Tempus

Welcome to Tempus. This Privacy Policy explains how Tempus, Inc. ("Tempus," "we," "us," or "our") collects, uses, shares, and protects your information when you use our website, mobile applications, and all related services (collectively, the "Service").

We are committed to protecting your privacy and handling your data with transparency.

1. Information We Collect

We collect several types of information to provide and improve our Service.

1.1. Information You Provide Directly This includes Personally Identifiable Information (PII) you provide when you create an account, complete your profile, or contact us. This information may include:

Personal Details: Your full legal name, email address, physical address, phone number, and date of birth.

Identity Verification: Your Social Security Number (SSN) and/or a copy of your government-issued ID (required for federal "Know Your Customer" (KYC) and Anti-Money Laundering (AML) compliance).

Financial Information: Your bank account details, routing numbers, annual income, net worth, and investment objectives (necessary to recommend a suitable portfolio and process transactions).

1.2. Information We Collect Automatically When you use our Service, we may automatically collect technical information, including:

Device Information: Your IP address, device type, operating system, and browser type.

Usage Data: Information about how you interact with our Service, such as pages visited, features used, and the time and date of your visits.

2. How We Use Your Information

We use your information for several key purposes:

• To provide, maintain, and improve our Service, including opening your account, processing your transactions, and managing your investment portfolio.
• To verify your identity and comply with our legal and regulatory obligations.
• To communicate with you about your account, respond to support requests, and send you service-related updates or marketing communications (which you can opt out of).
• To secure our platform and protect against fraud, abuse, and other unlawful activities.
• To enforce our Terms of Service and other agreements.
• To fulfill our tax and regulatory reporting obligations.

3. Information Sharing

We do not sell, trade, or otherwise transfer your personal information to third parties for their marketing purposes. We only share your information in the following limited circumstances:

3.1. With Service Providers: We share information with third-party vendors who help us operate our Service. This includes our brokerage and clearing partners, custodians, cloud hosting providers (e.g., AWS), analytics partners, and identity verification services. These partners are legally and contractually bound to protect your data and use it only for the services we have engaged them for.

3.2. For Legal and Regulatory Purposes: We may disclose your information if we believe in good faith that it is required by law, such as to comply with a subpoena, SEC or FINRA request, court order, or other legal or regulatory process.

3.3. For Business Transfers: If Tempus is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our site of any change in ownership.

3.4. With Your Consent: We may share your information for other purposes not listed here, but only with your explicit and documented consent.

4. Data Security

We implement robust administrative, technical, and physical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

All data transmitted to and from our Service is encrypted using 256-bit SSL (Secure Sockets Layer) encryption, the same standard used by major banks. Your personal data is stored in a secure, encrypted environment, and access is restricted to authorized personnel only.

5. Data Retention

We will retain your personal information for as long as your account is active and for a necessary period thereafter.

Even after you close your account, we must retain certain information to comply with our legal and regulatory obligations (such as record-keeping rules set by the SEC, which typically require records to be kept for a minimum of five years), resolve disputes, prevent fraud, and enforce our agreements.

6. Your Rights and Choices

You have rights regarding the personal information we hold about you.

Access and Update: You can access and update most of your profile information at any time by logging into your account settings.

Delete Account: You may request to close your account by contacting us. Please note that we may be required to retain certain information as described in our "Data Retention" policy.

Opt-Out of Communications: You can opt out of receiving promotional or marketing emails from us by following the "unsubscribe" link in those communications. You will still receive essential, service-related emails about your account and transactions.

State-Specific Rights: Residents of certain states, such as California (under the CCPA), may have additional rights regarding their personal information. Please contact us for more details.

7. Cookies and Tracking

We use cookies and similar tracking technologies (like pixels and web beacons) to enhance your experience, remember your preferences, and analyze how our Service is used. Cookies help us understand user activity and improve our platform. You can typically set your browser to refuse cookies, but this may limit your ability to use certain features of the Service.

8. Children's Privacy

Our Service is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take immediate steps to delete it.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page, updating the "Last updated" date, and/or sending you an email notification. We encourage you to review this policy periodically.

10. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us at privacy@tempus.app