Privacy and Cookie Policy

Introduction
Your Consent
Privacy and Confidentiality
Information We Collect And How It Is Used
Personal Information
Non-Personal Information
What Personal Information Do We Collect
Why Do We Collect Personal Information
How Do We Collect It
What Do We Use Your Personal Information For
How We May Use Or Disclose Your Personal Information
Data Processing
Choices For Personal Information
Where We Store Your Personal Information
Information Security
Accuracy And Access/Control Over Personal Information
Your Rights
Third-Party Websites
Information About Our Use Of Cookies
We Use The Following Cookies
Retention Of Personal Information
Changes To This Policy
Contact

Introduction

This website (“ Website”) is operated by CleverDo Payment Technologies Ltd registration number: BC1362982, having its registered office at SUITE 1700, 777 Dunsmuir Street, V7Y1K4 Vancouver, British Columbia, Canada. Regulated and licensed by FINTRAC, Canada, as a Payment Service Provider (PSP) and Money Service Business (MSB) with registration number: M22036350. CleverDo and any of its group companies (together “CleverDo” or “We” or “Us”) are committed to protecting and respecting your privacy. The Privacy and Cookie Policy (the “Policy”) applies to CleverDo Website www.CleverDo.app (“Website”) and mobile application (CleverDo, CleverDo App) and set out our practices for collecting, using, and disclosing certain personal information collected from or about you or that you provide to Us in the course of conducting its business, in conjunction with your access, navigation, and use of the Website and mobile application and any services offered therein (“Services”). By providing Us with information, you are consenting to the collection, use or sharing of your information as set out in our Policy, CleverDo is committed to protecting your privacy and all your personal, business and financial information in the course of conducting our business. We carefully follow privacy policies and security practices in everything We do, to support our commitment to you.

Your Consent

By visiting the Website and the mobile application, you acknowledge that you have read carefully and understood our Policy and you are accepting and consenting to the practices for collecting, using and sharing your Personal Information as described in this Policy. This Policy complies with the Personal Information Protection Act (British Columbia) (“PIPA”) and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) as applicable (collectively, the “Acts”).

Privacy and Confidentiality

We have safeguards in place to protect the security and confidentiality of your personal information. However, the Internet is not a secure place where privacy and confidentiality can be guaranteed. Your confidential use of the Services can not be guaranteed, and you acknowledge that your use of the Services may be subject to access or manipulation by, or disclosure to, third parties. CleverDo is not responsible or liable for any damages that you or any other person may suffer in connection with any such violation of privacy, confidentiality, or security.

Information that We Collect And How It is Used

We may collect and use Personal Information and Non-Personal Information from you when you access or use the Service. In this section, We will describe the type of information that may be collected and how that information may be used.

Personal Information

“Personal Information” means personally identifiable information that specifically identifies someone as an individual.

Non Personal Information

“Non Personal Information” is information that cannot be associated with or traced back to a specific individual or business entity. For example, our Web server will collect some anonymous/non-personal information automatically when you visit CleverDo digital channels. Gathered electronically, this information may include the pages you visited, the type of web browser you are using, the level of encryption your browser supports and your Internet Protocol address. The anonymous/non-personal information collected may be used or shared for research and analytical purposes. To help Us better understand our markets, We may also gather information for analytical purposes by conducting anonymous client surveys.

What Personal Information Do We Collect

Information We may collect: (i) Information establishing your identity (such as your name, address, postal code, email address or phone number, occupation, date of birth, financial or credit/debit card information, personal description, or photograph and other identification documents required by law); (ii) information to authenticate your identity such as knowledge-based information (i.e. username, password and account information), biometric information (i.e. signature, fingerprint, facial recognition and voiceprint), device information (i.e. device model, browser type and activity, IP address, security cookies and approximate physical location of device); (iii) informatin when it is required to prevent, detect or investigate fraud or criminal activity; (iv) information about your financial status including your employment history, annual income, assets, liabilities and credit history; (v) information reflecting your business dealings with us; (vi) full Uniform Resource Locators (URL), clickstream to, through, and from our Website (including date and time), (vii) information about the products you viewed or searched for, page response times, download errors, (viii) information about the length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number; (ix) any other information with your consent, or as permitted or required by law; and (vii) any additional information that may be requested to help Us determine your eligibility for products and services that we offer.

Information We receive from other sources: This is the information We receive about you if you use any of the other websites and/or mobile applications that We operate or any other services We provide. We are also working closely with third parties (including, for example, business partners, technical support teams, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) and may receive information about you from them. In this case, We will have informed you when We collected that data if We intend to share such data internally and combine it with data collected on this Website. We will also have told you for what purpose We will share and combine your data.

Why do We collect personal information?

We may require you to provide Personal Information to access the Service. Such personal information is used to help to provide you with a secure, private, and convenient experience.

How do We collect it?

Using the Service: We may collect Personal Information about you as part of your use of the Service. Information about you, that you give to Us on each of your visits to our Website and/or mobile application. Information is provided by filling in forms on our Website www.CleverDo.app or by corresponding with Us by telephone, email, or otherwise. This includes information you provide when you register to use our Website and/or mobile application, subscribe to our Service(s), search for a product or when you report a problem with our Website and/or mobile application. We will automatically collect the following information: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information (if relevant), browser type and version, time zone setting, browser plug-in types, and versions, operating system, and platform.

Contacting Us: When you choose to contact Us either by the Website or mobile application, We may collect, store and use the Personal Information that you provide Us, such as your name, email address, phone number, and other information you choose to provide in the content of your message, so We can respond to your inquiry. This is information about you, that you give us, by filling in forms on our website www.CleverDo.app or by corresponding with Us by telephone, email, or otherwise. This includes information you provide when you register to use our website and/or mobile application, subscribe to our Service(s), search for a product and when report a problem with our website and/or mobile application. The information you give Us may include your name, date of birth, address, postal code, email address or phone number, financial or credit/debit card information, personal description, or photograph.

What do We use your Personal Information for?

We will only use your Personal Information for the purposes for which We collected it unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. We may process your Personal Information for more than one (1) lawful ground depending on the specific purpose for which We are using your Personal Information.

How We May Use Or Disclose Your Personal information

(i) Information We receive from you

When We need to fulfil the contract We are entering into or have entered into with you (for example, to ensure your suitability and eligibility for products and/or services which you have requested).

Where it is necessary for our legitimate interests (or those of a third party) where your interests and fundamental rights do not override those interests (for example, undertaking analysis and research to improve our Website and/or mobile application user experience).

Where We need to comply with a legal or regulatory obligation (for example, equal opportunities monitoring). Please note that We may process your personal information without your knowledge or consent, where this is required or permitted by law. Generally, We do not rely on consent as a legal basis for processing your Personal Information other than concerning sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting Us. Please contact Us by email at info@CleverDo.app if you need details about the specific legal grounds We are relying on to process your Personal Information.

To carry out our obligations arising from any contracts entered into between you and Us and to provide you with the information, products, and services that you request from Us.

To provide you with information about other products and services We offer that are similar to those that you have already purchased or enquired about.

To provide you, or permit selected third parties to provide you, with information about products or services We feel may be of interest to you. If you are an existing customer, We will only contact you by electronic means (email or SMS) with information about products and services similar to those which were the subject of a previous sale or negotiations for a sale to you. If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by electronic means only if you have consented to this. If you do not want Us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which We collect your Personal Information.

To notify you about changes to our services.

To ensure that content from our Website and/or mobile application is adequately responsive to suit you and your devices.

To administer our Website and/or mobile application and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

To improve our Website and/or mobile application to ensure that content is adequately responsive for you and your devices.

To allow you to participate in interactive features of our service when you choose to do so.

As part of our efforts to keep our Website and/or mobile application safe and secure.

To measure or understand the effectiveness of advertising We present to you and others and deliver relevant advertising to you.

To make suggestions and recommendations to you and other users of our website and/or mobile application about goods or services that may interest you or them.

(ii) Information We receive from other sources

We will combine this information with the information We collect about you and from you. We will use this information and the combined information for the purposes set out above (depending on the types of information We receive).

Other Uses of Your Personal Information

We may also use the Personal Information that We collect to help provide you with a better service. Among other things, the Personal Information We collect enables Us to improve Our Service(s), communicate with you, and fulfil your requests for products, services, and information. If you give Us information on behalf of someone else, you confirm that you have given them the information set out in this notice and that they have given permission for Us to use their information as set out in this notice version.

What your information will not be used for

Marketing from CleverDo: You will not receive any marketing or advertisements from CleverDo at the email address you provide, without your consent.

Marketing from third parties: We will never sell your Personal Information to third parties.

How/When the Collected Information is Disclosed

We will never sell, share, transfer or rent your Personal Information for secondary purposes. In certain circumstances, We may share any or all information, including Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 2 (2) of the Canada Business Corporations Act.

When We will disclose your Personal Information to third parties:

(i) During due diligence or in preparation for or after a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation; (ii) If CleverDo or the majority of its assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; (iii) If We are under a duty to disclose or share your data to comply with any legal obligation, or to enforce or apply our Terms of Use or Terms and Conditions of supply and other agreements; or to protect the rights, property, or safety of CleverDo, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud prevention and credit risk reduction (iv) If We are required to disclose or share your Personal Information under a legal obligation, in order to enforce or apply our contractual agreements or without your consent pursuant to any of the exceptions in the Acts; and (v) We may share anonymous information (meaning information that does not identify you personally) with or to business partners.

Data Processing

We may disclose Personal Information to (i) Our service providers, business partners, suppliers, and subcontractors for the purpose of processing Personal Information on our behalf or assisting in the operation of the Service. We require that these parties agree to process such Personal Information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures; (ii) Selected third parties including: (a) Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers; however, We will provide them with aggregate information about our users (e.g.: We may inform them that five hundred (500) men aged under thirty (30) have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women aged 30-60). We may make use of the personal data We have collected from you: (a) to enable Us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; (b) Analytics and search engine providers that assist Us in the improvement and optimization of our Website and/or mobile application; (c) Credit reference agencies to assess your credit score where this is a condition of Us entering into a contract with you.

Choices For Personal Information

•If We propose to collect, use or disclose Personal Information for any purpose other than those described in this Policy, We will obtain your prior consent.

•You may choose to withdraw your consent to the collection, use, or disclosure of your Personal Information as outlined in this Policy at any time. If you withdraw consent, then We may no longer be able to provide you with full or any access to the Service.

•Users of the Service are also given the opportunity to “opt-out” of having their Personal Information used for specific purposes, such as receiving newsletters or other information from Us.

•Withdrawals of consent will not have an effect on Personal Information or other data that We have used or disclosed in accordance with this Policy prior to such withdrawals.

Where We Store Your Personal Information

By submitting your Personal Information, you agree to its transfer, storage or processing. We take all reasonable steps necessary to ensure that your data is treated securely in accordance with this Policy and the Acts. However, no data transmission over the Internet can be guaranteed to be 100% secure. Although We will endeavour to do our best to protect your data, We cannot guarantee the security of your data transmitted to our Website and/or mobile application, any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorized access. Your Personal Information may be transferred to and maintained on servers or databases located in Canada and the U.S. in accordance with the Acts, as applicable. You consent to such processing and storage.

Information Security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information. We use physical, electronic, and/or procedural safeguards to protect our systems and all Personal Information under our control against unauthorized access and use. We only use third party server hosts with certified facilities that contain the industry standard physical, operational, and digital security and restriction protocols. All safety and security measures are reasonable and appropriate to the sensitivity level of the information collected.

Accuracy And Access/Control Over Personal Information

We will take reasonable steps to ensure that the Personal Information collected by Us or on our behalf is accurate and complete, as required pursuant to the Acts.

We will allow you to access your Personal Information in our custody or control, and you may request that We: (i) update or correct such Personal Information; (ii) change your preferences with respect to communications and other information received from Us; or (iii) delete your Personal Information on our primary system, by submitting a request to info@CleverDo.app, though this may result in your inability to use the Service.

If We are satisfied on reasonable grounds that your request to update or correct your information should be implemented, We will correct your Personal Information on our primary system as soon as reasonably possible. We may retain an archived copy of your records as required or authorized by law.

Your Rights

You have the right to object to how We use your personal information. You also have the right to see what personal information We hold about you. In addition, you can ask Us to correct inaccuracies, delete or restrict personal information or ask for some of your personal information to be provided to someone else. We will endeavour to provide this information to you within thirty (30) calendar days, however, occasionally we may need additional time and We will communicate these reasons to you. To make enquires for further information about exercising any of your rights in this Policy, please contact Us at info@CleverDo.app.

You are entitled to exercise any of the following privacy rights: (i) Right to object: You can object to our processing of your personal information. Please contact Us as noted below, providing details of your objection; (ii) Access to your personal information: You can request access to a copy of your personal information that We hold, along with information on what personal information We use, why We use it, who We share it with, how long We keep it for and whether it has been used for any automated decision making; (iii) Right to withdraw consent: If you have given Us your consent to use your personal information to send you marketing emails, you can withdraw your consent at any time by clicking the “unsubscribe” link in any marketing email which you receive; (iv) Rectification: You can ask Us to change or complete any inaccurate or incomplete personal information held about you; (v) Erasure: You can ask Us to delete your personal information where it is no longer necessary for Us to use it, if you have withdrawn consent or where we have no lawful basis for keeping it; (vi) Portability: You can ask Us to provide you or a third party with some of the personal information that We hold about you in a structured, commonly used, electronic form, so it can be easily transferred. (vii) Restriction: You can ask Us to restrict the personal information We use about you where you have asked for it to be erased or where you have objected to our use of it (viii) Make a complaint: You can make a complaint about how We have used your personal information by contacting Us as noted below, or by contacting the supervisory authority for British Columbia at the office of the Information & Privacy Commissioner for British Columbia ( www.oipc.bc.ca).

Please make all requests to exercise your privacy rights in writing to Us at info@CleverDo.app. We are required to verify your identity in order to process your request and may ask you to provide valid identification documents to allow Us to do so. We will not make any charge for responding to any request from you to exercise your privacy rights and We will respond to your requests in accordance with our obligations under the Acts.

Third-Party Websites

Our site may, from time to time, make available third parties through hyperlinks or otherwise enable you to access third parties products or services from the Website and/or mobile application (Our partner networks, advertisers, and affiliates) that are not controlled by Us. We are not responsible for those parties, the content of their products or services, or the use of information you provide to them. If you follow a link to any of the third-party websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for any third-party use of your Personal Information you should review the privacy policies of these third parties. Please check these policies before you submit any Personal Information to these websites.

Information about Our Use of Cookies

When you access or use the Service, We (or a third-party provider) may use “cookies” to track what you view and how you interact with the Service. We treat information collected by cookies and similar technologies as Non-Personal Information.

A “cookie” is a small piece of record-keeping information (a small file of letters and numbers) that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. There are two common types of cookies: (i) Persistent and (ii) Non-persistent. (i) Persistent cookies are stored on your computer’s hard drive where they remain resident until they are either deleted or they reach a predetermined expiration date. Persistent cookies are most commonly used to provide visitors with a customized experience by recording preferences such as how a visitor prefers to have his/her web pages displayed. Additionally, cookies are commonly used to gather statistical information such as the average time spent on a particular page. This kind of information is valuable for several reasons, including providing insight on how to improve the design, content and navigation of a website; and (ii) Non-persistent cookies do not permanently record data and they are not stored on your computer’s hard drive. Rather, non-persistent cookies are stored in memory and are only available during an active session. Once a session ends, the cookie disappears. Non-persistent cookies are used primarily for technical reasons such as providing seamless navigation.

The cookies that We use do not include Personal Information and may be used to (i) help you navigate around the Website and/or mobile application; (ii) monitor how many people are using the Service, and (iii) track trends. Most browsers are initially set up to accept cookies, but you can disable cookies or set your browser to indicate when a cookie is being sent. However, disabling cookies may affect your ability to use the Service.

We use cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website or use the mobile application and also allows Us to improve our site. By continuing to browse the site, you are agreeing to Our use of cookies.

We use the following cookies:

Strictly necessary: These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into secure areas of our Services.

Analytical/performance: They allow Us to recognize and count the number of visitors to our Website and to see how visitors move around our Website when they are using it. This helps Us to improve the way our Website and/or mobile application works, for example, by ensuring that users are finding what they are looking for easily. This is statistical information and does not identify any individual.

Functionality: These are used to recognize you when you return to our website. This enables Us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Please note that third parties (including, for example, providers of external services like web traffic analysis services, or social media websites) may also use cookies, over which We have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website www.allaboutcookies.org (by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users. Please be aware that if you do not accept cookies, our website may not function correctly. You block cookies by activating the setting on your browser that allows you to refuse all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website. We will only retain your personal information for as long as necessary to fulfil the purposes We collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which We process your data, and whether We can achieve those purposes through other means as well as the applicable legal requirements. In some circumstances, We may anonymize your Personal Information so that it can no longer be associated with you, in which case We may use such information without further notice to you. We may also hold your Personal Information for longer where it is necessary to do so for the management of any active or potential legal proceedings, to resolve or defend claims, and for the purpose of making any necessary remediation payments.

Retention Of Personal Information

We retain Personal Information collected pursuant to this Policy only as long as is reasonably required to fulfil the purposes for which it was collected, or as required or authorized by law.

Changes To This Policy

We reserve the right to modify this Policy at any time. Any changes We make to our Policy in the future will be posted on this Website, and where appropriate, We may provide you with notice of such modifications, by sending you an email message or otherwise bringing it to your attention in the Service. Your continued use of the Service will signify your acceptance of the modifications to this Policy. We recommend you review the Policy regularly. If you disagree with any changes to this Policy, you will need to stop using the Service.

Have a concern about privacy?

CleverDo is committed to providing you with the best experience that We can.

Contact

If you have a concern about this Policy or our privacy practices, please follow our easy two (2) step privacy concern escalation process. We’ll work with you to resolve your concern as quickly as possible.

Step 1: Talk to our Customer Service Team

Tel: +1 604 330 0309

Email: info@CleverDo.app.

Step 2: Contact CleverDo's Privacy Officer –

Attention: Chief Privacy Officer, SUITE 1700, 777 Dunsmuir Street, V7Y1K4 Vancouver, British Columbia, Canada.

Email: privacyofficer@cleverdo.app

Note: If corresponding by email, please do not include any confidential information as email correspondence is not guaranteed to be secure.

If you want more information or are still not satisfied after contacting CleverDo’s Privacy Officer, the following external agencies can provide you with information and a further review of your concern:

Ombudsman for Banking and Investments (OBSI)

Telephone: 416-287-2877

Toll-free: 1-888-451-4519

Website: www.obsi.ca

Email: ombudsman@obsi.ca

Ombudsman for Banking Services and Investments

20 Queen Street West,

Suite 2400 P.O. Box 8

Toronto,

Ontario M5H 3R3

Office of the Privacy Commissioner of Canada (OPC)

Toll-free: 1-800-282-1376

Online Form: On the OPC website

Office of the Privacy Commissioner of Canada

30 Victoria Street Gatineau,

Quebec K1A 1H3