Privacy Policy
This Privacy Policy (“Policy”) covers TJM Financial Group LLC. and its affiliates and subsidiaries. These entities are collectively referred to as “TJM Financial,” “we,” “us,” and “our” throughout this Policy.
Privacy Principles:TJM Financial is committed to maintaining the confidentiality, integrity, and security of personal information about our current, past and prospective customers. In the course of offering and providing financial products and services, we collect and maintain certain personal information. This Policy explains what personal information we collect and how we use and share any such personal information. It also explains what you can do to limit the use and sharing of your personal information.
Please take a moment to read this Policy carefully. Privacy Policy Terms of Agreement:When you; visit our website, use our products or services, apply for a financial product or service, or open or maintain an account with us, you signify acceptance to the terms of this Policy and consent to the collection, use, and disclosure of your personal information as described below. If you do not agree with or you are not comfortable with any aspect of this Policy, you should immediately discontinue access or use of our Services.The Personal Information We Collect:
Personal information is data that can be used to identify you directly or indirectly as defined by applicable laws (“Personal Information”). Our Policy covers all Personal Information that you voluntarily submit to us, that is collected from other sources including our affiliates and non-affiliated third-party partners, and that we obtain automatically.
This includes, but is not limited to:
Personal Information you provide online and on applications or other forms, or mail to us, in connection with inquiries regarding, requests for, use of or access to any financial products or services, whether or not provided by us, such as your name, address, email address, phone number, social security number, driver’s license number, passport, date of birth, income (including frequency of pay cycle), profession/employment information, risk tolerance/ investment objectives.
Personal Information about your transactions with or through us, such as your account balance, trading activity, loan amount, and account history, if applicable.
Personal Information about you for account authentication and identity verification and for use with fraud prevention technologies.
Personal Information you provide to us about your external financial accounts, such as bank account number, account balance, account activity (including but not limited to direct deposits or spending activity), account history, and any other transaction data, so that we may provide you with Services, as well as special product and service features.
Technical, navigational and other information transferred when visiting the TJM Financial platform, including: IP address, mobile device IDs, device type, cookies, browsing activity, location and browser type.
Inferences drawn from any of the Personal Information listed above or from other available sources, or that you provide to us, in order for us to provide more personalized Services to you.
Any other Personal Information that you provide to or share with us.
Third-Party Sources. We may obtain Personal Information about you from third-party sources, including, but not limited to consumer reporting agencies. We also use service providers, including Teletrack LLC by Equifax Inc. (“Teletrack”), to gather end user data from financial institutions, e.g., to link your external financial account. By using our Services or linking your external financial account through these service providers, you grant us and these service providers, including Teletrack, the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by these service providers, including Teletrack by Equifax inc., in accordance with their privacy policies. You can find the Equifax privacy policy at https://www.equifax.com/privacy/privacy-statement/.
Aggregated Information.
In addition, we may compile aggregate, anonymous, or de-identified data from various sources, including but not limited to accounts and transactions. This data, which we may use for our business purposes consistent with applicable law, is not Personal Information as it does not identify individual customers.
Unsolicited Information.
You may have the opportunity to provide additional information to us through the TJM Financial platform or through any other means. This includes, but is not limited to, information posted to any public areas of the TJM Financial platform, such as by engaging with the content, including information volunteered in connection with participation in any of the webinars or other events hosted through the TJM Financial, or otherwise volunteered to us or third parties through the TJM Financial platform, any ideas for new products or modifications, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose and distribute such Unsolicited Information to others without limitation or attribution pursuant to the TJM Financial Terms of Service. Please take care and avoid providing us or third parties with any Personal Information through such public forums. For the avoidance of doubt, the definition of Unsolicited Information shall not include any information you volunteer to us through our customer service channels, as necessary for us to provide you with Services.
For more information, please see “Your Role in Your Privacy” section below.
How Your Personal Information Is Used:
TJM Financial uses the Personal Information you provide in a manner that is consistent with this Policy. Generally, we may use the information we collect in the following ways:
To identify and potentially personalize the Services when you visit, access or use the TJM Financial Platform;To develop, provide, and improve the Services;For fraud and information security;To conduct analytics such as usage trends;To respond to inquiries related to support or other requests;To send marketing and promotional materials about the Services;To provide non-affiliated business partners with lead generation;To manage our relationships;To build aggregated user profiles and segments
For more clarity, if you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For example, if you contact us by email to ask a question or report an issue with the Services, we will use the Personal Information you provide to answer your question or resolve your issue. Also, if you provide Personal Information in order to learn about certain products that may be available to you through third-party partners, we will use your Personal Information to provide you with information on such products and services or on the partner, to provide personalized Services, and/or to monitor your use of the Services.
We and our affiliates may also use your personal information and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and improve the Services.
Marketing.
If you have supplied your email address or phone number in relation to the Services, we may further send you emails, subject to applicable laws, to provide you with information, to inform you of new events or content, to solicit your feedback, or to keep you up to date on us. You can opt out of our marketing and promotional communications at any time by following the opt out prompts on these communications. You also may ask us not to send you other marketing communications by contacting us as specified in the “Contact Us” section below, and we will honor your request. Please note that even after you are removed from our marketing lists, we may still send you non-promotional communications, such as responding to service requests, payment reminders, account / system updates, and any other transactional communications in relation to your use of our Services.
Advertisements.
We use providers such as LinkedIn, Instagram, Twitter, TikTok, and YouTube for advertisements and remarketing. Advertisements appearing on any of the Services may be delivered to you by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Policy covers the use of cookies by us and does not cover the use of cookies by any advertisers.
We an
d our service providers may use information about your interactions with our Services to predict your interests and select the ads you see on and off our Services. This is known as interest-based ad
vertising. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance. For more information about interest-based advertising and how you can opt out, visit:
Digital Advertising Alliance: http://www.aboutads.info/choices/Network Advertising Initiative: http://www.networkadvertising.org/choices/
Sweepstakes & Contests. We occasionally offer sweepstakes, contests and other promotions (“Promotions”) via the TJM Financial Platform. To participate in these Promotions, we may require you to register and provide us with Personal Information, such as your name and email address. This Policy applies to Promotions we may administer online through the TJM Financial Platform or other social media or digital platforms. Some Promotions we advertise may be administered by third parties who would collect your information, and you should review the privacy policies of the administering party to understand how your Personal Information is used and protected by them. In the Promotions we offer, we will use the information you provide us for purposes including administering the Promotion, offering or providing Services to you, and other purposes disclosed at the time of registration. You should carefully review the official rules of any Promotion in which you participate, including any option to opt out of the use of your information for future promotional or marketing purposes. If you have any questions or concerns, please contact us via the “Contact Us” section below.
Disclosure or Information:In some circumstances, the following categories of data may be shared to third parties. If your Personal Information was provided in a request for financial services, please see our GLBA Privacy Notice.
IP address, Internet activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Like many companies, we use services that help deliver interest-based ads and personalization to you, which may involve the transfer of Personal Information to business partners for their use, such as Google Analytics.
To view an overview of the privacy of your Google Analytics cookies please go here:
https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631
You may install a Google Analytics opt-out browser add-on by going here: https://tools.google.com/dlpage/gaoptout?hl=en-GB
Email address. We may share your name and email address with our third-party business partners or companies assisting us with targeted advertising and marketing, such as Facebook, GoogleAds, and Criteo for general marketing and lead generation services, which may use this information combined with information collected via the use of cookies or internet activity information to deliver interest-based and personalized marketing to you.
In both of the cases above, because the definitions of ‘Personal Information,’ ‘share,’ and ‘sale’ under CCPA are broad, making Personal Information available to these companies may be considered a “sale” or “sharing” under CCPA. If you would like to opt out of this type of sharing with our third-party business partners or service providers, please reach out to us via the Contact Us section below.We may also disclose your Personal Information to the following entities:
Our affiliated and subsidiary companies (please see our GLBA Privacy Notice to learn how you may limit the sharing of some of this information for marketing purposes by our affiliated companies).
Non-affiliated third parties that perform services, such as marketing or market research, on our behalf (for example, we may provide your name, address, phone number, or email address to third parties that send email or regular mail on our behalf).
Non-affiliated third parties under contract that service, maintain, or process your transactions and accounts (for example, companies that provide administrative, telecommunications, computer, trade execution, payment, and securities clearing services, and that prepare and mail account statements and transaction confirmations and other services in connection with the operation of our business).
Non-affiliated third parties as permitted or required by law to defend our rights or enforce a contract, or to cooperate with government agencies or regulators, (including for tax purposes), securities exchanges, self-regulatory bodies (such as FINRA) and law enforcement officials (for example, for reporting suspicious activity or transactions, complying with a subpoena).
Non-affiliated third parties to protect against actual or potential fraud or unauthorized transactions, and to protect the security of our records and systems, unless prohibited by law.
Non-affiliated third parties at your direction or for which you provide your express consent (for example, banking or financial institutions and professional service providers).
Non-affiliated third parties in the event of merger, acquisition, sale of ownership or assets, divestitures, or other change of control.
In addition, we may disclose Personal Information we collect, such as the categories described above, to make our Services, as well as those offered by our third-party partners, available to you. We may also use and disclose Personal Information with your consent. If you decide to withhold certain information, it may limit our ability to provide you with the services or products you request or that may be of interest to you.
Our service providers (i.e., those companies that provide a service on our behalf pursuant to a written contract) are obligated to keep the Personal Information we share with them confidential and use it only to provide services specified by TJM Financial.
How We Protect Personal Information About You:
We consider the protection of Personal Information to be a foundation of customer trust and a sound business practice. We maintain appropriate physical, administrative, and technical safeguards to protect your Personal Information and we regularly adapt these controls to respond to changing requirements and advances in technology.
At TJM Financial, we restrict access to Personal Information to those who require it to develop, support, offer and deliver products and services to you.
Your Digital Privacy:
Privacy, security, and service in TJM Financial’s online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and authentication procedures, and we enforce physical access controls to our buildings among other controls, to maintain the security of your online session and to protect TJM Financial’s accounts and systems from unauthorized access.
As referenced above, we may collect technical and navigational information for a variety of purposes, such as maintaining the security of your session, facilitating Site navigation, improving the design and functionality of the TJM Financial Platform, and personalizing your experience.
Your Role in Your Privacy
In some cases, we cannot control, and are not responsible for, information that is shared about you. For example:
Information You Share.
Some of the services on the Site may let you share information with others, such as via messaging and posts. Remember that when you share information publicly, it may be indexable by search engines or otherwise further disclosed.
Social Media Accounts.
We maintain various social network accounts such as Facebook, Twitter, Instagram, TikTok or LinkedIn. Please note that comments and information that you leave in such settings are likely to be broadly visible and may not be controlled by us. We are therefore not responsible for any information or messages you leave in such settings or for how such information may be used by others. Please review the terms of use and privacy policies of any social network platforms you use, as they will control your rights and responsibilities, and your use of those platforms is not covered by this Policy.
You have choices about how we use your information. Please understand that if you choose not to disclose information to us, it may affect your ability to use some features of the Services or products.
Collection and Use of Information Collected Automatically:
We receive and store certain types of information automatically, such as when you visit our platform or download and use our Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, or web-browser software. For example, we may use data collection and tracking tools such as cookies, web beacons, pixel tags, and other similar tracking techniques that may be downloaded to your personal computer, tablet, mobile phone or other device when you visit or interact with our platform.
“Cookies” are small amounts of data that a website can send to your web browser and store on your computer. Cookies do not contain Personal Information (unless you knowingly provide it). We use both “session ID” cookies and “persistent” cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. If you reject cookies, you may still use the Site but your ability to use some areas of the Site content may be limited.
The use of cookies by our partners, affiliates, tracking utility company, and/or service providers is not covered by our Policy. We do not have access or control over these cookies.
Children:This Site is not directed at individuals who are under the age of majority in their state of residence (generally age eighteen (18) or nineteen (19) if you are in Alabama or Nebraska). TJM Financial does not knowingly collect or receive Personal Information from any minors. If you believe that a child under the age of majority may have provided us with Personal Information, please contact us as specified in the Contact Us section of this Policy.Third-Party Links:Our platform may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us – and which may link to other websites, services and/or applications. Please be aware that we are not responsible for the privacy or practices of other websites, services or applications, or the third parties that operate them. We do not make any guarantee regarding those third-party websites, services, or applications, and we are not liable for any loss or damage caused by the use of such websites. Any data collected by third parties is not covered by this Policy. You should review the policies of third parties and contact them directly if you have any questions about their services or practices.
Personal Information Retention:We keep your Personal Information only as long as necessary to provide you with our services, including if you have an active registered account with us, and for legitimate and essential business purposes, such as maintaining the performance of the Site and associated services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.