Tommensense Financial Privacy Policy

 This Privacy Policy outlines Tommensense Financial (“we,” “our” or “the Company”) practices with respect to information collected from users who access our website at www.ts-financial.ca (“Site”), or otherwise share personal information with us (collectively: “Users”).


Grounds for Data Collection

Processing of your personal information (meaning any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations toward you and providing you with our services, to protect our legitimate interests, and for compliance with legal and financial regulatory obligations to which we are subject.


When you use the Site, you consent to the collection, storage, use, disclosure, and other uses of your Personal Information as described in this Privacy Policy.


We encourage our Users to read this Privacy Policy carefully and use it to make informed decisions.


What Information We Collect

We collect two types of data and information from Users:


Non-Personal Information
The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“
Non-personal Information”). We are not aware of the identity of the User from which the Non-personal Information was collected.

Non-personal Information which is being collected may include aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site.


We may also collect information on your activity on the Site (e.g., pages viewed, online browsing, clicks, actions, etc.).


Personal Information
The second type of information is individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual. Such information includes:

Device Information

We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g., MAC address, UUID), and other information related to your activity through the Site.


Registration Information

When you register on our Site or contact us, you may be asked to provide certain details, such as:

  • Full name
  • Email address
  • Physical address
  • Phone number
  • Any additional details necessary for our services


Payment or Transaction Information (if applicable): If you use any paid services, we may collect billing details or limited payment information necessary to process transactions.


How Do We Receive Information About You?


We receive your Personal Information from various sources:

  • When you voluntarily provide us your personal details in order to register on our Site, subscribe to our newsletter, or contact us for support.
  • When you use or access our Site in connection with your use of our services (we collect certain technical information as described above).
  • From third-party providers, services, and public registers (for example, traffic analytics vendors, advertising networks, or social media platforms if you interact with us through those channels).


How We Use the Information We Collect

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy. We may use the information we collect for the following purposes:


  • To provide and operate our services and to enable you to access and use our Site.
  • Communicating with you – for example, sending you notices regarding our services, providing you with technical information, and responding to any customer service issues you may have.
  • To keep you informed of our latest updates and services.
  • To serve advertisements when you use our Site (see more under “Advertisements”).
  • To market our website and products (see more under “Marketing”).
  • Conducting statistical and analytical purposes, intended to improve the Site.

In addition to the uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies, and subcontractors.


We may also share Personal Information with our trusted third-party providers (who may be located in different jurisdictions across the world) for any of the following purposes:


  • Hosting and operating our Site.
  • Providing you with our services, including providing a personalized display of our Site.
  • Storing and processing such information on our behalf.
  • Serving you with advertisements and assisting in evaluating the success of our advertising campaigns, and help us retarget any of our users.
  • Providing you with marketing offers and promotional materials related to our Site and services.
  • Performing research, technical diagnostics, or analytics.


We may also disclose information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to:

  1. Comply with any applicable law, regulation, legal process, or governmental request;
  2. Enforce our policies (including our Agreement), including investigations of potential violations thereof;
  3. Investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
  4. Establish or exercise our rights to defend against legal claims;
  5. Prevent harm to the rights, property, or safety of us, our users, yourself, or any third party;
  6. For the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.


User Rights

You may request to:

  • Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
  • Receive a copy of the personal information you directly volunteer to us in a structured, commonly used, and machine-readable format.
  • Request rectification of your personal information that is in our control.
  • Request erasure of your personal information.
  • Object to the processing of personal information by us.
  • Request to restrict processing of your personal information by us.
  • Lodge a complaint with a supervisory authority.


Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the aforementioned rights or receive more information, please contact our team at tom.plocica@ts-financial.ca.


Retention

We will retain your personal information for as long as necessary to provide our services and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined by the type of information collected and the purpose for which it was collected, bearing in mind legal and contractual requirements.


We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion.


Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.


A “cookie” is a small piece of information that a website assigns to your device while you are viewing it. Cookies are very helpful and can be used for various different purposes, such as allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and making the interaction between you and our services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and compile statistical data on your use of our Services.


The Site uses the following types of cookies:

  • Session Cookies: Stored only temporarily during a browsing session and deleted from your device when the browser is closed.
  • Persistent Cookies: Read only by the Site, saved on your computer for a fixed period, and not deleted when the browser is closed.
  • Third-Party Cookies: Set by other online services that run content on the page you are viewing (for example, by third-party analytics companies who monitor and analyze our web access).


Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked by us to the information stored in and obtained from cookies. You may remove cookies by following the instructions of your device preferences. However, disabling cookies may limit certain features of our Site.


We also use may use a tool called Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.


Third-Party Collection of Information

Our policy only addresses the use and disclosure of information we collect from you. If you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. We encourage you to read the terms and conditions and privacy policy of each third party to whom you choose to disclose information.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set forth in this Privacy Policy.


How We Safeguard Your Information

We take great care in implementing and maintaining the security of the Site and your information. We employ industry-standard procedures and policies to ensure the safety of the information we collect and retain and to prevent unauthorized use of any such information. We also require any third party to comply with similar security requirements, in accordance with this Privacy Policy. However, while we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied, or otherwise, that we will prevent such access.


Marketing

We may use your Personal Information, such as your name and email address, ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials concerning our services, which we believe may interest you.


Out of respect for your right to privacy, we provide you within such marketing materials with a means to decline receiving further marketing offers from us. If you unsubscribe, we will remove your email address from our marketing distribution lists.


Please note that even if you unsubscribe from receiving marketing emails from us, we may send other types of important communications (e.g., customer service announcements or administrative notices) without offering you the opportunity to opt out.


Minors

We understand the importance of protecting children’s privacy, especially online. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at tom.plocica@ts-financial.ca.


Updates or Amendments to This Privacy Policy

We reserve the right to periodically amend or revise this Privacy Policy. Any material changes will be effective immediately upon the display of the revised Privacy Policy on the Site. The “Last Modified” date will be reflected below. Your continued use of the Site, following the notification of such amendments, constitutes your acknowledgment and consent to such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.


How to Contact Us

If you have any general questions about the Site or the information we collect about you, and how we use it, you can contact us at tom.plocica@ts-financial.ca


Last Modified: March, 2025