Privacy Policy

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Introduction, Definitions, Acceptance and Modifications

Welcome to the Exchange247 Application and Website. We are confident that you will find our Services useful. This Privacy Policy (the “Policy”) covers several different situations, so please refer to the following definitions for clarification:

Application” refers to the free app for iOS or Android created and owned by Exchange247. Application also includes any Application updates and upgrades that Exchange247 may provide to you or make available to you, or that you obtain after the date you obtain your initial copy of the Application, to the extent that such items are not accompanied by a separate privacy policy. The Application may be specified as either “iOS Application” or “Android Application”, for use with respect to the Application’s operating system environment.

Device” refers to the handheld or tablet device onto which you downloaded the Application and are using the Services.

Services” are the proprietary software services that Exchange247 has developed to allow Users to complete certain Transactions, and related functionalities. The Services may be accessed through the Application or the Website.

Exchange247” refers to Exchange247 Inc., a duly incorporated company located in the province of Quebec, Canada. Where the present Policy refers to “Exchange247”, it may refer to Exchange247 or its employees, officers, directors, subcontractors, agents or representatives, depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to Exchange247. In this Policy, a Website visitor or Services User may be referred to as “you”. When you have created an account, you may be referred to as a “User”, and when you have logged in with your account credentials, you may be referred to as a “Logged-in User”.

Transaction” refers to a financial transaction completed using the Services, as more fully described in the Terms of Use.

Website” is the website located at https://exchange247.net which is owned and operated by Exchange247, and includes all subdomains, present and future. Without limiting the generality of the foregoing, the Website includes the any subdomain of the Exchange247 domain, where the Services may be accessed.

Additional definitions may be made throughout this Policy, but they will be recognizable as they will be capitalized, bolded, and in quotation marks. Additional definitions may also be found in the Terms of Use, and will have the same meaning in this Policy as they do there. The definitions found in this Policy shall also apply to the Terms of Use.

By visiting the Website, using the Services on the Website, or downloading, using or accessing the Application on your Device in any capacity, you agree to be bound by the terms of the Policy. By submitting Personal Information to us through the Services or via other means, you consent to Exchange247's collection, use and disclosure of such Personal Information (as that term is defined hereinbelow) in accordance with this Policy (as amended from time to time) and as permitted or required by law. If you do not agree to all the provisions contained in the Policy, you are not authorized to use the Website or Services. If you have downloaded the Application and do not agree to all the provisions of the Policy, you must delete the Application from your Device.

If you are an individual using the Website or Services on behalf of a corporation, partnership, or other legally-registered organization (hereinafter “Legal Entity”), you represent and warrant that you have the capacity and authority to accept the Policy on behalf of the Legal Entity, and hereby agree to be the collection, use, and disclosure of Personal Information on behalf of that Legal Entity.

Exchange247 reserves the right, at any time and without prior notice, to modify or replace any of the Policy. Any changes to the Policy can be found at this URL. It is your responsibility to check the Policy periodically for changes. Your use of the Website and / or the Services following the posting of any changes to the Policy constitutes acceptance of those changes. If there are any significant changes to the Policy that materially affect the way we treat your information, you will be notified upon logging-in to the Services or via email.

The Policy should be read in conjunction with the Terms of Use, as both these documents govern your use of the Website and / or Application.

If you have any questions about the Policy or if you wish to inquire about and / or access any Personal Information Exchange247 holds about you, please contact:

Exchange247 Legal Services legal@exchange247.net

General Statement of Privacy and Protection of Personal Information

Exchange247 takes your privacy and security of Personal Information very seriously. We have provided a secure environment and this strict Policy that describes the limited ways the information is used and the limited access to such information.

What Does This Privacy Policy Cover?

This Policy covers the treatment of personally-identifiable information, i.e. any information that identifies an individual, or can be used in conjunction with other information to identify an individual (“Personal Information”) and other information gathered by Exchange247 when you are using or accessing the Website or using the Services. This Policy also covers Exchange247’s treatment of any Personal Information that Exchange247 may share with its business partners or other third parties under very limited circumstances.

This Policy does not apply to the general practices and treatment of information (whether personal or not) by third parties that Exchange247 does not own or control, including but not limited to any third-party websites or services that you elect to access through the Website or Services or via a link from the Website or Services (“Third-Party Website”), or to individuals that Exchange247 does not manage or employ. While we attempt to facilitate access or link only to those Third-Party Websites that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Websites. We encourage you to carefully review the privacy policies of any Third-Party Website you access. We have named and provided links to the most important of these Third-Party Websites elsewhere in this Policy.

Finally, this Policy does not cover any Personal Information you send to Exchange247 via any non-secured mode of communications such as email, instant messenger, Intercom, Facebook or Twitter, as communications via these methods may be subject to interception, loss, or alteration. While we welcome your comments and suggestions sent to us in this manner, we encourage you to carefully examine what Personal Information you send to Exchange247 via these methods.

Contacting Exchange247

If you have any questions about the Policy or if you wish to inquire about and / or access any Personal Information Exchange247 holds about you, please contact:

Exchange247 Privacy Officer privacy@exchange247.net

or:

Exchange247 Privacy Officer 350-204 rue Notre-Dame O. Montreal, QC H2Y 1T3

No Collection of Personal Information as a Matter of Course; Fraud Prevention Exception

Except as provided in the next paragraph, Exchange247 does not, as a matter of course, gather any of your Personal Information while you are using the Website or Services, unless you are asked to provide such information, for example by signing up for an account. Personal Information is only gathered with your informed consent. Where you have provided Personal Information, it will only be used for the stated purpose, as detailed more specifically in the next section.

In order to prevent fraud, help to keep your account secure and to meet our obligations under the law, Exchange247 automatically collects information about your Device when you create your account with us, or if you already have an account, when you open the Application for the first time following this new practice. We automatically collect information about your Device which may be considered Personal Information, including your Device’s name, unique ID, and serial number, among other information. We store this “Device Information” in our databases and it can be connected to your account. We require this information so that we can prevent fraudulent transactions, and help trace fraudulent activities. By creating an account, you consent to our collection and storage of this Device Information.

Personal Information Collected and Its Uses

The following is an exhaustive list of Personal Information collected from you when you use the Website or Services and what we use it for. You acknowledge that you are submitting this Personal Information with your informed consent.

  • Account Information”. As specified in the Terms of Use, Users will be required to create an account and enter the following Personal Information in order to use certain of the Services: email address and phone number. This Account Information is used to verify your identity, to manage your account, to verify your credentials for logging-in to the Services, to communicate with you information about your account, and to communicate with you about your Transactions.

  • Verification Information”. In addition to the Account Information listed above, you will need to submit additional Verification Information so that we may verify your account and allow you to use all of the Services. This Verification Information includes your first name, last name, current home address and length of time you have lived there, industry, and date of birth. Under certain circumstances we may also ask you for additional documents that include personal information, such as copies of photo identification or other personal documents. We use this Verification Information in order to verify your identity and account, so that you may use all of the Services, and to verify certain Transactions. For more information about the treatment of this Verification Information, please refer to the section entitled “Verification and Financial Information Transfer to Third Parties” further in this Policy.

  • Referral Information”. If you have a Exchange247 Account and are participating in the Referral Program as defined in the Terms of Use (a “Referrer”), or if you choose to accept a referral from a Referred and create a Exchange247 Account (the “Referee”), we will share information about you with you respective Referrer or Referred as applicable. As a Referrer, we may share your first and last name, city and province of residence, and a photo of you from publicly available sources (programs such as Gravatar) so that your Referee(s) can know who you are. As a Referee, we will share your first and last names with your Referrer so that they can know who was referred.

In addition, Exchange247 may use your email address and phone number for various marketing and advertising purposes. Please refer to the sections on Email Marketing and Exchange247 Advertising further in this Policy for more Information.

Finally, Exchange247 uses your email address and phone number for the purposes of two-factor authentication. Please see that section further in this Policy.

Security and Encryption of Information

Exchange247 uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. In addition, Exchange247 uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Website and the Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Exchange247 uses Digital Ocean and Google Cloud Platform, recognized leaders in secure data, for hosting of the Website and Services, and storage of information (including Personal Information). Please note that these third parties may not be located in your home jurisdiction – see the Transfer of Personal Information Outside Your Home Jurisdiction section further in this Policy for more information.

Where you use the Services to perform a Transaction, all Transaction data, including Financial Information, is transferred by encrypted Transport Layer Security (“TLS”), the highest modern standard for Internet financial transactions.

Limited Gathering of Information for Statistical, Analytical and Security Purposes

Exchange247 automatically collects certain information using third-party analytics programs Segment, Google Analytics, Amplitude, Branch and Fabric to help us understand how our Users use the Website and Services, but none of this information identifies you personally. For example, each time you visit the Website, we automatically collect your IP address, browser and computer type, access times, the web page from which you came, and the web page(s) you access (as applicable). We use information collected in this manner only to better understand your needs and the needs of the Website or Services Users in the aggregate. Exchange247 also makes use of information gathered for statistical purposes to keep track of the number of visits to the Website, the specific pages on the Website, and Users of the Services with a view to introducing improvements.

Your IP address and other relevant information may be used in order to trace any fraudulent or criminal activity, or any activity in violation of the Terms of Use.

Aggregated Information

In addition to the information collected by the analytics program as described in the previous section, we may also generate, use and disclose aggregated and / or anonymized information and statistics about the Services and Services Users for marketing and strategic purposes. However, no User of the Services will be individually identifiable from these aggregated and / or anonymized information and statistics.

Non-disclosure of Personal Information to Third Parties

Except as provided in the next paragraph and the next sections in this Policy on Email Communications, Verification and Financial Information, Two-Factor Authentication, and Fraud Prevention, Exchange247 does not divulge any Personal Information gathered via the Website or Services to third parties. Moreover, Exchange247 does not sell, rent, trade or license any Personal Information regarding its Users to third parties. Only the employees, representatives, subcontractors, officers, agents, or assigns of Exchange247 are responsible for the management and development of the Website and Services, and only these individuals have access to the information collected there. These employees, representatives, subcontractors, officers, agents or assigns all have been instructed to comply with the Policy.

Notwithstanding anything in the Policy to the contrary, we may share any information we have collected about you or that you have submitted (whether Personal Information or not): (1) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims or demands; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of the Terms of Use; (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website or Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website or Services infrastructure or the Website or Services generally); (4) to a parent company, subsidiaries, joint ventures, or other companies under common control with Exchange247 (in which case we will require such entities to honour this Policy); (5) if Exchange247 merges with another entity, is subject to a corporate reorganization, sells or transfers all or part of its business, assets or shares (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).

Email Communications and Compliance with Anti-Spam Laws

Exchange247 currently uses Mailgun and Intercom (“Email Providers”) to send out emails and manage our newsletter. Personal Information is transferred to the Email Providers in order for our email communications to function properly. Your Personal Information is only used for the proper sending out of email; the Email Providers do not use this Personal Information for any other purpose, and will not transfer or sell your Personal Information to any other third party. You may unsubscribe from receiving marketing emails from us at any time by following the link at the bottom of any email sent to you.

Shakepay’s practices with regards to its email practices are designed to be compliant with anti-spam laws, specifically the law unofficially called “CASL”, or Canada’s Anti-Spam Law. If you believe you have received email in violation of this law, please contact us using the contact information further up in this Policy.

Verification and Financial Information Transfer to Third Parties

When you request to have your account verified, your Account Information and Verification Information is transferred to a third party, Securefact (https://www.securefact.com/), in order for them to verify your identity and account so that you may use all of the Services. Securefact is contractually required to use this Personal Information only for the purposes of the verification process and to treat your Personal Information in the strictest confidence and highest security. For more information about how Securefact treats your Personal Information, please see their Privacy notice at https://www.securefact.com/privacy-notice/.

When you use the Services to complete a Transaction, certain financial information or Personal Information may be transferred to third parties in order to complete the Transaction, under the following circumstances: (1) certain Personal Information is sent to your Financial Institution upon their request when they need to verify certain information or Transactions; or (2) when transferring funds to Exchange247 in order to add money to your Wallet, your Verification Information may be shared with our financial partners in order to verify your identity to complete the Transaction. Our financial partners are contractually required to use this information only for this purpose, and to treat your Personal Information in the strictest confidence and highest security.

Two-Factor Authentication

Exchange247 uses third-party service Twilio for the purposes of verifying your phone number and enabling two-factor authentication to log into the Services. Your email and / or mobile phone number is transferred to Twilio in order for this service to function properly.

Fraud Prevention

Exchange247 uses third-party service Clearbit for the purposes of fraud prevention and account security. Your email address and IP address is transferred to Clearbit in order to facilitate these functions.

General Information Transfer from the Services

Any information (Personal or not) the Services collect while you use them may be stored locally on your Device or computer and then transferred to servers controlled by Shakepay, and Exchange247 may obtain this information as a result of the data being sent to our servers from the Services. The information, however, is only used (or not used) by Exchange247 as described elsewhere in this Policy. Your contact information, date of sign-up, number of payments you have received may be provided to Users when you transact with, on, or through Shakepay.

Transfer of Personal Information Outside Your Home Jurisdiction

Services Users may access the Services from any country in the world. Exchange247 and its third-party vendors, including service providers and hosting partners, are located in the United States, Europe and Canada. You acknowledge that Exchange247 and our third-party vendors may be located in jurisdictions or countries where the privacy laws may not be as protective as those in your home country, state, province or other governmental jurisdiction, and consent to the transfer of your Personal Information to such countries. Without limiting the generality of the foregoing, Users in the European Union acknowledge and agree that their Personal Information may be transferred to the United States.

Permissions for the Application

The following is a complete listing and description of what functions on the Device that were developed by third parties are accessed and / or modified by the Application. Unless otherwise specified, these Permissions apply both to iOS Devices and Android Devices. Where noted, they operate with User permission only.

  • Localisation services. Allows the Application to determine your location through network and GPS services. (User permission only)

  • Network services access. Application will access your wi-fi or cellular services to display your network connection, and exchange data (including Personal Information) with servers controlled by Shakepay. Allows retrieval and sending of information from and to the internet in general.

  • Contacts access. Application will request access to your contacts to display a list of recipients when sending or requesting funds and when sending an invite notification. (User permission only)

  • Phone status and identity. Application will use your Device identity for the purposes of identifying authentication requests from new devices, and collect your Device Information to help prevent fraud and trace fraudulent activities.

  • Camera access. Application will use the camera in order to scan QR codes for the purposes of capturing recipient cryptocurrency addresses. (User permission only)

  • Storage & media access. Application requests access to store data locally on your Device such as authentication tokens, and any other storage required by the Application.

Tracking Technology ("Cookies")

Exchange247 uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) on the Website and in the Application and by using the Website or Services you agree to their use. Cookies are small text files placed on your hard drive or memory when you visit a website or use an Application, in order to track use and to improve the User experience by storing certain data on your computer or Device. The Website and Services uses “session cookies,” which improve your User experience by storing certain information from your current visit on your computer.

Specifically, we use the following cookies to perform the following functions:

  • Session cookie for the Services to identify the Logged-in User. It expires when the User logs out;

  • Authentication cookie for the Services to facilitate signing in;

  • Google Analytics, Segment, Hotjar, and Amplitude cookies to provide general internal and User analytics and to assist in identifying possible fraudulent activities;

  • Intercom session cookie to help identify Users who use the customer support services provided by Intercom;

  • Advertising cookies as described in the next section of this Policy.

Your browser or Device can be set to refuse cookies or delete them after they have been stored. Please refer to your browser or Device’s help section for instructions. Please note that deleting or refusing these cookies may reduce your User experience by requiring you to re-enter certain information, including information required to use the Services. Furthermore, as we use authentication cookies, deleting those cookies may prevent certain functions, including the entirety of the Services, from working at all. Exchange247 and its Representatives shall not be held responsible for any function that may not operate after you refuse or delete cookies, or any losses or damages arising from those functions not operating, or having reduced functionality.

Exchange247 Advertising and Opting Out

Exchange247 currently uses Google Adwords and Display Network and by using our Website or Services you consent to this use. Specifically, Exchange247 uses the remarketing features of interest-based advertising of Google AdWords that delivers you advertisements that will be of particular interest to you, based on your browsing and activity history at our websites. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these ads around the web.

You may prevent this type of advertising by deleting the appropriate Google cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google advertising by following Google’s instructions.

Exchange247 also advertises using Facebook Custom Audience and Facebook Lookalike Audience, to display advertisements to you on Facebook that will be of interest to you, and by using the Services you consent to this use. Facebook may collect or receive information from our Application using a cookie or other related technology and other applications and use that information to provide measurement services and targeted ads. Exchange247 may also transfer your email address or phone number to Facebook to facilitate this type of advertising. If you do not want to receive such Facebook advertisements, please contact us by email at privacy@exchange247.net.

Exchange247 also advertises using AdRoll, and by using the Website or Services you consent to this use. AdRoll may place cookies on your browser for this purpose, or may collect or receive information from our Application using a cookie or other related technology and other applications and use that information to provide ads. Exchange247 may also transfer your email address or phone number to AdRoll to facilitate this type of advertising. You can opt-out from receiving these targeted advertisements by visiting the NAI website opt-out page here: http://www.networkadvertising.org/choices/ or the DAA opt-out page here: http://www.aboutads.info/, or by emailing privacy@exchange247.net.

Exchange247 may in the future add additional advertising networks or services, in which case this section will be updated accordingly.

User Control and Uninstall for the Application

For the Application, you can access and change certain User settings from the settings menu on your Device. You may also uninstall; uninstall methods may vary depending on your Device or iOS or Android version. Exchange247 has no control over these functions and denies any responsibility of your use thereof, and any data or Personal Information sent to third parties as a result of said activities. Exchange247 shall also not be held responsible for any damages, pecuniary or otherwise, for your failure to backup important information prior to uninstalling the Application.

Verification, Correction and Deletion of Personal Information

You have the right to: (i) verify what Personal Information Exchange247 holds about you; (ii) ask for your Personal Information to be corrected or updated; and (iii) to withdraw your consent to the use by Exchange247 of your Personal Information and have it deleted from our records. If you wish to inquire about and verify and / or correct Personal Information Exchange247 holds about you, or if you wish to have all your Personal Information permanently deleted from our records, please contact us using the contact information further up in this Policy. Please note that deletion of your Personal Information may make it impossible for you to use the Services, or certain portions thereof, and Exchange247 accepts no responsibility for any damages, pecuniary or otherwise, resulting therefrom. If you request deletion of your Personal Information, Exchange247 reserves the right to retain some of your Personal Information for a reasonable time in order to satisfy our legal obligations or under a legal procedure of any sort.

Risks Associated with the Internet and Wireless Data Transmission

Despite Shakepay's best efforts to ensure that third parties will not access or obtain your Personal Information through your use of the Website or Services, complete confidentiality and security cannot currently be guaranteed on the Internet and / or where data is transferred via wireless digital technology of any type. Communication via the Internet is subject to interception, loss, or alteration. You acknowledge and agree that Exchange247 cannot be held responsible for damages resulting from the transmission of confidential information or Personal Information over the Internet and that such communications are at your own risk.

Limitation of Liability

Shakepay, and / or its respective officers, directors, owners, officials, partners, partnerships, principals, employees, affiliates and other related entities, servants, agents, representatives, successors and assigns, will not be held liable for any losses or damages (pecuniary or otherwise) resulting from the misuse of any information collected by any third party, or any misuse of any information collected through the Website or Services not in violation of the Policy.

Compliance with Privacy Laws

This Policy and Shakepay’s practices in general are designed to be in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”, S.C. 2000, c. 5) and Quebec’s An Act Respecting the Protection Of Personal Information in the Private Sector (R.S.Q. c. P-39.1). If you have any questions regarding this compliance, please contact us using the contact information further up in this Policy.

© Exchange247 Inc. 2019