Privacy Policy

1. Introduction

TITAN MANAGER, S.L. (hereinafter, “TM” or “we“) grants Users access to an online platform known as the “TITAN MANAGER Platform,” which provides a variety of data and information related to the User’s investment portfolio (the “Platform“). Users may access the Platform through the website titanmanager.io (and all other TM-related websites) (collectively, the “Site“) and, coming soon, through a mobile application (the “Application“).

This Privacy Policy (the “Policy“) sets out TM’s privacy policy in relation to the Services. TM respects the privacy of its Users, and to that end we have created this Policy in which we explain, among other things, what personal data we process, how we collect it, and what processing we carry out when we provide the Services to you (the “Personal Data“).

2. Data Controller

TITAN MANAGER, S.L., with Tax ID No.: B-70809942, with registered office at Calle Doctor Klein, 94, P-1, Puerta-2, 08440 Cardedeu, Barcelona, Spain, is the controller of the personal data of Users collected and processed through the Services.

3. Modification of the Privacy Policy; Notice of Changes

TM may review and modify this Policy when changes occur in applicable legislation or in any of the personal data processing procedures relating to the data you have provided to us. The User acknowledges and agrees that it is their responsibility to periodically review the Site, the Application, and this Policy and to stay informed of any changes.

4. Types of Personal Data Collected

In the context of providing the Services, TM may process the following types of Personal Data:

1. Identification data: First name, last name, and user ID.
2. Contact data: Email address.
3. Data relating to the investment portfolio: type, name, and quantity of assets, dates of purchase and sale transactions, etc.

Additionally, information about your use of the Services may be collected in accordance with the Cookie Policy. For more information about our cookie practices, please visit our Cookie Policy.

Depending on the situation, some of the Personal Data that TM requests from the User is identified as mandatory and other data as voluntary. If the User does not provide the mandatory Personal Data or other required information with respect to a particular activity (for example, subscribing to a Premium Feature or purchasing any paid Service), the User will not be able to access that Service.

5. Source of Personal Data and Legal Basis

The Personal Data we process has been provided to TM by you.

The legal basis for the purposes of processing your Personal Data described in this Policy is the free, specific, informed, and unambiguous consent that you provide to us, and in the case of sending communications, the legal basis is TM’s legitimate interest as established in Article 21.2 of Law 34/2002, of July 11, on Information Society Services and Electronic Commerce.

By accepting the checkboxes provided for this purpose, you grant your express and unambiguous consent to TM for the processing of your personal data for the purposes and with the characteristics detailed in this Policy.

We also inform you that, on the legal basis of the consent you provide to us, some of your Personal Data may be shared with our Affiliates and business partners. In this regard, our Affiliates and business partners will act as data controllers in relation to the Personal Data provided by TM under the terms indicated above.

6. Purposes and Legal Basis for Processing the User’s Personal Data

Personal Data	Purpose	Legal Basis
Identification, contact, and financial data	To provide and manage the Services.	Consent
Identification and contact data	To respond to your requests, questions, comments, and concerns.	Consent
	To evaluate and improve the Services, as well as our other products and services, and to develop new products, services, features, and benefits.	Consent
	To engage in advertising and provide you with special offers and other information about the Services, as well as other TM products, events, and services that may be of interest to you. In all cases, these communications will provide the User with the ability to object to the processing of their data for this purpose through a simple and free procedure.	Legitimate Interest, based on Article 21.2 of the LSSI
	To engage in advertising and provide you with special offers and other information about the services of our Affiliates and business partners. In all cases, these communications will provide the User with the ability to object to the processing of their data for this purpose through a simple and free procedure.	Consent
	To provide referral bonuses for referring new Users to the Services.	Consent
	For our business and commercial purposes.	Consent
Identification data	To create User profiles in order to offer you services or communications tailored to your interests and needs.	Consent

7. Data Processors and Recipients of the User’s Personal Data

7.1 TM may share and disclose Personal Data with third parties, including the following:

• Our Service Providers. We may engage third parties to provide certain parts of the Services (e.g., hosting, data analytics, payment processing, order fulfillment, infrastructure provisioning, IT services, customer service, email delivery services, credit card processing, etc.), who will act as data processors. Personal Data will be made available to such data processors under a service agreement and a data processing agreement, with the obligation to follow the processing instructions provided by TM, to maintain confidentiality, and to return and/or destroy the Personal Data upon completion of the service, with the processing of Personal Data for the data processors’ own purposes being prohibited. Our data processors have privacy and security practices in place to ensure compliance with applicable data protection regulations. In particular, your Personal Data will be made available to the Vumi platform (www.vumi.io), which is responsible for providing us with the interconnection service between your banking institution and our Platform.

7.2 TM, on the legal basis of the consent that we will request from you where applicable, may disclose your Personal Data to the following third parties:

• Affiliates and business partners. We may share your Personal Data with our Affiliates and business partners, who will use such information in accordance with their own privacy policies.

8. Retention Periods

Personal Data will be retained for as long as necessary to fulfill the purpose for which it was collected, for as long as Users as data subjects do not request its deletion, and during the applicable limitation periods for claims regarding possible liabilities and compliance with TM’s legal obligations.

9. User Rights

Users may exercise their rights of access, rectification, erasure, restriction of processing, objection, portability, and, where applicable, revocation of consent granted for processing at any time, without this affecting the lawfulness of processing based on consent prior to its withdrawal, by sending a written request to TM along with a copy of their national ID to the following address: help@titanmanager.io.

10. Information Security

TM has implemented the necessary technical and organizational security measures in accordance with the state of technology to ensure the security of Personal Data, in line with security levels appropriate to the data provided, and all means and technical measures within our reach have been put in place to prevent the loss, misuse, alteration, and unauthorized access to the data provided to us by Users.

TM is committed to complying with the duty of secrecy and confidentiality with respect to Personal Data in accordance with applicable legislation.

11. Miscellaneous

11.1 Age Policy. The User must be at least 18 years of age to use any of the Services. Accordingly, access to the Services by persons under 18 years of age is prohibited.

11.2 Terms and Conditions. Use of the Services is also subject to our Terms and Conditions.

12. Data Transfers Outside the European Economic Area

Whenever we transfer Personal Data to countries located outside the European Economic Area (EEA), or to countries or territories that have not been declared to have an adequate level of protection by the European Commission, or where adequate guarantees for the protection of personal data are not provided, we will obtain your consent before carrying out such data transfer.

13. Profiling

Whenever you give us your consent, TM may identify usage trends and analyze your data for the purpose of building commercial profiles that allow us to personalize your interactions with us, better understand you, and offer you services or communications tailored to your interests and needs.