GLB Privacy Notice
Last Updated: December 23, 2025
FACTS: WHAT DOES TRILLION CAPITAL MARKETS INC. DO WITH YOUR PERSONAL INFORMATION?
At Trillion Digital, we are committed to protecting the confidentiality and security of the personal information entrusted to us. As a financial services company, we are subject to the Gramm-Leach-Bliley Act (GLBA), a federal law that governs how financial institutions collect, use, safeguard, and share consumer financial information.
Federal law requires us to provide you with this notice, so you understand:
- What personal information we collect
- How we use and share that information
- How we protect your information
- Your rights regarding certain types of information sharing
We apply this policy not only because it is legally required, but because transparency, data protection, and responsible data stewardship are core components of our compliance and risk management framework.
Why?
Financial companies, including Trillion Digital, may share personal information in order to operate safely, efficiently, and in compliance with legal and regulatory obligations.
What we share for everyday business purposes
We may share your personal information for our everyday business purposes, which include:
- Processing transactions you request
- Maintaining and servicing your account(s)
- Providing customer support
- Detecting and preventing fraud
- Managing risk and ensuring operational security
- Responding to court orders, subpoenas, or lawful investigations
- Complying with federal, state, and regulatory reporting requirements (including reporting to credit bureaus where applicable)
This type of sharing is permitted by federal law and is necessary for us to provide financial services and meet our regulatory obligations. Under the Gramm-Leach-Bliley Act, consumers do not have the right to limit this type of information sharing.
What we collect
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
- Social Security number and government-issued identification
- Account balances and transaction history
- Wire transfer and digital asset transaction information
- Income, assets, and employment information
- Digital asset wallet addresses and blockchain transaction data
When you are no longer our customer, we continue to share your information as described in this notice.
How we may access, review, retain, and disclose personal information
Trillion Digital reserves the right to access, review, retain, and disclose personal information where we determine, in good faith and consistent with applicable law, that such action is necessary to:
- Comply with applicable federal, state, or local laws, regulations, regulatory guidance, legal processes, subpoenas, court orders, or lawful governmental requests;
- Enforce this Privacy Notice and our Terms of Service, including the investigation of potential violations;
- Detect, investigate, prevent, or address fraud, financial crime, security incidents, cybersecurity threats, or technical issues;
- Respond to customer service inquiries or support requests; or
- Protect the rights, property, safety, and security of Trillion Digital, our customers, our partners, or the public.
Reasons we can share your personal information
| Reasons we can share your personal information | Does Trillion share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes - to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | No | We don't share |
| For our affiliates' everyday business purposes - information about your transactions and experiences | No | We don't share |
| For our affiliates' everyday business purposes - information about your creditworthiness | No | We don't share |
| For affiliates to market to you | No | We don't share |
| For nonaffiliates to market to you | No | We don't share |
Who we are
| Who is providing this notice? | Trillion Capital Markets Inc. d/b/a Trillion Digital, a Florida corporation registered as a Money Services Business (MSB) with FinCEN (Registration No. 31000289656453) and licensed as a Money Transmitter in the State of Florida (License No. FT230000409) under Florida Statutes Chapter 560. |
What we do
| How does Trillion Capital Markets protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards such as firewalls and data encryption, secure technology infrastructure, physical access controls to our facilities, and limiting access to information to those employees for whom access is necessary to perform their job responsibilities. |
| How does Trillion Capital Markets collect my personal information? | We collect your personal information, for example, when you:
We also collect your personal information from third parties, such as identity verification services and public databases, as part of our compliance obligations. |
| Why can't I limit all sharing? | Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing. |
Definitions
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies. Trillion Capital Markets Inc. does not have any affiliates. |
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies. Trillion Capital Markets Inc. does not share with nonaffiliates so they can market to you. |
| Joint Marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Trillion Capital Markets Inc. does not jointly market. |
Other important information
Service Providers
We may disclose nonpublic personal information about you to companies that perform services on our behalf, such as identity verification services, blockchain analytics providers, payment processing, and regulatory compliance services. These companies are contractually obligated to keep the information we provide to them confidential and to use the information only for the services for which we engaged them.
Legal and Regulatory Requirements
We may disclose nonpublic personal information about you to comply with federal, state, or local laws; to comply with a civil, criminal, or regulatory investigation, subpoena, or summons by federal, state, or local authorities; or to respond to judicial process or government regulatory authorities having jurisdiction over us for examination, compliance, or other purposes as authorized by law.
Bank Secrecy Act (BSA) Compliance
As a registered Money Services Business, we are required to collect and maintain certain customer identification information under the Bank Secrecy Act and its implementing regulations. We maintain comprehensive Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) programs, including Customer Due Diligence (CDD) and ongoing transaction monitoring. We may share information with government authorities, including FinCEN, as required by law.
OFAC Compliance
We are fully compliant with Office of Foreign Assets Control (OFAC) regulations, ensuring that all transactions and client engagements do not contravene any U.S. economic and trade sanctions. We screen all customers and transactions against OFAC sanctions lists.
Record Retention
We maintain detailed records of all transactions and client information as required by applicable laws and regulations. Records are typically retained for a minimum of five (5) years following the termination of the customer relationship, or longer if required by law.
California Residents
We will not share information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example, with your consent or to service your account.
Contact Information
This notice is provided pursuant to the Gramm-Leach-Bliley Act (15 U.S.C. § 6801 et seq.) and its implementing regulations.