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 range of data and information related to the User’s investment portfolio (the “Platform”). Users may access the Platform via the website titanmanager.io (and all other websites related to TM) (collectively, the “Site”) and, soon, through a mobile application (the “Application”).
This Privacy Policy (the “Policy”) sets forth TM’s privacy practices in connection with the Services. TM respects the privacy of its Users, and for this reason we have created this Policy to explain, among other things, what personal data we process, how we collect it, and how we handle it when providing you with the Services (the “Personal Data”).

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

3. Changes to the Privacy Policy; Notice of Changes
TM may revise and update this Policy when there are changes to applicable legislation or in any of the procedures related to the processing of personal 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 stay informed about any modifications.

4. Types of Personal Data Collected
In the course of providing the Services, TM may process the following types of Personal Data:

• Identifying data: Name, surname, and user ID.

• Contact data: Email address.

• Data related to the investment portfolio: type, name, and quantity of assets, purchase and sale transaction dates, etc.

We may also collect information about your use of the Services in accordance with our Cookie Policy. For more information, please visit our Cookie Policy.

Depending on the case, some of the Personal Data requested by TM is marked as mandatory and others as optional. If the User does not provide the required Personal Data or other mandatory information for a given activity (e.g., subscribing to a Premium Feature or purchasing a 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 directly by you to TM.
The legal basis for processing your Personal Data, as described in this Policy, is your free, specific, informed, and unequivocal consent. In the case of sending communications, the legal basis is TM’s legitimate interest pursuant to Article 21.2 of Law 34/2002, of July 11, on Information Society Services and Electronic Commerce.
By accepting the relevant checkboxes, you give your express and unequivocal consent to TM for the processing of your Personal Data for the purposes and under the terms detailed in this Policy.

Furthermore, we inform you that, based on the consent you grant us, some of your Personal Data may be shared with our Affiliates and business partners. These parties will act as data controllers for the Personal Data provided by TM under the terms outlined above.

Personal Data	Purpose	Legal Basis
Identifying, contact, and financial data	To provide and manage the Services	Consent
Identifying and contact data	To respond to your requests, inquiries, comments, and concerns	Consent
Identifying and contact data	To assess and improve the Services, as well as our other products and services, and to develop new ones	Consent
Identifying and contact data	To carry out advertising and provide you with special offers and other information about TM’s Services and other products, events, and services of potential interest. In any case, Users will be given the opportunity to object to this processing via a simple and free procedure.	Legitimate interest (Article 21.2 LSSI)
Identifying and contact data	To carry out advertising and provide you with special offers and information from our Affiliates and business partners. Again, you will have the opportunity to object via a simple and free procedure.	Consent
Identifying and contact data	To provide referral rewards for introducing new Users to the Services	Consent
Identifying and contact data	For our business and commercial purposes	Consent
Identifying data	To create User profiles in order to offer you services or communications tailored to your interests	Consent

7. Data Processors and Recipients of User Personal Data
7.1 TM may share and disclose Personal Data with third parties, including:

• Our Service Providers. We may engage third parties to provide certain parts of the Services (e.g., hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer support, email delivery, credit card processing, etc.). These parties will act as data processors. Personal Data will be made available to them under a service agreement and a data processing agreement, which requires them to follow TM’s processing instructions, maintain confidentiality, return and/or delete the Personal Data upon completion of the service, and prohibits them from processing the Personal Data for their own purposes. These processors follow privacy and security practices that comply with applicable data protection laws. In particular, your Personal Data will be shared with the Vumi platform (www.vumi.io), which provides interconnection services between your bank and our Platform.

7.2 Based on the consent you provide, TM may share your Personal Data with:

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

8. Retention Period
Personal Data will be retained for as long as necessary to fulfill the purpose for which it was collected, unless Users request its deletion, and for the duration of any applicable statute of limitations and legal obligations TM must comply with.

9. User Rights
Users may exercise their rights of access, rectification, erasure, restriction of processing, objection, data portability, and, where applicable, withdrawal of previously granted consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Such requests must be sent to TM along with a copy of your ID card to the following email: help@titanmanager.io.

10. Information Security
TM has adopted the necessary technical and organizational security measures in accordance with the state of the art to ensure the security of Personal Data, according to the appropriate levels of protection required for the data provided. We have also implemented all available technical means to prevent the loss, misuse, alteration, and unauthorized access to the Personal Data provided by Users.
TM is committed to maintaining the confidentiality of Personal Data in accordance with applicable laws.

11. Miscellaneous
11.1 Age Policy. Users must be at least 18 years of age to use any of the Services. Therefore, access to the Services is prohibited for anyone under 18.
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 outside the European Economic Area (EEA) or to territories not declared to have an adequate level of protection by the European Commission and where no adequate data protection safeguards are in place, we will request your consent to carry out such transfers.

13. Profiling
If you provide your consent, TM may analyze your data and usage trends to create business profiles that help us personalize your interactions with us, better understand your needs, and offer services or communications tailored to your interests.