Privacy Policy

Effective Date: May 28, 2025

This Privacy Policy forms an integral part of the Terms of Service.

“Tokenfolio”, “we”, “us”, and “our” refer to funds managed by TF Capital Management Limited (a registered investment manager under regulations 3(1), 7(1), and 7(2)(b) of the Investment Business (Approved Managers) Regulations, 2012) and TF Capital Management LLC or its members, together with any of their subsidiaries, affiliates and group companies.

We are committed to protecting your privacy and safeguarding your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website or use our investment services.

We collect your personal data for the purpose of our platform, including our website (www.tokenfolio.co) and mobile/internet based applications operated by Tokenfolio, if any (“Platform”).

This Privacy Policy applies to you when you access or use the Platform or when you access, use, or download any other products, services, features, content, widgets, materials or other tools offered by the Company or its subsidiaries and affiliates (collectively the “Services”).

Age Restriction

We offer our Services to persons who have attained majority and are accredited investors under the laws of their country of residence;

We reserve rights to verify the age and competence of a person and in case of failure, we may in our sole discretion suspend/terminate your account and forfeit its contents.

What Data Do We Collect?

We collect various types of personal and technical data relating to you, including but not limited to:

Identity Data: Name, date of birth, nationality, government-issued identification numbers (e.g. passport, driver’s license).
Contact Data: Email address, telephone number, postal address.
Account Data: Username, password, investor profile.
Financial Data: Payment information, transaction history, portfolio holdings.
Compliance Data: Documents and information collected for Know Your Customer ("KYC"), Anti-Money Laundering ("AML"), and other legal/regulatory requirements.
Technical/Usage Data: IP address, device information, browser type, geolocation data, operating system, browsing behavior, cookies, and other tracking data.
Communications Data: Correspondence and communications with our team or customer support.
Third-Party Data: Information from public databases, credit reference agencies, identity verification services, and third-party service providers.

How We Collect Data

We collect your data through:

Direct Interaction: When you register, fill out forms, communicate with us, or use our Services.
Automated Technologies: Via cookies, web beacons, server logs, and analytics tools when you visit our Platform or use our Services.
Third Parties: From trusted third-party partners like identity verification services and regulators.

How We Use Your Data

We process your personal data to:

Open, administer, and manage your investment accounts and transactions.
Comply with legal, regulatory, and compliance obligations, including KYC, AML, and tax reporting.
Provide tailored investment offerings, updates, newsletters, and customer service.
Enhance, personalize, and improve our Services and Platform functionality.
Communicate marketing materials and promotional offers, subject to your consent where required.
Monitor and improve our security and mitigate fraud.
Fulfill contractual obligations and enforce our legal rights.
Your Tokenfolio account is secured by your login id and password and we advise you to keep them secure. It is your responsibility to protect your log in information and in case you fail to do so you will be liable. We advise you to refrain from disclosing your login details to anyone. You are requested to contact us immediately if you have reason to suspect any breach of security, including compromise of your log in information.
Our Platform may contain links to third party websites. Such third party websites are governed by their own terms of use and privacy policy. We advise you to read the terms of use or privacy policy of such websites before accessing their services or submitting your personal details.
Security checks for verification and identification purposes whether by us or through third party service providers.

Disclosure of Your Data

We do not sell your personal data. We may disclose your information to:

Service Providers: Companies providing website hosting, payment processing, identity verification, IT services, marketing, legal, and compliance support.
Regulatory and Government Authorities: When required by law or regulation.
Affiliates and Partners: Financial institutions such as custodians, brokers, or investment partners to facilitate your investments.
Business Transfers: In connection with mergers, acquisitions, or sale of assets.

All recipients are subject to strict confidentiality obligations and must comply with applicable data protection laws.

Consent to Data Transfer

Your information may be transferred, stored, and processed in countries outside your jurisdiction, including countries that may not have the same level of data protection. By using our Platform and Services, you explicitly consent to such transfer and processing, subject to appropriate safeguards including standard contractual clauses or other legal mechanisms.

Your Data Use Choices

You can:

Opt-out of marketing communications at any time by following the unsubscribe instructions or contacting us.
Manage Cookies: Adjust your browser or device settings to control or block cookies. However, disabling some cookies may reduce functionality.
Access and Update: Access, correct, or delete personal information via your account or by contacting us.
Object to or Restrict Processing: Exercise your right to limit certain data uses as permitted by applicable law.

How to Exercise Your Data Subject Rights?

You may exercise your rights, including:

Right to access your data.
Right to correction or deletion.
Right to restrict or object to processing.
Right to data portability.
Right to withdraw consent at any time.

Submit your requests using the contact information provided below. We may require verification of your identity before addressing requests. We will respond in accordance with applicable legal timeframe, typically within 30 days. If we require additional time or information to verify your identity, we will notify you promptly.

Jurisdiction Specific Rights

This Privacy Policy is designed to comply with the European Union General Data Protection Regulation ("GDPR") and relevant U.S. state privacy laws including the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), and associated regulations (collectively, “CCPA”).

GDPR (European Union)

If you are an EU resident, you have the following rights under the GDPR:

Right of Access: You have the right to obtain confirmation of whether we process your personal data and access that data.
Right to Rectification: You may request correction of inaccurate or incomplete data.
Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal data under certain conditions.
Right to Restrict Processing: You may ask us to limit how we use your data.
Right to Data Portability: You can request a copy of your data in a structured, commonly used format.
Right to Object: You have the right to object to certain data processing, including direct marketing.
Right to Withdraw Consent: Where processing is based on your consent, you can withdraw it at any time without affecting processing done before withdrawal.
Right to Lodge a Complaint: You may submit a complaint to a relevant data protection authority.

CCPA (California, USA)

If you are a California resident, under the CPRA you have these rights:

Right to Know: Request information about the personal data we collect, disclose, or sell.
Right to Delete: Request deletion of personal information we hold, subject to certain exceptions.
Right to Opt-Out: You may opt out of the sale of your personal information.
Right to Non-Discrimination: We will not discriminate against you for exercising your rights.
Right to Correct: Under CPRA, you may also request correction of inaccurate personal information.
Right to Access and Limit Use: CPRA provides enhanced rights for accessing and limiting use of sensitive personal information.

To exercise these rights, please contact us at the information provided below.

Children Online Privacy

Our Platform and Services are not directed to individuals under the age of 18 (or the age of majority in your jurisdiction), and we do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately so we can remove the information.

Changes to Our Privacy Notice

We may update this Privacy Policy from time to time to reflect changes to our practices, legal requirements, or technology. We will post the updated policy on our website with a revised “Effective Date”. Please review the policy periodically to stay informed about how we protect your information.

Contact Information

For further information, questions, or concerns about our data practices, please contact:
support@tokenfolio.co

GRIEVANCE REDRESSAL OFFICER

Please see below the details of our grievance redressal officer:
Name: Abhishek Malik
Email: abhishek@tokenfolio.co

Cookie Policy

What Are Cookies?

Cookies are small data files placed on your device when you visit a website. They help improve usability, collect analytics, personalize content, and support advertising.

How We Use Cookies

We use cookies for the following purposes:

Essential Cookies: Necessary for website operation and security.
Performance and Analytics Cookies: Help us understand and improve how our site is used.
Functional Cookies: Remember your preferences and enhance your experience.
Advertising and Targeting Cookies: Deliver relevant advertisements and measure ad effectiveness.

Managing and Withdrawing Consent

You can manage cookie preferences or withdraw consent at any time by:

Adjusting cookie settings through the banner or our cookie preference center.
Modifying browser settings to block or delete cookies (note this may limit site functionality).