This Privacy Policy is intended to help you understand how WonderFi Technologies Inc. and its affiliates (“WonderFi”, “we”, “us” or “our”), collect, use, and disclose your personal information (as defined below) when you access https://bitcoin.ca or any of our associated websites (collectively, the “Site).  

We will treat personal information in a manner consistent under which it was collected and our privacy practices, unless we have your consent to treat it differently. This Privacy Policy applies to any information we collect or receive about you, from any source.  

This Privacy Policy is a legally binding agreement between you (“user”, “you” or “your”) and WonderFi. If you are entering into this Privacy Policy on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this Privacy Policy, 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 Policy, you must not accept this Privacy Policy and may not access and use the Site. By accessing and using the Site, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree to abide by the terms of this Privacy Policy, you are not authorized to access or use the Site. This Privacy Policy 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 in this Privacy Policy. We may collect the following types of personal information:

• Identity & contact information: Name, date of birth, address, phone number, email

• Communication information: Communications with you regarding the Site, including by phone, chat, email, and other means of communication

• Usage information: Data about the way you use the Site, 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

How we collect your personal information

We will 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, the reasonable expectations you might have in the circumstances, and the purposes for which we are collecting the personal information. Most of the personal information we collect from you is provided by you (for example, when you fill out a form or provide your information to the Site).  

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 collect and use the personal information necessary to achieve these purposes:

• to enforce the terms of our Terms & Conditions and other agreements;

• to allow for more meaningful and useful marketing initiatives

• to collect your personal information in aggregate form to develop consumer profiles;

• to enhance your experience;

• to understand, maintain, develop and improve the Site, we use analytics to understand our Site activity and customer needs and to improve the Site;

• to administer the Site

• to ensure network and information security;  

• such purposes for which we 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 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 Policy 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: website hosting providers and other parties who assist us in operating the Site. In the event that personal information is transferred to a service provider based in the US or other foreign jurisdiction.

• Affiliates: We share personal information with affiliated entities, such as Coinsquare Capital Markets Ltd. Our affiliates are not permitted to use your information for any unauthorized purpose and will only receive your information with your consent.

• Legal & Compliance: We may also provide your personal information 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 WonderFi, 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 Policy

All comments, questions, concerns or complaints regarding your personal information or our privacy practices should be forwarded to our Chief Privacy Officer as follows:  

By e­mail: privacy@wonder.fi

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.  

How we use cookies

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) in order to collect certain information about your equipment, browsing actions and patterns. We may use this information to improve the Site, store information about your preferences and recognize you upon your return to the Site. 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

Our Site may contain links to other websites that we do not own or operate. Also, links to our Site may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to you. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we encourage you to read carefully. We do not have any control over such websites, and therefore we have no responsibility, accountability or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

Changes to this Privacy Policy

The Privacy Policy 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 Policy 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 Policy, we will take steps to notify you in advance of the change.  

An updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Site after the effective date of the revised Privacy Policy will constitute your consent to those changes.