Effective Date: November 30, 2017
We collect and maintain different types of personal information in respect of the individuals with whom we interact. Depending on the interaction this may include:
contact and identification information, such as your name, address, telephone number, organization name, job title, and e-mail address;your marital status, biography;information regarding your location;your date of birth or age; andcredit card or cheque information (if required).
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. We may also collect information related to our media, public relations activities, and information related to our interactions with financial and other advisors.
Typically, TokeIn collects personal information from you. In other circumstances, TokeIn collects information from TokeIn in the mantter described below. In addition, where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
The TokeIn’s websites, mobile applications, channels and software and social media pages collectively shall be referred to as the “Sites”.
We may collect information related to your visit to our Sites, including the IP address and domain used to access our Sites, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and your geographic location. We may collect and process information about your actual location using various technologies including IP address, GPS and other sensors. We use this information to monitor our Sites’ performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our Sites.
We may place a "cookie" on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our sites to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our Sites so that we can customize and tailor the Sites to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.
Finally, our Sites may contain links to other sites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these sites. TokeIn is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.
TokeIn collects personal information to enable us to manage, maintain, and develop our operations, including for example:
to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);to protect TokeIn against error, fraud, theft and damage to our goods and property;to enable us to comply with applicable law or regulatory process; and any other reasonable purpose to which you consent.
We may use or disclose your personal information:
We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.
For example, we may share your personal information from time to time with our third party information technology and data processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in Canada or the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.
Finally, your personal information may be disclosed:
as permitted or required by applicable law or regulatory requirements;to comply with valid legal processes such as search warrants, subpoenas or court orders;as part of TokeIn's regular reporting activities;to protect the rights and property of TokeIn;during emergency situations or where necessary to protect the safety of a person or group of persons; and with your consent.
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
TokeIn will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.
Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information in order to operate, develop, or improve our products and services are granted access to personal information. The computers/servers in which we store personal information.
The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
The Sites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Sites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Sites or on or through any of its features/register on the Sites, engage in any transactions through the site, use any of the interactive or public comment features of the Sites or provide any information about yourself to us, including, without limitation, your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.