking our responsibilities towards you and your data very seriously. We will always use your data in a way that is legal,that seeks to take good care of your privacy, and uses your data to design better services for you. We will never use your data in a way that we think could harm you. If you have any concerns relating to your data, we are keen to hear from you and see if we could do better.

We collect, use, and retain information about you

Information you give us when you get in touch with us, through The Tenn app, when you register to use the app, sign up for an account, correspond with us by email, phone or otherwise, use the in-app chat, engage in promotions or reward schemes, or other communications:

1. Your name, phone number, home address, date of birth, residency
2. Your email address, details of your device
3. Your United States ID information, or passport and any other identification documents
4. Your selfie when you set up an account with us, and your photo if you upload one
5. The login and registration information and settings you choose on the app (including username, password)
6. Your bank account details, including account number and IBAN
7. Your location
8. Details you give us which we pass to our partners when you let us know you are interested in their services
9. Information you give us through the in-app chat or records of discussions if we contact each other
10. The email address you use and the contents of email you send us (and any attachments)
11. Public details from your social media profiles (Facebook, Instagram, or Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us
12. Answers you give to surveys
13. Details about top-ups into your account, payments to and from your account, and transfers you make between your account and other The Tenn accounts including payment reason, and beneficiaries’ details
14. Details about services from us and our partners that you express interest in and where their services are integrated with us
15. Details about how you use our app and your visits to our website, including location information about where you use the app
16. Details of marketing information we have sent you, including data on whether and how you have accessed this information
17. Details of any accounts you have linked to your account via the app
18. Information we collect from your device:
    1. The mobile network information and operating system, the type of mobile browser you use
    2. Your login information, browser type and version and information
    3. The type of device you use, unique device identifier
    4. Your IP (Internet Protocol) address and device ID for security reason
    5. Your mobile advertising ID, so we can share it with companies that help us with advertising online. You can reset this ID or limit tracking in ‘Settings’ on your phone
    6. Your location so we can help protect you against fraud when we track your location using GPS and your IP address
    7. Your phone contacts who use Hubpay if you give access to do so
    8. Information on your use of the app, including links to, through and from our website to other sites
    9. Transaction data around your payments and beneficiaries
19. Information from external sources
    1. Fraud prevention agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil our legal duties
    2. Information from your social media network. When you log in to the Hubpay app from your social media account we will receive information to authenticate you

Cookies Policy

We use cookies, pixels, and other technologies (collectively, "Cookies") to recognize your browser, or device, learn more about your interests, and provide you with essential features and services and for additional purposes including:

1. Recognizing you when you sign-in to use our Services. This allows us to provide you with product recommendations, display personalized content, enable you to use 1-Click transactions and provide other customized features and services
2. Keeping track of your specified preferences. This allows us to honour your likes and dislikes, such as whether or not you would like to see interest-based ads. You may set your preferences through Your Account
3. Keeping track of your financial transactions left incomplete
4. Conducting research and diagnostics to improve our content, products, and services
5. Preventing fraudulent activity
6. Improving security
7. Delivering content relevant to your interests
8. Designing new products and services to benefit you, through analysis of your data
9. Reporting. This allows us to measure and analyse the performance of our services
10. Improving your customer experience by keeping track of language preference, country, and previously viewed pages.
11. To summarise, we use the following cookies:
    1. Necessary cookies:these cookies enable the basic use of our Services
    2. Personalisation cookies:these cookies allow our Services to be personalised for you
    3. Analytical cookies:these cookies allow us to see how people use ourService so that we can understand how to improve it
12. By using our Services, you agree to place the cookies described above on your device. You have the right to withdraw your consent at any time. If you would like to delete our cookies, you can do so by changing the settings of your browser
13. Blocking or deleting cookies may mean that some features of the Service may not be available to you

Why we use your information

We must have a lawful basis for using your personal data. At least one of the following must apply: contract, legal duty, legitimate interest, public interest, vital individual interest, or consent. In this section we explain which one we rely on to use your data in a certain way.

We need to use your data for a contract we have with you, or to enter into a contract with you.We use details about you to:

1. Consider your application, including our KYC, customer due diligence and security checks
2. Give you the Services we agreed to in line with our terms and conditions
3. To process your transactions
4. Send you updates and communications about your account and other services you use if you get in touch, or we need to notify you of changes to our Services, tell you about something or contact you through customer support services
5. To handle your enquiries in our communications
6. Exercise our rights under contracts we have entered into with you
7. Allow our partners provide information on their services, if you agree
8. Investigate and resolve complaints and other issues

We need to use your data to comply with the law.We use your details to:

1. Check your identity when you sign up or get in touch
2. Check your record at immigration and fraud prevention agencies
3. Prevent illegal activities like money laundering, tax evasion and fraud
4. Keep records of information we hold about you in line with legal requirements
5. Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforce mentor other third parties)
6. Compare information we hold about your account with your tax residency information to make sure we do not have a reason to doubt it

When it is in our ‘legitimate interest’

We need to use your data for our legitimate interests, or those of a third party (like companies that provide services to us). This means using data in a way that you might expect us to, for a reason which is in your and/or our (or a third party’s) interest and which does not involve overriding your privacy rights. Ways we will use your data in this regard include:

1. Product development and marketing:
   1. We will tell you about products and services through the app or other channels, like social media companies, based on how you use our products and services and other information we hold about you. We do this so we can make sure our marketing is useful. We do not share any identifying information with social media companies other than your mobile advertising ID
   2. We track, analyse, and improve the services we give you and other customers and how you respond to ads we show. We may ask for feedback if you have shown interest in a service. We do this so that we can make our products better and understand how to market them
   3. We will develop new products and services designed to benefit you, based on data obtained via the application process and app
2. Special features:
   1. We will continue to build special features which will give you a unique user experience. We will use your transactional date for these features
3. Security and business management:
   1. Protect the rights, property or safety of us, our customers, or others
   2. Carry out security and maintenance checks to make sure the The Tenn app, website and other services run smoothly for you
   3. Share information with fraud prevention agencies so we can benefit from up-to-date information when we make decisions about accounts. This helps us fight financial crime
   4. Share your name, title and account number with other banks and financial institutions so that people making payments to you can confirm the name they have for you matches the name we hold in our records. This helps us fight financial crime
4. Companies that give services to us:
   We share your information with companies so that they can help us provide our services

Consent

We will ask for your consent to:

1. Tell you about our products and services, and those of our partners by email or push notification if we think they are of interest to you. You can unsubscribe from these by email or via the app
2. Help protect you against fraud by tracking the location of your phone if you have authorised it
3. Show your profile picture in the app if you add one
4. Show your profile picture and name to contacts in their app, provided they have stored your phone number. If you pay someone, they will see your name regardless of whether you have given permission. It is our legal duty to show this, so it is not something you can opt out of
5. Share information about you with companies we work with when we need your permission

You do not have to share information about yourself if you do not want to. But if you do not, you may not be able to use some (or any) of our Services.

Who we may share your information with:

1. Companies that give services to us

Here we mean companies that help us provide services you use and need to process details about you for this reason. We share as little information as we can and encrypt and/or make it impossible for you to be identified by the recipient where possible (for instance by using a User ID rather than your name).

We share your personal data with third parties that help us provide services you use or to comply with applicable laws. We will never sell your personal data to other organisations We may share your data with:

1. Our parent company or subsidiaries
2. Business partners that provide services to us, including IT and payment services
3. Know Your Customer (KYC) service providers that help us with identity verification or fraud checks
4. Cloud computing services and storage providers
5. Our business intelligence and analytics partners
6. Companies that help us with functional analytics (to help us solve technical issues with the app for instance)
7. Software companies that we use for emailing you, or for processing and storing email communications with you
8. Companies that help us with customer support
9. Companies that offer benefits or rewards through special programmes you sign up to via the app
10. Legal or regulatory authorities where we have a legal obligation to do so or to prevent fraud

We will use this information to:

1. Verify your identity and make sure what you have told us is true
2. Help detect and prevent fraud, crime, and money laundering
3. Manage your account with us
4. Make sure our offers are relevant for you
2. Anyone you give us permission to share it with.
   1. We tell you in the app when we need your consent to share your data with other applications
3. Law enforcement and other external parties
   1. We may share your details with authorities that spot and stop financial crime, money laundering, terrorism, and tax evasion if the law says we have to, or if it is necessary for other reasons
   2. The police, courts, or dispute resolution bodies if we have to
   3. Other banks to help trace money if you are a victim of fraud or other crimes or if there is a dispute about a payment
   4. Any other third parties where necessary to meet our legal obligations
4. Corporate Finance events.
   1. We may also share your details with people or companies if there is a corporate restructure, merger, acquisition or takeover

Retention of data

We keep most of your data as long as you are using your account, and for 7 years after that to comply with the law and if we face a legal challenge. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to (that is in our legitimate interest) and/or the law says we have to.

Your rights

You have the right to:

1. Access the personal data we hold about you, or to get a copy of it
2. Make us correct inaccurate or out of date personal information
3. Ask us to delete your data unless we have a legal obligation to retain it
4. Withdraw any consent you have given us or object to processing of your personal information
5. Ask a member of staff to review a computer-made (automated) decision
6. Contact us at [email protected]

Where we store or send your data

Ask us to delete your data unless we have a legal obligation to retain it. To provide our services to you we may process, transfer and store the data we collect from you to other financial organisations. When we do this, we make sure that your data is protected and that appropriate security measures are in place.

How we keep your data secure

Your data is stored on secure servers. We maintain reasonable security measures to safeguard your personal data from loss, interference, misuse, unauthorised access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and it is accurate, complete, and up to date.

How long we retain your data

Unless data is deleted in order to comply with law or regulation, or in order to comply with a legal request for data deletion from you, we will store all data indefinitely, in order to have as much data as possible to design new products and services for you.

How to make a complaint

If you have a complaint about how we use your personal information, please contact us through the Hubpay app or email us at [email protected] and we will do our best to fix the problem.