Privacy Policy

Updated On Wed, Jan 29, 2025

1. Introduction

Tenet Global Ltd, Tenet Bank Ltd (“Tenet” or “we” or “us”) and its affiliates understand that your privacy is important to you. We are committed to protecting the privacy, confidentiality and security of the personal data we collect and hold, including all pages within this website (collectively referred to herein below as this “Website”), by complying with applicable laws and regulations, including the Cayman Islands Data Protection Act (as amended) (“DPA”). This Privacy Policy covers how we collect, handle, use, disclose, transfer, store, and protect your personal information. For more information about the general terms and use of this Website, click here.

We will collect, store or use personal data for a variety of purposes, where we have a lawful basis for doing so. Here are some of the ways in which we collect data:

When you visit our Website
When you register your email address on the Website
When you submit a query or request to us
When you respond to a survey that we run or fill in forms on one of our websites
When tracking your use of our websites and mobile applications
From third parties who are entitled to disclose that information to us
When you apply for a job with us.

In some cases, we may be required by law to collect certain types of personal data about you.

Where we collect personal data from you, we will generally do so ourselves. However, in some cases we may collect personal data from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.

2. Information We Collect

The kinds of personal data that we collect and hold about you may include:

Identifying information, such as your name and email address
Contact information, such as email address and telephone number
Social media handles and other social media profile information that you make available to us or to the public blockchain identifiers, such as blockchain addresses and public keys
Details of any products or services that we provide to you
Information about how you use the products and services we provide
Records of our communications with you, including any messages you send us

Without this information, we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

3. Use of Information

The personal data we collect may be used for the operation of the Website or to provide certain products or services to you. We will only use personal data for purposes permitted by applicable law. The use of your personal data may include:

To verify your identity when you are dealing with us
To determine your eligibility for any of our products or services
To comply with requests from law enforcement authorities or other government officials
To improve our website based on your information and feedback
To answer your queries and requests
To carry out market analysis and research
To monitor use of our products and services
To assess, maintain, upgrade and improve our products and services
To carry out education and training programmes for our staff
To carry out planning and forecasting activities and other internal business processes
To keep you informed about our activities, including by sending out newsletters

Furthermore, we may disclose information about you, in certain circumstances. This may include:

When we believe it is necessary to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity
To enforce our Terms of Use
To protect our property, services and legal rights
To comply with any and all applicable laws
To manage and resolve any legal or commercial complaints or issues

We may also use and disclose your information for other purposes in accordance with your requests or instructions.

We may from time to time use your personal data in order to send you marketing materials about our products or services that we think you may be interested in (including in some cases products and services that are provided by a third party).

We may use your following personal data for the purpose of direct marketing:

Identifying information, such as your name and date of birth
Contact information, such as your email address and telephone number
Products and services portfolio information and demographic data held by us from time to time.

You can opt-out of direct marketing by contacting us at info@tenet.ky.

4. Transfer of Information

We may share personal data about you with:

Your representatives, advisers and others you have authorised to interact with us on your behalf
Our staff who need the information to discharge their duties
Related entities within our corporate group
Our business partners, agents and service providers with a need to know in order to discharge their duties to us
Professional advisers who we engage to provide advice on our business
Government and regulatory authorities who require us to disclose that information, or to other people as required by law.

In some cases, the people to whom we transfer your personal information may be located overseas, including but not limited to countries which do not offer equivalent protection of personal data under the DPA. In such cases, we will process personal information or will ensure that your personal information is processed in accordance with the requirements of the DPA.

5. Security and Storage of Information

We generally store the personal data that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal data in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats that you become aware of.

We also take steps to monitor access to and modification of your information by our staff, and ensure that our staff are aware of and properly trained in their obligations for managing your privacy.

We will store your personal data for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will generally retain your personal data for the period in which we provide you our products or services. Some personal data will be retained after your cease to use products or services. We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.

6. Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use our website.

The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality of our website. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

7. Automated Decision-Making

We will not take decisions producing legal effects concerning you, or otherwise significantly affecting your, based solely on automated processing of your personal data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the applicable requirements under the DPA.

8. Your Rights

You (and any persons whose personal data is provided) have certain rights regarding how we use your personal data, which include the right to:

Be informed about the purposes for which your personal data are processed
Access to your personal data
Stop direct marketing
Restrict the processing of your personal data
Have incomplete or inaccurate personal data corrected
Ask us to stop processing your personal data
Be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you)
Require us to delete your personal data in some limited circumstances.

If you would like to make a request to exercise any of these rights, or to discuss how we process your personal data, please contact us at info@tenet.ky.

We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact us at info@tenet.ky.

By using our Website, providing personal data or using any of our products or services, you agree that: You consent to this privacy policy, as updated from time to time. If you have provided personal data to us relating to any other person, you represent and warrant that you: have a right to provide that information; have shared the information contained in this privacy policy, as updated from time to time, with that person; and each such person has agreed to those terms.

Data protection, privacy and security is of the utmost importance to us. We intend to make changes to this policy from time to time, to take into account changes to our standard practices and procedures, where necessary to comply with applicable laws and regulations. The latest version of this policy will always be available on our website. We reserve the right to make changes to this Privacy Policy from time to time.

9. Contact Us

If you have any questions about our Privacy Policy, please contact us at info@tenet.ky.

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