Effective as of August 20, 2020

Privacy is of utmost importance at 170639 Canada Inc. (hereinafter “TrustSwap”). We recognize the significance of protecting information which is stored on our servers or network or is intended to be stored on our servers or network and which relates to an individual. The data we protect are the “Personal Data” which is any information relating to an identified or identifiable natural person, sometimes called a data subject, and have made protecting the privacy and the confidentiality of Personal Data a fundamental component of the way we do business. This Privacy Policy informs you of the ways we work to ensure privacy and the confidentiality of Personal Data and describes the information we gather, how we use those Personal Data and the circumstances under which we disclose such information to third-parties.

This Privacy Policy is designed to address regulatory requirements of the jurisdictions in which TrustSwap offers its Services, including the General Data Protection Regulation (“GDPR”), as enacted by the European Commission. In this Privacy Policy, the terms “Site” and “Services” have the same meaning as described in our Terms of Use. If you do not agree with this Privacy Policy, in general, or any part of it, you should not use the Services. This Privacy Policy is periodically reviewed to ensure that any new obligations and changes to our business model are taken into consideration. We may amend this Privacy Policy at any time by posting an amended version on our website.

Information About TrustSwap

By using the Services, you understand that your Personal Data may be used by the following entity (the “Controller”): TrustSwap. If you have any inquiries regarding our Privacy Policy or your Personal Data, please contact [email protected].

Collection of Personal Data

When you access or use the Services, we collect the following information:

Information you may provide to us: You may give us information about you by filling in forms on our website or through or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the Services and when you report a problem with the website.

Information we collect about you: With regard to each of your visits to our website we automatically collect the following information:

Login Information: We log technical information about your use of the Services, including the type of browser and version you use, the wallet identifier, the last access time of your wallet, the Internet Protocol (IP) address used to create the wallet and the most recent IP address used to access the wallet.

Device Information: We collect information about the device you use to access your account, including the hardware model, operating system and version, and unique device identifiers, but this information is anonymised and not tied to any particular person.

Information We Collect from Other Sources: We also receive information from other sources and combine that with the information we collect through our Services. For instance:

We use third-party services that may be co-branded as TrustSwap but will do so with clear notice. Any third-party services may collect information as determined by their own privacy policies.

We also use “cookies” from time to time to help personalise your online experience with us. A cookie is a small text file that is stored on your computer to help us make your visit to our site more “user-friendly.” Cookies provide us with information about your use of the site that can help us improve the site and your experience with it. We will process Personal Data collected through cookies in accordance with this Privacy Policy.

Advertising or analytics providers may provide us with anonymised information about you, including but not limited to, how you found our website.

Use of Personal Data

We will use your Personal Data, to:

• Understand and strive to meet your needs and preferences in using our Services;
• Develop new and enhance existing service and product offerings;
• Manage and develop our business and operations;
• Carry out any actions for which we have received your consent;
• Prevent and investigate fraudulent or other criminal activity;
• To address service requests and resolve user questions; and
• Meet legal and regulatory requirements.
• We also reserve the right to use aggregated Personal Data to understand how our users use our Services, provided that those data cannot identify any individual.

We also use third-party web analytics tools that help us understand how users engage with our website. These third-parties may use first-party cookies to track user interactions to collect information about how users use our website. This information is used to compile reports and to help us improve our website. The reports disclose website trends without identifying individual visitors.

We will process your Personal Data legally and fairly and not use it outside the purposes of which we have informed you, including selling it individually or in the aggregate for commercial use.

Disclosure of Personal Data

We may share your information with selected recipients to perform functions required to provide certain Services to you and/or in connection with our efforts to prevent and investigate fraudulent or other criminal activity. All such third parties will be contractually bound to protect data in compliance with our Privacy Policy. The categories of recipients include:

Companies within the TrustSwap corporate family located in Canada in order to provide the Services to you.

Cloud service providers to store certain personal data and for disaster recovery services, as well as, for the performance of any contract we enter into with you.

Fraud detection service providers who will run certain fraud detection checks against Personal Data provided.

We also may share Personal Data with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of TrustSwap’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by TrustSwap is among the assets transferred.

Except where we are required by law to disclose Personal Data, or are exempted from, released from or not subject to any legal requirement concerning the disclosure of Personal Data, we will require any person to whom we provide your Personal Data to agree to comply with our Privacy Policy in force at that time or requirements substantially similar to such policy. We will make reasonable commercial efforts to ensure that they comply with such policy or requirements, however, where not expressly prohibited by law, we will have no liability to you, if any person fails to do so.

We shall require any third-party, including without limitation, any government or enforcement entity, seeking access to the data we hold to a court order, or equivalent proof that they are statutorily authorised to access your data and that their request is valid and within their statutory or regulatory power.

Transaction information related to your use of certain Services may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when block chain data is combined with other data.

Because blockchains are decentralised or third-party networks that are not controlled or operated by TrustSwap or its affiliates, we are not able to erase, modify, or alter Personal Data from such networks

Security of Your Personal Data

We protect Personal Data with appropriate physical, technological and organisational safeguards and security measures. Your Personal Data comes to us via the internet which chooses its own routes and means, whereby information is conveyed from location to location. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Every member of TrustSwap is committed to our privacy policies and procedures to safeguard Personal Data. Our site has security measures in place to protect against the loss, misuse and unauthorised alteration of the information under our control.

Retention of Your Personal Data

The length of time we retain Personal Data outside our back-up system varies depending on the purpose for which it was collected and used, as follows:

Data you provide to us when subscribing for our Services (if applicable): while the user remains active, stored in United States.

Country location data: while the user remains active, stored in United States.
Data on your preferences: while the user remains active, stored in United States.
IP address login: until subsequent login from a new IP, stored in United States.
When Personal Data is no longer necessary for the purpose for which it was collected, we will remove any details that identifies you or we will securely destroy the records, where permissible. However, we may need to maintain records for a significant period of time (after you cease using a particular Service) as mandated by regulation.

Except where prohibited by law, this period may extend beyond the end of the particular relationship with us, but only for as long as we are bound to do so for the audit, regulatory or other accounting purposes. When Personal Data is no longer needed, we have procedures either to destroy, delete, erase or convert it to an anonymous form. If you have opted-out of receiving marketing communications, we will hold your details on our suppression list so that we know you do not want to receive these communications.

After you have terminated the use of our Services, we reserve the right to maintain your Personal Data as part of our standard back-up procedures in an aggregated format.

Storage of Personal Data

TrustSwap stores your Personal Data at secure locations in Canada. TrustSwap ensures that appropriate security standards are in place regarding the safeguarding, confidentiality, and security of Data.

The information that we collect from you will be transferred to, and stored in, destinations outside of your country as described below:

We may transfer your Personal Data outside Canada to other company subsidiaries, service providers and business partners (i.e. Data Processors) who are engaged on our behalf. To the extent that we transfer your Personal Data outside of Canada, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with relevant privacy laws.

Your Rights

Your Rights The rights that are available to you in relation to the Personal Data we hold about you are outlined below.

Information Access: if you ask us, we will confirm whether we are processing your Personal Data and, if so, what information we process and, if requested, provide you with a copy of that information within 30 days from the date of your request.

Rectification: it is important to us that your Personal Data is up-to-date. We will take all reasonable steps to make sure that your Personal Data remains accurate, complete and up-to-date. If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your Personal Data to others, we will let them know about the rectification where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly. You may inform us at any time that your personal details have changed by emailing us at [email protected] and we will change your Personal Data in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof that we are required to keep for regulatory or other legal purposes.

Erasure: you can ask us to delete or remove your Personal Data in certain circumstances such as if we no longer need it, provided that we have no legal or regulatory obligation to retain that data. Such requests will be subject to any agreements that you have entered into with us, and to any retention limits, we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your Personal Data to others, we will let them know about the erasure request where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly.

Processing restrictions: you can ask us to block or suppress the processing of your Personal Data in certain circumstances, such as, if you contest the accuracy of that Personal Data or object to us processing it. It will not stop us from storing your Personal Data. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your Personal Data to others, we will let them know about the restriction of processing where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly.

Data portability: in certain circumstances, you might have the right to obtain Personal Data you have provided us with (in a structured, commonly used and machine-readable format) and to re-use it elsewhere or ask us to transfer this to a third party of your choice.

Objection: you can ask us to stop processing your Personal Data, and we will do so if we are:

Relying on our own or someone else’s legitimate interests to process your Personal Data, except if we can demonstrate compelling legal grounds for the processing;

Processing your Personal Data for direct marketing; or
Processing your Personal Data for research, unless we reasonably believe such processing is necessary or prudent for the performance of a task carried out in the public interest (such as by a regulatory or enforcement agency).

Automated decision-making and profiling: if we make a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to access our Services or has another significant effect on you, you can request not to be subject to such a decision unless we can demonstrate to you that such a decision is necessary for entering into, or the performance of, a contract between us. Even if a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention. We may not be able to offer our Services if we agree to such a request by terminating our relationship with you. You can exercise any of these rights by contacting us at [email protected]

Acceptance

By using the Site and/or Services, you signify your agreement to this Privacy Policy. TrustSwap reserves the right to change or amend this Privacy Policy at any time. If we make any material changes to this Privacy Policy, the revised Policy will be posted here. Please check this page frequently to see any updates or changes to this Privacy Policy.