The following privacy notice (Privacy Notice) is provided by 2237667 Alberta Ltd. doing business as Cash 2 Crypto, and/or its affiliates (Cash 2 Crypto, we, our, or us) to explain our collection, use, retention and security of personal information in connection with the use of services provided by Cash 2 Crypto through its web-site (www.cash2crypto.ca) (the Website). Clients, and visitors are assured of our commitment to protecting your privacy and the safety, security and confidentiality of your personal information.
What is Personal Information?
Personal information is data about an identifiable individual (Personal Information). It is information that on its own or combined with other pieces of data, can identify you as an individual, such as your name, address, email, personal identification numbers and identity verification documents, financial information, IP address and location data, or other details about you.
1. What Information We Gather and How
In order to operate our business in accordance with applicable laws and regulations, Cash 2 Crypto is required to collect certain Personal Information, which may include, among other things, your name and address, date of birth, phone number, email address, mailing and business address (if applicable), identity verification information, payment and banking information, cryptocurrency wallet public address and transactional data based on your activity within the Cash 2 Crypto environment.
We may also collect information about you when you visit our Website. We may combine the information collected on our Website with Personal Information collected from or about you in other contexts. This may include information collected online, such as through our email exchanges with you, or from offline sources, such as when you establish your account with us or call customer service.
In addition to the Personal Information you provide to us, we may receive information about you that you authorize other parties to provide to us. We also may obtain Personal Information from service providers unaffiliated with Cash 2 Crypto to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you. We will treat such combined information in accordance with our Privacy Notice. If you do not wish to provide certain Personal Information to Cash 2 Crypto, we may be unable to provide certain products or services to you.
Account Information: When an account is opened, Personal Information may be required as part of the account documentation. This information may include name, address, phone number, email address, social insurance number, date of birth, citizenship, driving license number, signature, banking information, investment experience, and public address for cryptocurrency wallet(s).
Transaction Information: Any time a transaction (including a digital asset transaction) is initiated in an account with us, we collect information about that transaction. This transaction information will be used to provide you with reports and information in respect of your transaction history. This transaction information may also be used in an aggregated, non-personally identifiable form to help us understand our customers and to enhance our product and service offerings. We also keep information such as transaction history, payment details to and from you, details of services we have provided to you.
We may gather Personal Information for “Know Your Client” and other purposes on a continuing basis through document requests, and at times other than those noted above, to ensure we have accurate and up-to-date information to provide services and to meet regulatory obligations.
Information From Payment Processing Companies and Financial Institutions: To facilitate depositing and withdrawing funds and the ordinary use of our Service, we use a third-party providers, including Zum Rails. Zum Rails uses an application programming interface (API) and other integration features to connect with your bank to provide us with your bank or another financial institution account information, including for example, the name associated with the account, the institution, transit and account numbers, account balance, as well as other information. This information is used to facilitate the verification of your identity and the deposit and withdrawal of funds from your bank account. Zum Rails may also send us your (i) account balance to ensure you have a sufficient balance in your account to withdraw funds pursuant to a request made by you; and (ii) up to six (6) months of your account transaction history, which we use in a small number of cases as part of our fraud prevention measures.
Other Information: If you enter a secured section of the Website through the use of an ID, we already have on file your name, address, and account information. We time-stamp all incoming sessions, and we collect the IP, domain name, session duration, transactions made, and pages viewed. In addition, we, and our service providers, may use various website tracking tools, such as Cookies, Web Beacons and Website Analytics, as described in greater detail in the section below, to enhance your experience with improved design and personalized content that may be relevant to you.
Cookies, Web Beacons, Website Analytics and Log Files
We use a variety of online technologies, such as Cookies, Web Beacons, Website Analytics and Log Files as described further below, to collect information that helps us understand how our Website is used. Specifically, when you visit our Website, we or our service suppliers may automatically collect a variety of technical and navigational information about you via these technologies, including, as applicable: your computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; pages you view; links you select; searches you conduct; the internet protocol (IP) address used to access our website or mobile application; your general geographic location (e.g., your city, state, or zip code); and the website visited before our site.
We also may use similar tracking technologies in emails that we, or our service providers, send to you, as further described below. This information may be used, for example, to alert you to software compatibility issues, to resolve technical or service problems, and for security purposes. We also analyze this information, with the assistance of our service providers, to improve our Website design and functionality, to enhance our ability to serve you and your accounts, and to tailor our communications to you regarding our products and services.
A cookie is a small file of letters and numbers that is stored on your computer or other device when you visit a website or a mobile application. Cookies contain information that is transferred to or read on your device and allow websites and mobile applications to recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our online services. This helps us to provide you with a useful experience when you browse and allows us to improve our online services. We and our service providers use session cookies, which link your actions during a particular online session and expire at the end of that session, as well as persistent cookies, which remain on your device and allow us to remember your actions or preferences across multiple browser sessions.
We and third-party service providers acting on our behalf, use session and persistent Cookies to:
• remember preferences that you submit as well as those generated from your usage data on our Website;
• measure your use of our Website in an effort to improve its quality and enhance your overall experience, including tracking page views, time and date of our Website access, and other usage data, and identifying your operating system and browser type (but not other information about your computer or the programs on it) and your general geographic location; and
• measure the effectiveness of our communications, such as newsletters and advertising campaigns.
We may use aggregated usage data to track trends and analyze patterns on our Website. If you register to enter an area of our Website, the Website will recognize who you are and collect all information that you submit (including subscription to emails, etc.). Any information collected about you from our Website may be associated with other identifying information that we have about you.
Managing Cookie Privacy Settings
If you are concerned about having cookies on your computer or other device, you can set your web browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. The help feature on most web browsers will tell you how to prevent your browser from accepting new cookies, how to receive notice when a new cookie is set, and how to disable cookies altogether. However, if you choose to block or delete cookies, certain features of our website may not operate correctly.
For further information about deleting or blocking cookies, please visit here.
Our Website and the emails that you receive from Cash 2 Crypto may use an application known as a web beacon (also known as a pixel tag or clear gif). A web beacon is an electronic file that usually consists of a single-pixel image, embedded in a web or mobile application page or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device.
We and our service providers use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information such as the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you select any links in the email. These technologies enable us to gauge the effectiveness, relevance, and value of our email communications, as well as to target relevant advertising to you and to measure the impact of that advertising.
If you are a Cash 2 Crypto platform user who has registered for secure online access to your Cash 2 Crypto account, we are able to combine the information we collect about your usage of our Website during a secure (logged-in) session with other information we know about you, such as any account transactions you conduct during your session. We can also identify your computer or device on each online visit to Cash 2 Crypto, even if you do not log in, and link information about that visit, as well as Cash 2 Crypto ads that you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our website and in our mobile application and the effectiveness of our online advertising, as well as to identify Cash 2 Crypto products and services that may be of interest to you.
We engage service providers to collect the information discussed above to engage in analysis, auditing, research, and reporting. These service providers may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our Website or our mobile application. In particular, our Web Site uses Google Analytics site to help collect and analyze certain information for the purposes discussed above. The information generated about your use of our online services may be transmitted to and stored by Google Analytics on servers outside your country of residence.
We also use IP addresses to analyze trends, administer our Website, track user's movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personal information.
2. How We Use Collected Information
We may use information you provide us to:
• provide specific services or products to you;
• respond to your questions and requests and otherwise provide service communications;
• manage our relationship;
• provide service support;
• manage risk;
• assess your satisfaction with our services or products;
• contact you about updates to our online services;
• conduct research and analytics (for example, regarding the use of our online services), and provide you customized content and communications that we believe may be of interest to you;
• engage in marketing activities;
• maintain measures aimed at detecting and preventing fraud and protecting the security of personal information and our online and offline operational infrastructure, including our Website;
• allow you to utilize features within our Website by granting us access to information from your device, such as contact lists, when you request certain services;
• monitor the performance of our online services, diagnose problems and ensure that our online services function properly, make our online services easier and more convenient to use, and otherwise administer our online services;
• investigate suspected fraud, harassment, or other violations of any law, rule, or regulation, the terms, rules or policies of our online services, or the rights of third parties, or to investigate any suspected conduct which we deem improper;
• comply with laws, regulations, legal processes and law enforcement requirements; and
• otherwise operate our business in accordance with applicable laws and regulations.
We may also use anonymized or aggregate customer data for any business purpose, including to better understand needs and behaviours of customers, improve products and services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties. Anonymization is a data processing technique that removes or modifies personal information so that removes or modifies personal information so that it cannot be associated with a specific individual.
3. Sharing Information About You
Cash 2 Crypto does not sell and does not share Personal Information about our clients or investors with unaffiliated third parties for use in marketing their products and services.
We may share Personal Information with the following entities:
Unaffiliated service providers. While we may use a service provider to assist in relation to any of the purposes for which we may collect personal information, they generally fit within one or more of the following categories of service providers:
• auditors, accountants, legal and other professional advisors agents or independent contractors that provide services to Cash 2 Crypto;
• security and identity verification service providers;
• consumer and credit reporting agencies;
• infrastructure and technology service providers, such as network and cloud storage providers;
• providers of services for Cash 2 Crypto products or services, such as intermediaries, financial service providers;
• marketing, advertising, analysis, research, event, and communications providers.
In the course of providing such services, these service providers may have access to your Personal Information. We will always use our best efforts to ensure that the service providers we work with will keep your Personal Information secure. However, we will only provide our service providers with the information that is necessary for them to perform the services, and we instruct them not to use your Personal Information for any purpose other than the following:
• Government agencies, regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions).
• Other third-parties, with your consent or as directed by you (if you use service that you have provided permission to access your Cash 2 Crypto account on your behalf).
• Other entities and organizations as permitted or required by law (for example for fraud detection or fraud prevention or to respond to a subpoena) Our service providers are obligated to keep the Personal Information we share with them confidential and use it only to provide services specified by Cash 2 Crypto.
Regulatory and law enforcement authorities. We may share personal information to law enforcement, officials, regulatory authorities or other third parties as part of our obligations under applicable laws and regulations, when we are compelled to do so by a subpoena, court order, or legally valid inquiry, 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 actual or suspected violations of our Terms of Service or any other applicable policies.
4. Retention of Personal Information
Your Personal Information may be kept in electronic or paper format in the offices of Cash 2 Crypto, in encrypted form on cloud servers operated by service providers, who may themselves store it in multiple locations and forms (in and outside Canada).
Personal information is held in line with local regulatory requirements (i.e. seven years after our business relationship with you has ended or longer if you have legitimate interests (such as handling a dispute with you)). 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. We may keep your data for longer than seven years if we cannot delete it for legal, regulatory, or technical reasons.
5. Protecting Personal Information
We have implemented commercially reasonable administrative, technical and physical measures in an effort to safeguard your personal information against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers. In the event a detected breach may result in the potential risk of harm, disclosure of sensitive information or risk of theft of identity and/or assets, Cash 2 Crypto will contact you as soon as possible, as we would had you raised a privacy complaint with us directly, outlining the details and actions taken to reduce the risks identified. We may also retain a third party to investigate and remedy the breach.
6. Accessing and Updating Personal Information
Requests to review and verify, and to correct or delete your Personal Information, or to find out to whom we have disclosed it, must be made to us in writing. We will need specific information from you to enable us to search for, and provide you with, the personal we hold about you. We may charge you a reasonable fee depending on the nature of your request, and we will advise you of any fee prior to proceeding with your request. If we are unable to provide some of the Personal Information we hold about you, we will tell you why.
To make a request for access to your Personal Information, for a purpose detailed above, please submit your written request to our Compliance Officer as listed in the Contact Us section below.
7. Notification of Changes
8. Your Consent
Meaningful consent is required for the collection, use and disclosure of Personal Information. To make consent meaningful, our clients and investors will be required to confirm in writing their consent to the collection of their Personal Information, based on the disclosed nature, purpose and consequences of the collection, use or disclosure of their Personal Information.
You may withdraw your consent for the collection and use of your Personal Information by contacting Cash 2 Crypto at any time. Certain services and products may no longer be provided to you, in the event you withhold consent to the use of information upon which such services and products are dependent and/or required by rules and regulations that govern them.
By using our Website, you consent to the collection and use of your Personal Information by Cash 2 Crypto, affiliates, partners, service providers and associated businesses. If you do not agree to the terms of this Privacy Notice, please change the selection on our Website cookies tracking and/or do not use our Website.
Contact Us We welcome your questions and concerns about privacy or your Personal Information. Your issue or concern may be easily resolved by contacting our client relations team:
If your concerns are unresolved, you may escalate to the Compliance Officer:
If, after contacting Cash 2 Crypto, your issue or concern has not been resolved, you may contact:
The Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Telephone: 1-800-282-1376 or 819-994-5444