Privacy Policy
Effective Date: December 21, 2023.
This Privacy Policy describes how TWM Finance (“we”, “us”, or “our”) collects, uses, and protects the personal data of users (“you”, “your”) when you interact with our website [insert website URL] and use our financial education, consulting, or informational services.
We are committed to processing your data lawfully, fairly, and transparently in accordance with the General Data Protection Regulation (EU Regulation 2016/679 – “GDPR”), as well as industry best practices for financial data privacy and protection.
1. Who We Are
TWM Finance is a financial services company offering educational and strategic business support. We are not a licensed broker, investment advisor, or financial institution, and we do not engage in regulated financial transactions or manage client funds.
If you have questions about this policy or our practices, you can contact us at:
TWM Finance
[Insert Office Address]
Email: [Insert Email Address]
Phone: [Insert Phone Number]
Data Controller: TWM Finance
2. What Data We Collect
We only collect personal data that is relevant and necessary for the services we provide. This may include:
Personal Identification Information
- Full name
- Email address
- Phone number
- Mailing address
- Company/business name and information
Voluntary Financial Information (Non-Brokerage)
- Revenue, income, business performance details (for consulting purposes only)
- General information you provide regarding investments, goals, or business planning
(Note: We do not collect banking credentials, investment account access, or perform brokerage services.)
Automatically Collected Data
- IP address and location data
- Device information and browser type
- Site usage, page visits, time spent
- Cookie and tracking data (see Section 7)
3. Legal Basis for Processing Personal Data
We process your personal data based on one or more of the following legal grounds under GDPR:
- Consent – When you give us clear permission to process your data for a specific purpose.
- Contract – When the processing is necessary for the performance of a contract (e.g., providing consulting services).
- Legitimate Interest – For purposes such as business development, fraud prevention, or service improvement.
- Legal Obligation – To comply with legal or regulatory requirements, such as recordkeeping.
4. How We Use Your Information
We use your information for the following purposes:
- To respond to inquiries and provide requested services
- To deliver newsletters, updates, or educational content (opt-in only)
- To assess your business situation and provide non-licensed financial insights
- To communicate regarding service updates, schedules, or offers
- To improve our website, services, and user experience
- To meet legal, tax, or compliance obligations
5. How We Share Your Data
We do not sell your data. We may share it under strict confidentiality with the following third parties:
Authorized Service Providers
We use vetted partners to host our website, process contact forms, send emails, and analyze site traffic. These third parties are contractually obligated to protect your data and act only on our instructions.
Legal or Regulatory Authorities
If legally required (e.g., court orders or fraud investigations), we may disclose your data to authorities.
Business Transfers
In the event of a sale, merger, or restructuring of TWM Finance, your data may be part of the assets transferred, in accordance with data protection laws.
6. International Data Transfers
If you are located in the EU or UK, and we transfer your data outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, such as:
- Standard Contractual Clauses (SCCs)
- Transfers to countries with adequate protection levels (as recognized by the European Commission)
7. Cookies and Tracking Technologies
Our website uses cookies to enhance your experience. Cookies help us analyze traffic, remember your preferences, and deliver tailored content.
You can manage or disable cookies via your browser settings. For more details, please see our [Cookie Policy] or contact us for a copy.
8. Your GDPR Rights
If you are an individual located in the EEA, UK, or Switzerland, you have the following rights under the GDPR:
- Right of Access – Know what personal data we hold about you
- Right to Rectification – Request correction of inaccurate or incomplete data
- Right to Erasure (“Right to be Forgotten”) – Request deletion of your personal data
- Right to Restrict Processing – Limit how we process your data in certain cases
- Right to Data Portability – Receive your data in a structured, machine-readable format
- Right to Object – Object to processing based on our legitimate interests
- Right to Withdraw Consent – Withdraw consent at any time, where applicable
- Right to Lodge a Complaint – File a complaint with your local data protection authority
To exercise any of your rights, email us at [Insert Email Address]. We will respond within 30 days as required by law.
9. Data Retention
We retain personal data only as long as necessary for the purposes described above, unless a longer retention period is required by law (e.g., financial or legal recordkeeping obligations). After this period, your data will be securely deleted or anonymized.
10. Data Security
We implement industry-standard technical and organizational safeguards to protect your data, including:
- HTTPS encrypted website
- Password-protected accounts and systems
- Secure cloud infrastructure with access control
- Staff confidentiality agreements and data minimization practices
However, no method of transmission over the Internet or method of electronic storage is 100% secure. We encourage you to take precautions and understand the limitations of digital communications.
11. Third-Party Links and Tools
Our website may contain links to external websites, plug-ins, or tools. We are not responsible for the privacy practices of those websites or platforms. Please review their privacy policies independently.
12. Children’s Privacy
Our website and services are not intended for children under the age of 18. We do not knowingly collect data from minors. If you believe we have collected such data, contact us immediately at [Insert Email Address].
13. Disclaimers Regarding Financial Advice
TWM Finance does not offer investment brokerage, securities trading, or asset management. Any content or recommendations offered are strictly educational or strategic in nature. We disclaim all liability for decisions made based on our content or consulting.
14. Updates to This Policy
We may update this Privacy Policy periodically. When changes are made, we will update the “Effective Date” at the top of this page. Significant changes will be communicated via email or a notice on our homepage.
15. Contact Us
For questions, requests, or concerns regarding your privacy:
TWM Finance
Email: info@twmfinance.com
Subject Line: “Privacy Request – TWM Finance”
