Personal Information We Collect

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We may collect your name, email address, IP address, payment information and any other information that you provide to us directly when you use our Services, when you request information about our Services or otherwise communicate with us.

How We Use Your Personal Information

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, for legal and compliance, and to market our products and services, as described below.

A. Provide Our Services

We use your personal information to perform or fulfill our contract with you or a third party and provide you with access to our Services, including without limitation:

• Managing your information;
• Providing access to certain areas, functionalities, and features of our website;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our website, and policy changes;
• Processing your financial information and other payment methods to facilitate purchases and transfers via our Services.

B. Administrative Purposes

We use your information for our legitimate business interest, including without limitation:

• Pursuing our legitimate interests such as direct marketing, research and development, network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Improving, upgrading or enhancing our Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transfers and other compliance activities;
• Sharing information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Other uses as required to comply with our legal obligations.

C. Marketing our Products and Services

We may use personal information to tailor and provide you with content. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in "Contact Us" below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

How We Disclose Your Information

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. We do not sell individual personal information for any reason, including for marketing purposes.

A. Disclosures to Provide our Services

We may disclose your personal information to third parties, including without limitation:

• Customers. We provide our customers access to personal information for purposes of performing and fulfilling our contract with those customers.
• Other Users of the Services and Parties You Transact With. Some of your personal information may be visible to other users of the Services (e.g., information featured on a user profile). In addition, to complete purchases and transfers via the Services, we will need to share some of your personal information with the party that you are transacting with.
• Third Party Websites and Applications. You may choose to share personal information or interact with third-party websites and/or third-party applications, including, but not limited to, third-party electronic extensions. Once your personal information has been shared with a third-party website or a third-party application, it will also be subject to such third party’s privacy policy. We encourage you to closely read each third-party website or third-party application privacy policy before sharing your personal information or otherwise interacting with them. Please note that we do not control, and we are not responsible for the third-party website’s or the third-party application’s processing of your personal information.
• Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services.
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
• Affiliates. We may share your personal information with members of our corporate family.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be transferred as part of such a transaction, as permitted by law and/or contract.

Your Privacy Choices and Rights

A. Email Communications

If you receive an unwanted marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive equity-related emails required by the Services we provide. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding your investments that require legal notice, our Services, or updates to our Terms of Service or this Privacy Policy).

B. Your Privacy Rights

In accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; or (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (aka the right of data portability);
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion of your personal information; and
• Withdraw Your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in "Contact Us" below. We will process such requests in accordance with applicable laws. Note that our customers control how we process and store personal information of end users. If you are an end-user, please first contact the customer through whom you access our Services to request deletion of your personal information or withdraw your consent for processing.

Security of Your Information

We take steps designed to ensure that your information is treated securely and in accordance with this Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our website, by mail or by sending an email to you.

International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States, Canada, or other countries, which may have data protection laws that are different from the laws where you live. We endeavour to safeguard your information consistent with the requirements of applicable laws.

Retention of Personal Information

We store the personal information we collect as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Use of the Services by Minors

The Services are not directed to minors, and we do not knowingly collect personal information from individuals under the age of 18.