Privacy Policy

Privacy Notice

Last Updated: May 31, 2024

Welcome! This Privacy Notice explains how ThriveCoin Inc. (“Thrive Protocol”, “Company”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal information in connection with our websites, including https://thrivecoin.com/ and other websites we own and operate that link to this Privacy Notice (collectively, the “Sites”), our Thrive Protocol mobile applications (the “Apps”) and the related content, platform, services, products, and other functionality offered on or through our online services (collectively, the “Services”). It does not address our privacy practices relating to Thrive Protocol employees and other personnel.

Blockchain Participants:

Please note that by virtue of the public nature of the blockchain, including the Ethereum and Polygon blockchains, the holdings and transactions associated with your crypto wallet address will be publicly available and accessible to third parties. This includes, but is not limited to, your public sending address, the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on the blockchain may not be able to be modified or deleted due to the immutable nature of the blockchain. Transactions and addresses may reveal information about the user’s identity and information can potentially be correlated now or in the future by any party who chooses to do so. Please review how privacy and transparency on the blockchain works.

1.OUR COLLECTION OF PERSONAL INFORMATION

We collect personal information in connection with your visits to and use of the Service. This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically such as through the use of cookies and other technologies.

Personal Information Collected from Individuals

We may collect the following personal information submitted to us by individuals through the Services:

  • - Account and Profile Information. To use certain portions of the Services, you may be required to maintain an account with us. To create an account, we collect your email address, username, and password. We may also collect your public blockchain address associated with your crypto wallet. We use this information to administer your account, provide you with the relevant services and information, communicate with you regarding your account, the Service, and for customer support purposes.
  • - Communications. If you communicate with us through any paper or electronic form (e.g., Discord, Twitter, a “contact us” form, email), we may collect your name, username, social media handle,, crypto wallet public address, email address, phone number, or any other personal information you choose to provide to us. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
  • - Marketing Emails. If you sign up for our newsletter, we collect your email address in order to send you regular updates about the Service, such as information about new features of the Service or rewards available. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
  • - User Content. You may upload, or transmit audio, videos, images, data, or information through your communications with us or as part of a submission made when you complete a Request, or otherwise use the Service (collectively, "User Content"). We may collect this information, and information about this content, such as the date and time you created this content, along with other information about you, including your username, social media handle and/or crypto wallet information. Please remember that Thrive Protocol may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. Each Poster is responsible for managing their own communities. For more information, please see ourTerms of Service
  • - Contribution, Challenge and Survey Information, including information provided when you enter a Thrive Protocol Contribution or Challenge, or information included in any questions submitted through surveys.
  • - Employment or Contractor Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment or to work as an independent contractor.

Personal Information Automatically Collected

As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and website usage patterns automatically when visiting or interacting with our Services, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Services, through our Services and when exiting our Services, as well as usage and activity on our Services such as user list, roles, image, description, tags, and information related to a Request such as the description, reward amount, access terms, release terms) and location data (such as general geographic location based on the log data we or our third-party providers collect).

When you access our Sites from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. For example, our Sites use Google Analytics, a web analytics service provided by Google LLC (“Google”), to collect and view reports about the traffic on our Sites. More information about the use of Google Analytics for these analytical and non-advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here

To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Services, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
For more information on our and third-party partners’ data collection and online advertising practices, please see theThird Party Data Collection and Online Advertising section of this Privacy Notice.

Personal Information from Third Parties

We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual.
We may receive the same categories of personal information as described above from the following third parties:

  • - Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our Services. For example, if you engage in one of our communities hosted on third-party platforms, such as Discord, we will be able to see any public communications made within that platform.
  • - Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services on our Services.
  • - Social Media or Third-party Platforms: When an individual interacts with our Services through various social media networks and third-party platforms, we may collect information publicly shared such as your username or handle. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and communications platforms before sharing information.
  • - Crypto Wallets: When you connect your crypto wallets such as MetaMask, we receive information such as your wallet address, crypto wallet types (including amounts and balances), and any related transaction and technical information associated with your crypto wallet address such as network information regarding transactions. We use this information to administer your account, provide you with the relevant Services.
  • - Single Sign-On: We may use single sign-on (“SSO”) to allow a user to authenticate their account using one set of login information, including through Google. We will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties, which may include, for example, your name, username, email address, language preference, and profile picture. We use this information to operate, maintain, and provide to you the features and functionality of the Service. We may also send you service-related emails or messages (e.g., account verification, customer support, changes, or updates to features of the Site, technical and security notices).
  • - Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal information and often share some or all of this information with us.
  • - Information from Other Sources: We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, other customers, third-party digital wallet providers, or through transactions such as mergers and acquisitions. Such information may include contact information, employment-related information, and interest-in-services information. We may combine this information with the information we collect from an individual directly. We use this information to provide the Services, contact individuals, to process employment applications and job applicant screening, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

2. OUR USE OF PERSONAL INFORMATION

We use personal information we collect to:

  • - Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services;
  • - Manage our business and its day-to-day operations;
  • - Authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account;
  • - Communicate with individuals, including via email and social media;
  • - Request individuals to complete surveys about our company, companies we partner with, and the Services;
  • - For marketing and advertising purposes, including to market to you or offer you through email, direct mail, and updates on products or services we think that you may be interested in;
  • - Enable you to communicate and share files with users you designate;
  • - Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
  • - Facilitate customer benefits and services, including customer support through our command center services;
  • - Identify and analyze how individuals use our Services;
  • - Conduct research and analytics on our customer and user base and our Services;
  • - Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
  • - Help maintain the safety, security and integrity of our property and Services, technology assets and business;
  • - Evaluate your candidacy for employment or to work as an independent contractor, to communicate with you during the application process and if successful, to facilitate the onboarding process.
  • - Fulfill or enforce our legal or contractual obligations and requirements (including in relation to our Terms of Service), to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • - Audit transactions conducted in connection with our services;
  • - Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
  • - For any other lawful purpose, or other purpose that you consent to or for which you provide your information.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

3. OUR STORAGE OF PERSONAL INFORMATION

We may transfer, store, and process your information in countries other than your own. Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (please see the OUR COLLECTION OF PERSONAL INFORMATION section above), in Portugal, the United States, and other countries.

If you are a resident in the European Economic Area (“EEA” ), United Kingdom ( “UK”), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Data Retention

We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Privacy Notice will require us keeping your personal information for longer than twenty four (24) months past the start of the idle period of the user's account. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. We may not be able to modify or delete your information in all circumstances, especially in relation to information on the blockchain.

Information Security

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

4. OUR DISCLOSURE OF PERSONAL INFORMATION

We disclose personal information in the following ways:

  • - Blockchain Participants: If you participate in our Services, by virtue of the public nature of the blockchain, the holdings and transactions associated with your crypto wallet address will be publicly available and accessible to blockchain participants and other third parties, as well as any other information you choose to provide or make public.
  • - Survey Providers We may share personal information with third parties who assist us in delivering survey offerings and processing the responses.
  • - Other Users of the Service: We may share your information with other users in order to facilitate the Services. For example, if you complete a submission, we may share your submission with the relevant Posters.
  • - Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
  • - Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
  • - Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, conducting crypto transactions, employment application-related services, payment processing services, and administrative services.
  • - Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
  • - Affiliates We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include any parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • - Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:some text
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws or to respond to lawful requests and legal process;
    • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
    • to detect, suppress, or prevent fraud;
    • to protect the health and safety of us and others; or
    • as otherwise required by applicable law.
  • - With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

5. THIRD-PARTY TRACKING AND ONLINE ADVERTISING

We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services, to collect information about your use of our Site over time so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies (like web beacons and pixels), which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information. This information is used to display targeted ads on or through our services or on other websites, apps, or services. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/ and you can opt-out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, by vising NAI’s online resources at http://www.networkadvertising.org/choices or by downloading the Google Analytics Opt-out Browser Add-on, currently available at https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page, currently available at https://policies.google.com/.

6. CONTROL OVER YOUR INFORMATION

You may control your information in the following ways:

  • - Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
  • - Cookies: For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to cookies, please see the Information We Collect Automatically section above.
  • - Online Advertising. For information about any choices you may have in relation to online advertising please see the Third Party Tracking and Online Advertising section above.
  • - Reviewing, Modifying or Deleting Your Information and Withdrawing Consent to Process. Based on the applicable laws of your country or state of residence in the United States, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law and we may not be able to modify or delete your information in all circumstances, especially in relation to information on the blockchain. If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you have any questions about reviewing, modifying, or deleting your information or withdrawing your consent to process your personal information, you can contact us directly at [email protected].
    • In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at the email provided directly above. We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority, currently available at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm, or UK data protection authority, currently available at https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner, currently available at https://www.edoeb.admin.ch/edoeb/en/home.html.
    • Upon your request to delete your information, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
    • Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
    • Under certain United States state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

7. CHILDREN’S PERSONAL INFORMATION

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

8. LINKS TO THIRD-PARTY WEBSITES OR SERVICES

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

9. NOTICE TO CALIFORNIA RESIDENTS

If you are a resident of the State of California, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the California Consumer Privacy Act Privacy Notice here. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at [email protected] with the subject line “California Opt Out Request” to submit such a request.

10. NOTICE TO NEVADA RESIDENTS

If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at [email protected] with the subject line “Nevada Opt Out Request” to submit such a request.

11. NOTICE TO EU OR UK RESIDENTS

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
  • Consent We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. In such case, please see the Control Over Your Information section of this Privacy Notice.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • Send users information about special offers and discounts on our products and services
    • Develop and display personalized and relevant advertising content for our users
    • Analyze how our Services are used so we can improve them to engage and retain users
    • Support our marketing activities
    • Diagnose problems and/or prevent fraudulent activities
    • Understand how our users use our products and services so we can improve user experience
  • Legal Obligations.We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests.We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

12. NOTICE TO CANADA RESIDENTS

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In such case, please see the Control Over Your Information section of this Privacy Notice.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

13. NOTICE TO AUSTRALIA OR NEW ZEALAND RESIDENTS

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act). This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information. If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

  • Offer you the products or services that you want
  • Respond to or help with your requests
  • Manage your account with us
  • Confirm your identity and protect your account


At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us at the email in the Control Over Your Information section of this Privacy Notice. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner, currently available at https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us, and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner, currently available at https://www.privacy.org.nz/your-rights/making-a-complaint/.

14. NOTICE TO REPUBLIC OF SOUTH AFRICA RESIDENTS

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us at the email in the Control Over Your Information section of this Privacy Notice. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

15. UPDATES TO THIS PRIVACY NOTICE

UPDATES TO THIS PRIVACY NOTICE We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

16. CONTACT US

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to our Data Protection Officer at [email protected].

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