Cybrid Technology Privacy Policy

1. Our Commitment to Privacy

Cybrid Technology Inc. ("Cybrid Tech", "we", "us") is committed to protecting the privacy and security of the personal information of our clients. As a regulated financial entity in Canada, we operate under several regulatory frameworks that require us to collect, verify, and occasionally disclose specific information to maintain the integrity of the financial system.

2. Information We Collect and Why

To provide our services to you we may collect personal information including:

• Identity Information: Name, date of birth, occupation, government-issued identification, and other information related to your personal identity.
• Corporate Information: Use on behalf of a corporation will also involve corporate information such as legal name, address, executive officers, etc. 
• Contact Information: Address, email, and phone number.
• Financial & Transactional Data: Bank account details, source of funds, and transaction history.
• Regulatory Data: Other information required for "Know Your Client" (KYC) and Anti-Money Laundering (AML) compliance, such as your status as a Politically Exposed Person.
• Cryptocurrency Addresses: Blockchain addresses that you provide to us as part of transactions.
• Location Information: Your physical location, if geolocated, or stated location is prompted to provide it. We may also collect device identifiers or other information that may be related to your location.

Information may be collected temporarily, as part of transmitting personal information to a relevant affiliate or third-party, or it may be collected permanently. 

3. Technology Platform: No Sale Of Personal Information

We do not sell, rent, or lease your personal information. Our services are only ever related to the technology platform that Cybrid Tech operates. 

4. Information Sharing and Disclosure

We do not sell your personal information. However, we share information in the following circumstances:

A. Affiliates and Parent Company

For the purposes of centralized data processing, risk management, and integrated service delivery, Cybrid Tech shares personal information with:

• Our affiliate in the United States of America: Cybrid Inc.
• Our affiliate in Canada: Cybrid Canada Inc.
• We may also share personal information with our affiliate in the United States of America: Cybrid Payments Inc.
• Other national affiliates, as disclosed to you

B. Commercial Partners

We work with "Partners", companies that operate platforms referring customers to Cybrid Tech. We share information with these Partners to facilitate your use of their platforms. All such Partners are bound by commercial agreements that obligate them to treat your information as confidential and use it only for the purposes defined in our relationship.

C. Law Enforcement and Regulatory Demands

We reserve the right to disclose personal information to law enforcement, government authorities, or regulatory bodies (e.g. FINTRAC or FINCEN) if:

• we receive a valid subpoena, warrant, or court order; or,
• we have reasonable grounds to believe that a crime has been committed, is currently being committed, or is imminent; or,
• disclosure is necessary to report suspicious transactions as required by the PCMLTFA or the laws of a foreign jurisdiction.

5. International Data Transfers

Your information may be stored or processed in the United States of America by our affiliates or service providers. While in the United States of America, your information is subject to the laws of that jurisdiction, which may allow for access by local law enforcement under different standards than those in Canada.

6. How Do We Store and Protect Personal Information?

We prioritize the security of your data through a combination of physical, electronic, and procedural safeguards.

• Storage and Infrastructure: Your personal information is stored and processed using secure third-party servers located in data centers in the United States of America and Canada (and potentially other locations). These facilities are protected by industry-standard physical security measures.
• Technical Safeguards: We employ robust technical defenses, including firewalls, advanced data encryption, and secure communication protocols.
• Access Controls: Access to your personal information is strictly limited. We enforce the "principle of least privilege," ensuring that only authorized employees with a legitimate business need can access your data to fulfill their job responsibilities.
• Shared Responsibility: While we strive to maintain the highest security standards, no system is impenetrable. We cannot guarantee that information will never be accessed, altered, or destroyed by a breach of our safeguards. We urge you to take precautions, such as maintaining a unique, strong password and never sharing your Cybrid credentials.
• Breach Notification: In the event of a "real risk of significant harm" resulting from a security breach, we will notify you and the Office of the Privacy Commissioner of Canada. We may notify you electronically via our website, mobile application, or the email address associated with your account. You may request a formal written notice of a security breach by contacting us at support@cybrid.xyz.

7. How Long Do We Store Your Personal Information?

We retain your personal information for as long as necessary to provide our services and to comply with our legal requirements. Our retention criteria are as follows:

• Standard Retention: Personal information related to your ongoing relationship with Cybrid Tech is generally stored for the duration of your account plus a period of ten years.
• Regulatory & Legal Requirements: We may retain data for longer periods if required by:
  
  • Regulatory/Statutory Obligations: There may be specific laws that require us to keep some or all of the personal information that relates to you, typically for a fixed period required by that law.
  • Legal Proceedings: Information relevant to ongoing or anticipated litigation, government investigations, or regulatory audits.
  • Dispute Resolution: Data required to protect against legal claims or to enforce our User Agreement.

You have the right to request the deletion of your data once it is no longer required for legal or regulatory purposes.

8. How Do We Use the Personal Information We Collect?

Our primary goal is to provide a secure, efficient, and compliant financial experience. We use your personal information to:

• Deliver Services: Provide the payment, foreign exchange, and virtual currency services you request, including processing transactions and providing customer support.
• Manage Your Account: Resolve disputes, collect fees, troubleshoot technical issues, and facilitate connections between your Cybrid account and authorized third-party platforms or Partners.
• Service Improvements: Customize and improve the layout and functionality of our website and mobile applications.
• Communications: Send you essential transaction notices, policy updates, and information regarding new products or services that may be of interest to you.
• Security Enhancement: If you choose to share Geolocation Information, we use it to verify the legitimacy of login attempts and transactions to protect your account from unauthorized access.

9. Access to and Correction of Personal Information

You have the right to access the personal information that Cybrid Tech holds about you and to request an account of its use and disclosure. We strive to ensure that the personal information we maintain is accurate, complete, and up-to-date for the purposes for which it is used.

1. Requesting Access or a Copy: If you wish to obtain a copy of your personal information, you may submit a written request to our Privacy Officer. Upon receipt of your request and verification of your identity, we will provide you with a copy of your personal information in a structured, commonly used, and machine-readable format, subject to certain exceptions prescribed by law (such as information that contains references to other individuals or is subject to solicitor-client privilege).

2. Amending Your Information: If you believe that the personal information we hold is inaccurate, incomplete, or out-of-date, you may request an amendment. We will promptly investigate your request and, if the information is found to be deficient, we will make the necessary corrections. Where appropriate, we will transmit the amended information to third parties (such as our Affiliates or Partners) who have previously received the incorrect data.

3. How to Contact Us All requests for access or correction must be made in writing to:

Privacy Officer 

Cybrid Tech Inc.

legal@cybrid.app 

We will respond to your request within 30 days, or provide notice if additional time is required as permitted by law. Please note that while we do not typically charge for these requests, we reserve the right to charge a reasonable administrative fee where permitted and where the request is complex or requires significant resources.

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