Privacy at a Glance
(Simple Summary for Members)
Your privacy matters to us. Here is a clear summary of how Tontine Trust handles your personal information.
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What We Collect
We collect information needed to:
• Set up and administer your trust participation
• Verify your identity (where required by law)
• Process distributions
• Communicate with you
• Keep the platform secure
This may include your name, contact details, date of birth, identification information, account activity, and technical data (like IP address and device type).
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Why We Collect It
We use your information to:
• Provide and manage your account
• Administer trust services
• Meet legal and regulatory requirements
• Prevent fraud and protect security
• Improve our website and app
We only collect what we need to provide services properly and safely.
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We Do Not Sell Your Data
Tontine Trust does not sell your personal data.
We never trade, rent, or monetize your personal information.
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Who We Share It With
We only share data when necessary, such as with:
• Secure IT and hosting providers
• Compliance and identity verification providers
• Custodians or financial partners (where required)
• Authorities if legally required
All partners must protect your data and comply with GDPR.
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Emails & Notifications
If you have an account, you will receive important service communications such as:
• Distribution notices
• Account updates
• Security alerts
These are necessary to provide the service.
If you enable app notifications, you may receive push alerts. You can turn these off in your device settings.
Marketing emails (if any) can be unsubscribed from at any time.
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Your Rights
Under EU data protection law (GDPR), you have the right to:
• Access your data
• Correct inaccurate data
• Request deletion (where legally permitted)
• Restrict or object to certain processing
• Receive a copy of your data
You may also file a complaint with Sweden’s data protection authority (Integritetsskyddsmyndigheten).
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How We Protect Your Data
We use appropriate security measures, including secure systems, access controls, and encryption where appropriate.
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Questions?
If you have any questions about your privacy:
Email: [email protected]
Controller: Tontine Trust Europe KB
For full legal details, please read the complete Privacy Policy below.
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Privacy Policy
Effective Date: 10th February 2026
Last Updated: 13th February 2026
This Privacy Policy explains how Tontine Trust Europe KB (“Tontine Trust”, “we”, “us”, “our”) collects, uses, shares, and protects personal data when you use:
• https://tontine.com (the “Website”);
• The MyTontine mobile or web-based application (the “App”);
• Our trust administration services;
• Any related communications or interactions (together, the “Platform”).
We are committed to protecting your privacy and processing personal data in accordance with:
• The EU General Data Protection Regulation (GDPR);
• Applicable Swedish data protection laws; and
• Other relevant regulatory requirements.
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1. Data Controller
The data controller responsible for your personal data is:
Tontine Trust Europe KB
[Insert Registered Address]
Email: [email protected]
For privacy-related inquiries, you may contact us at the above email address.
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2. What Personal Data We Collect
We collect personal data directly from you, automatically through the Platform, and where necessary from trusted third parties.
2.1 Information You Provide
This may include:
• Full name
• Date of birth
• Contact information (email, phone number, address)
• Identification documents (where required for compliance)
• Financial information necessary for trust participation
• Beneficiary details
• Communications with us
2.2 Account and Platform Data
When you use the Website or App, we may collect:
• Account login credentials
• Transaction and trust participation information
• Distribution records
• User preferences
• Communication history
2.3 Technical and Device Information
We may automatically collect:
• IP address
• Browser type and version
• Device type and operating system
• App usage data
• Log files and timestamps
• Security and authentication information
2.4 App Permissions
If you use the MyTontine App, we may request permissions such as:
• Internet/network access
• Secure authentication access
• Push notification permissions
• Biometric authentication (if enabled by you)
These permissions are used solely to provide Platform functionality and security.
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3. How We Use Personal Data
We process personal data only where there is a lawful basis under Article 6 GDPR.
3.1 To Provide Services (Contractual Necessity)
We use your data to:
• Establish and administer trust structures
• Manage accounts and member participation
• Process distributions
• Provide reporting and statements
• Deliver customer support
3.2 For Legal and Regulatory Compliance
We may process data to:
• Comply with anti-money laundering (AML) and regulatory obligations
• Conduct identity verification
• Respond to legal requests
• Meet accounting and reporting requirements
3.3 For Legitimate Interests
We may process data for:
• Platform security and fraud prevention
• Improving services and user experience
• Internal administration
• Risk management
Where we rely on legitimate interests, we ensure such interests are not overridden by your fundamental rights and freedoms.
3.4 Based on Consent
Where required, we rely on consent for:
• Marketing communications
• Certain cookies or analytics tools
• Optional app features
You may withdraw consent at any time.
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4. We Do Not Sell Personal Data
Tontine Trust does not sell personal data to third parties.
We do not engage in data brokerage or monetization of personal information.
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5. How We Share Personal Data
We only share personal data where necessary to provide services or comply with legal obligations.
This may include:
• IT and hosting providers
• Custodians or financial institutions (where required)
• Compliance and identity verification providers
• Professional advisers (legal, audit, regulatory)
• Authorities where legally required
All service providers are contractually required to:
• Process data only on our instructions;
• Maintain confidentiality;
• Implement appropriate security measures;
• Comply with GDPR requirements.
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6. International Transfers
Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including:
• EU Standard Contractual Clauses;
• Adequacy decisions by the European Commission;
• Other legally recognized safeguards.
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7. Data Retention
We retain personal data only as long as necessary for:
• Providing services;
• Meeting contractual obligations;
• Complying with legal and regulatory requirements;
• Resolving disputes and enforcing agreements.
Regulatory obligations may require retention for a specified minimum period under Swedish and EU law.
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8. Security of Personal Data
We implement appropriate technical and organizational measures to protect personal data, including:
• Encryption where appropriate;
• Secure servers and infrastructure;
• Access controls and authentication safeguards;
• Monitoring for unauthorized access.
While we take reasonable steps to protect data, no system can guarantee absolute security.
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9. Electronic Communications
9.1 Service Communications
By using the Platform, you agree to receive necessary service communications, including:
• Account notifications
• Distribution notices
• Security alerts
• Legal updates
• Administrative communications
These are essential to providing services and cannot be opted out of while you maintain an account.
9.2 Marketing Communications
Where you have opted in, we may send marketing emails. You may unsubscribe at any time via the link provided in the email.
9.3 Push Notifications
If you enable push notifications in the App, we may send:
• Account updates
• Trust activity alerts
• Security notifications
• Important service announcements
You may disable push notifications in your device settings.
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10. Cookies and Tracking Technologies
The Website may use cookies and similar technologies to:
• Ensure proper functionality;
• Improve user experience;
• Analyze site usage;
• Enhance security.
Where required by law, we obtain your consent before placing non-essential cookies.
Details are available in our Cookie Policy [or cookie banner system].
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11. Your Rights Under GDPR
You have the following rights:
• Right of access
• Right to rectification
• Right to erasure (“right to be forgotten”)
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent (where processing is based on consent)
To exercise your rights, contact us at [email protected].
You also have the right to lodge a complaint with:
Integritetsskyddsmyndigheten (IMY)
Sweden’s supervisory authority for data protection.
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12. Children’s Data
The Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children.
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13. Changes to This Privacy Policy
We may update this Privacy Policy periodically. Updated versions will be published on this page with a revised “Last Updated” date.
Continued use of the Platform after updates constitutes acknowledgment of the revised policy.
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14. Contact Us
If you have questions about this Privacy Policy or our data practices, please contact:
Tontine Trust Europe KB
Kungsbro Strand 29 112 26 Stockholm, Sweden
Email: [email protected]
Website: https://tontine.com