Privacy Policy

Privacy Policy

June 2, 2021 2023-09-27 20:01


This Privacy Policy represents the policy of the TUMA, a RightQode Inc. owned application, regarding the collection, use, and management of personal data belonging to:

  • All site visitors to the company’s website located at
  • Anyone who downloads or uses the company’s mobile application.

Site visitors, app users, and clients are referred to collectively as “users”. The Website and the Application together with the Services (as defined below) and all content contained therein are referred to collectively as the “resources” as further described in the User Agreement.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your personal data. If you do not agree with our policies and practices, your choice is not to use the resources. By accessing or using the resources, you indicate that you understand, accept, and consent to the practices described in this Policy. Unless an alternative lawful basis for processing personal data is available to the Company, the Company requires Users’ permission to collect, use, and disclose personal data, with some exceptions. The exceptions are determined by applicable law and can include times where legal, medical, or security reasons make it impossible or impractical to seek consent.

Collection of Information

The initial information we collect from you is the information that you provide to us via our resources. This includes information about a user including the legal full name, address, date of birth, mobile number, home address, email address and documentation to prove your identity (passport, driver’s license among others).

Also, you provide us with payment source and receiver information. Payment source information can include a debit visa card or credit card. Receiver information includes name, address, mobile phone number and/or bank account information.

When you give TUMA permission to access your contacts, this information is used to auto populate receiver information only upon adding a new recipient/beneficiary.  We do not store your contacts on our servers.

TUMA reserves the right to verify all the information that you provide to us via the resources (or the information that we collect using our third parties including the financial institution that issues your payment card you choose to use, the telecom companies that allow us to push your money to the receiver and the banking institutions through which your user receives the funds).

TUMA also has the right to confirm information provided with our identity verifying partners and electronic databases. TUMA may also choose to share your information with identity verifying partners, payment processor companies, banks, and telecom service providers. Occasionally, TUMA may prompt you to verify your identity and the identity of the receiver.

On accessing the resources, we may collect and store information regarding your use of the app and the associated service rendered. This includes the rate at which you use the app, the amount of time you spend on the app, you transaction history, and the details of your transfer and receivers.

When you reach out to our support team via chat or email, we may store information that you share with us.

Use Of Information

TUMA reserves the right to retain and utilize all the data and records you furnish, along with information inferred from your service usage and data acquired from third parties. This is done with the purpose of delivering the TUMA service to you and ensuring compliance with legal requirements, including those aimed at preventing fraud, money laundering, and other financial system abuses. Your data may be employed for transaction verification, contact for transaction finalization, and to facilitate our agents, partners, and service providers in fulfilling their roles in delivering the TUMA service. Additionally, we may leverage your data for service enhancement, problem-solving, the development of new products and services, and the creation of advertising, marketing, and promotional campaigns. Prior to sending you marketing communications regarding TUMA products and services, we will request your consent. More information regarding TUMA’s utilization of your data for marketing and promotional purposes can be found below.

TUMA is committed to safeguarding your information from being sold, rented, or shared with third-party marketers or unrelated entities for the purpose of advertising or selling other services to you. However, in accordance with applicable laws, TUMA may engage in cross-context behavioral advertising and collaborate with third parties to analyze the data collected from your online interactions with us, including our website, Facebook page, and Facebook advertisements, even if you are not a TUMA service user. This data, which may include Personally Identifiable Information, can be used by TUMA to promote, and advertise its services to you and others. We may tailor our marketing messages to you based on your service usage, the information you provide, or data we obtain about you, utilizing algorithms designed to anticipate your potential needs, drawing from your information and that of other TUMA service users. TUMA views such programs as beneficial for our current and potential users. However, if you reside in a jurisdiction where obtaining your consent is required for the use of your data in marketing and promotional activities, TUMA will refrain from using your data for these purposes unless you expressly “opt in” to such uses.

Sharing Your Personal Information

We highly value your personal information. Nonetheless, there are situations where it becomes essential for us to disclose your data for valid business reasons, such as running our app and delivering services to you, all in strict compliance with relevant laws and adherence to confidentiality and professional secrecy standards as mandated by professional and regulatory requirements. Furthermore, your personal information may also be revealed:

  1. To Other Users: This entails the sharing of a User’s personally identifying information within the Application, including their application profile.
  2. At the User’s Request: This encompasses sharing data with:
    • Other individuals as per the User’s request.
    • Business partners of the Company. For instance, if a User requests a service through a third-party partnership or promotional offering, certain data may be shared with those third parties. This could involve services, platforms, apps, or websites that integrate with the Company’s APIs.
  3. To the General Public: Queries or feedback submitted by Users through public forums like Company blogs and social media pages may be visible to the public, including any personal data contained in the questions or comments submitted.
  4. To the User Account Owner: If an account is managed by a User other than the registered account owner, information will be shared with the registered User account owner.
  5. To Company Subsidiaries and Affiliates: We share data with our subsidiaries and affiliates to assist us in delivering our services or performing data processing on our behalf.
  6. To Company Service Providers and Business Partners: The Company provides data to various entities, including vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:
    • Payment processors and facilitators.
    • Background check and identity verification providers (where applicable).
    • Cloud storage providers.
    • Marketing partners and providers of social media advertising services.
    • Data analytics providers.
    • Research partners involved in surveys or research projects.
    • Vendors assisting in enhancing application safety and security.
    • Consultants, legal professionals, accountants, and other professional service providers.
    • Insurance and financing partners.
  1. For Legal Reasons or in Dispute Scenarios: The Company may share Users’ personal data if compelled by applicable law, regulation, licensing requirements, legal processes, government requests, or safety concerns. This includes sharing personal data with law enforcement, public health authorities, government entities, or third parties as needed to enforce our User Agreement, protect Company rights, safety, or property, or address claims or disputes related to service usage. In cases where another person’s credit card is used, we may be obligated by law to share personal data, including trip or order information, with the credit card owner.

Additionally, personal data may be shared with others during negotiations or in connection with mergers, asset sales, consolidations, restructurings, financings, or acquisitions involving all or part of our business.


The Company may, with the user’s consent, share information about its products and services. Users can grant this consent when they register for the services as outlined in the User Agreement. If you have previously agreed to receive such marketing materials, you can choose to unsubscribe at any time. You retain the right to request that the Company cease contacting you for marketing purposes whenever you wish.

Protection of your data

Safeguarding your personal data is of utmost importance to the Company. In pursuit of this goal, the Company utilizes a combination of physical, electronic, and administrative measures designed to safeguard Users’ personal data, thereby mitigating the risks associated with inadvertent loss and unauthorized access, utilization, modification, or disclosure. User-provided information is securely stored on our protected servers behind firewalls, and any payment transactions are encrypted using SSL technology.  Additionally, each user is provided with a one-time password to login to the platform which expires right after the user has access to the platform. The Company securely stores User data on servers leased from a reputable third-party hosting service situated in Germany.

However, it’s important to note that the transmission of data over the Internet is not entirely foolproof. While the Company takes diligent measures to protect Users’ personal information, the security of data transmitted to our Resources cannot be guaranteed entirely. Any transmission of personal data is undertaken at the User’s own risk, and the Company cannot be held accountable for any attempts to bypass privacy settings or security measures on our Resources.

In certain cases, the Company may process, store, or transfer User data to a foreign country with varying privacy laws, which may not provide the same level of data protection as the laws applicable to a specific User. Under these circumstances, government entities, courts, law enforcement agencies, or regulatory bodies in that foreign country may potentially access a User’s personal data in accordance with the laws of that jurisdiction.


Cookies are small pieces of data that websites and online services stored on your computer or device when you interact with them. TUMA utilizes ‘cookies’ and other tracking mechanisms to aid in recognizing you, remembering your preferences, and facilitating your future transactions and interactions with us. Additionally, we employ these tracking mechanisms to gain insights into consumer behaviour on our services, thereby enhancing and streamlining its usability for future use. Settings to delete, block, and allow cookies are available in most browsers. Keep in mind that adjusting your cookie settings may affect your browsing experience on our services. Please reach out to us via if you encounter any issues.

User Rights

Subject to applicable legal provisions, you may possess various rights concerning the handling of your pertinent personal information, which encompass:

  1. The entitlement to request access to your personal information, including comprehensive insights into the nature, processing, and disclosure of said data.
  2. The prerogative to request rectification of any inaccuracies present in your personal information.
  3. The right to seek the deletion of your personal information. Please be aware that we will maintain a record of your name if you request the erasure of your personal information.
  4. The capacity to request limitations on our utilization of your personal information.
  5. The right to petition for the transfer of your personal information to another entity.

To ensure the safeguarding of your personal information, we will only act on your request after satisfying ourselves that we have effectively verified your identity and confirmed that you are indeed the individual making the request. Consequently, we may require evidence of your identity before we can honour these rights. If you possess an account with us, logging into your account and submitting a request through it will serve as verification, although we may solicit additional information if concerns arise about the security of your account. If you’d like to exercise these rights, please reach out to us at the information provided below:

Contact Information

Questions or any inquiries should be sent to Tuma, as follows:

online at

by post to: Tuma, attn: Customer service, Tuma, 7398 Yonge Street, Suite 1373, Thornhill ON L4J 8J2, registered with FINTRAC under no. M21515523