VirgoCX Inc. (the “company”, “we”, “us” or “our”) is committed to protecting and respecting your privacy.
We may collect and process the following data about you:
1)We collect and retain information you provide directly to us. For example, we collect information about you when you create an online account, complete a transaction, fill out a form, respond to surveys, post messages to our forums or otherwise communicate with us. The types of information we may collect are as follows:
a)contact information, such as your name, mailing address, telephone number, and email address;
b)financial information, such as bank account numbers, credit or debit card numbers and digital asset account information;
c)government identification numbers, such as your government-issued identification number;
d)biographic or demographic information, such as your date of birth, gender, occupation, employment status and any other information you choose to provide about yourself.
2)Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
a)information about transactions you complete using our services, including the amount of funds associated with a digital asset transaction, the type of transaction executed, and other related information;
b)technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
c)information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
3)Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We use both session cookies and persistent cookies on our site. A “session” cookie lasts for a single browser session only and is deleted when the user closes the web browser. A “persistent” cookie remains on the user’s device (even while powered off) until it expires or is deleted.
3.Uses Made Of The Information
We use information held about you in the following ways: 1)Information you give to us. We will use this information to:
a)carry out our obligations arising from any contracts entered into between you and us, and to provide you with information, products and services that you request from us;
b)provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
c)notify you about changes to our service;
d)ensure that content from our site is presented in the most effective manner for you and for your computer.
2)Information we collect about you. We will use this information:
a)to administer our site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
b)to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
c)to allow you to participate in interactive features of our service, when you choose to do so; d)as part of our efforts to keep our site safe and secure;
e)to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
f)to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
3)Information we receive from other sources:
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4.Disclosure Of Your Information
1)We may share your personal information with any member group, which means our subsidiaries, our ultimate holding company and subsidiaries, as necessary to provide a product or service that you have requested or where the member group company is acting as our service provider.
2)We may share your personal information with FINTRAC and other relevant authorities according to anti-money laundering and terrorist financing legislation or similar laws.
3)We may share your information with selected third parties including:
a)Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
b)Analytics and search engine providers that assist us in the improvement and optimisation of our site.
c)In particular, we have engaged Securefact Transaction Services Inc. (Securefact”) to provide identity verification services for us. To verify your identity, your name and contact information will be matched with the information contained in your Credit File Report. We will obtain your Credit File Report through Securefact from either Equifax Inc. or Trans Union of Canada Inc. You also consent to your name and contact information being compared to records maintained by utility companies that you have a relationship with, such as telecom and similar service providers, and you consent to those third parties providing personal information to us and Securefact for the purpose of identity verification. By clicking "Complete Automatic Verification" and submitting your information, you confirm your consent to Securefact collecting, using, disclosing, and storing your personal information for the purpose of this verification. This is a soft inquiry and will not affect your credit score or be visible to other financial institutions.
We may disclose personal information in other circumstances where permitted or required by law.
5.How We Protect The Data We Collect
Personal data is maintained on our servers or those of our service providers. We implement reasonable security practices and procedures to help protect the confidentiality and security of your information, including any personal data. We protect your information using reasonable physical, technical and administrative security measures, including by limiting access to your information to employees with a need to know such information. We and our service providers and business partners may be located outside of your country of residence including in United States of America and Canada.
Please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
6.Access to Information
You have the right to request access to, or correction of, the information held about you. We will respond to your request for access to or correction of information we collect about you within the time frame required by applicable law.
If we make material changes, we will do so in accordance with applicable legal requirements, and we will post a notice on our website alerting you to the material changes prior to such changes becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.