Privacy Policy

HIGHLIGHTS 

CurrencyWorks USA Inc. and our corporate affiliates (the “Company”, “we”, “us”, “our”) understand that your time is valuable. Therefore, we have set out below some important highlights of our Privacy Policy. You can obtain more information about how we collect, use, disclose and protect your personal information by reviewing our full Privacy Policy below. 

For purposes of this Policy, “you” and “your” means you as the user of the Services.‎

PLEASE READ THIS PRIVACY POLICY CAREFULLY, as it contains important information regarding your legal rights. If you do not consent to the collecting and processing of your personal information in accordance with this Privacy Policy, you may not access or use the Services.  By clicking “I consent to the Privacy Policy”, or by using or accessing the Services, you represent that you understand and consent to the collection and processing of your personal information in accordance with this Privacy Policy, which forms an essential part of our Terms of Service; which are available here for reference motoclubstg.wpengine.com/terms-of-service.

What personal information do we collect?

  • We collect personal information directly from users of our website located at motoclubstg.wpengine.com (the “Website”), and such other related software, websites and services (collectively, the “Service”). The personal information we collect includes your name, email address, billing information, site usage through the use of tracking pixels to better serve advertising. ‎ You may also provide additional information by choosing to fill out free-form fields on our Service, if any, and we may also collect and generate information from your access and use of the Service such as performance data of the Service (the “Usage Data”). 
  • By using our Service you are choosing to provide us with your personal information and you acknowledge and consent to the processing of your personal information in the United States, and Canada. 
  • We also use cookies, and tracking pixels on our Website and automatically collect certain information about the way our Service is used.

Why do we collect personal information and how is it used?

  • We collect personal information to facilitate your use of our Service. 
  • We also use the Usage Data in aggregate and de-identified form for research and evaluation purposes. 

Is personal information shared or disclosed?

  • Personal information provided to us is never sold or rented to other organizations. 
  • We also use certain third party service providers who may access and process the personal information we collect in order to provide services which are integral to the operation of our Service. 
  • We may also disclose or share personal information for fraud prevention, and other permitted disclosures under applicable law.  

How do we protect personal information?

  • We have implemented safeguards to protect personal information under our control, and regularly review our practices to ensure they align with reasonable practices appropriate to the level of sensitivity of the information, in order to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure. 

What are the risks?

  • Although we take steps to safeguard the personal information under our control, “perfect security” does not exist online or elsewhere. In particular, we cannot guarantee the security of information posted or transmitted using our Service or via email. It is possible that third parties may unlawfully intercept or access such information.

What are your choices?

  • You may request to access and review your personal information in our possession, subject to certain limitations.  
  • You may also request that we correct your personal information in our possession. We will make best efforts to comply with such requests, subject to certain limitations.

What else should you know?

  • We may use cloud services provided by third party service providers who may be outside the United States, or Canada, to store the personal information that we collect. This means that your personal information may be transferred to, or stored in, another country and accessible to foreign courts, law enforcement and national security authorities. 
  • We may amend our Privacy Policy from time-to-time. Although we will notify you of major changes, we encourage you to check for updates.
  • You can contact us with questions, complaints or to access your personal information at [email protected]

PRIVACY POLICY

CurrencyWorks USA Inc. and our corporate affiliates (the “Company”, “we”, “us”, “our”) respect and uphold individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services to you.  Based on applicable privacy and data protection principles common to the United States and other jurisdictions to which we are subject to, we have developed this privacy policy (the “Policy”) to explain our practices for processing your personal information.  This Policy does not apply to our employees’ personal information or any anonymized information. 

This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct, update and access your personal information that you provide as a user of (a) the website operated at motoclubstg.wpengine.com, and other locations from time to time‎ (the “Website”, (b) any applications or other software we provide you (the “Application”), excluding third party software that may interact with the Service as defined below, and (c) the services we provide through the Website and the Application (collectively, the “Service”). This Policy references the general Terms of Service for the Service available at motoclubstg.wpengine.com/terms-of-service, and forms an integral part of such Terms of Service. All capitalized terms not otherwise defined herein have the meaning provided in our Terms of Service.

Our Service may contain links to other applications or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting another Internet resource. We have no responsibility or liability for, or control over, those other Internet resources or their collection, use and disclosure of your personal information.  We encourage you to read the privacy policies of those other Internet resources to learn how they collect and use your personal information. 

PLEASE READ THIS PRIVACY POLICY CAREFULLY, as it contains important information regarding your legal rights. If you do not consent to the processing of your personal information in accordance with this Privacy Policy, you may not access or use the Services.  By clicking “I consent to the Privacy Policy”, or by using or accessing the Services, you represent that you understand and consent to the processing of your personal information in accordance with this Privacy Policy.

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Service or otherwise provide any personal information to us. 

1. Personal Information

For the purposes of this Policy, “personal information” means any identifiable information about an individual, including but not limited to an individual’s name, home address, telephone number, email address, except any other information otherwise exempted by applicable privacy laws.  

When you use our Service, we may collect the following personal information from you:

  • Contact information such as name, email address, mailing address, and phone number;
  • Billing information such as credit card details;
  • Unique identifiers such as username, account number, and password;
  • Usage Data such as cookies; 

Your personal information may be collected when: 

  • You register for an account with us;
  • You connect with us through social media;
  • We collect data from third parties or publicly available sources.

We only collect the personal information that we need.  We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.

Collection from Third Parties

We do not knowingly collect your personal information from a third party unless you consent or we are otherwise exempted, required or permitted by applicable laws to do so.  

If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected. 

Links to Other Sites

To the extent that our Service contains links to other sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party applications.

Information about Minors

This site is intended solely for users who are at least eighteen years of age or older. ‎

We do not knowingly collect personal information about any minor. No such minor, nor any parent or guardian as it relates to such minor, should submit such minor’s personal information to us through the Service for any reason and under any circumstances.  

2. Purpose for Which Personal Information is Processed

We may process your personal information for the following purposes (the “Purposes”):  

  • To verify and authenticate your identity;
  • To ensure that the Service is optimized for your use and benefit;
  • To analyze user experience and improve the Service;
  • To operate, maintain and provide to you the Service;
  • To communicate with you to provide you services, contacts, materials or recommendations for your needs as identified by you through phone, email, or the Service;
  • To carry out our obligations arising from any contracts entered into between you and us;
  • To comply with internal policies and procedures and other legal, accounting, or security requirements;
  • To share your personal information with our employees, contractors, consultants and other third party service providers such as application hosting providers, advertising agencies, payment processors or customer service agencies (“Third Party Processors”) who require this information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the Service for your use and benefit. Please note that we may change or add Third Party Processors at any time, in our sole discretion, either in Canada, the United States, or elsewhere. We encourage you to reference this Policy from time-to-time, to obtain updated information.

We will only process your personal information for the Purposes for which we intend to process such information.  Otherwise, we will not process your personal information without your consent.

3. Disclosure of Your Personal Information 

We may disclose your personal information for the Purposes as described in this Policy in the following ways: 

  • To our employees, contractors, and agents on an as-needed basis;
  • To our business partners;
  • To our service providers including application hosting providers, advertising agencies, payment processors and customer service agencies; and
  • To law enforcement, government or regulatory bodies, or other lawful authorities. 

Your personal information that we collect may be processed outside of the United States but only in relation to the Purposes. As a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with other jurisdictions’ applicable laws.

4. Legal Basis for Processing Your Personal Information 

Consent

We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested.  Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request.  Your consent can also be provided by your authorized representative.  Taking into account the sensitivity of your personal information, Purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed.  By using our Service or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected.  When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Service or otherwise provide any personal information to us.  

You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences through the Service or by (ii) deleting your account with the Service and stopping use of the Service.   However, if you withdraw or change your consent, we may not be able to provide you with the Service through the Service.

Other Legal Bases 

Aside from consent, we may also process your personal information under other legal bases, as permitted by applicable laws.  

5. Security of Personal Information 

The security of your personal information is important to us. We protect personal information using physical, technological and organizational safeguards. We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure. 

However, no method of transmission over the Internet, or method of electronic storage, is completely secure; as such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

6. Requests for Access to and Correction of Personal Information

Applicable privacy laws allow, to varying degrees, individuals the right to access or request the correction of errors or omissions in their personal information that is in our custody or under our control. You may request access to and review of your personal information in our possession. However, access may be declined where permitted or required by applicable law.

You may request that we correct your personal information in our possession. We reserve the right not to change any personal information if we do not agree that it is inaccurate or outdated, but will append any alternative text the individual concerned believes appropriate.

If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal. 

7. CASL Policy 

We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”).   Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.

In addition to adopting and updating this Policy, we undertake various transparency initiatives to ensure we comply with CASL, which include:

  • Consent— we do not send you CEMs without your consent. This consent typically must be “express” (expressly acknowledged by you), but in certain circumstances can be “implied”. In other limited circumstances, consent is not required.  We modified or adopted our sign-up, registration and consent forms in order to ensure that your consent is meaningful (i.e. informed and freely given) as required by CASL.  When we collect your electronic contact information, you will know the exact purposes behind the collection.
  • Content— we adopted processes to ensure that our CEMs contain the following requirements prescribed under CASL, which will usually be in the footer of the CEM. We will:
    • Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
    • Provide you with our contact information; and
    • Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
  • Clarity— we ensured that each aspect of a CEM, including its header, content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.

If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days.  If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 10 below.

8. Retention of Your Personal Information

We generally keep personal information for only as long as it is needed to accomplish the Purposes for which it was collected, or as needed for authorized or legitimate purposes.  More specifically, we retain personal information as long as necessary for the fulfillment of the identified Purposes for its collection or as otherwise necessary to comply with applicable laws or protect our interests. When personal information is no longer necessary or relevant for the identified Purposes, or is required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to personal information. 

9. Updates or Changes to this Policy

This Policy was last updated on June 6, 2021. We will occasionally update this Policy and revise the “last updated” date appearing in this paragraph. 

If we make any material changes we will either (a) notify you by email (sent to the email address listed in your account), or (b) provide a notice on the Service or otherwise through the Service before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that this Policy is posted or on the date as specified in the notification. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes.  Your continued use of the Service signifies your acceptance of any changes to this Policy.

10. Contact Information for Privacy Officer

You can direct any questions or concerns regarding our compliance with this Policy and our processing of your personal information to our Privacy Officer by emailing [email protected]

If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws.  Our Privacy Officer will provide you with the contact information to do so if requested. We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.

End of Policy