*Last updated: July 27, 2022
2. THE PERSONAL INFORMATION WE COLLECT
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.
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.
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 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.
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.
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
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.