ON THIS PAGE
1. About this Privacy Policy
2. Scope and our role
3. Personal data we may collect
4. How we collect personal data
5. Why we use personal data
6. KYC, KYB and compliance screening
7. Cookies and similar technologies
8. When we share personal data
9. International data transfers
10. Data retention
11. How we protect personal data
12. Automated processing and decisions
13. Marketing communications
14. Your privacy rights
15. Children’s privacy
16. Third-party services and links
17. Applicable privacy frameworks
18. Complaints and supervisory authorities
19. Changes to this Privacy Policy
20. Contact us
1. About this Privacy Policy
This Privacy Policy explains how Titan Global Technologies Limited (“Titan”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal data when you visit titangt.net, contact us, apply to use our technology platform, interact with our portals or applications, or access services made available through our partner ecosystem.
Titan Global Technologies Limited is incorporated in Hong Kong. Our registered address is Unit 1603, 16/F, The L. Plaza, 367–375 Queen’s Road Central, Sheung Wan, Hong Kong.
This Policy should be read together with our Cookie Policy, Website Terms of Use and any product-specific, onboarding or partner privacy notice presented to you.
2. Scope and our role
This Policy applies to personal data processed by Titan in connection with our website, technology platform, customer and partner relationships, communications, demonstrations, applications and support services.
Titan provides technology and orchestration services. Accounts, payment execution, acquiring, card issuance, safeguarding, foreign exchange, remittances, Digital Assets services, identity verification and other regulated or specialist functions may be delivered by third parties. Depending on the service and applicable law, a partner may act as:
- an independent data controller responsible for its own purposes and legal obligations;
- a joint controller with Titan where responsibilities are agreed and disclosed; or
- a processor or service provider acting only on documented instructions.
Where a partner acts as an independent controller, its privacy policy will govern its processing. You should review the partner notice provided during onboarding or before using that service.
3. Personal data we may collect
The information collected depends on how you interact with Titan and which services you request. It may include:
- Identity and profile information, such as name, date of birth, nationality, photograph, identification-document details and signatures where required.
- Contact information, including business or residential address, email address and telephone number.
- Business and professional information, including company name, registration details, role, ownership or control information, industry and business activity.
- Verification and compliance information, such as KYC/KYB results, sanctions or PEP screening results, risk classifications, source-of-funds or source-of-wealth information and supporting documents where required by law or a service provider.
- Account and service information, including application status, product selections, user permissions, limits, preferences, support history and partner-service identifiers.
- Transaction and technical records made available to Titan where necessary to display, route, reconcile, support or secure a service. Titan may not receive or retain all information held by the regulated service provider.
- Device and usage information, including IP address, browser type, operating system, device identifiers, access times, pages viewed, referral source, logs and diagnostic information.
- Communications, including emails, enquiries, call notes, meeting records, feedback and customer-support interactions.
- Marketing preferences and records of consent, opt-out requests and engagement with communications.
Please do not send special-category or highly sensitive information unless Titan or an approved provider specifically requests it through an authorized and secure process.
4. How we collect personal data
- Directly from you when you submit a form, create an account, request a demonstration, contact us, complete onboarding or use our services.
- From your employer, company administrator, authorized representative, beneficial owner, colleague or other person acting for an organization.
- From approved partners, including identity-verification providers, regulated financial institutions, payment providers, card-program providers, Digital Assets providers and fraud-prevention services.
- From publicly available and lawful sources, such as corporate registers, sanctions lists, regulatory databases, professional networks and fraud-prevention databases.
- Automatically through cookies, logs and similar technologies when you use our website or platform.
5. Why we use personal data
Subject to applicable law, Titan may process personal data for the following purposes and legal grounds:
- To provide, administer and support our website, platform, portals, applications, APIs and customer relationships; to take steps at your request before entering into a contract; and to perform our contractual obligations.
- To assess applications, facilitate onboarding and connect eligible users with suitable technology or regulated partners.
- To verify identity and business information, prevent fraud, conduct screening and support legal or partner compliance obligations.
- To protect our systems, users and partners; investigate suspicious activity; manage access; maintain audit records; and respond to security incidents.
- To process enquiries, provide support, communicate service information and manage complaints.
- To improve functionality, performance, user experience, analytics and product development using information that is aggregated or minimized where reasonably possible.
- To comply with applicable laws, lawful requests, court orders, regulatory obligations and the establishment, exercise or defence of legal claims.
- To send marketing communications where you have consented or where otherwise permitted, always subject to your right to opt out.
Where consent is the legal basis, you may withdraw it at any time. Withdrawal will not affect processing already carried out lawfully. Where we rely on legitimate interests, we consider the impact on your rights and apply proportionate safeguards.
6. KYC, KYB and compliance screening
Titan may use specialist providers, such as an approved KYC/KYB and compliance-technology provider, to verify identity, validate documents, conduct liveness or biometric checks, screen against sanctions and politically exposed person lists, identify adverse media and support fraud or transaction-risk controls.
The precise provider and checks may vary according to the product, partner, customer type and jurisdiction. The provider may process personal data on Titan’s instructions, on a regulated partner’s instructions, or as an independent controller. The relevant onboarding screen or partner notice will identify the applicable arrangement where required.
A regulated partner may require additional information and may make its own eligibility, compliance or risk decision. Titan does not control every decision made independently by a regulated provider.
7. Cookies and similar technologies
Our website may use essential cookies necessary for security, navigation and core functionality. With your consent where required, we may also use analytics, preference or marketing technologies to understand website use and improve communications.
You can manage non-essential cookies through our cookie banner or browser settings. Blocking essential cookies may affect website or account functionality. More information will be available in our Cookie Policy and cookie-preference centre.
8. When we share personal data
We may disclose personal data only where reasonably necessary and permitted by law, including to:
- regulated banks, EMIs, payment institutions, acquirers, card issuers, remittance providers, foreign-exchange providers and Digital Assets providers selected for the requested service;
- identity-verification, screening, fraud-prevention, cybersecurity and compliance-technology providers;
- hosting, cloud, communications, analytics, customer-support, software-development and professional-service providers;
- Titan group entities, contractors and personnel who need access for authorized business purposes and are subject to appropriate obligations;
- auditors, insurers, legal advisers, accountants, corporate-service providers, investors or prospective transaction parties under appropriate confidentiality and due-diligence controls; and
- courts, regulators, law-enforcement bodies, tax authorities or other competent authorities where disclosure is legally required, proportionate or necessary to protect rights or prevent harm.
Titan does not sell personal data in exchange for money. If applicable law defines “sale” or “sharing” more broadly, we will provide any legally required notice and choices.
9. International data transfers
Titan operates internationally and works with providers in different jurisdictions. Personal data may therefore be accessed, hosted or processed outside Hong Kong or the country in which it was collected.
Where required, Titan will use appropriate safeguards for international transfers, which may include contractual protections, approved standard clauses, adequacy mechanisms, transfer assessments, encryption, access restrictions and data minimization. A regulated or independent partner remains responsible for its own international-transfer obligations.
10. Data retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including to provide services, maintain security and audit records, resolve disputes and satisfy legal, tax, contractual or regulatory obligations.
Retention periods vary according to the data type, service, jurisdiction, partner requirements, legal limitation periods, fraud risk and whether an account or commercial relationship remains active. When data is no longer required, we will delete, anonymize or securely isolate it, subject to lawful exceptions and technical backup cycles.
11. How we protect personal data
Titan applies technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration or disclosure. Measures may include encryption in transit, access controls, multi-factor authentication, role-based permissions, logging, secure development practices, monitoring, backups, incident management and vendor due diligence, as appropriate to the risk.
Our partners are responsible for the security controls and certifications applicable to the services they provide. A partner’s ISO, PCI DSS, SOC or similar status does not automatically mean that Titan holds the same certification. No system is completely secure, and we cannot guarantee absolute security.
12. Automated processing and decisions
Titan and its partners may use automated tools to support identity verification, fraud detection, sanctions screening, risk scoring, routing or service eligibility. These tools may flag a case for review or contribute to a decision.
Where applicable law gives you rights in relation to a decision based solely on automated processing that produces legal or similarly significant effects, you may request information, human review or contest the decision. Some regulated partners make independent decisions under their own policies and legal obligations.
13. Marketing communications
We may send product, partnership, event or company communications where you have consented or where permitted by applicable law. You may opt out at any time by using the unsubscribe link or contacting legal@titangt.net. We may still send non-marketing messages necessary for security, service administration or contractual matters.
14. Your privacy rights
Your rights depend on the law applicable to the processing. Subject to legal conditions and exemptions, you may have the right to:
- request access to personal data held about you and information about how it is used;
- request correction of inaccurate or incomplete personal data;
- request deletion or erasure in circumstances provided by law;
- restrict or object to particular processing, including direct marketing;
- withdraw consent where processing is based on consent;
- receive certain personal data in a portable format;
- request review of qualifying automated decisions; and
- lodge a complaint with the competent data-protection authority.
To exercise a right, contact legal@titangt.net. We may request information necessary to verify your identity and authority. We will respond within the period required by applicable law. A request may be limited or refused where a legal exemption applies, the rights of another person would be affected, or retention is legally required.
If your request concerns data controlled by a regulated or independent partner, we may direct you to that partner or assist in forwarding the request where appropriate.
15. Children’s privacy
Titan’s website and services are intended for adults and organizations and are not directed to children under 18. We do not knowingly collect personal data from children through the website. If you believe a child has provided personal data without proper authorization, contact us so that we can investigate and take appropriate action.
16. Third-party services and links
Our website and platform may contain links to or integrations with third-party websites, applications and services. Titan is not responsible for the privacy practices of independent third parties. Please review their privacy notices before providing personal data or using their services.
17. Applicable privacy frameworks
Titan’s handling of personal data may be subject to the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486). Depending on the location of our operations, users and processing activities, other laws may also apply, including the DIFC Data Protection Law No. 5 of 2020, the UAE Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data, and the EU or UK General Data Protection Regulation.
References to these frameworks do not state that every law applies to every processing activity. Titan will determine the applicable requirements based on the relevant entity, service, user, processing location and jurisdiction.
18. Complaints and supervisory authorities
Please contact us first at legal@titangt.net so we can investigate and attempt to resolve your concern. Where applicable, you may also complain to the relevant supervisory authority, including:
- The Office of the Privacy Commissioner for Personal Data, Hong Kong: www.pcpd.org.hk
- The Commissioner of Data Protection, DIFC: www.difc.com/business/registrars-and-commissioners/commissioner-of-data-protection
- Your local data-protection authority in the European Economic Area, United Kingdom or other applicable jurisdiction.
19. Changes to this Privacy Policy
We may update this Policy to reflect changes in our services, providers, processing practices or legal requirements. The revised version will be published on our website with an updated effective date. Where a change materially affects your rights or how we use personal data, we will provide additional notice where required.
20. Contact us
Privacy and data-protection enquiries may be sent to:
Titan Global Technologies Limited
Unit 1603, 16/F, The L. Plaza
367–375 Queen’s Road Central
Sheung Wan, Hong Kong
Email: legal@titangt.net
Website: https://titangt.net
Questions about this document? Write to info@titangt.net.