Tessa. Privacy Policy

This Privacy Policy was last updated on 22nd March 2022.

Nothing is more important to us than the trust of our users.

This privacy policy (“Privacy Policy”) describes how, Tessa. (“TESSA,”
“we,” “us,” and “our”), collect, use and disclose any personal information
provided to us through our website, mobile application, and other online
services (collectively, the “Services”) and when you otherwise interact
with us, such as through our customer service channels. A “user” or “you”
refers to anyone who accesses, browses, or in any way uses the Services.
By using the Services, you acknowledge and consent to our practices
described below. Your use of the Services and this Privacy Policy are
subject to and governed by our TESSA Portal Terms of Service.

We are committed to protecting your privacy and preserving your trust.
Please carefully review this Privacy Policy.

Personal Information We Collect and Process

We collect and determine the purposes and means of the processing of
certain information that may personally identify you (“Personal
Information”) when you use our Services, like when you sign up for an
account, make an investment, or otherwise interact with or communicate
with us. We may also receive, and process Personal Information controlled
and stored by third parties with your consent.

Personal Information we collect includes, among other things, your:

Identity data such as your full name, date of birth, gender, social security
numbers, and other data on government-issued identification documents.

Contact data such as your email address, mailing address, and telephone
numbers.

Financial data such as your bank account information, card payment
details, credit reports and information about your income and net worth
(“Financial Data”).

Profile data such as your username and password, investments made by
you, your investment experience, your educational and/or professional
history, your employment status, your marital status, your investor quiz
results, and your interests, preferences, and feedback.

Usage information such as information about how you access and use our
Services, your actions on the Services, including your interactions with
others on the Services, photos or media you upload to the Services,
comments and posts you make in our public discussion forums, and other
content you may provide.

Technical Data such as IP (internet protocol) address, ISP (internet service
provider), the web browser used to access the Services, the time the
Services were accessed, which web pages were visited, operating system
and platform, a mobile device-type identifier, and other technology on the
devices you use to access our Services (“Technical Data”). We may also
access your photo and cameral roll and Apple Face ID through our mobile
application with your permission.

Additional information such as information that you submit via job
applications, customer support, or other similar means and any other
information you provide to TESSA.

In order to invest using the Services, you will need to register a user
account. When you register a user account, we will collect certain
Financial Data from you. Please note that we do not store Financial Data
such as your bank account information and credit card details, but we do
store other Financial Data, such as net-worth and income representations.
If you choose to add an investment entity to your account, we will also
collect information about that entity, such as the date of formation, tax
identification number and state or country of formation, in addition to the
Personal Information listed above.

The decision to provide Personal Information is optional when using the
Services; however, if you decide not to register an account or provide the
necessary Personal Information or Financial Data to validate your account
or fulfil your obligations when using the Services, you may not be able to
use certain features of our website or the Services, as further explained in
our TESSA Portal Terms of Service.

Even if you do not register a user account, we may collect Technical Data
from you. Technical data may allow us to determine more specific
information about you, such as the operating system of the device used to
access the Services and your approximate location. We also use third-
party analytics services to provide us with a clearer picture of how you
use the Services, such as where you click on our website, non-sensitive
text entered into our website, and mouse movements.

Third-Party Sites

We process Personal Information provided to us from third-party sites
when you register on our website or link your user account to third-party
sites such as Twitter, Facebook, Apple or banking institutions. Examples of
Personal Information a third-party site may control and, with your consent,
share with Tessa include your name, your email address, your phone
number, your mailing address, your government issued identification
document, your tax identification number, and your Financial Data.

This Personal Information is not held on TESSA’s systems but is stored by
and controlled by the third-party site in accordance with the terms and
conditions of their relevant policies. We are not responsible for the
maintenance or security of Personal Information stored and controlled by
any third-party sites. For information on how a third-party site manages
the information your share with that third-party site, please read that
third-party site’s privacy policy and terms of use.

You may be able to revoke our access to your account on the third-party
sites by updating the appropriate settings in the account preferences of
the respective third-party sites. You understand that certain Services may
not be available to you if you choose to remove our access to your
account with the third-party sites.

Cookies and Other Identifiers

Similar to many digital platforms, we collect certain information through
cookies, web beacons and other identifiers when you use our Services in
order to provide, improve, protect, and promote our Services.

Cookies are small text files containing strings of alphanumeric characters
that may uniquely identify your browser and let us help you log in faster
and enhance your navigation through our website. A cookie may also
convey information to us about how you use the Services (e.g., the pages
you view, the links you click, how frequently you access the Services, and
other actions you take on the Services), allow us to track your usage of
the Services over time, and help us remember information about your
visit. You can set your browser to not accept cookies, but this may limit
your ability to use the Services.

Our website uses the following types of cookies:

• Essential Cookies: These cookies are necessary to provide you with the Services available
  through our website.
• Performance and Functionality Cookies: These cookies are used to enhance the
  performance and functionality of our website.
• Analytics and Customization Cookies: These cookies collect information that is used either
  in aggregate form to help us understand how our website is being used or how effective
  our marketing campaigns are, or customize our website for you.
• Advertising Cookies: These cookies are used to make advertising messages more relevant
  to you. They perform functions like preventing the same ad from continuously reappearing,
  ensuring that ads are properly displayed for advertisers, and in some cases selecting
  advertisements that are based on your interest.
• Social Networking Cookies: These cookies are used to enable you to share pages and
  content that you find interesting on our website through third party social networking and
  other websites. These cookies may also be used for advertising purposes.

This Privacy Policy does not cover the collection of information by cookies
or other methods by third-parties. Please see How to Remove Cookie
Tracking below for details on how to disable cookie tracking.

Other Identifiers

Web beacons or tracking pixels or clear gifs are another tool we employ. A
tracking pixel is a transparent graphic image that is placed on a web page
and, in combination with a cookie, allows us to collect information
regarding the use of the web page that contains the tracking pixel. We
use tracking pixels to trigger ads on participating websites based on
activity tracked from the browser on a device used to visit our website.
We also use them to tell when an advertisement we run on another
website has been clicked on by TESSA visitors and use that information to
judge which advertisements are more appealing to users.

Tracking pixels can also be used for third party web analytics and are
used in HTML-based emails we send you to track which emails are opened
and which links you click. The information collected from web beacons
allows for more accurate reporting and improvement of the Services.

Although we do our best to honor your privacy preferences, we are not
able to respond to “Do Not Track” signals from your browser or device at
this time.

Information Provided in Public Forums

Some of the investment opportunities and related pages presented
through the Services include publicly accessible discussion forums and
other pages on our website or mobile application allow for public
comment and discussion (collectively, “Public Comment”). You should be
aware that any information you provide in these forums may be read,
collected, and used by the general public. Information that you disclose in
any of these forums is unencrypted, public information, and there is no
expectation of privacy or confidentiality there. Please refrain from
disclosing any Personal Information about yourself or anyone else in these
discussion forums.

If you choose to post a Public Comment, we may use that Public Comment
for marketing purposes, including through our social media. If you
subsequently delete or make your Public Comment private, we will
discontinue any subsequent use, but cannot retract previous re-
publications of your previously posted Public Comment.
If you choose to make an investment public, a notice will be generated
including certain details about that investment (a “Public Investment
Notice”). We may use that Public Investment Notice for marketing
purposes, including through our social media. If you subsequently make
your Public Investment Notice private, or withdraw such investment, we
will discontinue any subsequent use, but cannot retract previous re-
publications of your previously posted Public Investment Notice.

How We Share and Use Your Personal Information

We may share Personal Information you provide to us with our affiliated
entities (“Affiliated Entities”). If the Services you use are exclusively
provided by one of our Affiliated Entities, you have the right to limit the
other Affiliated Entities from contacting you for marketing purposes
(“Affiliate Marketing”). Examples of Personal Information that we may
share for Affiliate Marketing include your name, email address, phone
number, net worth and income.

We provide Personal Information on a confidential basis to non-affiliated
companies we engage as vendors or agents (“Third Party Providers”) and
where we have a legal basis for sharing your Personal Information
including (i) to facilitate the Services, such as with the companies we host,
escrow agents, transfer agents, counsel, advisors, accountants, banks and
other financial service providers, and (ii) to service our operations, such as
maintaining software or servers, designing or implementing marketing
initiatives on our behalf, or conducting audit or testing of any aspect of
our operation or Services. Personal Information will be shared with such
Third Party Providers only to the extent reasonably necessary for them to
perform services for us or on our behalf and pursuant to confidentiality
obligations, or in response to information requests, subpoenas, court
orders, or legal process, from law enforcement agencies, self-regulatory
organizations, state, federal and foreign regulators.

In addition to some of the specific uses of Personal Information we
describe in this Privacy Policy, we collect and process Personal Information
in order to: (i) deliver and improve our Services; (ii) manage user accounts
and provide customer support; (iii) perform research and analysis about
the use of the Services; (iv) develop, display, and track content and
advertising tailored to your interests on the Services and other websites,
including providing our advertisements to you when you visit other
websites or mobile applications; (v) diagnose or fix technology problems;
(vi) automatically update the Services; (vii) verify your identify and
prevent fraud or other unauthorized or illegal activity; (viii) enforce or
exercise any rights in our TESSA Portal Terms of Service ; (ix) provide
users with statistics on how they use the Services relative to other
anonymous users; (x) comply with applicable laws and legal obligations;
and (xi) perform functions or services as otherwise described to you at the
time of collection.

If you choose to make an account, we provide private messaging services
between registered-users of our website and mobile application; while we
do not monitor these messages, we will periodically select a few to review
for compliance and audit purposes; therefore, you should assume any
message you send through our website or mobile application may later be
accessed by our staff or our regulators for compliance or audit purposes.

Note that in the ordinary course of internet activity, certain information
may be sent from your browser to third parties such as advertising
networks and analytics companies. TESSA has no control over the
information sent from your browser to those networks or other third
parties and recommends that you ensure that your browser settings
prevent the disclosure of information you would not like to share.

For further information on our opt-out policies, please see Your Choices
About Your Personal Information below.

How We Transfer Your Personal Information

The Services are maintained in the United States of America. Personal
Information that you provide us may be stored, processed and accessed
by us, our staff, sub-contractors and third parties with whom we share
Personal Information in the United States of America. We may also store
Personal Information in locations outside the direct control of TESSA (for
instance, on servers or databases co-located with hosting providers).

Although we welcome users from all over the world, by accessing the
Services and providing us with your Personal Information, you consent to
and authorize the export of Personal Information to the United States and
its storage and use as specified in this Privacy Policy. Note the laws of the
United States might not be as comprehensive or protective as laws in the
country where you live.

Changes of Control

In the event a TESSA entity merges with another entity, is sold, or
transfers its assets, we may disclose or transfer your Personal Information
in connection with the negotiation and/or conclusion of such transaction.

Security and Storage of Your Personal Information

We follow industry privacy and data security standards as required under
applicable data security rules and regulations (“Data Protection Laws”) to
protect Personal Information submitted to us, both during transmission
and once we receive it. When you provide us with Personal Information
(such as Financial Data), we encrypt the transmission of that information
using secure socket layer technology (SSL). We routinely review our
security procedures to consider appropriate new technology and methods.
Please be aware, however, that no method of transmission over the
Internet, or method of electronic storage, is free of risk. Therefore, we
cannot guarantee that your Personal Information will not be accessed,
disclosed, altered, or destroyed by breach of any of our physical,
technical, or managerial safeguards. We disclaim all responsibility and
liability for unauthorized access to our servers and systems.

We will retain your Personal Information for as long as your account is
active or is needed to provide you the Services and may retain your
Personal Information after you discontinue use of the Services provided
there is a legal basis to do so. We will retain and use your Personal
Information as necessary to comply with our legal obligations, including to
meet our regulatory obligations, to resolve disputes, and to enforce our
agreements.

Your Choices About Your Personal Information

Registering a user account with TESSA is voluntary and you do not need to
create an account to use some of the Services. If you decline to submit
Personal Information, TESSA may not be able to provide certain Services
to you. If you elect to register an account with us, you may update or
correct your account information and email preferences at any time by
logging into your account. If you would like us to remove or amend your
Personal Information from our database, please send a request
to privacy@tessa.finance; please note, as many of the Services we
provide are regulated, we will not be able to remove Personal Information
we are required to retain for audit purposes or where a legal basis exists
for retaining your Personal Information.

When you sign up for our Services, we will send periodic emails to you
regarding the Services or to tell you about new services we believe will be
of interest to you. You may also subscribe to our blog and newsletter or
sign up to hear about investing opportunities without registering a user
account. You may choose to stop receiving our marketing emails by
following the unsubscribe instructions included in these emails. If you do
not wish to receive Affiliate Marketing, or any marketing, in general, you
may always opt out by accessing your notification settings. You can also
opt out of promotional email communications at any time by clicking on
the unsubscribe link in any email you receive from us, or you can contact
us at privacy@tessa.finance

User Access Rights

Under certain Data Protection Laws, you may have the right to request
access to your Personal Information where your Personal Information is
controlled by TESSA. Such rights may include:

• The right to request that your Personal Information be corrected.
• The right to request that your Personal Information be deleted from TESSA’s systems. This
  process is also referred to as the ‘right to be forgotten’. TESSA will comply with this request
  except where TESSA is required by law or regulation to keep your Personal Information. In
  such circumstances TESSA will advise you as to this legal or regulatory obligation.
• Where TESSA relies on your consent to process your Personal Information controlled by
  TESSA, you may have the right to withdraw such consent to further use your Personal
  Information.
• In certain circumstances, you may have the right to object to TESSA processing your
  Personal Information. For example, you may unsubscribe from marketing messages or
  blogs to which you consented and subscribed by following the unsubscribe link or
  instructions contained in such message or blogs.
• In certain circumstances, you may have the right to request that TESSA transfer Personal
  Information that you have provided to us to a third-party.
• The right to file a complaint with the local data protection regulator if you believe that
  TESSA has breached Data Protection Laws when using your Personal Information.
• The right to request access to Personal Information collected and controlled by TESSA by
  sending an email to: privacy@tessa.finance.

Special Notice Regarding Minors

TESSA respects the privacy of children of all ages and in particular
recognizes the sensitivity of Personal Information concerning children
under the age of 18 (“Minors”) and therefore provides this special notice
to parents and legal guardians regarding the collection and use of
Personal Information collected from Minors. The Services are not directed
toward Minors. If you are under the age of 18, you may not use or access
the Services. If we discover that a Minor has provided us with Personal
Information, we will use commercially reasonable efforts to delete such
Minor’s Personal Information from our system and close their user
account. In some instances, we may be required to retain a Minor’s
Personal Information in a limited capacity to comply with regulatory
requirements.

How to Remove Cookie Tracking

We use tools, such as Google Analytics, to facilitate the collection of
information. If you wish to disable Google Analytics from all websites you
visit (not limited to our website), you can follow this link. The information
gathered through the tools we employ is used to create reports about the
use of our website and Services.

Please contact us if you wish to opt out of any of the tools we use. Please
note, we reserve the right to add more tools or disable tools and will
update this Privacy Policy to reflect these changes. Your request to disable
such tools or your disabling of tools may limit your ability to access and
utilize the Services.
Most browsers allow you to refuse to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version
to version. You can obtain information about blocking and deleting cookies
on certain web browsers via these links: Chrome, Firefox, Safari,
and Edge.

The Google Privacy Policy and Terms of Service apply when you access
Google’s website.

Changes to Our Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or
remove portions of this Privacy Policy at any time. Any changes or
updates will be effective immediately upon posting to this page. You
should review this Privacy Policy regularly for changes. You can determine
if changes have been made by checking the effective date at the top of
this Privacy Policy. Your continued use of our Services following the
posting of any changes to this Privacy Policy means you consent to such
changes.

How to Contact Us

If you have any questions about our practices or this Privacy Policy, please
contact us at privacy@tessa.finance