Privacy Policy

1. We are committed to your privacy.

At Localcoin (9992987 Canada Inc. o/a Localcoin) (“Localcoin”, “we” or “us”), our mission is to provide a simple buying and selling experience of digital currency for customers (“customers” or “you”) while upholding privacy standards across North America.  We are committed to respecting and protecting the privacy and confidentiality of the personal information (“PI” as defined below) you have entrusted to us. This Privacy Policy (this “Policy”) helps you understand how we collect, use, disclose and safeguard your PI.  It also explains the choices, rights and responsibilities you have relating to your PI in our care. 

2. This Policy applies to Localcoin services and channels in its North American operations.

Information: This Policy applies to PI.  PI is defined as information about an identifiable individual. It includes information that you have provided to us or that we collected from other sources. It may include details such as your name, contact details, transaction records, and identification numbers including your Social Security Number. PI may be factual or subjective, as well as recorded or not.

Services and Channels:  This Policy applies to all services offered by Localcoin and to all channels through which we provide those services, including Localcoin ATMs and our website.

Jurisdiction and Regulation: This Policy applies to our operations in North America. As a regulated money services business, the practices described in this Policy are subject to applicable Canadian federal and provincial privacy laws and applicable United States federal and state privacy laws in the jurisdictions in which we operate.

No Persons under 18: We do not knowingly solicit from, and our services are not intended for persons under 18 years of age (“Minors”), and Minors should not provide us with their PI. If a parent or guardian becomes aware that his or her Minor child has provided us with information, the parent or guardian should contact us as provided in Section 14. We will delete such Minor’s information from our files.

Applicable ‘As Of’: We may periodically make changes to this Policy. This Policy is current as of the “date last updated” which appears at the end of the Policy. We recommend that you review this Policy on a periodic basis as we may amend it from time to time.

3. The PI we may collect from you.

We only collect the PI that we determine we need for the identified purposes in Section 4.  We may collect your:

• Name.
• Contact Information including telephone number, postal address, and email address.
• Identification Documents including copies of Driver’s License and Passport and recorded document number, type of document, place of issue, date of issue, and expiry date.
• Photographs including those taken at the time of ATM transactions and the selfie you provide to compare against identification documents.
• Occupation for Know Your Client (“KYC”) purposes.
• Transaction Information including sales, purchases, credit cards, e-transfers, and other information about your use of our services.
• Social Security Number for U.S. KYC applicants only.
• Communications including when you communicate with us, or respond to communications from us, via email, chat, audio or video calls.
• Location Information, such as the information about your device’s approximate physical location for purposes such as validating your identity, the prevention, suppression or detection of crime, and to enhance the functionality of a particular service, for example locating a nearby Localcoin ATM. 
• Device Information, such as information about your operating system, browser, software applications, IP address, geolocation, security status and other similar device information in order to improve your experience, to protect against fraud and manage risk. 
• Website Use Information, such as browsing behaviour on the Localcoin website and links, as well as other data gathered from the use of web tools (for example, Cookies) to better understand your interests and needs so that we can serve you better. For more information about our use of web tools, please see Section 11.

We may collect PI about you when you voluntarily provide it to us, from third parties, and/or from sources that are available to the public. You can choose not to provide us with certain information in some situations, but if you make this choice, we may not be able to provide you with the service you request.

We may monitor or record our incoming or outgoing telephone calls with you to ensure accuracy, security, service quality, for training purposes and to establish a record. If you do not wish to have your call recorded, see Section 14 below to notify us. You have other options to conduct business with us such as online, or by contacting us in writing.

We may use cameras or video surveillance in and around our ATMs and other locations for the safety of our customers and employees, and to protect against theft, property damage and fraud.

Other Information, such as any feedback you may provide to us, answers to surveys and questionnaires, and use of online tools.

4. The purpose for which we collect, use, and disclose your PI.

We always collect your PI by fair and lawful means, for example, when you register with us, complete identity verification, complete a transaction, or make an inquiry.  We will use or disclose your PI only for the purpose(s) it was collected. When we collect your PI, we may use or disclose it to:

• manage your user access to Localcoin ATMs; 
• verify your identity (as required by law if you reach certain transaction value thresholds); 
• contact you if we determine verification is required;
• ensure we have accurate and up-to-date information about you;
• process your transactions; 
• understand our customers and develop and tailor our services;
• conduct anonymized sales analysis and identify marketing opportunities and strategies; 
• determine your eligibility for our services, promotions, discounts, and other offers;
• communicate with you regarding services that may be of interest;
• collect opinions, comments, and survey responses about our services;
• respond to questions, comments, or concerns regarding your use of Localcoin;
• administer Localcoin websites and any Localcoin software applications;
• comply with legal or regulatory requirements and inquiries;
• investigate legal claims; 
• protect you, and our business, against fraudulent actors, behaviours, and transactions; 
• protect our business against other legal, regulatory, financial, or business risks; and
• as otherwise permitted by law.

If a new purpose for using your PI develops, we will identify that purpose to you.

5. We obtain your consent and respect your choices regarding your PI.

Consent: By initiating services at a Localcoin ATM, you are providing your consent for us to collect, use, and disclose your PI for the purposes set out in Section 4. You also provide us with your consent to collect, use, and disclose your PI when you complete the online KYC application when you have reached or exceeded the legally mandated and Localcoin’s risk-based transaction value thresholds. Your Identity verification is required in accordance with KYC requirements under the relevant anti-money laundering regulations. 

Your Choices: During your relationship with us, we may direct-market to you by communicating with you, using the contact information you have provided, to inform you about services, promotions, discounts and other offers that we think may be of interest and value to you. Direct marketing does not include communications regarding services that you currently have, including improved ways to use the services, or additional features of the services as well as transactional information.  You can manage your direct marketing preferences to opt out of some or all of our direct marketing communications. If you want to change these privacy preferences, see Section 14. 

Your Choices about Communication: If you prefer not to receive electronic communications from us, you can unsubscribe by clicking the “Unsubscribe” button provided in the promotional emails or SMS messages you receive from us. Please allow up to 10 business days for us to process your request. However, if you unsubscribe, we may still send you transactional emails/SMS messages about your transaction and/or services. 

Your Choices about Voluntary Participation: From time to time, you may choose to enter your information in order to participate in online surveys or other activities that we sponsor. We use this information for a variety of reasons, such as measuring the performance of the website or identifying products and services that might interest you. All information is used in accordance with the purposes outlined in this Policy. Do not participate in these voluntary activities if you do not want your information used for these purposes.

Consent Withdrawal: Please note that you cannot withdraw your consent to the collection, use and disclosure of your PI if (a) we are legally required to collect, use or disclose your PI, or (b) we need it to perform the services. Withdrawing your consent in certain situations may also mean that we may not be able to provide you with the services you want.

6. We may share your PI for limited purposes.

We will only disclose your PI for the purpose(s) it was collected and as otherwise identified in this Policy.  

We may release PI to third parties including legal or regulatory authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations, or to comply with a court order or for the protection of our assets.

We may share your PI amongst Localcoin affiliates, including locations outside of Canada and/or the United States where we do business, for the purposes described in Section 4. 

We do not sell the names or other PI of our customers. We do not disclose the names or other PI of our customers to other companies outside of Localcoin without consent unless required or permitted by law. 

Over time, we may, or explore opportunities to, buy new businesses, sell some or all of our business, or participate in a corporate reorganization, merger, or other change in corporate control. In those circumstances, we may transfer the associated PI without your consent.

We may use affiliates or other third-party service providers to provide services on our behalf such as data processing, KYC services, transaction administration, analytics and marketing. We limit the PI we disclose to those affiliates or third-party service providers to only the PI they need to perform those services and we do not authorize them to use or disclose PI for their own marketing or other purposes. We have contracts in place holding these affiliates or third-party service providers to the same standards of confidentiality by which we govern ourselves.

7. We store your PI according to the applicable requirements and retain your PI only as long as required for the identified purposes.

Storage: We store the PI that we collect electronically at the Localcoin offices in Canada, or at the offices of our third-party service providers, as applicable. As such, we, our affiliates, and third-party service providers may store your PI in a jurisdiction outside of the one in which you reside but we ensure that your PI is protected in accordance with the data protection requirements of that jurisdiction.

Retention: We retain your PI for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements.

8. We seek to maintain the accuracy of your PI.

We are committed to maintaining the accuracy of your PI and ensuring that it is as complete and up-to-date as needed for the identified purposes. We do not routinely update your PI, unless an update process is necessary. You are responsible to inform us of any updates to your PI as it changes over time.  Failure to notify us of changes to your PI may negatively impact the way we communicate with you, provide services to you, and/or fulfil our legal and regulatory obligations. If we do not agree to make the amendments that you request, you may challenge our decision by contacting us as described in Section 14. If you successfully demonstrate that your PI in our records is inaccurate or incomplete, we will amend it as required.  Where appropriate, we will transmit any material amendments to your PI to affiliates orthird party service providers having access to your PI.

9. We implement security safeguards to protect your PI.

We use physical, organizational, technological, and contractual security safeguards to protect your PI against loss or theft, unauthorized access, disclosure, copying, use or modification.

We have agreements and controls in place with our third-party service providers requiring that they must safeguard any PI we provide to them or any PI they collect on our behalf and require that they use the PI only for the purpose of providing the service we have requested them to perform.

We make our employees aware of the importance of maintaining the confidentiality of PI.  Each of our employees is responsible for respecting and protecting the PI to which the employee has access. The only employees who are granted access to your PI are those with a business ‘need to know’ where their duties reasonably require such information.

You are also responsible for helping to protect the security of your PI.  For instance, safeguard and never give out your information or passwords associated with the services. 

10. We respond to PI access requests from you.

Requests to access, review or verify your PI in our care and control, or to find out to whom we have disclosed it, must be made to us in writing. By reaching out to us, we can assist you with the written request. We will need specific information from you to enable us to search for, and provide you with, the PI we hold about you. 

We may validate your identity prior to considering the request to ensure the request is valid.  We will only use the identifying information we ask you to produce for this purpose.

We will attempt to respond to your written request within the timeframe provided in the applicable legislation governing such requests. We will advise you in writing of an extension if we cannot meet your request within this time limit. You may make a complaint to the applicable regulatory or legal authorities in the event of an extension.

We will provide you with access to any such PI or information about your PI, to the extent required by law. Where we are able to fulfil your request, we will make the PI or the information about your PI available to you in a form that is generally understandable, and will explain any acronyms, short forms, or codes. We may charge you a token fee depending on the nature of your request and we will advise you of any fee prior to proceeding with your request. If we are unable to provide any of the requested PI we hold about you, we will tell you why. 

To request to access, review or verify your PI, please contact us as provided in Section 14.

11. We may use various tracking tools, such as Cookies, on our websites, mobile applications, and advertisements.

Cookies We Use:

• Cookies are a string of data sent between a server and a web browser to, for example, help facilitate the use of a website and to help understand how a website is being used. Different types of cookies are used for different types of activities. Examples of cookies we may use are:
• 
  
• Session cookies enable the website you are visiting to keep track of your movement from page to page. Session cookies allow you to proceed through many pages of a site quickly and easily. These cookies do not gather PI about you that could be used for marketing or remembering where you have been on the Internet.
• Persistent cookies help websites remember your information and settings when you visit them in the future, and help us provide you with a more personalized experience when you are using our websites. When you visit or use our websites or applications, we associate you with a unique internal identifier. The unique identifier allows us to know who you are; however, the cookie will never contain PI that would identify you to a third party. Persistent cookies are stored on your computer.
• Third Party cookies and other information enable us to deliver tailored advertising to you on third party websites. We are able to track which of our ads you interact with on third-party websites. This enables us to provide ads that are more relevant to you.
• Pixel Tags, Web Beacons and similar technologies are tracking tools that may be used on our website that, when combined with cookies, monitor user activity. They help us capture user activity for analysis to better understand the use and effectiveness of the website, enhance user experience and provide additional security controls. We do not collect any PI through these tools.

Opting Out of Cookies:

Cookies are a commonly used technology and many web browsers default to automatically accept cookies. If you decide that you do not wish to accept cookies, refer to your browser’s online help for further instructions and information on setting cookie preferences. If you do not accept cookies, you may continue to browse our website; however, you should be aware that certain features of our websites may not function properly without cookies. 

Interest-Based Advertising:

We or third parties on our behalf may use cookies and other web tools to collect and use information about you to help determine which ads or offers to present to you and to identify other people with similar interests to you.

Opting Out of Interest-Based Advertising:

You can opt out of our interest-based and relationship-based advertising on third-party websites. Opting out will block these third parties from other sites you may visit as well. To opt out, you can update your settings on your social media, webmail sites, or where the third-party websites provide an opt-out. If you click on one of our ads on a third-party website, cookies may also be used to track the effectiveness of our online advertising and for the purposes of delivering ads that may be relevant to you in the future. Click the AdChoices icon on the ad and follow the instructions, or visit http://youradchoices.ca/choices/. 

The platforms through which we advertise subscribe to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising, We do not respond to "do not track" signals transmitted by web browsers or similar mechanisms.

Technical Information and Your Options:

When you visit our website or use our applications, we may also collect:

• your Internet Protocol (IP) address;
• your Internet Service Provider (ISP) and the region from which you are connecting to our website or applications; and
• attributes related to the device and browser you are using to connect to our website or applications (e.g. operating system type and version, current language, browser version and plug-ins, screen resolution etc.).

We use Google Maps to provide location-based services (e.g. to help find a Localcoin ATM nearby) that you request. When using services offered by Google on our website or applications (e.g. Google Maps, ATM Locator), you agree to the collection, processing and storing of the data that is automatically gathered by Google LLC., its representatives and/or third parties. For more information, please visit https://cloud.google.com/maps-platform/terms

We use this information to optimize our websites and the content we make available, and to help secure your connection to our websites and for fraud prevention and investigation purposes.

Please note the ability to collect certain PI is controlled by your device. Please review the settings on your device to manage your preferences.

12. Third-party links on our website.

Our website or communications with you may contain links to other websites that we do not own or operate. Also, links to our website may be featured on third-party websites on which we advertise. We provide links to third-party websites as a convenience to you. These links are not intended as an endorsement of, or referral to, the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your PI.

13. Additional U.S. Privacy Terms

U.S. Notice: If you are a U.S. consumer, the Gramm-Leach-Bliley Act consumer privacy notice in Appendix A applies to you.

14. You can reach us.

We are open about our practices relating to the management of PI, as outlined in this Policy.  From time to time, we may make changes to this Policy. This Policy is always the most recent version, indicated by the date last updated below. 

Please forward all comments, questions, access requests, concerns or complaints regarding your PI or our privacy practices to our Chief Privacy Officer as follows:

By email: [email protected]

By post: Attn: Chief Privacy Officer

By phone: 1 (877) 412 2646

DATE LAST UPDATED:  AUGUST 1, 2021