Last Updated: January 1, 2019
The Deposit Exchange Inc. (“CFO2,” “we,” “us,” or “our”) is committed to the protection of personal information, including personal information that we collect, use, disclose and otherwise manage personal information in connection with CFO2 products and services (the “CFO2 Services”) and through other interactions we may have with you.
COLLECTION AND USE OF PERSONAL INFORMATION
The CFO2 Platform (the “Platform”) provides small business owners with analysis and insights of where their business is going, to make better business decisions today. Our small business customers determine what types of personal information about their business they will upload into the Platform, and this data may be deleted by our customers from our systems at any time. We require our customers to ensure that they are authorised to provide personal information to us in accordance with applicable privacy laws. We do not collect or use client personal information of our customers for any purpose other than to provide services on behalf of our customers.
CFO2 may collect and use the following information:
- Sign up: If you sign up for the CFO2 Services, you may provide us with certain personal information about yourself, such as your name, address, phone number, and e-mail address. We use this information for the purpose of processing and responding to your sign up request.
- CFO2 Services: In addition to the personal information set out above, you may provide us with personal financial information, such as account names and numbers, passwords, and PINs as part of registration for and usage of the CFO2 Services. We use this information for the purpose of providing the CFO2 Services.
- Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings (including the Platform and Website).
DISCLOSURE OF PERSONAL INFORMATION
As a matter of practice, CFO2 does not disclose, trade, rent, sell or otherwise transfer our customers’ clients’ personal information, except as set out in this policy.
We may transfer or disclose personal information as follows:
- Service Provider Arrangements: In connection with our Website, Platform or other services we provide to our customers, we may transfer (or otherwise make available) personal information to third parties who provide services on our behalf. For example, we may use service providers to process payments, host our website and store information on our behalf. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.Personal information may be maintained and processed by third party service providers in the US and Canada. For more information about the way in which our service providers treat personal information, contact us as set out in the “Contact Us” section below.
- Sale of Business: We may transfer personal information as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of CFO2 or as part of a corporate reorganization or other change in corporate control.
- Legal: CFO2 and our Canadian, US or other service providers may provide personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US, or other foreign governmental authorities, courts, or law enforcement agencies), or to other organizations in the case of investigating a breach of an agreement or contravention of law, or detecting, suppressing, or preventing fraud, or as otherwise required or permitted by applicable Canadian, US, or other law. We may also disclose personal information where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
INFORMATION ABOUT OUR WEBSITE
Visiting our Website: We collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website.
SECURITY OF PERSONAL INFORMATION
We understand that data security is a critical issue for our customers and we are committed to safeguarding the personal information in our custody and under our control. We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control.
ACCESS TO PERSONAL INFORMATION
You may request access, updating or correction of your personal information in our custody or control at any time, subject to limited exceptions prescribed by law by contacting us as set out in the Contact Us section below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
Please contact us at the e-mail address set out below if:
- you wish to access, update, and/or correct inaccuracies in your personal information; or
- you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.
312 Adelaide Street West, 2nd Floor