Coinsquare Privacy Statement
At Coinsquare we take privacy seriously. This Privacy Statement is intended to help you understand how we, being Coinsquare Capital Markets Ltd. and its affiliates (“Coinsquare”, “we”, “us” or “our”), collect, use, and disclose your personal information (as defined below) when you access https://coinsquare.com/ or any of our associated websites and mobile applications (collectively, the “Site”), and use the services that we provide via the Site (the “Services”). Our Privacy Statement is our commitment to you that we will handle your personal information with care and in accordance with applicable privacy legislation.
We will treat personal information in a manner consistent with the Privacy Statement under which it was collected and our privacy practices, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.
This Privacy Statement is a legally binding agreement between you (“user”, “you” or “your”) and Coinsquare. If you are entering into this Privacy Statement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this Privacy Statement, in which case the terms “user”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this Privacy Statement, you must not accept this Privacy Statement and may not access and use the Site and Services. By accessing and using the Site and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Statement. If you do not agree to abide by the terms of this Privacy Statement, you are not authorized to access or use the Site and Services. This Privacy Statement does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
The types of personal information we collect
The term “personal information”means any information that is identifiable with you, as an individual. We limit the collection of personal information to that which is necessary for the purposes identified by Coinsquare in this Privacy Statement (see “How we use your personal information”). We collect the following types of personal information:
- Identity & contact information: Name, date of birth, , address, phone number, email
- Financial & transaction information: Employment information, payment information, online payments and money transfers, payment methods, CAD value of transactions, quantity of crypto assets or fiat per order, time stamps associated with orders and payments, payment authorization information, and order activity history, and where required, bank account information. For institutions, we also collect tax ID, proof of legal formation, corporate address, personal identification information and address for all material beneficial owners and authorized users
- Account information: Account agreements entered into, your government-issued photo identification or other identity document, data about your assets, the origin of assets, generic job title, whether you are a politically exposed person or the family member or close associate of a politically exposed persons, whether you or a family member work for another investment dealer, whether you can materially influence the price or supply of any crypto asset that is available through Coinsquare’s platform, date on which the account is opened, date on which the account moves through various states (KYC submissions, KYC approval, 2FA enabled, password reset etc.)
- Communication information: Communications with you regarding the Services, including by phone, chat, email, and other means of communication
- Usage information: Data about the way you use the Services, including the date and time, data about your device, operating system and hardware settings, browser type and characteristics, length of visits, pages viewed, geographic location, language preferences, referring URLs, time spent on pages, scrolling, mouse movements, and links clicked, and information derived from SIM card, network operator, IP address, GPS geolocation data
- Legal compliance information: Data obtained in order for us to comply with legal requirements, including data requested by government and tax authorities
How we collect your personal information
Except where otherwise permitted or required by law, we will obtain your informed consent prior to collecting, and in any case, prior to using or disclosing your personal information for any purpose. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information, the reasonable expectations you might have in the circumstances, and the purposes for which we are collecting the personal information. Express consent may be obtained verbally, electronically or in writing. Implied consent may be obtained through your use of the Services, or when you approach us to obtain information, inquire about or apply to use our Services.
Most of the personal information we collect from you is provided by you (for example, when you register with us, fill out a form, change settings, enter an order or request a transfer). We may also collect personal information about you from public or third-party sources, such as public databases, ID verification partners, payment providers, companies providing services for money laundering and terrorist financing checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services.
How we use your personal information
Our primary purpose in collecting personal information is to provide you with a secure, efficient, and customized experience. We generally use your personal information for the following purposes, and we only use the personal information necessary to achieve these purposes:
- to properly identify you and fulfill our anti-money laundering obligations with FINTRAC;
- to open, manage, and administer your account with Coinsquare;
- to determine your eligibility for our Services and the products and services of companies with which we are affiliated, and determine their price;
- to enforce the terms of our Terms & Conditions and other agreements;
- to process your activity using the Services, including payment transfers, orders, and withdrawals;
- to respond to questions, comments or concerns regarding Coinsquare;
- to allow for more meaningful and useful marketing initiatives (although you can withdraw consent at any time by using the unsubscribe mechanism set out in our messages or by contacting our Chief Privacy Officer at email@example.com;
- to collect your personal information in aggregate form to develop consumer profiles, perform sales analysis and identify marketing opportunities and strategies;
- to enhance your experience;
- to collect opinions and comments in regard to Coinsquare’s operations;
- to recruit for positions at Coinsquare;
- to maintain legal and regulatory compliance;
- to understand, maintain, develop and improve the Services, we use analytics to understand our Site activity and customer needs and to improve our Services. We may also generate aggregated information to monitor performance and use to improve our Services;
- to investigate legal claims and regulatory inquiries;
- to protect against fraud and/or funds or asset loss;
- to administer our Site and Services;
- to ensure network and information security;
- such purposes for which Coinsquare may obtain consent for other uses from time to time; and
- such other uses as may be permitted or required by applicable law.
How we store your personal information
We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements. We may retain personal information, including financial information relating to transactions, for accounting and auditing purposes and otherwise in accordance with our obligations under applicable law.
How we safeguard your personal information
We have implemented 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 your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
While we strive to protect your personal information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Site and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
How we disclose your personal information to third parties
Except as set forth in this Privacy Statement or as required or permitted by law, we do not sell or share your personal information with third parties. Even when we do disclose your personal information, we will not disclose more personal information than necessary for the purpose of disclosure and in compliance with data protection legislation. Here are the circumstances where we disclose your personal information:
- Service Providers: We may transfer or otherwise make your personal information available to third-party service providers who provide services to us in accordance with our instructions and on our behalf. Our service providers are only given the personal information they need to perform their agreed-upon services, and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers include: ID verification partners; website hosting providers and other parties who assist us in operating the Site; payment services providers; companies providing services for money laundering and terrorist financing checks, credit risk reduction and other fraud and crime prevention purposes, including financial institutions and credit reference agencies; partners who provide us with accounting services in order to prepare invoices; our financial and legal consultants and auditors; and debt collectors in order to collect a debt. In the event that personal information is transferred to a service provider based in the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.
- Affiliates: We share personal information with affiliated entities of Coinsquare Capital Markets Ltd. who provide support and ancillary services, including our parent company Coinsquare Ltd. (with consent where required by applicable law). Our affiliates are not permitted to use your information for any unauthorized purpose.
- Legal & Compliance: We may also provide your personal information in response to a search warrant, production order or other legally valid inquiry or order, including to public authorities and state institutions such as law enforcement agencies, bailiffs, notaries, tax authorities, supervisory authorities, regulatory authorities, financial intelligence agencies such as the Financial Crimes Enforcement Network and Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), or as otherwise required or permitted by Canadian, US, European, or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise, or defence of legal claims, or when we believe disclosure is appropriate to comply with the law or protect ours or others’ rights, property, or safety, including to investigate or prevent actual or suspected loss or harm to persons or property.
- Business Sale: Your data may be provided to third parties in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Coinsquare, or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Contacting us about your personal information or this Privacy Statement
All comments, questions, concerns or complaints regarding your personal information or our privacy practices should be forwarded to our Chief Privacy Officer as follows:
Coinsquare Capital Markets Ltd.
Attn: Chief Privacy Officer
110 Cumberland St, Unit 342
Toronto, ON, Canada M5R-3V5
By email: firstname.lastname@example.org
If your concern remains unresolved by us, you may contact the Privacy Commissioner of Canada at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Phone: (819) 994-5444
Fax: (819) 994-5424
Accessing your personal information
If you make a written request to our Chief Privacy Officer to review any personal information about you that we have collected, utilized or disclosed, we will provide you with any such personal information to the extent required by law. We will make such personal information available to you in a form that is generally understandable, and will explain any abbreviations or codes.
In addition, you can review and edit information saved in your account settings and verification profile at any time by logging in to your account. We will ensure that your personal information is kept as accurate, complete and up to date as possible. We will not routinely update your personal information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your personal information, when required.
At any time, you can challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties having access to your personal information. We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit.
We will not charge any costs for you to access your personal information in our records or to access our privacy practices without first providing you with an estimate of the approximate costs, if any. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your personal information. Any such identifying information shall be used only for this purpose.
Our Site may pass a “cookie” (a string of information that is sent by a website to be resident on your system’s hard drive, and/or temporarily in your computer’s memory blocks). You may set your browser to decline cookies. If you do so, however, you may not be able to fully experience some features of our Site.
We may provide links to third party websites
Changes to this Privacy Statement
The Privacy Statement is current as of the “Last Updated” date which appears at the top of this page. From time to time, we may update this Privacy Statement to reflect changes to our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices. If we materially change our Privacy Statement, we will take steps to notify you in advance of the change.
An updated version of this Privacy Statement will be effective immediately upon the posting of the revised Privacy Statement unless otherwise specified. Your continued use of the Site and Services after the effective date of the revised Privacy Statement will constitute your consent to those changes.
Age Of Consent
By using the Site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
We do not knowingly collect any personal information from children under the age of 18. If you are under the age of 18, please do not submit any personal information through the Site and Services. If you have reason to believe that a child under the age of 18 has provided personal information to us through the Site and Services, please contact us to request that we delete that child’s personal information from our Services.
Last Updated: October 12, 2022