This Privacy Policy describes how Ethio American LLC, operating the Terenza platform at terenza.org, collects, uses, stores, and shares personal information. It is effective as of the date shown below and applies to all users of the Terenza website and services.
Ethio American LLC is a limited liability company organized under the laws of the United States. We operate the Terenza platform, a licensed cryptocurrency exchange and software wallet service. Our registered address for regulatory purposes is 3425 S 176 St Apt 284, SeaTac, WA 98188. Our operational office is located at 400 Interstate N Pkwy # 500, Atlanta, GA 30339.
Ethio American LLC is registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business (MSB) under the Bank Secrecy Act (BSA), 31 U.S.C. § 5311 et seq. This registration imposes specific data collection and retention obligations on us, which are reflected in this Privacy Policy.
For privacy-related inquiries, contact us at: support@terenza.org or by phone at +1 (404) 566-5855.
We collect personal information in the following categories, depending on how you interact with the Terenza platform:
Under the USA PATRIOT Act (31 U.S.C. § 5318(l)) and FinCEN's Customer Identification Program (CIP) rules, we are required to collect and verify the identity of every individual who opens an account. This includes: full legal name, date of birth, residential address, government-issued identification number (such as Social Security Number or Individual Taxpayer Identification Number), and a copy of a government-issued photo ID (such as a passport or driver's license).
Email address, phone number, and mailing address collected during account registration or contact form submissions.
Records of all transactions conducted through the Terenza platform, including dates, amounts, asset types, wallet addresses, and counterparty information where applicable. This data is retained as required under BSA regulations.
IP address, browser type, device identifiers, operating system, pages visited, time spent on pages, referring URLs, and other technical information collected automatically when you access our website. This data is collected through cookies and similar technologies. See our Cookie Policy for details.
Records of correspondence with our support team, including emails, form submissions, and any documentation you provide in connection with a support request or compliance inquiry.
We use personal information for the following purposes:
To fulfill our obligations under the Bank Secrecy Act, the USA PATRIOT Act, FinCEN regulations (31 C.F.R. Chapter X), and applicable state money services business laws. This includes identity verification, transaction monitoring, suspicious activity reporting, and currency transaction reporting.
To create, maintain, and administer your Terenza account. To authenticate your identity when you access the platform. To process your transactions and maintain records of those transactions.
To conduct customer due diligence (CDD) and, where applicable, enhanced due diligence (EDD). To screen customers and transactions against OFAC sanctions lists maintained by the US Department of the Treasury. To file required reports with FinCEN, including Currency Transaction Reports (CTRs) for transactions exceeding $10,000 and Suspicious Activity Reports (SARs) where warranted.
To respond to your inquiries, resolve disputes, and assist with account issues.
To analyze how the website is used in order to improve its functionality, performance, and user experience. This analysis uses aggregated and anonymized data where possible.
To comply with court orders, subpoenas, legal process, or lawful requests from government authorities, including law enforcement agencies and regulatory bodies with jurisdiction over our activities.
Terenza processes personal information on the following legal bases under applicable US law:
Legal Obligation: A substantial portion of our data processing is required by federal law. The Bank Secrecy Act, the USA PATRIOT Act, and FinCEN regulations mandate that we collect, verify, retain, and in some cases report certain customer information. We have no discretion to waive these requirements.
Contractual Necessity: Processing your account information, transaction records, and communications is necessary to provide the services described in our Terms of Use.
Legitimate Interests: We process technical and usage data to maintain the security and functionality of our platform, to detect fraud and unauthorized access, and to improve our services. These interests do not override your fundamental privacy rights.
Consent: Where we process data beyond what is legally required or contractually necessary, we will seek your consent. You may withdraw consent at any time, subject to any legal retention obligations that apply.
Terenza does not sell personal information to third parties. We share information in the following circumstances:
Government and Regulatory Authorities: We share information with FinCEN, the IRS, OFAC, and other federal and state regulatory bodies as required by law. This includes mandatory reporting of certain transactions and suspicious activity.
Law Enforcement: We respond to lawful requests from law enforcement agencies, including subpoenas, search warrants, and court orders. We may be prohibited by law from notifying you of such disclosures.
Service Providers: We share information with vendors who assist us in operating the platform, including identity verification services, cloud hosting providers, and compliance technology providers. These vendors are contractually bound to protect your information and may not use it for their own purposes.
Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
With Your Consent: We may share information for other purposes with your explicit consent.
We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with our legal obligations.
Under the Bank Secrecy Act (31 U.S.C. § 5318), we are required to retain records relating to customer identification and transactions for a minimum of five (5) years from the date of the transaction or the date the account is closed, whichever is later. Certain records may be retained for longer periods if required by other applicable laws or regulations.
Technical and usage data that does not relate to a specific transaction or regulatory requirement is typically retained for a shorter period and deleted or anonymized when no longer needed for operational purposes.
When data is no longer required to be retained, we take reasonable steps to securely delete or anonymize it.
Depending on your state of residence, you may have certain rights regarding your personal information under applicable state privacy laws.
Under the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA), California residents have the following rights:
To exercise these rights, contact us at support@terenza.org. We will respond within 45 days as required by the CCPA. Note that certain information may be exempt from deletion requests because we are legally required to retain it under the BSA.
Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and other states with comprehensive privacy laws may also have rights regarding their personal information. We will honor requests made under applicable state law. Contact us to submit a request.
Terenza uses cookies and similar tracking technologies on its website. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and understand how the site is used.
We use the following categories of cookies: strictly necessary cookies (required for the site to function), functional cookies (for preferences and settings), and analytics cookies (for understanding usage patterns). We do not use advertising or targeting cookies.
You can manage your cookie preferences through the cookie consent tool available on our website. Refusing non-essential cookies will not affect your ability to use the core features of the site. For full details, see our Cookie Policy.
We implement technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit and at rest, access controls limiting who can view sensitive information, periodic review of security practices, and staff training on data handling obligations.
No system is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other security incidents will never occur. If you believe your account has been compromised, contact us immediately at support@terenza.org.
In the event of a data breach that requires notification under applicable US law (including state breach notification laws such as the California Data Breach Notification Law, Cal. Civ. Code § 1798.82), we will notify affected individuals and relevant authorities as required.
Terenza services are not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If you believe we have inadvertently collected information from a minor, contact us immediately and we will take steps to delete that information, subject to any retention obligations imposed by law.
The Children's Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq., prohibits the collection of personal information from children under 13 without verifiable parental consent. We comply with COPPA and do not permit individuals under 18 to open accounts on the platform.
Terenza is operated from the United States and is intended for US-based customers. If you access the platform from outside the United States, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.
By using the Terenza platform, you acknowledge that your information will be processed in the United States in accordance with this Privacy Policy and applicable US law.
We may update this Privacy Policy from time to time to reflect changes in our practices, regulatory requirements, or platform features. When we make material changes, we will update the "Last Updated" date at the top of this document and, where required by law, provide notice to affected users.
We encourage you to review this Privacy Policy periodically. Continued use of the Terenza platform after changes become effective constitutes your acknowledgment of the updated policy.
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us:
Ethio American LLC
400 Interstate N Pkwy # 500
Atlanta, GA 30339
Email: support@terenza.org
Phone: +1 (404) 566-5855
We aim to respond to all privacy-related inquiries within 30 days. California residents may expect a response within 45 days as required by the CCPA.