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Tenure Privacy Statement

Tenure Inc. ("Tenure", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website http://www.tenurefi.com and associated sites (collectively, the "Site"), and use our services. By accessing or using the Site and our services, you agree to this Privacy Policy. If you do not agree with our policies and practices, please do not use the Site.

We are the owner of the content on and operator of the website http://www.tenurefi.com, its associated sites and microsites accessed through the aforementioned website (each a “Site“ and collectively the “Sites“) (“Tenure Inc Inc“, “we“ or “us“). Please be advised that Tenure Inc Inc is not responsible for hyperlinks to other sites or content on the internet which are owned or operated by third parties. The linked site or content is not under our control and Tenure Inc Inc is not responsible for any errors, omissions, delays, defamation, libel, lies, pornography, obscene content, inaccuracies or other material contained in the content, or consequences of accessing any related website.

Privacy Statement
`Protecting your privacy is very important to Tenure Inc Inc. We value your privacy and we are committed to the protection of personal information which you may provide. We designed this Privacy Policy to make clear to you how we may collect and use your personal information. “Personal information” means any information that can be used to personally identify you (this does not include any information that has been aggregated or made anonymous) and as interpreted under Regulation of Minister of Communication and Information Technology No. 20 of 2016 on Personal Data Protection within Electronic System (hereinafter referred to as “Regulation 20/2016”).

Information contained herein has been prepared in accordance and in compliance with the applicable laws and is for the exclusive use if Tenure Inc Inc and its affiliates and/or its assigns.

You are required to read our Privacy Policy from time to time. By accessing or using our services or products as well as our Website, it shall be considered as your approval and acceptance to our Privacy Policy, thus, you agree to be bound under each provision stated in our Privacy Policy. If you do not agree with any term or provision in this Privacy Policy, please do not use our services or products as well as our Website. By delivering a notification to your email, we reserve our rights to revise and/or update our Privacy Policy from time to time and you agree to be bound by such revised and/or updated Privacy Policy.

Your acceptance and approval of this Privacy Policy will also relate to the provisions stated under the Terms of Use and it shall deem and constitute as inseparable and one single agreement that govern our right and obligations to you.

Your Acceptance and Approval
When you sign up for a Tenure account we collect and manage your personal information as part of our identity verification process through your employer, in the course of a transaction, or when you request a digital receipt. We may collect but are not limited to collecting the following:

1. Basic user information, such as your full name, email address, phone number, birth date, and age; in accordance with our KYC or KYB (Know your customer or know your business) process to open your Tenure account.
2. Any information uploaded by you or any information about your products and services;
3. Information attached to you while you are accessing our Site;
4. Any information on the computers, phones or other devices where you installed our application or access our services, which will depend on the permissions you’ve granted;
5, Any information collected by cookies, web beacon as well as general log information;

We shall be entitled, from time to time, to conduct a verification towards the personal information that you have provided to us, by sending a verification mail, e-mail, or requiring you to submit supporting documentation, or any manner whatsoever, as necessary.

You hereby agree that your Personal Information may be disclosed to the following:

1. The Company’s affiliates and subsidiaries, agents and subcontractors;
2. The government, regulatory agencies, and fraud prevention agencies for purposes of identifying, preventing, detecting or tackling fraud, money laundering, or other crimes, and for other lawful purposes;
3. To a third party for risk management purposes;
4. Other entities as may be required by law or as the public interest may warrant, for the purposes identified in the next paragraph; and
5. The buyers upon the occurrence of acquisition. You understand and are aware that such disclosure must be made and agree to waive your rights to submit a claim for an indemnity, to the extent permitted under the law.

Collection of Your Personal Information

At Tenure Inc Inc, we use information about you to provide, maintain, and improve our services and to deliver the information and support your request, including receipts, alerts, and support and administrative messages.

We may use the information we collect to the following activities:

1. Send you news and information about our services and to communicate with you about products, services, promotions, and updates offered by us and select partners;
2. Improve our products, services or Site and fulfilling your requests;
3. Maintain internal records;
4. Respond to your questions and comments, to provide you with access to our products or services and to communicate with you about our products or services;
5. Investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the rules or policies of a Site, or the rights of third parties; or to investigate any suspected conduct which we deem improper;
6. For our internal purposes such as auditing, analysis, and research to improve our products, services and customer communications;
7. For disclosures required by law, regulation, or court order; and
8. For the purpose of or in connection with legal proceedings or necessary for establishing, defending, or exercising legal rights.

We may use information about you to improve, personalize and facilitate your use of our services and products in order to provide better services.

Use of Information

You hereby agree that your Personal Information may be shared to our affiliates or vendors for processing purposes as may be required in the maintenance and performance of its duties and responsibilities of our services, in accordance with applicable laws, rules and regulations. We may, as necessary, engage subcontractors or data processors in each case with respect to the purposes enumerated above.

All data processing, subcontracting or data sharing agreements will be in accordance with the requirements under the Regulation No. 20/2016, or applicable laws and regulations as may be hereafter passed and implemented. To the extent that such processing, subcontracting, or sharing requires notice or consent, we will provide or request for such notice and/or consent, in each case, prior to any processing or sharing of your Personal Information (if applicable).

Except as provided for herein, we will not provide any of your Personal Information to any third parties without your specific consent.

Sharing of Personal Information

To the extent permitted under the law, the Personal Information will be retained by Tenure Inc for the period necessary to fulfill the purposes outlines in this Privacy Policy.

Use of Card Information

Tenure Inc offers a number of benefits that rely on the data (date, time, amount and merchant) created when you make a purchase on an enrolled credit card (your “Card Information”).

When you enroll your credit card to participate in the Roundups and Cashback

Rewards Programs made available to you within your Tenure Inc account, you will be asked to authorize the related payment card network (i.e. Visa, Mastercard) to monitor your payment card and share transaction details, the Card Information, for purchases you make. This Card Information will be shared with Olive Group Ltd. in order to enable the benefits of the Tenure Inc app. These benefits include enabling card linked offers, identifying and providing offers that are located near you, calculating round up amounts, and providing program notifications.

Neither Tenure Inc, nor our service providers, store your sensitive card credentials about your enrolled cards Reference to your enrolled card(s) are made by way of tokenized identifiers. That means we do not see the number or CVV of your card.

When you enroll in Roundups, the Card Information that Tenure Inc may have access to is date of purchase, the merchant category and the purchase amount. This data is used solely to calculate the Roundup amount to be allocated to your Tenure Inc roundup account and apply the round up rules you have selected to your purchases. Your enrolled card will be charged to fullfill the roundup amount and placed in your Tenure Account and will be subject to any processing fees.

When you have enrolled in Cashback Rewards, the Card Information that Tenure Inc may have access to is the date of the purchase, merchant name, and purchase amount for transactions that are made with participating merchants. This data is used solely to evaluate if the purchase qualified for the reward, and upon qualification, allow us to calculate the reward amount to be credited to your Tenure Inc account.

You may also opt-out of this transaction monitoring on your enrolled card at any time by going to your settings and deactivating or removing the card.

Use of your card’s tokenized identifier for monthly payments

When you are a enrolled in Tenure Inc, your Enrolled Card will be charged for the roundup feature of the program and any processing fees to complete the transaction. We use the tokenized identifier of your enrolled Card to process this payment via our merchant account.

Retention and Security of Your Information

We value both the Personal Information and Card Information (together your “Information”) collected through our Site, and will take reasonable measures including administrative, physical and technical safeguards, to protect it from possible threats, both online and offline.

However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or information stored on the Site or our servers, will be completely free from unauthorized access by third parties such as hackers and your use of the Site demonstrates your assumption of this risk. In the event that such information is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and where appropriate, notify the individual whose information may have been compromised and take other steps in accordance with the applicable laws or regulations. To the fullest extent permitted by law, we are not responsible and liable for any direct, indirect, consequential, or punitive damages, loss, and/or claims, that you may suffer due to any loss, unauthorized access, misuse, or alteration of any information you submit to a Site.

Confidentiality of Your Account

You shall be responsible for maintaining the confidentiality of your own account and password, as well as any and all applications submitted, obligations agreed to or entered into and all other activities that occur under the said account. You agree to immediately notify us of any unauthorized use or disclosure of your account or password, any unauthorized activities under your account or any other breach of security. We will not be liable for any loss that you may incur as a result of a third party’s use of your account or password, either with or without your knowledge, without fault or negligence on the part of us.

Transfer of Assets

During the course of our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, Information that we have collected about you may be transferred to such entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. If any of the above has occurred, you agree to grant us your consent and a right for us to transfer it to a third party without any further notification, to the extent permitted under the applicable laws and regulations.

Governing Law

Any reference to applicable laws and regulations under this Privacy Policy shall be interpreted as in accordance with provisions stated under the laws of the province in which you are ordinarily resident at the time that you enter agree to this privacy policy and the federal laws applicable therein without regard to the principles of conflict of laws.

If any term or provision of this Privacy Policy shall be held or declared to be invalid, illegal or unenforceable for any reason by any rule of law or public policy, such provision shall be severed to the extent invalid or unenforceable and the remaining provisions shall continue in full force and effect.

Severability

For any questions, concerns or clarifications about our Privacy Policy, we may be contacted through the customer support system by email to privacy@tenurefi.com