Tesouro HQ, Inc. Privacy Policy
Your privacy is important to us at Tesouro. We respect your privacy regarding any information we may collect from you across our website.
This Privacy Notice for Tesouro HQ, Inc. (doing business as Tesouro) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
- Visit our website at https://www.tesouro.com, or any website of ours that links to this Privacy Notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at legal@tesouro.com.
Summary of Key Points
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents in the side floating navigation.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? No. We do not collect or process sensitive personal information through this website.
Do we collect any information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? Email us at privacy@tesouro.com with the subject line "Privacy request" and tell us what you'd like us to do. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
01What Information Do We Collect?
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information we collect through this website is limited to what you provide when you contact us via our "Book a 30-minute walkthrough" form:
- first and last name
- work email address
- job title
- company name
- business type (a self-selected category — Bank, Software Company, Payment Facilitator, ISO, or Other)
- any message content you choose to include
When you interact with our products as an end-user of a financial institution that has deployed Tesouro, the financial institution — not Tesouro — is the controller of that personal information. This Privacy Notice covers only the personal information we collect directly through this website.
Sensitive Information. We do not collect or process sensitive personal information (such as government identifiers, financial account numbers, racial or ethnic origin, sexual orientation, religious beliefs, biometric data, or precise geolocation) through this website.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
02How Do We Process Your Information?
We use the information you submit through this website for the following limited purposes:
- To respond to your inquiry. When you submit our "Book a 30-minute walkthrough" form, we use the information you provide to schedule and prepare for a conversation with you about Tesouro's products.
- To send marketing communications (only if you opt in). If you check the marketing-consent checkbox on the form, we may email you product updates and news. You can opt out at any time. See "What Are Your Privacy Rights?" below.
- To meet our legal obligations, such as responding to lawful requests from regulators or law enforcement.
- To protect the security of this website — for example, blocking abusive traffic and preventing form spam.
We do not use this information for cross-context behavioral advertising, profiling, or automated decision-making with legal effect.
03When And With Whom Do We Share Your Personal Information?
We may need to share your personal information in the following situations:
- Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Service providers we use
We share limited personal information with service providers who help us operate this website and respond to inquiries:
- AWS Amplify Hosting (Amazon Web Services, Inc.) — hosts the website, with CloudFront fronting the origin for edge caching, TLS termination, and DDoS protection. Receives standard HTTP request data (IP address, user agent, requested URL). No tracking cookies set.
- Google LLC (Google Workspace) — when you submit our contact form, your submission is stored in a Google Sheet owned by Tesouro and processed by a Google Apps Script we operate. Data is held in Google's US-based infrastructure under our Google Workspace agreement.
- Slack Technologies, LLC — when you submit our contact form, a notification (containing the same fields you submitted) is posted to an internal Slack channel so our team can respond promptly.
We do not sell personal information to any of these providers. They process it only on our instructions and only to deliver the service we have contracted them for.
Cross-border data transfers
Tesouro is based in the United States, and our service providers (Amazon Web Services, Google, Slack) host data in the United States. If you submit information from outside the US — including from the European Economic Area, the United Kingdom, or Switzerland — your information will be transferred to and processed in the US. Where required by law, we rely on Standard Contractual Clauses or equivalent safeguards with our service providers to protect this data.
04How Long Do We Keep Your Information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than sixty (60) months from your last contact with us, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
05How Do We Keep Your Information Safe?
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
06Do We Collect Information From Minors?
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@tesouro.com.
07What Are Your Privacy Rights?
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Information you submitted through our website
If you would at any time like to review, change, or delete the information you submitted through our "Book a 30-minute walkthrough" form, you can:
- Contact us at privacy@tesouro.com, or use the contact details provided below.
Upon your request, we will review, correct, or delete the information you submitted from our active records. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at privacy@tesouro.com.
08Controls For Browser Tracking Signals
Browser opt-out signals. Most browsers offer a "Do Not Track" (DNT) header, but no industry standard governs how websites respond to it, so we do not act on DNT signals. We do, however, honor the Global Privacy Control (GPC) signal. If GPC is enabled in your browser when you visit our site, we treat the visit as a request to limit any processing that would qualify as "sale" or "sharing" under applicable US state privacy laws.
09Do United States Residents Have Specific Privacy Rights?
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, work email address, and Internet Protocol address (in standard server logs) | YES |
| B. Personal information as defined in the California Customer Records statute | Name, work email address, job title, and company name | YES |
| C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | NO |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Job title and company name provided through our "Book a 30-minute walkthrough" form, and any information you provide if you apply for a job with us through our Careers page | YES |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics | NO |
| L. Sensitive personal Information | Debit or credit card numbers and social security numbers | NO |
Because we do not collect or process sensitive personal information through this website, the right to limit its use or disclosure does not apply here.
We retain information submitted through our contact form only as long as needed to respond to your inquiry and for a reasonable period afterward — typically no more than sixty (60) months from your last contact with us, unless you ask us to delete it sooner or we are required to retain it longer by applicable law. See Section 4 for our full retention practices.
Sources of Personal Information
Learn more about the sources of personal information we collect in "What Information Do We Collect?"
How We Use and Share Personal Information
Learn about how we use your personal information in the section, "How Do We Process Your Information?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "When And With Whom Do We Share Your Personal Information?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's privacy law)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)
How to Exercise Your Rights
To exercise these rights, email us at privacy@tesouro.com, or refer to the contact details at the bottom of this document.
We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@tesouro.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "How Can You Contact Us About This Notice?"
10Do We Make Updates To This Notice?
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
11How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at privacy@tesouro.com, or contact us by post at:
12How Can You Review, Update, Or Delete The Data We Collect From You?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, email us at privacy@tesouro.com.