MoneyClip Privacy Policy

Introduction

This Privacy Policy applies to the privacy practices of Money Clip Canada Inc. (hereby referred to as “MoneyClip”, “we”, “us”, or “our”) in the course of providing our Platform, App and Services (as those terms are defined in our Terms of Use), as well as our website located at www.moneyclip.io, (the “Website”). By accessing the content on the MoneyClip Website or using the Platform, App or Services, you are consenting to these privacy policies and practices. If any of these policies or practices are unacceptable to you, please do not visit, access or use MoneyClip.

By accessing and using the MoneyClip Website, you acknowledge that you are at least sixteen (16) years of age or older and have the legal capacity to consent to this Privacy Policy.

Consent

“Personal Information” means information about an identifiable individual or any information that allows an individual to be identified. By submitting Personal Information to us, you signify your consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. If you do not consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy, please do not provide any Personal Information to us. However, most Services can only be offered to you if you provide Personal Information.

Collection of Personal Information

Generally, we collect your Personal Information directly from you when you sign up for a Wallet, buy, or sell Digital Credits. In order to provide the Wallet, we collect your name, phone number, email address, mailing address and phone specifications (device manufacturer and model number).

MoneyClip has a legal obligation to meet specific regulatory requirements enforced by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) with respect to regulations regarding KYC (Know Your Customer); AML (Anti-Money Laundering); and ATF (Anti-Terrorist Financing). For this reason, the following information may be collected when you purchase Digital Credits.

If you are using MoneyClip on behalf of a business, we may collect incorporation documents, tax documents or documentation related to the ownership or structure of the business, which may include Personal Information.

How we use Personal Information

MoneyClip use Personal Information to provide you with the digital Wallet and Services, including allowing you to purchase Digital Credits and sell Digital Credits.

We also collect and use Personal information to fulfill our legal obligations. In particular, we collect Personal Information for the following reasons:

Certain transactions made using MoneyClip may be permanently recorded in a public database (e.g. blockchain). The information recorded does not include Personal Information; however, user anonymity is not guaranteed. When you use the Services, MoneyClip may view transactions on a public blockchain. In particular, MoneyClip may be able to view Digital Credit transactions made by Users. This Personal Information is used for the following purposes:

MoneyClip will use the contact information provided to notify users of important information that is relevant to the Services. You may opt out of receiving marketing communications; however, despite your indicated e-mail preferences, we may send you relevant notices about the Services where permitted by law.

MoneyClip may also collect certain information from Users of the Platform, App, Website and Services, such as Internet addresses, time spent logged into the Services and other usage data (“Usage Data”). This Usage Data is logged to help diagnose technical problems, and to administer our Platform, App, Website and Services in order to constantly improve the quality of the Services.

Disclosure of Personal Information

We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our products and services, including the provision of maintenance services, database management, payment processing, web analytics and general improvement of the Services, and businesses who engage our Services (to the extent provided for above).

If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities.

Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

Cookies

When you access the MoneyClip Website, we may place small data files called cookies (or other tracking tools) on your computer or other devices to automatically store information including (but limited to) identifying user information and your usage preferences. This information helps us recognize you as a user and better customize our services, content and preference for you. By using MoneyClip, you acknowledge and agree that we may collect and transmit any data collected to third-party providers (such as data analytics providers) to make use of the technologies described above. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use MoneyClip.

Protection of Your Personal Information

We work hard to guard the privacy of your Personal Information and protect it from unauthorized access, use, disclosure or destruction. To deliver our Services, internally we have restrictive, permissioned access for employees, affiliates and subcontractors to relevant portions of your data on an as-needed basis only. We conduct ongoing training with our employees regarding the importance and treatment of customer information. We maintain physical, electronic and procedural safeguards and comply with all laws and regulation to protect your information from unauthorized access.

Despite this effort, transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information during transmission, any acts of transmission are at your own risk.

Storage and Retention

We use servers located on our premises as well as cloud services hosted by third-party service providers whose servers are located in the Canada. Accordingly, your Personal Information may be available to government and/or law enforcement agencies in Canada and may be accessed by these entities pursuant to a lawful order, irrespective of the safeguards we have implemented to protect your Personal Information.

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personal Information, or if otherwise required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

MoneyClip has a regulatory requirement to maintain records for a minimum of seven years after record creation. Once this time has passed, you may request that your Personal Information be erased from our system, provided that it is no longer necessary to any active legal or regulatory requirements or legitimate business purposes.

Accessing and Correcting Your Personal Information

You have the right to request access to your Personal Information, and to receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. For example, if the requested information would reveal Personal Information about another individual, your request for access may be limited or denied. If your request is denied, we will notify you in writing of the reason for the denial.

You also have a right to challenge the accuracy and completeness of your Personal Information, and to have it amended as appropriate.

If you would like to request access to your Personal Information, challenge the accuracy and completeness of your Personal Information, or if you have any concerns regarding our privacy practices, please contact our Privacy Officer at: privacy@moneyclip.io

You have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) or other privacy regulator in your jurisdiction regarding the treatment of your Personal Information.

10. Changes to Our Privacy Policy

From time to time, we may make changes to our Privacy Policy. We will notify you of such changes by updating this Website and/or by sending an email to the email address we have on file. Continued access and/or use of our Website and Services or provision of Personal Information to us after any update to our Privacy Policy will constitute your acceptance of, and agreement to this revised Privacy Policy. Please periodically review our Privacy Policy so that you are aware of our current policies on the collection, use and disclosure of Personal Information.

Effective Date: October 21, 2019

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