the types of information we may collect or that app users (“you“) may provide when you purchase, download, install, register with, access, or use the SpendTheBits Mobile App (the “App“); and
Our practices for collecting, using, maintaining, protecting, and disclosing that information.
Privacy laws in Canada generally define “Personal Information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person (“Personal Information”). Personal Information does not include business contact information, including your name, title, or business contact information.
- we collect offline or on any other Company apps or websites, including websites you may access through this App; or
- You provide to or is collected by any third party (see Third-Party Information Collection).
Our websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect information about you through:
Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us directly;
Automated technologies or interactions, when you use the App, for example, usage details, IP addresses, and information collected through cookies and other tracking technologies; and
OTHER COLLECTION METHODS.
The types of information that we collect include:
Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, internet protocol (IP) address, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you.
We provide an opportunity for any user to unsubscribe from SpendTheBits or opt-out of contact for marketing purposes on an ongoing basis by e-mailing Security@spendthebits.com.
Non-Personal Information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. We may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific app feature.
Technical information, including your login information, device type, time zone setting, and usage details.
Activity on bitcoin blockchain, in an effort to identify any activity on dark markets or any fraudulent activity or illegal activity, including money laundering or terrorist financing.
Information You Provide to Us
When you download, register with, or use this App, we may ask you to provide:
- information by filling in forms in the App, which includes information you provide when registering to use the App;
- records and copies of your correspondence, including email addresses and phone numbers, if you contact us; and
- details of transactions you carry out through the App and we may require you to provide financial information before placing an order through the App.
Automatic Information Collection and Tracking Technologies
When you download, access, and use the App, it may automatically collect:
Usage details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, and other communication data and the resources that you access and use on or through the App.
Device information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
Stored information and files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Location information. This App collects real-time information about the location of your device.
The technologies we use for this automatic data collection may include:
Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
The information we collect automatically is statistical information and may include Personal Information. We may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. This usage information helps us to improve our App and to deliver a more personalized service, including by helping us to:
- estimate our audience size and usage patterns;
- store information about your preferences and customize our App according to your individual interests;
- speed up your searches; and
- recognize you when you use the App.
If you do not want us to collect this information do not download the App or delete it from your device. Note, however, that opting out of the App’s collection of location information will cause its location-based features to be disabled.
Third-Party Information Collection
When you use the App or its content, certain third parties collect information about you or your device.
These third parties may include:
- advertisers, ad networks, and ad servers;
- analytics companies;
- your mobile device manufacturer; your mobile service provider; and
- Anti-money laundering software which collects personal information for the purposes of compliance with the Proceeds of Crime (Money Laundering) Terrorist Financing Act and regulations and the Financial Action Task Force standards and guidelines.
You can access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties’ tracking technologies or how they use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any Personal Information:
- to provide you with the App and its contents;
- to provide you with information, products, or services that you request from us;
- to fulfill the purposes for which you provided it or that were described when it was collected, or any other purpose for which you provide it;
- to provide notices about your account, including expiration and renewal notices;
- to carry out our obligations and enforce our rights in any contracts with you, including for billing and collection or to comply with legal requirements;
- to notify you when App updates are available, and of changes to any products or services we offer or provide though it;
- to improve our App, products or services, or customer relationships and experiences; for marketing purposes;
- to allow you to participate in interactive features, social media, or other features on our App;
- to measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you; and
- for any other purpose with your consent.
Usage information that we collect helps us to improve our App and to deliver a better and more personalized experience, including by enabling us to:
- estimate our audience size and usage patterns;
- recognize you when you use the App.
We may also use your information to contact you about services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please e-mail us at Security@spendthebits.com. For more information, see Choices About How We Use and Disclose Your Information.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- to our subsidiaries and affiliates;
- according to applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SpendTheBits’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by SpendTheBits about our customers and users is among the assets transferred;
- to advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers target a specific audience. We may use the Personal Information we collect from you to display our advertisers’ advertisements to their target audiences;
- to third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information;
- to fulfill the purpose for which you provide it;
- for any other purpose we disclose when you provide the information; with your consent;
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request, according to applicable law;
- to enforce our rights arising from any contracts between you and us, including the App User Agreement, and for billing and collection; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SpendTheBits, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.
TRANSFERRING YOUR PERSONAL INFORMATION
By submitting your Personal Information or engaging with the App, you consent to this transfer, storage, or processing.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
Location Information. You can choose whether to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may be inaccessible or not function properly.
Third-Party Advertising and Marketing. If you do not want us to share your Personal Information with unaffiliated third parties for marketing or promotional purposes, you can opt-out by sending us an email stating your request to Support@spendthebits.com.
Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish for us to use your contact information to promote our own or third parties’ products or services, you can always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to Support@spendthebits.com.
The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any transactions will be encrypted using SSL technology. Our server does not store private keys or Passcodes, as this resides on the App.
The safety and security of your information also depends on you. Where we have given you or you have chosen a password for access to certain parts of our App, you are responsible for keeping it confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through the App. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any App privacy settings or security measures.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
CHILDREN UNDER THE AGE OF 13
Our App is not intended for children under 13 years of age. No one under age 13 may provide any Personal Information to or on the App. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this App or on or through any of its features/register on the App, make any purchases through the App, use any of the interactive or public comment features of this App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any 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 Support@spendthebits.com.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.
If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us an email at Support@spendthebits.com to request access to, correct, or delete any Personal Information that you have provided to us. We may not be able to delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at Support@spendthebits.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
Rajveer Sidhu & Jaskaran Kambo