STUFF TECHNOLOGIES INC. PRIVACY POLICY (this “Privacy Policy”)

This Privacy Policy shall be effective starting on July 27, 2022

*Last updated: July 27, 2022

1. INTRODUCTION

1.1 Stuff Technologies Inc. (“Stuff Technologies”, “Coincards”, “we”, “us” and “our”) respects and protects the privacy of visitors (“you”, “your”) to our website and our customers who use our services. This Privacy Policy describes how your personal information (any information relating to you as an identified or identifiable natural person, that we may hold about you) is collected, used, stored, disclosed, and removed (each and all referred to as “processing”) when you access content we own or operate on the webpages located at www.Coincards.com or any other websites, pages, features, apps, or content we own or operate (collectively, the “Site(s)”) and/or when you use the Stuff Technologies services (collectively, the “Services”).

1.2 This Privacy Policy only applies to information we process. It does not apply to the practices of companies that we don’t own or control, or employees that we don’t manage. Information on our Services may contain links to third party websites or applications, and any information you provide to those sites will be covered by any privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit, or applications you use.

1.3 By accessing and using our Services, you explicitly accept the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as further described below. We may provide periodic updates about the data collection, use and sharing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

1.4 We reserve the right to modify this Privacy Policy at any time. If we make any material changes, we will notify you by e-mail (sent to the e-mail address specified in your account) and/or by means of a notice on our Site(s) prior to the change becoming effective.

 

 

PLEASE TAKE A MOMENT TO READ THIS PRIVACY POLICY CAREFULLY. IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY POLICY, PLEASE CONTACT US AT [email protected]. IF YOU DO NOT AGREE WITH OR YOU ARE NOT COMFORTABLE WITH ANY ASPECT OF THIS PRIVACY POLICY, YOU SHOULD IMMEDIATELY DISCONTINUE ACCESS OR USE OF OUR SERVICES.

 

2. THE PERSONAL INFORMATION WE COLLECT

2.1 This Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized information, as it cannot be used to identify you. It further does not apply to information that is not about you, therefore please avoid supplying us with any irrelevant information.

2.2 You may be asked to provide personal information anytime you use our Services or Site or are in contact with any Stuff Technologies-affiliated entity or individual. The Stuff Technologies-affiliated entities may share your personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, Services, and content (see the section below).

2.3 When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes, in order for you to use our Services. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all or any of our Services when you choose not to share certain information with us.

For example, we collect personal information which is required under the law to open an account, or execute a transaction. We also collect personal information when you use or request information about our Services, subscribe to marketing communications, or request support. We may use this information in combination with other information we collect about you as set forth in this Privacy Policy. Your personal information may also be processed for the purposes of protecting our users from illegal activity, maintaining legal and regulatory compliance and helping us to prevent, detect and investigate fraud, money laundering, terrorism financing and/or other criminal activity or misuse of our Services.

We may collect the following types of information:

  • Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or e-mail address.
  • Formal Identification Information: Incorporation and corporate subsistence records, non-expired government-issued photo ID cards and information thereon (i.e. passports, driver’s licenses, national identity card, permanent resident cards, citizenship cards, VISAs, etc.).
  • Transaction Information: Information about the transactions you make on our Services, such as your name, payment method, the fiat and crypto value, and/or timestamp.
  • Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.
  • Usage Data:  Information provided to our support team, authentication data, security questions, user ID, and other similar data.
  • Corporate Information: If you sign up as a corporate entity, we collect information and documentation related to the name, industry, ownership (including beneficial ownership), registration, country of incorporation, business address and financial information of the company. Company information may also contain personal identification information and formal identification information related to the company account holder, shareholders, beneficial owners and/or members of the board of directors of the company.

 

3. HOW YOUR PERSONAL INFORMATION IS USED

3.1 Our primary purpose in collecting personal information is to provide you with a secure, efficient, and customised experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content, and for loss prevention and anti-fraud purposes.

3.2 Some of our Services are subject to laws and regulations requiring us to collect and use the information listed herein in certain ways. For example, Know Your Client, Anti-Money Laundering and Counter-Terrorism Financing laws.

3.3 Should your use of our Services change, we may require you to provide additional information which we may use to verify your identity or address, and/or to manage risk as required under applicable law. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform the Services in accordance with legal and regulatory requirements.

3.4 We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to so limit the use of your personal information, certain features or Services may not be available to you.

EXCEPT AS DESCRIBED IN THIS PRIVACY POLICY AND OUR COOKIE POLICY, WE WILL NOT GIVE, SELL, RENT OR LOAN ANY PERSONAL INFORMATION TO ANY THIRD PARTY.

 

4. INFORMATION AND THIRD PARTIES

4.1 We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. We will only share your information in the following circumstances:

  • We may share your information with service providers under contract who help with parts of our business operations such as bill collection, legal services and technology services.
  • We share your information with payment processors with which we partner to process payments you have authorised.
  • We may share your information with companies or other entities that we plan to merge with or be acquired by. Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policies.
  • We may share your information with companies or other entities that purchase Stuff Technologies assets pursuant to a court-approved sale under Canadian bankruptcy or insolvency law.
  • We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.

5. HOW WE PROTECT AND STORE PERSONAL INFORMATION

5.1 We may store and process all or part of your personal and transactional information, including certain payment information in Canada and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining safeguards in compliance with the applicable laws and regulations.

For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our computers, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities.

5.2 We cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account.

5.3 We cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including e-mail, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information at the end of this Privacy Policy.

6. HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

6.1 You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account.

If you close your Coincards account, we will mark your account in our database as “Closed,” but will keep your account information in our database for 30 days. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by us for any further purposes except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

RETENTION OF PERSONAL INFORMATION

We store your personal information securely throughout the life of your Coincards account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.

  • Contact Information such as your name, e-mail address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list indefinitely.

HOW TO CONTACT US

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should can contact us at [email protected].

COMPLAINTS

You can also complain about our processing of your personal information to the relevant data protection authority. In Canada that is the Office of the Information & Privacy Commissioner of Canada, which can be reached at: 1-800-282-1376.