Privacy policy

Introduction

Welcome to Currency.com's privacy policy ("Privacy Policy").

NEUROTHENA INC. respects your privacy and we are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (available at www.currency.com) and our mobile applications (together, the "Platform") and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this Policy

This Privacy Policy aims to give you information on how Currency.com collects and processes your personal data, including any data you may provide to us when accessing the Platform and using any of the services which we offer through the Platform ("Services").

The Platform is not intended for any person under 18 years of age ("Minors"), and we do not knowingly collect data relating to Minors.

It is important that you read this Privacy Policy together with any other policy which we may publish and direct to you from time to time, as this Privacy Policy supplements other notices and policies and is not intended to override them.

Controller

This Privacy Policy is issued on behalf of NEUROTHENA INC., an Ontario business corporation incorporated in Canada with Business Number 763635232 and Registry ID 1001387720, having its registered office in Ottawa, Ontario, and operating address at 94 Lakeshore Road East, Unit 203, Mississauga, Ontario, L5G1E3, Canada, so when we mention "Currency.com", "we", "us" or "our" in this Privacy Policy, we are referring to NEUROTHENA INC. as the entity responsible for processing your data.

NEUROTHENA INC. is registered as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under registration number C10001741, and is subject to Canadian federal and provincial privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Anti-Money Laundering and Counter-Terrorist Financing legislation administered by FINTRAC.

We have appointed a privacy officer ("Privacy Officer") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your rights (as more thoroughly described below), please contact us using the Contact Details set out here below.

Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer in the following ways:

Privacy Officer

Email address: [email protected]

Additionally, you can contact us by emailing to [email protected] or mailing to us using the postal address provided below:

NEUROTHENA INC.
94 Lakeshore Road East, Unit 203, Mississauga, Ontario, L5G1E3, Canada

You have the right to make a complaint to the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca. We would, however, appreciate the chance to deal with your concerns before you approach the OPC so please contact us in the first instance.

Changes to Privacy Policy and your duty to inform us of any change to your information

We keep our Privacy Policy under regular review, and you may find the date this Privacy Policy was last revised at the beginning of this document.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites (including any plug-ins, web applications and mobile applications) and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the respective privacy policy of every website you visit.

2. What data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes full name or its parts, username or similar identifier, marital status, title, date and place of birth, nationality, tax number, gender, information from your identity document(s), employment status and related information and your pictures / pictures of your identity (including biometric information such as a visual image of your face or other document(s) we may request from time to time. Where collected, biometric information (e.g., a selfie or video) is used solely for identity verification, fraud prevention and compliance with AML/CFT requirements, and is retained only as long as necessary for those purposes.
• Contact Data includes billing address, residential address, email address and telephone number.
• Financial Data includes bank account and payment card details, virtual currency wallet address(es) and source of funds and wealth.
• Transaction Data includes details about payments to and from you in relation to our Services.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Platform.
• Profile Data includes your username and password, orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you access our Platform and use our Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (please refer to our Terms of Use), and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our Services). In this case, we may also have to cancel or suspend your access to our Services, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data (as defined above) by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • create and verify an account on our Platform;
  • access our Platform and use our Services;
  • request marketing to be sent to you; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including but not limited to social media, search engines, virtual asset service providers, KYC service providers (including e-KYC) and screening data vendors.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract (in this case, our Terms of Use) we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where you have provided us with your consent (or explicit consent).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In order to access our Platform and Services you will first have to enter into a contract with us governing our relationship. The contract in question is the Terms of Use and is available at https://legal.currency.com/terms.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing necessary to comply with applicable Canadian federal and provincial laws, including obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related FINTRAC Regulations (e.g., record-keeping and customer due-diligence obligations).

Generally, we do not rely on consent as a legal basis for processing your personal data, with the exception of our marketing and advertising activities. We will make sure to provide you with clear and concise information with regard to what you consent to and make it easy for you to withdraw consent at any time.

Purposes for which we use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a customer, verify your identity and provide you with a live account on the Platform	(a) Identity (b) Contact (c) Financial	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Explicit consent
To perform an ongoing due diligence and monitoring of your activity under the AML/CFT requirements	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Profile	Necessary to comply with a legal obligation
To protect you, our company and other persons against fraud	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Profile (g) Usage	(a) Necessary to comply with a legal obligation (b) Performance of a contract with you (c) Necessary for our legitimate interests (to keep the integrity of our Platform and the Services)
To provide you with the Services: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our Terms of Use, privacy and other policies in place (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)
To administer and protect our business and this Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy) Consent (where applicable)
To use data analytics to improve our Platform, Services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our Services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Services that may be of interest to you, and provide you with exclusive offers	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our Services and grow our business) Consent (where applicable)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have designed a dedicated section on the Platform which allows you to view and decide how we use your personal data for marketing purposes. You have the right to withdraw consent to marketing at any time by changing your Notifications preferences in your account Settings.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or accessed certain Services from those available on our Platform and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time through the Platform by either: checking or unchecking relevant boxes to adjust your marketing preferences in your account, by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of Service purchase, Service experience, or other transactions.

We will honor your opt-out without affecting your access to core Services.

Cookies

We use cookies and similar technologies to enhance your user experience, provide our Services, and understand how customers use our Services. If you want to learn more about how we use cookies and your choices regarding them, please read our Cookie Policy. Your browser and device settings may also allow you to manage cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the certain parties as set out below:

• Internal Third Parties (Affiliated companies of Currency.com Group).
• External Third Parties (Third-party service providers, including financial institutions, KYC and anti-fraud service providers, cloud storage providers, customer support software providers, analytics providers, project management providers, communication providers, auditors, virtual asset service providers, regulators including FINTRAC, and law enforcement).
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may transfer personal data to service providers and affiliates in other countries. Where we do so, we take reasonable steps to protect your information, including contractual safeguards, vendor due-diligence and technical/organizational measures. Any cross-border transfer of personal data will be carried out in compliance with PIPEDA and applicable Canadian privacy legislation, including ensuring substantially similar protection to the personal data being transferred.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the Office of the Privacy Commissioner of Canada (and any other applicable regulator) of a breach where we are legally required to do so under PIPEDA's mandatory breach reporting requirements.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a minimum of five (5) years after the end of the business relationship for compliance purposes under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC Regulations.

In some circumstances you can ask us to delete your data – please see section “Your privacy controls' below” below for further information about this.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your privacy controls

Under PIPEDA and applicable Canadian privacy legislation, you have the following rights. You may request: access to your personal information held by us; correction of any inaccuracies; withdrawal of consent to our use of your personal information at any time, subject to legal or contractual restrictions; and objection to direct marketing. You may also challenge our compliance with PIPEDA by filing a complaint with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.

If you wish to exercise any of the controls set out above, please contact us at [email protected], or alternatively, our Privacy Officer at [email protected].

Please note that certain requests (for example, deletion) cannot be fulfilled where we are required by law to retain records, including AML/CFT requirements (e.g., to keep customer due-diligence and transaction records for at least five years).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within thirty (30) days as required under PIPEDA. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Governing law

This Privacy Policy and any non-contractual obligations arising out of or in connection with it are governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein.