Privacy Policy

Introduction

Last Modified:  July 25, 2018       

This policy (the “Privacy Policy”) sets out the privacy practices of Newton Crypto Ltd. (“we”, “us” or “our”), a corporation formed pursuant to the Canada Business Corporations Act (R.S.C., 1985, c. C-44) in Canada.

The Privacy Policy addresses how we collect, store and use your personal information related to our website ("Website") our online crypto currency exchange and corresponding iPhone (iOS), Apple Watch (WatchOS) and any other applications for platforms which we may subsequently offer (the "Service"). The Website and web-based portion of the Service are hosted at https://newton.co and other domains and sub-domains. The iPhone and Apple Watch applications, which for part of the Service, are available for download on the Apple App Store. 

At our discretion, we may amend this Privacy Policy at any time. Any changes will be reflected here, so we encourage you to visit this page regularly. We will also notify our registered users of updates to this Privacy Policy via email or in your account. Your continued use of our Website and Service after any amendments shall be regarded as acceptance of such amendments.

Collection of Personal and Business Information

To establish an account with us, we collect your personal and business information including, but not limited to, your:

  • Full legal name;
  • Email address;
  • Phone number;
  • Business name(s) if applicable;
  • Mailing address;
  • Address associated with your bank account;
  • Payment and banking information, including the information provided to us via Flinks Technology Inc. (“Flinks”) and Plaid Inc. (“Plaid”), as set out below;
  • Identity verification documents which you upload or otherwise provide to us, including passports, government issued ID cards, bank statements and others;
  • IP address and location data, including geo-location data;
  • Website statistics and analytics data regarding your use of the Website and Service;
  • Other types of raw data relating to how you interact with the Website and Service, for example, your browser information and session duration;
  • Comments, feedback, reviews and other information you upload or provide to the Website or Service;
  • The contents of your correspondence with us; and
  • All other information you provide on our Website, Service or otherwise in correspondence with us.

To the extent you provide us with, or upload data that includes the personal information of another person, you represent and warrant that you have their authorization to provide us with that information.

Use of Location Services

Our Service may use location services made available online and by iOS, WatchOS, Android and other platforms.  Location services allows location-based apps and websites to use information from internet service providers, cellular, Wi-Fi, Global Positioning System (GPS) networks, and iBeacons to determine your approximate location.  To learn more about the use of Location Services in iOS please click here.

We use location services to verify you are using our Service, or, registered for our Service from within Canada. You can turn off location services on your mobile device if you are using our mobile app, and in your internet browser if you are accessing the Service via our web application.

Payment Processing Companies and Banks

As referenced in our Terms and Conditions of Use, to facilitate depositing and withdrawing funds and the ordinary use of our Service, we use a third-party providers, including Flinks and Plaid. Flinks and Plaid use an application programming interface (“API”) and other integration features to connect with your bank to provide us with your bank account information, including for example, the name associated with the bank account, the institution, transit and account numbers, account balance, as well as other information. This information is used to facilitate the verification of your identity and the deposit and withdrawal of funds from your bank account. Flinks and Plaid may also send us your account balance to ensure you have a sufficient balance in your account to withdraw funds pursuant to a request made in your account on our Service. 

By using our Website and Service, you consent to us providing your personal information to both Flinks and Plaid to facilitate the ordinary use of the Service.  You agree that Flinks and Plaid may use your personal information and data related to your account in accordance with their privacy policies, as amended from time to time. To view the Flinks privacy policy and better understand how they use your personal information, visit https://flinks.io/privacy-policy.  To view the Plaid privacy policy and better understand how they use your personal information, visit https://plaid.com/legal.

In addition to Flinks and Plaid, we use various financial institutions to process payments to and from your account. To do so, we may provide such financial institution with your personal information, including your name and bank account information. You acknowledge and agree that such financial institution may have their own privacy policy on how they store, collect and use personal information. You agree that we are authorized to share your personal information with them in order to facilitate the ordinary use of the Service.

The Use of Your Personal Information

The collection of your personal information may also be used to:

  • Facilitate the ordinary operation of the Website and Service, including providing your personal and business information to third-party service providers and payment processors;
  • Verify your identity and contact information;
  • Verify your device is an authentic Apple iOS device via the Apple DeviceCheck API (for more information see https://developer.apple.com/documentation/devicecheck);
  • Promote our Website and Service offerings to you in various forms of communication;
  • Provide user support and to improve the Website and Service we offer;
  • Communicate with you about your account or services we offer;
  • Bill and collect money owed to us;
  • Pursue available legal remedies to us and to prosecute or defend a court, arbitration or other proceeding;
  • Send or display informational and promotional materials from us, our partners or other third parties to you;
  • To meet legal requirements, including but not limited to, reporting to governments or government agencies to comply with any applicable laws, rules or regulations;
  • Seek advice from our legal and other advisors; and
  • To enforce compliance with any terms and conditions or applicable law.

IN ADDITION, WE RESERVE THE RIGHT TO PROVIDE YOUR CONTENT AND INFORMATION (INCLUDING BUT NOT LIMITED TO YOUR PERSONAL AND BUSINESS INFORMATION) UPLOADED OR COLLECTED BY OUR WEBSITE, SERVICE OR OTHERWISE TO THIRD PARTIES IF REQUIRED BY LAW (SUCH AS IN RESPONSE TO A SUBPOENA, COURT ORDER OR OTHER LEGAL PROCESS IN ANY JURISDICTION), AND TO COOPERATE WITH LAW ENFORCEMENT AUTHORITIES IN THE INVESTIGATION OF ANY CRIMINAL OR CIVIL MATTER.

IF WE ARE REQUIRED BY LAW TO MAKE ANY DISCLOSURE OF YOUR CONTENT OR PERSONAL OR BUSINESS INFORMATION, WE MAY (BUT ARE NOT OBLIGATED TO) PROVIDE YOU WITH WRITTEN NOTICE (TO THE EXTENT PERMITTED BY LAW) PRIOR TO SUCH DISCLOSURE SO THAT YOU MAY TAKE APPROPRIATE ACTION.

The Disclosure of Your Personal Information and Access to It

We do not sell your personal information.

However, we may share personal and business information with our employees, advisors and partners to use that information in connection with one or more of the purposes for which that personal information was collected.

We also operate the Website and Service in conjunction with our independent contractors.  Our independent contractors may have access to your personal information in providing services to us, or, providing you with access to the Website and Service.  We may use a variety of service providers, servers and employees in locations both inside and outside of Canada, which may make your personal information the subject of foreign laws and foreign legal proceedings.

We may also disclose your personal information to our successors (if our business or the Website and Service are acquired by another legal entity) or any assignee of our assets relating to the Website and Service.

WHILE WE TAKE MEASURES TO PROTECT PERSONAL INFORMATION, YOU AGREE THAT, TO THE FULLEST EXTENT PERMITTED BY LAW, IN NO EVENT WILL WE, OUR AFFILIATES, OFFICERS, DIRECTORS, SHAREHOLDERS, EMPLOYEES, CONTRACTORS, ADVISORS OR AGENTS, BE LIABLE, HOWSOEVER CAUSED, FOR THE LOSS OR THEFT OF YOUR PERSONAL INFORMATION OR ANY DAMAGES CAUSED AS A RESULT THEREOF, SO LONG AS WE WERE NOT GROSSLY NEGLIGENT IN THE PROTECTION OF SAID INFORMATION.

Retention of Your Personal Information

We keep your personal information for as long as it is required for the purpose for which it was collected. There is no single retention period applicable to the various types of personal information collected. If you have closed your account on the Service and wish to ensure your personal information is deleted, please contact us at hello@newton.co.

If you believe that we have not adhered to this Privacy Policy or would like to request an amendment to your personal information being held by us, please contact us by e-mail at hello@newton.co. Only amendments which can be verified by us will be accepted.

 

USE OF COOKIES

We use "cookies" to collect information about you and your activity across our site. A cookie is a small piece of data stored on your computer and accessed each time you visit our Website and Service, so we can understand how you use our Service and serve you content or save setting you have specified. 

If you do not wish to accept cookies from us, you should instruct your browser to refuse cookies from our Website and Service, with the understanding that we may be unable to provide you with some of your desired service without them. This policy covers only the use of cookies between your computer and our Website and Service; it does not cover the use of cookies by any third-party advertisers.

Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. timezone, notification preferences and usernames), and to personalise your content.

Types of cookies and how we use them

Cookies set by the website you are visiting are normally referred to as "first-party cookies", and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called "third-party cookies" and can be used to track you on other websites that use the same third-party service.

Essential cookies

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, and payment processing. We use essential cookies to enable certain functions on our Website and Service.

Performance cookies

Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience's overall website experience. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use performance cookies on our Website and Service.

Functionality cookies

Functionality cookies are used in collecting information about your device and any settings you may configure on the website you are visiting (like language and time zone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use functionality cookies for selected features on our Website and Service.

Targeting/advertising cookies

Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you are visiting (first-party) or by third-party services. Targeting/advertising cookies set by third parties may be used to track you on other websites that use the same third-party services. We use targeting/advertising cookies on our site.

Third-party cookies on our site

We may employ third-party companies and individuals on our websites - for example, analytics providers and content partners. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by Newton Crypto Ltd.'s cookie policy. You should disable cookies if you do not wish to permit third-party cookies to track your usage.