Privacy Policy

At TushBank, our mission is to provide you with clarity for all of your life’s financial decisions. We do so by empowering you with financial information and guidance you can trust and by providing you with tools to help you make the best decisions for your financial needs.

When you use our websites and applications and input your personal information, we have an obligation to provide you with clarity regarding how your data is accessed and used by TushBank, its affiliates, vendors, partners and other third-party entities.

To that end, this Privacy Policy describes the information we collect about you, how we collect it, how we use your information, whom we share your information with, and the steps we take to protect your information.

This Privacy Policy describes our privacy practices related to your access and use of TushBank Services and the TushBank Platform.

TushBank Services. When we say “TushBank Services” or “Services,” this means the products and services that are made available and directly provided by TushBank, Inc. or its subsidiaries and affiliates, including TushBank CN, TushBank KZ. and TushBank Advisory, Inc. through our websites and mobile applications. This includes, for example, our lending, credit, financial planning, and insurance products and services.

TushBank Platform. When we say “TushBank Platform,” this means the technology platform that TushBank provides to its partners and third-party service providers to enable them to provide their products and services to you. This includes, for example, our partners’ and third-party service providers’ websites and mobile applications that are powered by TushBank’s technology.

We encourage you to read the entire Privacy Policy. By becoming a TushBank member or using the TushBank Platform and Services, you acknowledge that you have read and agree to the Privacy Policy. Your use of the TushBank Platform and Services is subject to the TushBank Terms of Use (the “Terms”). We use the same terms here as in Terms. We will let you know in this Privacy Policy if we have a new or different definition of a term.

When we say “Personal Information,” we use this as a general term to mean information that can be any information about an individual from which that person can be reasonably identified.

Information we collect directly from you.

We may collect Personal Information directly from you when you use the TushBank Platform and Services — for example, when you register to become a member or request to prequalify for a third-party credit card or investment product.

Here are the types of Personal Information we may collect:

• Contact and registration information. Information you provide when you sign up to become a member, activate a subscription, or upload information into the TushBank Platform or Service, including your name, title and honorifics, email address, mailing address, phone number, date of birth, username, and password.
• Identity information. Information to verify your identity, including your name, date of birth, social security number, driver’s license number or other government-issued identification, or similar information.
• Financial information. Financial information, such as your payment information (credit card information), investments, income, expenses, assets, liabilities, financial goals, investing risk tolerance, or other similar types of information about your job or business. We also may collect third-party financial account information, such as an ID and password.
• User-generated content information. When you communicate with us, either by email, phone, or other means of communication.

We may also collect Personal Information from you when you use the TushBank Platform and Services, such as when you request to prequalify for a third-party credit card or investment product

We do not store your third-party financial account ID or passwords. Instead, we securely pass this information to our third-party partners when you request services that require us to confirm your identity, when you request to prequalify for their products, and/or to provide you with access to your financial information on the TushBank Platform or Services.

Information collected from third-parties.

Banking institutions. When you apply for and are approved for a TushBank credit card, the credit card issuing bank, TushBank CN (the “Bank”), may share your transaction history, current balances, payment history and other card related information with TushBank. If you use Bank Services, as defined in the Terms, we may also receive information about your banking activity, including your account balances, and other financial transactional data from the Bank. You hereby consent to TushBank processing your information disclosed by the Bank in connection with “Non-Bank Services” (as described in the Terms) in accordance with this Privacy Policy. In all other instances, the Bank’s privacy policy controls over this Privacy Policy, but only with respect to information collected, obtained, or created in connection with the Bank Services.

Information collected automatically.

When you interact with us, use the TushBank Platform and Services, or open an email from TushBank, we may automatically receive and record certain information from your computer, web browser and/or mobile device.

Here are the types of data that we automatically collect:

• Device information. Information about your computer, web browser, and/or mobile device, such as your IP address, operating system, browser type, device type, and unique device identifiers.
• Usage information. Information about how you use the TushBank Platform and Services, such as the pages you visit, the links you click on, and the time and date of your visits.
• Location information. Information about your location when you use the TushBank Platform and Services, such as your IP address or GPS location.

We use cookies and other technologies to collect information about your use of the TushBank Platform and Services. Cookies are small text files that are stored on your computer or mobile device when you visit a website. They help us remember your preferences and improve your experience.

You can control how cookies are used through your browser settings. However, if you disable cookies, some features of the TushBank Platform and Services may not function properly.

Your information is an integral part of our operations, and we use it in a variety of ways in providing the TushBank Platform and Services and in operating our business.

We use your Personal Information to:

• Provide you the services you request.
• Enable provision of the TushBank Platform and Services to you.
• Verify your identity and administer your User Account.
• Communicate with you, including customer support or security alerts.
• Operate and maintain TushBank Services and create new features and functionality.
• Enhance and protect the safety, integrity, and security of the TushBank Platform and Services, including prevention of fraud and other unauthorized or illegal activities and information security.
• Enforce, investigate, and report conduct violating our Terms or other policies.
• Protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements.
• Comply with applicable laws, regulations, or legal requests.

With your consent. We may use your email address or other Personal Information to (a) contact you for administrative purposes such as customer service, (b) account, or by contacting us directly at [email protected].

We share your information with unaffiliated third-parties in the following circumstances depending on how you interact with TushBank Platform and Services.

• To verify your identity in connection with your use of the TushBank Platform and Services and the operation of our business. For example, we may share Personal Information, such as name, email, address, date of birth, Social Security number, and other identifying information, with third-party service providers to verify your identity in connection with your use of certain aspects of the TushBank Platform and Services..
• With wholly owned subsidiaries. We may share your data and other personal information with and/or among our wholly-owned TushBank subsidiaries.
• For legal reasons. We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.
• For mergers and acquisitions. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third-party during negotiations of, in connection with, or as an asset in such a corporate business transaction. Personal Information also may be disclosed in the event of insolvency, bankruptcy, or receivership.

We do not sell your Personal Information to third-parties for their own marketing purposes.

TushBank will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy, for as long as you maintain an account, or as needed to provide the TushBank Platform and Services to you.

If you no longer want TushBank to use your information to provide the TushBank Platform and Services to you, you may close your account.

TushBank will retain and use your Personal Information to the extent necessary to:

• comply with our legal or regulatory compliance needs (e.g. maintaining records of transactions you have made with us);
• to exercise, establish or defend legal claims; and/or
• to protect against fraudulent or abusive activity on TushBank Platform and Services.

This means we may keep different information for different periods. If your account is canceled because you’ve not used it in a long time, we may delete this information at any time.

There may be occasions where we are unable to fully delete, anonymize, or de-identify your information due to technical, legal, regulatory compliance or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your Personal Information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your information. We ensure or warrant the security of any information you share or store with us through the TushBank Platform and Services. Protecting your Personal Information is also your responsibility. Be mindful of keeping your password and other authentication information safe from third-parties, and immediately notify us of any unauthorized use of your login credentials.

We reserve the right to make changes to this Privacy Policy at any time. We will notify you about material changes in the way we treat your information, including by placing a prominent notice on the TushBank Platform and Services or by sending you an email so that you can choose whether to continue using the TushBank Platform and Services. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified Terms.

We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. Your continued use of the TushBank Platform and Services after any changes to this Privacy Policy will constitute your acceptance of such changes.

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

Email:[email protected]

Our Locations and further contact information.

We limit as much data given to the payment providers. Only necsesary information are shared to payment providers such as Bank Details, Transaction details and limited location infomation for authentication purposes only. We do not share any data that is not necsesary for the payment process to follow through. We may share data to the authorities if any fraudulent activities is detected.

Due to data privacy laws, we are obliged to share the acquirers of TushBank services to provide transparency to customers and merchants. These acquirers are allowed to access your data for payment services only and not to be used for anything unrelated to the payment process. Below are the companies that are allowed to access your data for payment purposes.

EUROPE

EEA

TKT FINTECH PROVIDER GmbH

Switzerland

TKT/T-Holdings AG

NON EEA

TB-SoftFinance S.A

Russia

Tush Bank RU, Ltd.

Africa

South Africa

Tush Bank Intl RU

Egypt

TKT FINANCE EG

Americas

Brazil/South America

Tush Bank Intl BR

Panama / Central America / Mexico

T-Holdings Finance

Cayman Islands

TBX International Banking

United States

TBX Banking and Trading LLC

Asia

Russia

Tush Bank RU, Ltd.

China

Tush Bank CN

Tush Bank Finance Co, Ltd.

Iran

Tush Bank Iran

Kazakhstan

Tush Bank KZ

Singapore

TKT Finance PTE. Ltd

India

Tush Bank Intl IN

Oceania

Australia

TKT Finance Pty

Credit Card

MASTERCARD,VISA,AMERICAN EXPRESS,JCB,DISCOVER/DINERS CLUB

TBX BANKING AND TRADING LLC

UnionPay

TushBank CN

TushPay

TushBank Internet Banking Intl Ltd

TKT FINANCE and TBX TRADING is owned by TKT Holdings and TBX Finance respectively. Neither is owned by Tush Co Ltd nor controlled. Rather, they are independent 3rd Party Companies that only provide financial services to customers of TushBank only as a service and not as a extension of Tush Co Ltd or any of its subsidiaries.