1. Who we are and what this policy covers
TSV LLC, a Puerto Rico limited liability company (TSV, we, us), operates the tokenized securities venue at tokenizedstockvenue.com. This Policy explains how we handle personal information about website visitors, applicants, participants, liquidity providers, authorized users and business contacts in connection with our website, interfaces, APIs and related services (Services).
TSV is responsible for the processing described here and acts as controller where that term applies. Issuers, transfer agents, wallet providers and other independent providers handle information under their own privacy notices. This Policy does not cover their separate services or other venues using the same technology.
2. Information we collect
We collect information from you, your organization or intermediary, transfer agents and other service providers, our systems, and relevant public records and distributed ledgers. Depending on your interaction with us, this includes:
Identity and contact information. Your name, contact details, organization, role and authority to act, and identity, ownership, sanctions and eligibility information needed for access or compliance. The transfer agent performs participant verification and holds the underlying verification records; TSV receives the results and supporting information needed for its responsibilities.
Account and transaction information. Approved wallet addresses and ledger-party identifiers, permissions, orders, transactions, fees, liquidity positions and related settlement records.
Technical and communication information. IP addresses, device and browser information, access times, usage and security logs, cookie or local-storage information, and correspondence, support requests and complaints.
3. How we use information
We limit collection, use and disclosure of confidential participant information to what is reasonably necessary for Venue operation, compliance, risk management and applicable legal obligations, consistent with item (w) of TSV's Public Notice. We use information to assess eligibility, administer access, facilitate trading and settlement, provide support, maintain records, calculate fees, meet legal and regulatory requirements, monitor market conduct, prevent fraud and security threats, investigate complaints and enforce or defend legal rights. We also use technical information to maintain and improve the Services and communicate service changes.
Where applicable law requires a legal basis, we rely on performing a contract with you or taking steps at your request; complying with legal obligations; legitimate interests in operating, securing and improving the Services and protecting legal rights, subject to your interests and rights; or consent where required. Required information may be necessary to provide or continue access. Consent may be withdrawn without affecting earlier lawful processing.
4. How we disclose information
We disclose relevant information, including confidential participant information and personally identifiable information, only as reasonably necessary for the purposes in Section 3 and consistently with TSV's Public Notice and applicable law:
To service providers and advisers. Affiliated or independent technology, hosting, security, compliance and support providers, and professional advisers, subject to appropriate confidentiality and data-use restrictions.
To support transactions and ownership records. Issuers, transfer agents, intermediaries, wallet or custody providers, settlement providers and authorized ledger participants, as needed for verification, processing, settlement or recordkeeping.
For legal and regulatory purposes. Regulators, law-enforcement authorities, courts or other persons where disclosure is required or permitted by law, including for investigations, fraud prevention and protecting legal rights.
For a business transaction or at your direction. Parties involved in a proposed or completed merger, financing or transfer of our business, or persons you authorize, only to the extent consistent with the limits above, applicable law and appropriate confidentiality protections.
We do not sell personal information or share it for cross-context behavioral advertising. Operational disclosures and required public trading data are described in this Policy.
5. Ledger records and public trading data
Canton selectively discloses transaction information to parties and infrastructure authorized to process or validate it. TSV also publishes post-trade information required by its regulatory framework, including asset symbols, price, size, time, direction and pool information. Identity-verification records and personally identifiable information are generally maintained separately from public trading data. We do not publicly disseminate confidential unexecuted trading intent.
Omitting names does not guarantee anonymity: transaction details or identifiers may be linked to you using other information. Ledger records and copies of public data may persist, and TSV may be unable to alter or delete copies outside its control. This does not remove our obligations under applicable privacy law. The public reporting arrangements are described at https://www.tokenizedstockvenue.com/notice.html.
7. Retention, security and international processing
We retain information for the period needed for the purposes described here, taking account of the relationship, record type, applicable recordkeeping duties, investigations, legal holds and claim periods. Required TSV books and records, including personal information they contain, are preserved in the United States while the TSV Exemption under SEC Release No. 34-106402 is effective and for three years after the end of that exemption, or longer where required by law or a legal hold. This duty continues after a participant stops using the Services. We delete or de-identify information under our control only after applicable retention duties have been satisfied and retention is no longer necessary; we do not delete, alter or de-identify required records in a way that impairs those duties. Ledger and public records remain subject to Section 5.
We maintain administrative, technical and organizational safeguards designed to protect information, including access restrictions and security monitoring. No system or transmission method is completely secure.
Information may be processed in the United States and other countries where our providers or authorized personnel operate. Privacy laws may differ. Where required, we use legally recognized transfer safeguards, such as approved contractual clauses, and supplementary measures. Contact us for information about applicable safeguards and how to obtain a copy. Such processing does not displace the United States recordkeeping requirement above.
8. Your choices and rights
Depending on applicable law, you may request access, correction, deletion or a portable copy of your information; object to or restrict processing; withdraw consent; or appeal a decision on your request. You may also have rights concerning decisions based solely on automated processing. Our access and monitoring controls use verification results and transaction or security information to flag activity or restrict access; contact us to raise an error or request review.
Send requests to legal@tokenizedstockvenue.com. We may verify identity and any representative's authority before acting. We respond within applicable legal time limits and explain any refusal or limitation. Rights may be subject to lawful exceptions, including regulatory recordkeeping, fraud prevention and other persons' rights. You may complain to your competent privacy authority, and we will not unlawfully discriminate against you for exercising your rights.
You may opt out of promotional messages using their unsubscribe instructions or by contacting us. Necessary service and compliance communications may continue.
9. Children
The Services are intended for persons aged 18 or older. We do not knowingly collect personal information from children. Contact us if you believe a child has provided information so we can take appropriate action.
10. Changes and contact
We may update this Policy and will display the revised effective date. We will provide additional notice of material changes and obtain consent where required by law. Using the Services is not, by itself, consent to processing that legally requires consent.
For privacy questions or requests, contact TSV LLC at legal@tokenizedstockvenue.com or 151 Calle de San Francisco, Ste 200 PMB 1513, San Juan, PR 00901.