PLEASE BE CAREFUL WHEN ACCESSING THE SERVICES. COINBERRY WILL NEVER ASK YOU FOR YOUR LOGIN CREDENTIALS. MAKE SURE TO ONLY PROVIDE YOUR CREDENTIALS TO THE COINBERRY.COM DOMAIN ONLY. ANY OTHER SPELLING MAY LEAD TO AN IMPERSONATING WEBSITE.
2. Why We Collect Your Personal Information
We use the information that you provide to us or that we collect about you to provide the Services. We collect your personal information for the following purposes:
Provision of the Services
• To operate the Services and make its contents and features available to you.
• To provide you with customer support and assist in resolving complaints or disputes relating to the Services.
• To contact you via email, SMS, push notifications, or otherwise to provide administrative notices, marketing notifications, promotional offers and other communications relevant to your use of our Services.
• To notify you about changes to our Services or any products or services we offer or provide through them.
• To identify and verify the information you provide to us.
• To facilitate and manage your relationship with Coinberry and its related and affiliated entities.
• To be able to facilitate electronic fund transfers to and from your account.
• To improve the Services’ marketing and customer relationship experiences.
• To provide you with information, products or services that you request from us and to enforce our Terms and other policies.
• To carry out our rights and obligations including to comply with legal and regulatory requirements, and help manage and assess our risks and operations
“Know Your Client”
• We collect Know Your Client (“KYC”) information, including photo identification and other personal information, when you first access the Services and on an ongoing basis to comply with our regulatory, contractual and tax requirements. We require this information to send and receive funds to the Services. This information also helps us detect and prevent errors, fraud and other illegal activities.
Compliance with Laws and Regulatory Obligations
• We are required to collect your personal information, risk profile information and usage of the Services, in order to comply with our regulatory requirements.
3. Personal Information We Collect
We collect and use your personal information to provide you with a robust experience when accessing and using the Services. Our collection and use of your personal information will be limited to that which is necessary to provide you with a tailored experience.
For the purposes of: (i) registering your account; (ii) providing the services to you; (iii) communicating with you; (iv) responding to your requests; (v) providing support; (vi) and complying with our regulatory obligations, we will collect from you when opening up an account:
• Identity and Contact Information: first and last name, date of birth, email, phone number, and personal address. In order to set up a corporate or institutional account on the Services, we will collect from you:
• Corporate Information: Constating documents of the corporation, corporate address, beneficial owner information, authorized user information, tax information. For the purposes of complying with our KYC requirements, we collect directly from you, or from a third-party service provider we direct you to provide your personal information to:
• KYC Information: first and last name, phone number, email, addresses, date of birth, social insurance number (tax purposes), employment information (such as your job title), net worth, political exposure (of yourself or a family member), photo identification, government-issued identification, other identity documents, financial information, financial literacy, financial objectives, ownership of crypto-asset wallets you direct withdrawals to, banking information, and transaction history.
For the purposes of operating the Services and making its contents and features available to you, including funding and withdrawing your account with Fiat currency, we may collect from you:
• Financial Information: bank account information, payment information, payment authorization information, credit bureau information,
For the purposes of complying with our legal and regulatory obligations and improvements to the Services, we collect:
• Technical Information: login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your internet connection (IP address), and the equipment you use to access the Service. This also includes IDs of errors, communications with the support team or bug reports to improve the Service.
• Statistical and Aggregated Information: this includes information that we receive across users that does not directly identify a person. Any aggregated information will be anonymized and de-identified if analyzed and used.
• Details of Your Usage of the Services: the value of transactions made through the Services, quantity of crypto-assets or fiat per order, time logs of orders and money transfers, activity history, frequency of deposits and withdrawals, methods of deposits and withdrawals, sources and destinations of deposits and withdrawals.
4. How We Collect Your Personal Information
We collect Identity and Contact Information and Financial Information from you when you sign up for a user account, interact with the Services and update your account’s information. You may provided with prompts that request feedback on your experience with the Services that will be associated with your user account.
We collect your Personal Information, KYC Information, Financial Information and Technical Information from third-parties that provide it to us when:
• you provide our contracted third-party providers with the KYC Information we are required to collect.
• you make referrals or provide your personal information to other third-party service providers we rely on.
• you request the use of the Services’ while accessing and using the products and services of Coinberry’s affiliated or related companies.
• you are provided with surveys by contracted third-parties that request your feedback on your experience with the Services. Any information you provide may be associated with your user account.
(d) Automated Data Collection Technologies
• details of your usage of the Services, including traffic data, location data, regional settings, logs, other communication data and the resources that you access and use; and
• information about your computer and internet connection, including your IP address, operating system, and browser type.
The technologies we use for this automated data collection include:
(ii) Web Beacons. Pages of our Services may contain small electronic files known as web beacons that permit us, for example, to count users who have visited the Services and for other related Services statistics (for example, recording the popularity of certain content on the Services and verifying system and server integrity).
(i) Affiliated and Related Companies: We may share your information, including KYC information, personal information and information about your assets on our platform(s), with our subsidiaries, parent company and other affiliated entities to effectively provide you with the Services, and to offer and provide you with the features and functionality that they offer. We may use and disclose this information to promote our products and services, and to promote and offer you access to products and services of our affiliated entities we select which we believe may be of interest to you. We may communicate with you through various channels using the contact information you have provided. Our affiliated and related companies may offer products and services in addition to the Services at such time and on such conditions as may be communicated to you. By accepting an offer for or using such services or products, you expressly provide your consent for us to share your information, including personal information, KYC information and information about your assets on our platform(s) with such affiliated or related entity.
(ii) Third-Party Service Providers: We may share your information with our and our affiliated and related companies service providers, contractors, the organizations they act on behalf of, and other third parties (such as cloud hosting, identity verification, analytics, legal, accounting and search engine providers) we use to support our and our affiliates’ businesses on an ongoing basis. For these third-party service providers to perform or facilitate these functions, they may require us to provide them with your personal information. If we provide them with your information, we will contractually obligate them to keep your information confidential, use it only for the purposes for which we disclose it to them.
(iii) Payment Processors / Bank Transfers: Users may be able to submit credit card, banking information or other payment information to the Services to deposit or withdraw funds. Coinberry utilizes third-party payment processors and interbank networks (such as Interac) to facilitate fund deposits and withdrawals. We do not receive nor store any payment information on our servers. All payment transactions are encrypted when communicated through our third-party payment processors and interbank network providers.
(iv) Storage Providers: We may process, store, and transfer your personal information in and to a foreign country (such as the United States), with different privacy laws that may or may not be as comprehensive as privacy laws in Canada. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation. (v) Commercial Partners: We may share your information or anonymized aggregated data derived from your information and the information of others with some of our commercial partners. If you provide us with your information and request for your information to be shared with a commercial partner in order to access their offerings, we may provide the relevant commercial partner with your information as requested.
(vi) Legal Requirements: We may share your information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, under applicable law. To comply with securities law requirements, we may share your personal information, including the purchase of equities or crypto-assets to the applicable Canadian securities regulatory authority where required by applicable law. We may also share your personal information in response to a production order, search warrant or other valid government or regulatory action. This includes sharing your personal information with law enforcement, tax authorities, regulatory authorities, financial intelligence agencies, or as otherwise required by Canadian, US or other government authorities. Your personal information may also be disclosed for the establishment or defence of legal actions and to comply with the law or protect our rights.
(vii) Business Transactions: Coinberry reserves the right to share your information in connection with any proposed or realized merger, divestiture, consolidation, restructuring, purchase, sale or any other type of business combination that requires its disclosure.
(g) Security of Collected Information
Coinberry uses physical, electronic, technical and administrative safeguards designed to secure your personal information from accidental loss and unauthorized access, use, modification, and disclosure. We store all of the information you provide to us on secure servers. Although we implement measures to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information to the Services is done is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained in the Services.
The safety and security of your personal information also depend on you. User accounts on the Services are password-protected with two-factor authentication. If you have a user account you are solely responsible for keeping your password confidential. You must: (a) not share your password with anyone; (b) not post your password in any public areas online (c) not use your password on any public devices that you might forget to log-out of; and (d) provide your credentials or grant access to a third-party or to third-party software such as AnyDesk or TeamViewer as example.
(h) Data Retention
(a) Retention Policy. To improve the Services, we may aggregate information from users after removing information that can allow them to be identified. You acknowledge and agree that we may use anonymized personal information for legitimate business purposes that cannot be associated with you. We reserve the right to use such anonymized information without further notice.
We may periodically de-identify or delete personal information from inactive user accounts and unnecessary information that is flagged by our administrators. With the exception of aggregated or anonymized data, we will delete unnecessary or unused personal information after two (2) years of inactivity on the Services.
(i) User Rights
If you would like to exercise any of the following rights, please contact us at our email below:
(a) Accessing, Correcting or Updating Your Information: You may request for us at any time to correct your information or to provide you with a copy of your personal information that we maintain in electronic format. You may submit a request here.
(b) Deleting Your Information: You may request for us at any time to have your personal information that we maintain deleted. We will comply with your request unless there are legitimate business or legal grounds for the continued retention of your personal information.
(c) Object to our Processing: You may request for us to restrict or cease the processing of your personal information if you believe it has been processed (i) in a manner contrary to applicable law; (ii) in a manner outside of the consent you provided; or (iii) after your consent has been withdrawn. We will comply with your request unless there are legitimate business or legal grounds for the continued processing of your personal information.
(d) Withdrawing Consent: You may withdraw your consent for our collection, use and disclosure of your personal information at any time. We will comply with your request unless it conflicts with our legal obligations or an established standard of practice. Please be aware that if you withdraw your consent, we may be unable to provide you with the Services.
(e) Transfers of Data. We and our affiliates and third-party service providers primarily store data about you, on servers located and operated within Canada and the United States of America (the “Territory”). If you reside or are located outside of the Territory, we may send and store your data to the Territory in order to provide and operate the Services.
(j) Opting Out of Communications
We may send periodic marketing, promotional or informational emails to you in accordance with your communication preferences. These may include emails for future events and products. You may withdraw your consent and opt out of such communications at any time by following the opt out instructions contained in the email or by contacting us at the email below.
(k) Third-Party Websites
(l) Children’s Privacy
The Services are not intended for children under eighteen (18) years of age. We do not knowingly collect personal information from children under eighteen (18) years of age. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete that information. If you (i) believe we might have any information from or about a child; (ii) would like to review any personal information we may have collected about your child; or (iii) would like to request the deletion of your child’s personal information, please contact our Privacy Officer at the email address below.
By email: firstname.lastname@example.org
By mail: Coinberry Limited
c/o Privacy Officer
342 - 110 Cumberland Street