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Coinchange Privacy Policy

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This policy (the "Privacy Policy") sets out the privacy practices of Coin Change Financials Inc. ("we", "us" or "our"), a corporation formed pursuant to the Canada Business Corporations Act (R.S.C., 1985, c. C-44) in Canada.

The Privacy Policy addresses how we collect, store and use your personal information related to our website ("Website") our online crypto currency exchange and any other applications for platforms which we may subsequently offer (the "Service"). The Website and web-based portion of the Service are hosted at coinchange.io and other domains and sub-domains.

At our discretion, we may amend this Privacy Policy at any time. Any changes will be reflected here, so we encourage you to visit this page regularly. We will also notify our registered users of updates to this Privacy Policy via email or in your account. Your continued use of our Website and Service after any amendments shall be regarded as acceptance of such amendments.


We ask our clients for no more personal information than necessary.


We need to collect personal information from our clients and prospective clients in order to provide services to you and fulfill our legal obligations. This is both a regulatory requirement and good business. We are committed to protecting our clients' privacy and the confidentiality of their personal information in our possession. This memorandum explains the measures we take to fulfill these commitments.

The "Know Your Client" information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone and fax numbers, email addresses, birth date, social insurance numbers (for tax reporting purposes), asset holdings and values, investment knowledge and objectives. We also collect your chequing account information, transactional history, account balances/limits and optional beneficiary information (e.g. spouse's name and occupation, children's and dependents' names and ages).

To establish an account with us, we collect your personal and business information including, but not limited to, your:
  • Full legal name;
  • Email address;
  • Phone number;
  • Business name(s) if applicable;
  • Mailing address;
  • Address associated with your bank account;
  • Payment and banking information;
  • Identity verification documents which you upload or otherwise provide to us, including the information provided to us via Jumio Corporation ("Jumio");
  • IP address and location data, including geo-location data;
  • Website statistics and analytics data regarding your use of the Website and Service;
  • Other types of raw data relating to how you interact with the Website and Service, for example, your browser information and session duration;
  • Comments, feedback, reviews and other information you upload or provide to the Website or Service;
  • The contents of your correspondence with us; and
  • All other information you provide on our Website, Service or otherwise in correspondence with us.
To the extent you provide us with, or upload data that includes the personal information of another person, you represent and warrant that you have their authorization to provide us with that information.

We limit the use of your personal information.

The personal information we collect when you open an account is used for the following purposes:

  • helping us choose the portfolio that best fits you and your needs;
  • verifying your identity and other information you have provided to us;
  • opening and servicing your account;
  • sending and receiving bill payments through your chequing account;
  • detecting and preventing fraud and other unauthorized or illegal activities;
  • meeting legal and regulatory requirements;
  • transferring your account to or from another institution; and
  • as otherwise required or permitted by applicable law


Use of Location Services

Our Service may use location services made available online. Location services allows location-based apps and websites to use information from internet service providers, cellular, Wi-Fi, Global Positioning System (GPS) networks to determine your approximate location.

We use location services to verify you are using our Service, or, registered for our Service from within Canada. You can turn off location services on your mobile device and in your internet browser if you are accessing the Service via our web application.

The Use of Your Personal Information

The collection of your personal information may also be used to:

  • Facilitate the ordinary operation of the Website and Service, including providing your personal and business information to third-party service providers and payment processors;
  • Verify your identity and contact information via Jumio (Privacy Policy)
  • Promote our Website and Service offerings to you in various forms of communication;
  • Provide user support and to improve the Website and Service we offer;
  • Communicate with you about your account or services we offer;
  • Bill and collect money owed to us;
  • Pursue available legal remedies to us and to prosecute or defend a court, arbitration or other proceeding;
  • Send or display informational and promotional materials from us, our partners or other third parties to you;
  • To meet legal requirements, including but not limited to, reporting to governments or government agencies to comply with any applicable laws, rules or regulations;
  • Seek advice from our legal and other advisors; and
  • To enforce compliance with any terms and conditions or applicable law.

IN ADDITION, WE RESERVE THE RIGHT TO PROVIDE YOUR CONTENT AND INFORMATION (INCLUDING BUT NOT LIMITED TO YOUR PERSONAL AND BUSINESS INFORMATION) UPLOADED OR COLLECTED BY OUR WEBSITE, SERVICE OR OTHERWISE TO THIRD PARTIES IF REQUIRED BY LAW (SUCH AS IN RESPONSE TO A SUBPOENA, COURT ORDER OR OTHER LEGAL PROCESS IN ANY JURISDICTION), AND TO COOPERATE WITH LAW ENFORCEMENT AUTHORITIES IN THE INVESTIGATION OF ANY CRIMINAL OR CIVIL MATTER.

IF WE ARE REQUIRED BY LAW TO MAKE ANY DISCLOSURE OF YOUR CONTENT OR PERSONAL OR BUSINESS INFORMATION, WE MAY (BUT ARE NOT OBLIGATED TO) PROVIDE YOU WITH WRITTEN NOTICE (TO THE EXTENT PERMITTED BY LAW) PRIOR TO SUCH DISCLOSURE SO THAT YOU MAY TAKE APPROPRIATE ACTION.
We implement safeguards to protect personal information.

We maintain reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification and disclosure of. We train our employees to keep clients' personal information strictly private and confidential. We require all our staff to sign our privacy document that obliges them to respect and protect clients' personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients' personal information.

Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

We have personal information retention processes designed to retain personal information of our clients and prospective clients for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal requirements.

WHILE WE TAKE MEASURES TO PROTECT PERSONAL INFORMATION, YOU AGREE THAT, TO THE FULLEST EXTENT PERMITTED BY LAW, IN NO EVENT WILL WE, OUR AFFILIATES, OFFICERS, DIRECTORS, SHAREHOLDERS, EMPLOYEES, CONTRACTORS, ADVISORS OR AGENTS, BE LIABLE, HOWSOEVER CAUSED, FOR THE LOSS OR THEFT OF YOUR PERSONAL INFORMATION OR ANY DAMAGES CAUSED AS A RESULT THEREOF, SO LONG AS WE WERE NOT GROSSLY NEGLIGENT IN THE PROTECTION OF SAID INFORMATION.

Retention of Your Personal Information

We keep your personal information for as long as it is required for the purpose for which it was collected. There is no single retention period applicable to the various types of personal information collected. If you have closed your account on the Service and wish to ensure your personal information is deleted, please contact us at account@coinchange.ca.

If you believe that we have not adhered to this Privacy Policy or would like to request an amendment to your personal information being held by us, please contact us by e-mail at account@coinchange.ca. Only amendments which can be verified by us will be accepted.

Use of Cookies

We use "cookies" to collect information about you and your activity across our site. A cookie is a small piece of data stored on your computer and accessed each time you visit our Website and Service, so we can understand how you use our Service and serve you content or save setting you have specified.

If you do not wish to accept cookies from us, you should instruct your browser to refuse cookies from our Website and Service, with the understanding that we may be unable to provide you with some of your desired service without them. This policy covers only the use of cookies between your computer and our Website and Service; it does not cover the use of cookies by any third-party advertisers.

Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. timezone, notification preferences and usernames), and to personalise your content.

Types of cookies and how we use them

Cookies set by the website you are visiting are normally referred to as "first-party cookies", and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called "third-party cookies" and can be used to track you on other websites that use the same third-party service.

Essential cookies

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, and payment processing. We use essential cookies to enable certain functions on our Website and Service.

Performance cookies

Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience's overall website experience. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use performance cookies on our Website and Service.

Functionality cookies

Functionality cookies are used in collecting information about your device and any settings you may configure on the website you are visiting (like language and time zone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use functionality cookies for selected features on our Website and Service.


Targeting/advertising cookies

Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you are visiting (first-party) or by third-party services. Targeting/advertising cookies set by third parties may be used to track you on other websites that use the same third-party services. We use targeting/advertising cookies on our site.

Third-party cookies on our site

We may employ third-party companies and individuals on our websites - for example, analytics providers and content partners. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by Newton Crypto Ltd.'s cookie policy. You should disable cookies if you do not wish to permit third-party cookies to track your usage.

We take privacy seriously.

Our Chief Compliance Officer, Amber Scott, is responsible for ensuring that Coinchange adheres to its privacy policy. The Chief Compliance Officer is responsible for training our employees in our privacy policies and for monitoring the fulfillment of our privacy commitments. We invite any client or prospective client to contact him at the contact information set out below for any additional clarification desired. A client wishing to review his or her personal information in our possession should send a written request to this effect to our Chief Compliance Officer.

We will provide you with access to your information.

Individuals have the right to access, update, and correct inaccuracies in his/her personal information in our custody and control, subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account and clicking "Settings". Otherwise, an individual wishing to request access, updating and corrections of inaccuracies in other of his or her personal information in our possession or control may send a written request to this effect to our Chief Compliance Officer at the contact information below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Coin Change Financials Inc
200-250 University Ave,
Toronto, ON M5H 3E5
or
ATTN: Complaints
complaints@coinchange.ca

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Last Modified: November11, 2020
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