Last updated Jan 25, 2024
At TM Payments LLC ("TM Payments," "we," "us," or "our"), we are committed to protecting your privacy and maintaining the security of your personal information. This Privacy Policy explains how we collect, use, share, and protect your information when you use our financial services, website, and applications.This Privacy Policy applies to all services provided by TM Payments, including our cross-border payment solutions, mass payout services, wholesale foreign exchange (FX) services, and USD checking accounts. We understand your trust in us when sharing your personal information and take this responsibility seriously. Our commitment to your privacy extends across all interactions through our website, mobile applications, and other digital platforms.Throughout this policy, we use certain terms that are important to understand. "Personal Information" refers to any information that identifies or can be used to identify you directly or indirectly. When we mention "Services," we refer to all financial and technical services TM Payments provides. "Platform" encompasses our website, mobile applications, and other digital interfaces. "User," "you," or "your" refers to any individual or entity using our Services.We may update this Privacy Policy periodically to reflect changes in our practices, technological advancements, or regulatory requirements. When we make material changes to this policy, we will notify you through our Platform or via email before the changes take effect. Your continued use of our Services after such modifications constitutes your acknowledgment and acceptance of the updated Privacy Policy.
Personal Information
In our financial services, we collect personal information necessary for operations and regulatory compliance. This includes your contact information, such as name, email address, phone number, and physical address. For business clients, we also maintain relevant business contact details. To comply with financial regulations and ensure security, we collect identity verification data, including government-issued identification documents, proof of address, and date of birth.
Financial information is essential to our services, and we collect bank account details, credit/debit card information, and transaction histories as needed to process your payments and maintain our services. We maintain comprehensive records of your transactions, including payment amounts, dates, beneficiary information, and related communications to ensure accuracy and compliance with financial regulations.
Automatically Collected Information
When you interact with our Platform, our systems automatically collect technical data necessary for optimal performance and security. This includes information about your browser, operating system, and IP address. We track how you use our Platform, including pages visited and features used, to improve our services and user experience. Information about your devices to access our services, including device type and settings, helps us ensure compatibility and security. While we may collect location information through IP addresses or mobile device settings, this is primarily for security and regulatory compliance.
Information from Third Parties
We obtain information from trusted third-party sources to enhance our services and maintain regulatory compliance. We work with identity verification services to confirm your identity and comply with Know Your Customer (KYC) requirements. Our partnerships with financial institutions provide the necessary information for processing transactions and verifying account details. We may receive additional data from business partners, including payment processors and technology providers, to facilitate our services effectively. When necessary, we also consult public databases and records for verification purposes.
Core Business Functions
Your information enables us to provide our essential financial services. We use it to execute cross-border payments, mass payouts, and foreign exchange operations. Account management requires regular maintenance and updates, allowing us to process your requests efficiently and provide responsive customer support. We conduct thorough risk assessments by analyzing transaction patterns and account activity to prevent fraud and ensure the security of our services. Our customer support team uses your information to respond to inquiries, resolve issues, and provide technical assistance when needed.
Legal and Regulatory Compliance
As a regulated financial services provider, we have specific obligations regarding information use. We must verify identities and monitor transactions to comply with anti-money laundering (AML) regulations and prevent financial crimes. Regular reporting to financial regulators and government authorities requires careful transaction and account data management. We process information as needed to comply with court orders, subpoenas, and other legal requirements, maintaining detailed records of all compliance activities.
Service Improvement
We share information with trusted third-party service providers essential to our operations. This includes licensed payment processors facilitating secure transactions, identity verification services that help us maintain regulatory compliance, and secure cloud storage providers protecting our data infrastructure. We also work with analytics providers to understand Platform usage and improve our services, ensuring all providers adhere to strict confidentiality and security requirements.
Legal requirements may necessitate sharing information with law enforcement agencies, financial regulators, and other authorities. We comply with valid court orders, subpoenas, and other legal processes while maintaining appropriate protections for your privacy. In the event of corporate changes such as mergers, acquisitions, or restructuring, your information may be transferred as part of the transaction, but existing privacy protections will be maintained.
Your information enables us to provide our essential financial services. We use it to execute cross-border payments, mass payouts, and foreign exchange operations. Account management requires regular maintenance and updates, allowing us to process your requests efficiently and provide responsive customer support. We conduct thorough risk assessments by analyzing transaction patterns and account activity to prevent fraud and ensure the security of our services. Our customer support team uses your information to respond to inquiries, resolve issues, and provide technical assistance when needed.
TM Payments implements comprehensive security measures to protect your information throughout its lifecycle. We utilize industry-standard encryption technologies to secure data both in transit and at rest, ensuring that sensitive information remains protected. Our system architecture incorporates strict access controls and authentication procedures, limiting only data access to authorized personnel. Our dedicated security teams continuously monitor our systems for potential threats, maintaining vigilance against unauthorized access attempts and other security risks.
We maintain clear, specific data retention policies that balance business needs with privacy considerations. Your personal information is retained only as long as necessary to provide our services and comply with legal obligations. When data is no longer needed, we employ secure deletion methods to ensure it cannot be recovered. Our archive policies comply with regulatory requirements while ensuring that historical data remains secure and accessible when legally required.
In the event of a data breach, we maintain robust response procedures. Our systems are designed to detect potential security incidents promptly, and we follow a comprehensive incident response plan when issues are identified. Should a breach occur that affects your personal information, we will notify you and the relevant authorities as required by law, providing clear information about the incident and steps you should take to protect yourself.
TM Payments implements comprehensive security measures to protect your information throughout its lifecycle. We utilize industry-standard encryption technologies to secure data both in transit and at rest, ensuring that sensitive information remains protected. Our system architecture incorporates strict access controls and authentication procedures, limiting only data access to authorized personnel. Our dedicated security teams continuously monitor our systems for potential threats, maintaining vigilance against unauthorized access attempts and other security risks.
We maintain clear, specific data retention policies that balance business needs with privacy considerations. Your personal information is retained only as long as necessary to provide our services and comply with legal obligations. When data is no longer needed, we employ secure deletion methods to ensure it cannot be recovered. Our archive policies comply with regulatory requirements while ensuring that historical data remains secure and accessible when legally required.
In the event of a data breach, we maintain robust response procedures. Our systems are designed to detect potential security incidents promptly, and we follow a comprehensive incident response plan when issues are identified. Should a breach occur that affects your personal information, we will notify you and the relevant authorities as required by law, providing clear information about the incident and steps you should take to protect yourself.
As a global financial services provider, TM Payments regularly transfers data across international borders to facilitate our services. We understand the complexities of international data protection laws and maintain robust procedures to ensure compliant data transfers. When transferring data internationally, we implement appropriate safeguards, including standard contractual clauses and other legal mechanisms, to ensure your information receives consistent protection regardless of location.
Our international data protection standards are designed to meet or exceed requirements across all jurisdictions where we operate. We maintain compliance with various international data protection frameworks, including GDPR where applicable, and regularly review our practices to ensure alignment with evolving global privacy standards. This commitment to international compliance enables us to provide seamless services while protecting your privacy across borders.
TM Payments' services are designed for adult use only, and we do not knowingly collect or process personal information from individuals under 18. Our marketing efforts and service features target adult users, particularly those requiring financial services. We have implemented technical and operational measures to prevent the inadvertent collection of children's data through our Platform.
Should we discover that we have inadvertently collected information from a minor, we will promptly delete this data from our systems. In cases where parental consent may be relevant, we maintain strict procedures for verification and documentation. Our commitment to protecting children's privacy extends across all our operations and services.
We can be reached at hello@tm-payments.com or through our office at 8 The Green, Suite A, Dover, DE 19901.
We take privacy concerns seriously and have established clear procedures for handling complaints. All privacy-related inquiries receive a response within 30 days, and we maintain escalation procedures for complex issues. Our support team is trained to handle privacy matters with sensitivity and professionalism, ensuring your concerns are addressed thoroughly and promptly.
For California residents, we comply with the California Consumer Privacy Act (CCPA), providing specific rights regarding personal information. These include the right to know what personal information we collect and how it's used, the right to delete personal information (subject to certain exceptions), the right to opt-out of personal information sales, and protection against discrimination for exercising these rights.
New York residents receive additional protections under state law, including those provided by the NY SHIELD Act. These protections include specific requirements for data security, breach notification, and financial privacy. We maintain comprehensive compliance programs to meet these state-specific requirements while providing consistent privacy protection across all jurisdictions.
Our Privacy Policy evolves with our services and regulatory requirements. We regularly review and update this policy to reflect changes in our practices, technological capabilities, and legal obligations. When we make material changes, we provide clear notification through email and our Platform, typically with a 30-day notice period for significant updates.
Your continued use of our services after policy changes indicates acceptance of the updated terms. However, we encourage regular review of our privacy policy to stay informed about how we protect your information. For material changes requiring explicit consent, we will seek your agreement before implementing updates that affect your privacy rights.
We maintain several supplementary resources to support your understanding of our privacy practices. These include detailed Terms of Service, Security Policy, Acceptable Use Policy, and Data Processing Agreements. Our help center provides comprehensive FAQs addressing common privacy concerns and explaining technical concepts in accessible language.
We maintain a glossary of terms to help you understand technical and legal terminology used in our privacy documentation. This resource is regularly updated to reflect new terms and concepts as our services evolve. Additional educational materials about privacy and security are available through our Platform's help center.
