TNQ
PRIVACY POLICY
At TNQ(“TNQ”, “we”, “our”, or “us”), your privacy is of the utmost importance. Thank you for taking the time to read our privacy policy (the “Privacy Policy”). This Privacy Policy sets out how we collect, use, process, store, share, and disclose your personal information on https://tnqtoken.io (the “Website”) or any other websites, pages, features, or content we own or operate, the TNQ mobile app(s), as well as your use of any TNQ or TNQ API or third-party applications relying on such API, and any related services (collectively, the “Services”).
At TNQ, we highly prioritize protecting your personal information and being transparent about what we do with it. We are committed to using your personal information in accordance with all applicable laws concerning the protection of personal information and ensuring that you understand your data rights and freedoms.
This Privacy Policy describes how TNQ collects and processes your personal data through the TNQ Website and platforms that are referenced in this Privacy Policy. TNQ refers to an ecosystem comprising TNQ Websites (whose domain names include but are not limited to https://tnqtoken.io ), mobile applications, clients, applets, and other applications that are developed to offer TNQ Services, and includes independently-operated platforms, websites and clients within the ecosystem.
TNQ will be considered the "Controllers" of your data. We determine which personal data we need to process and for what purpose and are responsible for the safe storage and handling of this data.
First, we need to define the expression "Personal Data" (PD), and it is important for you to understand it. It generically represents any kind of information about a physical person, whose particularities can lead, directly or indirectly, to their identification. Here you have, by way of example, but not limited to: name and surname, geographical address, any identification number, political orientation, sexual orientation, email address, any location information, and any other online identifier, such as the device used to access the Internet, IP address, or cookie information.
With regard to your agreement on collection and use of personal data, we have taken all the necessary technical measures to provide you with this detailed agreement, so you can have a clear experience from the first to the last interaction with our website or our services.
Visitors and Users agree and accept that the use of our website is not possible without providing personal data.
In your relationship with us through the website, TNQ is the controller for the purposes of the Personal Data Protection laws, including the General Data Protection Regulation (GDPR), the CCPA, the PDPB, and other applicable data protection laws. This Policy does not apply to the websites of other companies or entities that may link to or from our website. You should carefully review the privacy policies of those sites to understand how they treat your personal information.
If you do not agree to this Privacy Policy, please exit and do not access or use our website.
Our data protection policy should be legible and understandable for the general public, as well as for our Users. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, inter alia, the following terms:
The processing of personal data will be in line with these main international legislations:
We are able to provide our services worldwide. For the purpose of avoiding any compliance conflict with any terminology used by any particular legislation, in this document “Users” are the “data subjects” or the “data principals” and TNQ is the “data controller” or “data fiduciary”.
Our Privacy Policy tells you what personal data (PD) and non-personal data (NPD) we may collect from you, how we collect it, how we protect it, how we may share it, how you can access and change it, and how you can limit our sharing of it. Our Privacy Policy also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our website.
You will have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Please take a moment to understand which use case(s) set out in this Privacy Policy apply to you:
You are a “Website Visitor” by definition when you visit our website or any other eventual subdomains associated with our principal domain. As a website visitor, we use your navigation statistical information for our own purposes primarily for improving the use of our website and to provide you with more relevant content.
You become a “User” if you create an account on our website/platform in order to benefit from our services. If you are a User, our primary purpose of using your personal data is for providing the service and the services to you. We retain your personal information for a limited time and for limited purposes such as to make it easier for you to re-join our service in the future or to wish you offers for services that we think you may be interested in.
TNQ has primary responsibility for your personal data, including providing you with data and responding to any requests you may make under data protection laws. You may be asked to provide personal data when you use TNQ Services. TNQ may share your personal data with a third-party company, and if they do so, they will use it consistently with this Privacy Policy.
Personal data is data that identifies an individual or relates to
an identifiable individual. This includes data you provide to us,
data collected about you automatically, and data we obtain from
third-parties.
Information you provide to us: To open an account and access our services,
we will ask you to provide us with some data about yourself. This data
is either required by law (e.g., to verify your identity and comply
with “Know Your Customer” obligations), necessary to provide the requested
services (e.g., you will need to provide your email address to open
your account), or relevant for certain specified purposes, described
in greater detail below. In some cases, if we add services and features,
you may be asked to provide us with additional data.
Failure to provide the required data implies that TNQ will not be able to offer you our services.
We may collect the following types of information from you:
| Category of Personal Data | Types of Personal Data |
|---|---|
| Personal Identification Data | Full name, e-mail address, gender, home address, phone number, date of birth, nationality, signature, utility bills, photographs, and a video recording of yourself. |
| Sensitive and Biometric Personal Data | TNQ may also collect sensitive personal data when permitted by local law or with your consent, such as biometric information, for example, to verify your identity by comparing the facial scan data extracted from your selfie or video with the photo in your government-issued identity document. |
| Government Identifiers | Government-issued identity documents such as passport, national identification number, national identity card details, and driver license number. |
| Institutional Information | Proof of legal formation; personal identification data for all material beneficial owners; personal data about the board of directors and senior persons responsible for the operations of the body corporate. |
| Financial Information | Bank account information, payment card information, source of funding, and source of wealth. |
| Transaction Information | Information about the transactions you make on our services, such as the name of the recipient, your name, and e-mail. |
| Information from Cookies | See our Cookies Policy for more information. |
| Employment Information | Job title, salary, wage rate, and company. |
| Communications | Surveys responses; information contained in the Survey. Communications with us, including call recordings with our customer services team. |
| Contact Information | E-mail address, country, and region. |
To the extent permitted under applicable law, we may collect certain types of information automatically, for example, whenever you interact with us or use the services. This information helps us address customer support issues, improve the performance of our sites and services, maintain and/or improve your user experience, and protect your account from fraud by detecting unauthorized access.
Information collected automatically includes:
| Category of Personal Data | Types of Personal Data |
|---|---|
| Browsing Information | Device ID, browsing information such as name and version, and IP address. |
| Usage Data | Authentication data, security questions,
click-stream data, public social networking posts,
and other data collected via cookies or similar
technologies.
Information about how our Services is performing when you use them, e.g., error messages you receive, and the performance of the site information. |
| Marketing and Research Information | Identifiers – the IP address or other online
identifiers of a person, and e-mail address if used
for direct marketing, and name and address.
Demographic data – e.g., income, family status, age bracket, gender, interests, etc. Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content; information about your mobile device including (where available) type of device, device identification number, and mobile operating system. Analytics and profiles of individuals based on the data collected from them. For more information about this, please see our Cookies Policy . Interests or inferred interests and marketing preferences. |
From time to time, we may obtain information about you from our affiliates or third-party sources as required or permitted by applicable law.
| Category of Personal Data | Types of Personal Data |
|---|---|
| Affiliates | In accordance with applicable law, we may obtain
information about you from the group of companies
related to us by common control or ownership
(“Affiliates”), as a normal part of conducting
business, so that we may offer our Affiliates’
Services to you.
We may obtain information about you, such as Personal Identification Information, Transactional Data, Institutional Information, and Usage Information. You can check how TNQ processes this information in here. |
| Blockchain Data | We may analyze public blockchain data, such as transaction IDs, transaction amounts, wallet address, timestamps, transactions, or events. |
Our primary purpose in collecting personal data is to provide our services in a secure, efficient, and smooth way. We generally use your personal data to deliver, provide, operate, our services, as well as for content and advertising, and for loss prevention and anti-fraud purposes. Below you will find an explanation of how we use your personal data for:
| Why does TNQ process my Personal Data? | Legal Basis for our use of personal information (Malaysia PDPA Act 2010) |
|---|---|
| To Manage Our Contractual Relationship with You
and Create and Maintain Your Account: This includes using your personal data to take and handle orders and process payments. The Category of Personal Data processed includes Personal Identification Data, Institutional Information, Contact Information, and Financial Information. The consequences of not processing your personal data for such purposes are the inability to open an account with us or the termination of your account where one is already open. | Processing is necessary for the performance of a contract of which you are a party. |
| To Maintain Legal and Regulatory Compliance: Most of our core services such as exchange services are subject to strict and specific laws and regulations requiring us to collect, use, and store certain personal data, including Personal Identification identity information and, in some cases, Sensitive Personal Data (including biometrics) (as detailed in Section I). For example, to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations and in particular to comply with Anti-Money Laundering laws and regulations. The Category of Personal Data is Personal Identification Data, Institutional Information, Sensitive and Biometric information, Government Identifiers, Contact Information, and Financial Information. If you do not provide the personal information required by law, you may be unable to open an account, or we may have to close your account which it is already open. | Processing is necessary to comply with our legal obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations. |
| To Communicate with You on Service and
Transaction-Related Matters: We use your personal data to communicate with you in relation to TNQ Services on administrative or account-related information. We will communicate with you to keep you updated about our Services, such as informing you of relevant security issues, updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our services. You may not opt out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes. | Processing is necessary for the performance of a contract to which you are a party. |
| To Provide Customer Services: We process your personal data when you contact us in order to provide support with respect to questions, disputes, complaints, troubleshooting problems, etc. The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Communications, Contact Information, Financial Information, Browsing Information, and Usage Data. Without processing your personal data for this purpose, we cannot respond to your requests. | Processing is necessary for the performance of a
contract to which you are a party.
Processing is necessary for the legitimate interest pursued by us to improve our services and enhance our users’ experience. |
| To Promote the Safety, Security, and Integrity of
Our Platform: We process your personal data in order to enhance security, monitor, and verify identity or service access, combat malware, or security risks and comply with applicable security laws and regulations. We process your personal data to verify accounts and related activity, find and address violations of our Terms and Conditions, investigate suspicious activity, detect, prevent, and combat unlawful behavior, detect fraud, and maintain the integrity of our Services. The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, and Usage Data. Without processing your personal information, we may not be able to ensure the security of our Services. We use your personal data to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of TNQ Services. | Processing is necessary for the performance of a contract to which you are a party. |
| To Promote the Safety, Security, and Integrity of
Our Services: Fraud prevention and detection, and credit risks. The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, and Usage Data. We process Personal Identification Data to prevent and detect, prevent and mitigate fraud and abuse of our services, and in order to protect you against account compromise or funds loss and in order to ensure the security of our users, TNQ Services, and others. We may also use scoring methods to assess and manage credit risks. | Processing is necessary for the legitimate interests pursued by us and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others. |
| To Provide TNQ Services: We process your personal data to provide services to you and process your orders. For example, when you want to use the exchange service on our platform, we ask for certain information such as your identification, contact information, and payment information. The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, and Usage Data. We cannot provide you with services without such information. | Processing is necessary for the performance of a contract to which you are a party. |
| To Improve Our Services: We process personal data to improve our services and for you to have a better user experience. The Category of Personal Data processed includes Personal Identification Data, Institutional Information, Transactional Information, Browsing Information, and Usage Data. | Processing is necessary for the legitimate interest pursued by us to improve our services and enhance our user experience. |
| To Provide You with Promotions: We use your information to provide you with promotions, including offers, rewards, and other incentives for using our services. The Category of Personal Data processed includes Personal Identification Data, Institutional Information, Transactional Information, Browsing Information, and Usage Data. | Processing is necessary for the purpose of our legitimate interest and your interest in rewarding your customer loyalty. |
| To Conduct Research and Innovate: We carry out surveys to learn more about your experience with our services. We also use your information to support research and development and drive innovations in our services and products. This information will also be used for Marketing purposes. | Processing is necessary for the purpose of our legitimate interest to improve and run our services through information obtained from these surveys. |
| For Recommendations and Personalization: We use your personal information to recommend features and services that might interest you, identify your preferences, and personalize your experience with TNQ Services. |
Processing is necessary for the purpose of our
legitimate interest and your interest in rewarding
your customer loyalty.
Processing is necessary for the performance of a contract to which you are a party. |
| To Provide Marketing Communications to You: We use your information based on your consent, to send you targeted marketing communications through e-mail, mobile, in-app, and push notifications. We also use your information to carry out profiling for marketing purposes. The Category of Personal Data processed is Personal Identification Data, Institutional Information, Transactional Information, Browsing Information, Usage Data, Marketing and Research Information, and Communications. |
Where required by applicable law, we rely on your
consent to process your personal information for
marketing purposes. When you consent to processing
your personal information for a specified purpose,
you may withdraw your consent at any time, and we
will stop processing your personal information for
that purpose. The withdrawal of consent does not
affect the lawfulness of processing based on consent
before its withdrawal.
Where we carry out profiling for marketing purposes, for example, to establish what Services or promotions you may be interested in, this processing is based on legitimate interest. |
For Events Purpose:
|
|
| For Cookies Purpose: Where we use cookies and similar technologies as part of our Service. The Category of Personal Data processed is Information from Cookies. |
Where required by applicable law, we rely on your
consent to place cookies and similar technologies.
When you consent to processing your personal
information for a specified purpose, you may
withdraw your consent at any time and we will stop
processing your personal information for that
purpose.
The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. |
| To Comply with Other Legal and Regulatory
Obligations: We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, government, and other legal requests, court orders, or disclosure to tax authorities. The Category of Personal Data processed is Personal Identification Data, Institutional Information, Financial Information, Transactional Information, Browsing Information, Usage Data, and Blockchain Data. |
Processing is necessary to comply with our legal
obligations under applicable laws and regulations.
We may also rely on legitimate interests in responding to legal requests where we are not compelled by applicable law but have a good faith belief it is required by law in the relevant jurisdiction. |
Automated individual decision-making, including profiling. TNQ does not rely solely on automated tools to determine whether a transaction or a customer account presents a fraud or legal risk.
TNQ does not allow anyone under the age of 18 to use TNQ Services and does not knowingly collect personal information from children under 18.
We use cookies and similar tools to enhance your user experience, provide our services, enhance our marketing efforts, and understand how customers use our services, so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will inform you how to accept or refuse cookies. A copy of our Cookies Policy is available here.
We may share your personal data with third-parties if we believe
that sharing your Personal Data is in accordance with, or
required by, any contractual relationship with you or us,
applicable law, regulation, or legal process. When sharing your
personal data, we will use our best endeavors to ensure that
such entities are either subject to this Privacy Policy or
follow practices at least as protective as those described in
this Privacy Policy. For more information, please refer to
Section 1.
We may also share personal data with the following persons or in
the following circumstances:
Personal data that we process and collect may be transferred between TNQ companies as a normal part of conducting business and offering our Services to you. Refer to Section 1 (Relationship with TNQ) and Section 2 (What Personal Data Does TNQ Collect and Process?).
We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. These third-party service providers only have access to personal information needed to perform their functions and may not use it for other purposes. Furthermore, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.
We may be required by law or by the Court to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to legal authorities to the extent we are obliged to do so according to the law. We may also need to share your information in order to enforce or apply our legal rights or to prevent fraud.
We release accounts and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of TNQ, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
To facilitate our global operations, TNQ may transfer your
personal information outside Labuan, Malaysia. Transfers outside
Labuan are sometimes referred to as “third-country transfers”.
We may transfer your personal information to our Affiliates, third-party
partners, and service providers based throughout the world. In cases
where we intend to transfer personal information to third-countries
or international organizations outside Labuan, TNQ puts in place
suitable technical, organizational, and contractual safeguards, to
ensure that such transfer is carried out in compliance with applicable
data protection rules.
We also rely on decisions from the Labuan Financial Services Authority
(LFSA) where they recognize that certain countries and territories
outside of Labuan ensure an adequate level of protection for personal
information. These decisions are referred to as “adequacy decisions”.
We design our systems with your security and privacy in mind. We
have appropriate security measures in place to prevent your
information from being accidentally lost, used or accessed in an
unauthorized way, altered, or disclosed. We work to protect the
security of your personal data during transmission and while
stored by using encryption protocols and software. We maintain
physical, electronic and procedural safeguards in connection
with the collection, storage and disclosure of your personal
data. In addition, we limit access to your personal data to
those employees, agents, contractors, and other third-parties
who have a business need to know.
Our security procedures mean that we may ask you to verify your identity
to protect you against unauthorized access to your account. We recommend
using a unique password for your TNQ account that is not utilized
for other online accounts and to sign off when you finish using a
shared computer.
In order for us to provide you with the best user experience, we may share your personal data with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising. You have the right to object at any time to the processing of your personal data for direct marketing purposes (Refer to Section 10 below).
Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your personal data. You have the right to request access to, correct, delete your personal data, and ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. In addition, when you consent to our processing of your personal data for a specified purpose, you may withdraw your consent at any time. If you want to exercise any of your rights please contact us using the webform available here. These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data:
You have the right to obtain confirmation that your personal data is processed and to obtain a copy of it, as well as certain information related to its processing.
You can request the rectification of your personal data that is inaccurate, and also add to it. You can also change your personal information in your account at any time.
In some cases, you can have your personal data deleted.
You can object to the processing of your personal data for reasons relating to your situation. For instance, you have the right to object where we rely on legitimate interest or where we process your data for direct marketing purposes.
In certain cases, you have the right to temporarily restrict our processing of your personal data, provided there are valid grounds for doing so. We may continue to process your personal data if it is necessary for the defence of legal claims, or any other exceptions permitted by applicable law.
In some cases, you can ask to receive your personal data that you have provided to us in a structured, commonly used, and machine-readable format, or, when possible, have us communicate your personal data on your behalf directly to another data controller.
For processing that requires your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter.
We hope that we can satisfy any queries you may have about how we process your personal data. However, if you have unresolved concerns, you also have the right to complain to the data protection authority in the location in which you live, work or believe a data protection breach has occurred.
If you have any questions or objections regarding how we collect and process your personal data, please contact us via email at [email protected].
We keep your personal data to enable your continued use of TNQ Token Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Policy, and as may be required by law, such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or to resolve disputes and/or legal claims, or as otherwise communicated to you.
While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal data are described below.
Personal Identifiable Data collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws.
Contact Information such as your name, email address and telephone number, for marketing purposes is retained on an ongoing basis and until you:
Thereafter, we will add your details to an unsubscribed list to ensure we do not inadvertently market to you.
Content that you post on our website, such as support desk comments, photographs, videos, and other content, may be kept after you close your account for audit and crime prevention purposes.
Recordings of voice calls with you may be kept for a period of up to six (6) years, for audit/compliance purposes and to resolve disputes and/or legal claims.
Information collected via cookies, web page counters, and other analytics tools is kept for a period of up to one year from the date of collection of the relevant cookie.
We can be contacted using the webform available here, or via email at [email protected], and will work to address any questions or issues that you have with respect to the collection and processing of your personal data.
If you have any concerns about privacy at TNQ, please contact us, and we will try to resolve them. You also have the right to contact your local Data Protection Authority.
Our business changes regularly, and our Privacy Policy may change. You should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.