Privacy Policy

1. Information We Collect

1.1 Personal Information

We collect personal information that you voluntarily provide to us when you:

• Register for an account
• Complete your profile
• Make a transaction
• Contact customer support
• Subscribe to our newsletter

This information may include:

• Full name
• Email address
• Phone number
• Date of birth
• Home address
• Government-issued identification (for KYC/AML compliance)
• Financial information (bank account details, transaction history)
• Biometric data (if you enable biometric authentication)

1.2 Automatically Collected Information

When you access our Services, we automatically collect certain information, including:

• Device information (model, operating system, unique device identifiers)
• IP address and location data
• Browser type and version
• Usage data and analytics
• Log files and crash reports

1.3 Information from Third Parties

We may receive information from:

• Identity verification services (for KYC compliance)
• Payment processors
• Fraud prevention services
• Credit bureaus (where applicable)
• Social media platforms (if you connect your accounts)

1.4 Blockchain Data

Important information about our blockchain infrastructure:

• Transaction Data: All transactions are recorded on public blockchain networks and are permanently visible
• Wallet Addresses: Your public wallet addresses are visible on the blockchain
• Private Keys: We do NOT collect, store, or have access to your private keys - you maintain complete control
• Non-Custodial Nature: We cannot access, freeze, or control funds in your wallet
• Blockchain Analytics: We may analyze on-chain data for fraud prevention and service improvement

2. How We Use Your Information

We use the collected information for various purposes:

• Provide Services: Process transactions, maintain your account, and deliver our services
• Compliance: Comply with legal obligations, including KYC, AML, and FINTRAC requirements
• Security: Detect, prevent, and address fraud, security threats, and illegal activities
• Communication: Send you transaction confirmations, updates, and customer support
• Improvement: Analyze usage patterns to improve our Services
• Marketing: Send promotional materials (with your consent)
• Legal: Enforce our terms and conditions and protect our rights

3. How We Share Your Information

We may share your information with:

3.1 Service Providers

• Payment processors and financial institutions
• Identity verification services
• Cloud storage providers
• Customer support platforms
• Analytics and marketing services

3.2 Legal Requirements

We may disclose your information:

• To comply with applicable laws and regulations
• To respond to lawful requests from public authorities
• To enforce our Terms and Conditions
• To protect our rights, privacy, safety, or property
• In connection with FINTRAC reporting obligations

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.

4. Data Security

We implement appropriate technical and organizational security measures to protect your personal information, leveraging blockchain technology for enhanced security:

• Blockchain Security: Transactions secured by cryptographic proof on distributed ledger technology
• Non-Custodial Architecture: You control your private keys - we never have custody of your funds
• Smart Contract Audits: Regular third-party audits of our blockchain smart contracts
• 256-bit encryption for data transmission
• Secure data storage with encryption at rest
• Regular security audits and penetration testing
• Multi-signature wallet support for enhanced security
• Access controls and authentication protocols
• Employee training on data protection and blockchain security
• Incident response and breach notification procedures

Blockchain Transparency: All transactions are permanently recorded on the blockchain, providing immutable proof and transparency. However, this also means transaction data cannot be deleted or modified once confirmed on-chain.

While blockchain technology provides enhanced security, no method of transmission over the Internet or electronic storage is 100% secure. You are responsible for securing your private keys and seed phrases.

5. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services to you
• Comply with legal and regulatory obligations (typically 7 years for financial records)
• Resolve disputes and enforce our agreements
• Prevent fraud and abuse

After the retention period, we will securely delete or anonymize your information.

6. Your Privacy Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information (subject to legal requirements)
• Objection: Object to certain processing of your information
• Portability: Request transfer of your data to another service
• Withdraw Consent: Withdraw consent for marketing communications

To exercise these rights, please contact us at privacy@coynitt.ca

7. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

8. International Data Transfers

Your information may be transferred to and processed in countries other than Canada. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable laws.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Remember your preferences and settings
• Analyze website traffic and usage patterns
• Provide personalized content and advertisements
• Detect and prevent fraud

You can control cookies through your browser settings. However, disabling cookies may affect the functionality of our Services.

10. Third-Party Links

Our Services may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date
• Sending you an email notification (for significant changes)

Your continued use of our Services after such changes constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us:

13. Regulatory Compliance

coynitt is committed to complying with all applicable privacy and data protection laws, including:

• Personal Information Protection and Electronic Documents Act (PIPEDA)
• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
• Provincial privacy legislation

We will update this Privacy Policy as necessary to maintain compliance with evolving regulations.