This Application collects some Personal Data from its Users.

Data Controller and Owner

Wealthica Financial Technology Inc. - 1100 Boulevard René-Lévesque O, 25th Floor, Montréal, QC H3B 5C9

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

• Registration information: When you register for a Service, you will be asked for basic registration information, such as an email address and password.
• Identification information: You may also be asked to provide identification information to confirm your identity, including your first and last name, username, address, and phone number.
• Payment account information: You may be required to provide your credit card number, expiration date, and credit card security code if you wish to use your credit card to make payments.
• Third party credentials: You may also enter in certain passwords, usernames, account numbers, and other account information for third party sites and Internet services ("Third Party Sites").
• Information from Third Party Sites: In order to display information to you through a Service, we may collect, on your behalf, your account and other personal information from Third Party Sites that you register under your account via the Service. For example, if you register your bank account with us, we will aggregate your bank information via our Site in order to present it to you.
• Technical and navigational information: We collect information about your interaction with our Site such as computer browser type, pages visited, average time spent on our Site, IP address, unique identifier of the device, operating system version and app version.
• Location information: If you choose to use a location enabled Service, we may collect location information from your device and will notify you of this collection. You may control or disable the sharing of location information via your device setting and/or the Site.
• Other information: We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service. In such instances, you will be given the opportunity to provide or decline that information.

The Personal Data may be freely provided by the User, or collected automatically when using this Application.

Any use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.

Failure to provide certain Personal Data may make it impossible for this Application to provide its services. Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Contacting the User, Displaying content from external platforms, Content performance and features testing (A/B testing), Hosting and backend infrastructure, Remarketing and Behavioral Targeting, Social features and User database management. The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data can be found here.

How we disclose personal information

We will not, without your permission, sell, publish, or share your personal information to third parties for their marketing purposes.

We reserve the right, in our sole discretion, to share or disclose your personal information with law enforcement, government officials, and other third parties:

• to respond to subpoenas, court orders, or legal process;
• in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites or Services;
• to respond to claims that any posting or other content violates the rights of third parties;
• in an emergency, to protect the health and safety of our Sites' users or the general public; or
• as otherwise required by any applicable law.

We may share your personal information with other third parties with your consent or instructions to do so.

We may share or make available anonymous or aggregate information that cannot be used to identify you individuals with:

• third parties for their research, marketing and promotional purposes and those third parties may publicly report the findings of their research or analysis;
• organizations that conduct research into consumer spending; and
• users of the Service for purposes of comparison of their personal financial situation relative to the broader community.

If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us. Such third parties will assume responsibility for the personal information collected by us in connection with our business operations or through our Sites and such third parties will assume the rights and obligations regarding such information as described in this Privacy Statement.

How we protect the information we collect

We take the security of your information seriously. We use technical and administrative security measures such as but not limited to firewalls, encryption techniques, and authentication procedures, among others, to maintain the security of your online session.

Your choices

We may send periodic Site related alerts, weekly summaries, notifications, newsletters, promotions, or other information via email. You may choose to stop receiving alerts, summaries, newsletters and promotions by indicating your preference in your account profile or settings. You may also follow the unsubscribe instructions in the email you receive. Please note that certain Services-related messages that we send are necessary for the proper functioning and use of the Services and you may not have the ability to opt-out of those messages.

Cookie Policy

This Application uses Cookies. To learn more and for a detailed cookie notice, you may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System Logs and Maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy

The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by Iubenda and hosted on Iubenda's servers.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

Cookies

Small piece of data stored in the User's device.

Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to this Application.