Foris Inc. Privacy Notice

Last Material Update: 29 September 2020

At Foris Inc. ("Foris", "we" or "us"), we understand how important your personal information is, and we follow industry best practices to protect it. This Privacy Notice describes how we handle your Personal Information when using any of our websites, products, services, or applications (together, the “Services”). Our Privacy Notice is our commitment to you that we will handle your personal information with care and in accordance with the law.

The purpose of this Privacy Notice is to inform you about the types of Personal Information Foris collects, uses, and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information. We understand privacy as an ongoing mission to which we commit by complying with the laws and regulations under the applicable privacy legislation in Canada. This Privacy Notice is created to meet the standards embedded in the Personal Information Protection and Electronic Documents Act and its inherent regulations thereunder (“PIPEDA”) as well as applicable provincial privacy legislation and regulations.

From time to time, we may make changes to this Privacy Notice. The Privacy Notice is current as of the “last update” which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Notice under which it was collected and our privacy practices, unless we have your consent to treat it differently. This Privacy Notice applies to any information we collect or receive about you, from any source.

1. To which companies does this Privacy Notice apply?

This Privacy Notice applies to the collection, use and disclosure of Personal Information by Foris.

2. What is Personal Information?

"Personal Information" is any information that is identifiable with you, as an individual. This information may include but is not limited to:

Categories of Personal Information Examples of Personal Information
Identity Data
  • full name (including, where applicable, maiden name),
  • username or similar identifier,
  • title,
  • date of birth,
  • gender,
  • biometric information,
  • photograph,
  • tax identification number or similar identifier,
  • national identity cards,
  • passports, driver’s licenses, or other forms of identification,
  • contact data,
  • occupation.
Contact Data
  • billing, delivery, home, and work address,
  • email address,
  • telephone numbers.
Financial Data
  • bank account,
  • payment card details.
Transaction Data
  • details about payments to and from you,
  • other details of any transactions you enter into using or accessing the Services.
Investment Data
  • information about your:
    • investment objectives,
    • investment experience,
    • prior investments,
    • source of funds.
Technical Data
  • internet protocol (IP) address,
  • your login data,
  • browser type and version,
  • time zone setting and location data,
  • browser plug-in types and versions,
  • operating system and platform; and/or
  • other technology or information stored on the devices you allow us access to when you visit our websites or access or use the Services.
Profile Data
  • your username and password,
  • requests by you for products or services,
  • your interests, preferences, feedback, and survey responses.
Usage Data
  • information about how you use:
    • our websites,
    • mobile applications,
    • products and Services.
Marketing and Communications Data
  • your preferences in receiving marketing from:
    • us,
    • your communication preferences.

Please note that business contact information – including an employee’s name, title, business address, telephone number facsimile number or email addresses – which we collect, use or disclose solely for the purpose of communicating with a person in relation to their employment, business or profession does not qualify as Personal Information under the PIPEDA.

3. How do we collect your Personal Information?

We use different methods to collect information from and about you, including but not limited to:

Direct interactions

You may give us your Personal Information by filling in forms, providing your biometric information via the Services, by email, or otherwise. This includes Personal Information you provide when you:

  • apply or register for our products or the Services;
  • create an account;
  • subscribe to our Services or other publications;
  • make use of any of our Services;
  • request or indicate that marketing materials may be sent to you;
  • enter a competition, promotion, or survey; or
  • give us feedback or communicate with us.

Automated technologies or interactions

As you interact with us via our websites or mobile application, we will automatically collect certain Personal Information about your equipment, browsing actions, transactions, feedback, responses, and patterns of use. We collect this Personal Information by using cookies, server logs, and other similar technologies. We may also receive Personal Information about you if you visit other websites employing our cookies. On our main website you will be informed about how we use cookies and the control that you can exercise through the Cookie Settings.

Third parties or publicly available sources

We may also obtain information about you from third parties who provide identity verification and anti-fraud services, or who verify that you are not limited in your ability to use the Services by any applicable laws.

4. How do we use your Personal Information?

We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the "Purposes"):

  • To register you as a new customer.
  • To verify your identity before providing our Services.
  • To conduct credit checks or due diligence checks to minimise risks or frauds.
  • To enable fraud protection and risk management processes
  • To comply with the requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations.
  • To provide, process and deliver our Services and any App features to you including:
    • Execute, manage, and process any instructions or orders, you make;
    • Manage, process, collect and transfer payments, fees, and charges; and
    • Collect and recover money owed to us.
  • To process your transactions.
  • To manage our relationship with you which would include:
    • Notifying you about changes to our terms or Privacy Notice;
    • Asking you to leave a review or take a survey; and
    • Keep you informed of our company's business and product development.
  • To manage risk and crime prevention including:
    • Detect, investigate, report, and prevent financial crime in broad sense;
    • Obey laws and regulations which apply to us; and
    • Responding to complaints and resolving them.
  • To enable you to partake in a prize draw, competition or complete a survey.
  • To administer and protect our business, our Site and App(s) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
  • To make suggestions and recommendations to you about goods or services that may be of interest to you.
  • To comply with all laws and obligations from any legal authorities.
  • To satisfy/meet all legal, compliance, contractual and/or regulatory requirements as may be applicable to us and/or to our suppliers, agents and other organizations (which are involved in the performance of Services for you or for us, or on our behalf) in order to provide you with the Services or any App feature.

Cookies

We use cookies to optimize your experience when browsing our website or using our online Services. Your browser may have settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or our website may become inaccessible or not function properly. On our main website you will be informed about how we use cookies and the control that you can exercise through the Cookie Settings.

5. To whom do we provide your Personal Information?

We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure.

We may share your Personal Information outside of the country with our third-party service providers, agents, subcontractors, and other associated organizations, our group companies and affiliates in order to complete tasks, provide the Services to you on our behalf, and otherwise fulfill our obligations. We require third-party service providers, under written agreements, to respect the security of your Personal Information and to treat it in accordance with applicable law.

We may share your Personal Information and other data you provide to us for the following purposes:

  • To verify your identity.
  • To detect and prevent fraud, money laundering, terrorist financing, and other financial crimes and illicit activities.
  • To facilitate the provision of services and relevant business operations to support our delivery of the Services and related aspects to you.
  • To improve our information, technology, and security systems including websites and mobile applications.
  • To provide customer service.
  • To promote our products or Services if you submit a product review or post content on public areas of our product, Services, or social media accounts.
  • To transfer our rights and duties under the relevant terms and conditions governing the use of any Services (to the extent allowed).
  • To comply, in our belief, with a legal request or to protect or enforce our rights, including to comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability, and to protect the rights, property, and safety of us or others.
  • To evaluate, effectuate, or otherwise transfer your Personal Information as part of a proposed or actual sale, merger, restructuring, transfer, or exchange of all or a portion of our assets to another company.

6. When and how do we obtain your consent?

We generally obtain your 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 and the reasonable expectations you might have in the circumstances.

7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?

We ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with Personal Information are contractually required to observe the intent of this Privacy Notice and our privacy practices.

Third-Party Sites

Because our Services are provided through digital means, those Services may include links to third-party websites, plug-ins, and applications ("Third-Party Sites"). 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 Sites and are not responsible for their privacy statements. We encourage you to read the privacy notice of every Third-Party Site you visit or use.

8. How long will we utilize, disclose, or retain your Personal Information?

We may keep a record of your Personal Information, correspondence, or comments, in a file specific to you. We will utilize, disclose, or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

9. How can you review your Personal Information that we have collected, utilized, or disclosed?

If you make a written request 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.

We may also contact you to ask you for further information in relation to your request to speed up our response.

10. How do you know that the Personal Information we have on you is accurate?

It is important that the Personal Information we hold about you is accurate, complete, and up to date as possible. Please keep us informed if your Personal Information changes during your relationship with us.

11. How fast will we respond to your written requests?

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. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.

12. Are there any costs to you for requesting information about your Personal Information or our privacy practices?

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.

13. How do we know that it is really you requesting your Personal Information?

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.

14. What safeguards have we implemented to protect your Personal Information?

While no online or electronic system is guaranteed to be secure, we take reasonable measures designed to protect the information we collect from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. In particular, we implement reasonable security practices and procedures designed to protect the confidentiality and security of this information in accordance with, and prohibit disclosure other than as permitted by, this Privacy Notice. We also use reasonable measures designed to limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business reason to know such information. Such access and disclosure are subject to a duty of confidentiality.

We have put in place reasonable procedures to deal with any suspected Personal Information breach and will notify you and any relevant regulator of a breach where we are legally required to do so.

If you want to know more about our security practice, please visit the following link: https://crypto.com/en/security.html

15. How do you contact us regarding access to your Personal Information or our privacy practices?

All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices, should be forwarded to our Data Protection Officer’s team as follows:

In writing:
Data Protection Officer,
1170 Peachtree Street, Suite 1200,
Atlanta, Georgia,
30309

By email: [email protected]