SpendTheBits

Privacy Policy

Last modified: 19 MARCH, 2024

INTRODUCTION

SpendTheBits Inc. (the "Company" or "We") respects your privacy and is committed to protecting it by complying with this Privacy Policy.

This Privacy Policy describes:

  • The types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the SpendTheBits Mobile App (the "App"), including using our new product, STB CASH.
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information

With the introduction of STB CASH, a versatile Canadian fiat payment platform designed to streamline how Canadians transact daily, our commitment to your privacy extends to all interactions and transactions made through this new feature. STB CASH merges the convenience of digital payments with the robustness of traditional banking, minus the monthly fees, and integrates with Interac for effortless deposits and withdrawals, including options for EFT and wire transactions.

We will only use your Personal Information in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

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.

This Privacy Policy applies only to information we collect in this App and/or in email, text, and other electronic communications sent through or in connection with this App.

This Privacy Policy DOES NOT apply to information that:

  • 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).

We encourage you to read the privacy policies of any other websites or apps you visit or use, including those that may be linked to or from the SpendTheBits App or STB CASH, to understand their information practices.

Please read this Privacy Policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not download, register with, or use this App or engage with STB CASH. By downloading, registering with, or using this App, and engaging in transactions through STB CASH, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App and STB CASH, after we make changes, indicates that you accept and consent to those changes, so please check the Privacy Policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect information about you through various means to provide and improve our services, including the SpendTheBits Mobile App and STB CASH. Our methods include:

  • Direct interactions with you when you provide information to us, such as by filling in forms within the App, registering for STB CASH, or corresponding with us directly.
  • Automated technologies or interactions when you use the App or STB CASH, such as usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • [OTHER COLLECTION METHODS], which might include surveys, user feedback, or publicly available information.

The types of information we collect include:

- Personal Information that can be used to directly or indirectly identify you. This encompasses details like your name, mailing address, email address, telephone number, IP address, usernames, billing and account information, and any transactions made through STB CASH Platform or SpendTheBits app, including personal payments and business transactions. 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 privacyofficer@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 regarding your device and usage, including login data, operating system, browser type, time zone setting, and device type.
  • Blockchain Activity Monitoring for identifying potential fraudulent or illegal activities, including money laundering or terrorist financing, by analyzing bitcoin blockchain transactions.
  • Activity on the Cash App Platform, 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 SpendTheBits including STB Cash 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 Apps/Platform.

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 SpendTheBits solution including STB Cash 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.

These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use the App. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps and other online services. They may use this information to provide you with behavioural advertising or other targeted content.

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 privacyofficer@spendthebits.com. For more information, see Choices About How We Use and Disclose Your Information.

DISCLOSURE OF YOUR INFORMATION

We value your privacy and are committed to protecting your personal information. In certain circumstances, we may share your information as follows:

- Aggregated and Non-Identifying Information: We may share information that is aggregated or otherwise non-personal and does not identify any individual user without any restriction. This might include usage statistics of our App and STB CASH, general demographic information, or other insights gathered from our data.

  • Personal Information: The personal information that we collect or that you provide may be disclosed as described in this privacy policy, including to:
  • Subsidiaries and Affiliates: Our business units, subsidiaries, and affiliates for the purposes consistent with this Privacy Policy, including to provide you with the SpendTheBits Solution and STB CASH services.
  • Business Transfers: In the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or any other sale or transfer of some or all of SpendTheBits' assets, we may transfer the personal information we hold to the relevant third party. This includes scenarios where SpendTheBits is involved in a bankruptcy, liquidation, or similar proceeding, and personal information held by us about our App users and STB CASH customers is among the transferred assets.
  • Legal Obligations and Law Enforcement: We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). This may include sharing information for purposes of law enforcement, national security, or other issues of public importance.
  • To Protect Rights, Property, or Safety: To enforce our terms and conditions, protect our operations, rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to allow us to pursue available remedies or limit the damages that we may sustain.
  • STB CASH Transactions: Given the financial nature of STB CASH, certain transactions may necessitate sharing information with financial institutions, payment processors, or other entities involved in the transaction process, always in accordance with this Privacy Policy and applicable laws.
  • 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 contractors, service providers, and other third parties we use to support our business, such as analytics and search engine providers that help us optimize and improve our services. We contractually require these third parties to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process Personal Information following the same standards set out in this Privacy Policy;
  • 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 including STB Cash Platform, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer Personal Information that we collect or that you provide us to contractors, service providers, and other third parties we use to support the App (such as analytics providers that assist us with App improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this Privacy Policy.

We may process, store, and transfer your Personal Information in and to other countries with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information. Whenever we engage a service provider, we require that its privacy and security standards comply with this Privacy Policy and applicable Canadian laws.

By submitting your Personal Information or engaging with the App, you consent to this transfer, storage, or processing.

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: CHOICES ABOUT HOW WE USE AND DISCLOSE 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 customersupport@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 customersupport@spendthebits.com

DATA SECURITY

The security of your Personal Information, including details related to STB CASH transactions, is of paramount importance to us. To protect your data, we implement a blend of physical, electronic, and administrative safeguards:

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.

DATA RETENTION

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 Apps SpendTheBits Solution including STB CASH Platform, are 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 customersupport@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 customersupport@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 customersupport@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.

CHANGES TO OUR PRIVACY POLICY

We may update our Privacy Policy from time to time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' Personal Information, we will post the new Privacy Policy on this page.

We include the date the Privacy Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this Privacy Policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact us at: Jaskaran Kambo

privacyofficer@spendthebits.com and/or via our telephone number:+1 (516) 515-0156

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Privacy Policy, and with applicable privacy laws. To discuss our compliance with this Privacy Policy please contact our privacyofficer@spendthebits.com using the contact information listed above.