Privacy Policy

Effective Date: June 1, 2024

Thank you for choosing Turris Financial Service, Inc.("we," "us," or "our") as your trusted financial service provider. This Privacy Policy outlines how we collect, use, store, disclose, and protect your personal information when you use our fintech banking services that work with insurance companies. We are committed to maintaining the privacy and security of your personal information in accordance with applicable data protection laws and regulations.

1. Information We Collect

1.1. Personal Information: We may collect personal information such as your name, address, email address, phone number, date of birth, national identification number, social security number, financial information, employment details, and other similar information necessary to provide our banking services.

1.2. Financial Information: To facilitate transactions and provide banking services, we may collect and process financial information, including but not limited to account balances, transaction history, insurance policy information, insurance claims data, and other relevant financial data.

1.3. Device and Log Information: When you access our services, we may automatically collect information about your device, including your IP address, browser type, operating system, referring URLs, pages visited, and the dates and times of your interactions with our services. When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by, writing to us via email, unsubscribing via any email communication you receive, or visiting https://app.retention.com/optout

2. Use of Information

2.1. Providing Services: We use the collected information to provide, maintain, and improve our fintech banking services, including processing transactions, managing accounts, verifying identities, and providing customer support.

2.2. Legal and Regulatory Compliance: We may use your personal information to comply with applicable laws, regulations, and legal obligations, including but not limited to anti-money laundering and fraud prevention requirements.

2.3. Communication: We may use your contact information to communicate with you regarding important service updates, account information, and promotional offers. You can opt-out of promotional communications at any time.

2.4. Data Analysis and Personalization: We may analyze the collected information to better understand your needs and preferences, personalize your user experience, and improve our services and offerings.

3. Information Sharing

3.1. Service Providers: We may share your personal information with trusted third-party service providers who assist us in operating our business and delivering our services. These service providers are contractually bound to protect your personal information and can only use it for the specific purposes outlined in our agreement with them.

3.2. Insurance Companies: In the context of providing fintech banking services that work with insurance companies, we may share your personal information with our partner insurance companies as necessary to facilitate insurance transactions, policy management, claims processing, and other related activities.

3.3. Legal and Safety Disclosures: We may disclose your personal information in response to legal process, law enforcement requests, or when we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government request.

4. Data Security

4.1. We take appropriate technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. We regularly review and enhance our security measures to ensure the ongoing confidentiality, integrity, and availability of your data.

4.2. Despite our best efforts, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security of your personal information.

5. Data Retention

5.1. We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

5.2. When we no longer need your personal information, we will securely delete or anonymize it, or if this is not possible (for example, due

to backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. Intended Use and Age Restrictions

6.1. Site Intended for Use in the U.S.: Our fintech banking services and this website are intended for use in the United States. If you access our services or provide personal information from outside the United States, you do so at your own risk, and you are responsible for complying with any local laws or regulations.

6.2. Children's Privacy: Our services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us using the information provided below, and we will take steps to delete such information.

7. Your Rights

7.1. You have the right to access, correct, update, or delete your personal information. You can exercise these rights by contacting us using the contact information provided below.

7.2. You have the right to object to or restrict the processing of your personal information in certain circumstances. However, such objections or restrictions may impact our ability to provide you with certain services.

8. Third-Party Links and Services

8.1. Our services may contain links to third-party websites or services. This Privacy Policy does not cover the practices of these third parties. We encourage you to review their privacy policies before interacting with their websites or services.

9. Changes to this Privacy Policy

9.1. We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the revised Privacy Policy on our website or through other communication channels.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact us at:

support@turrisfi.com

By using our fintech banking services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.