Last Modified: January 31, 2022
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
Use of Your Personal Information with Credit Reporting Agencies
We may also use your personal information to confirm your identity with Trans Union of Canada, Inc., Equifax Inc. and their related and affiliated entities (the “Credit Agencies”). To confirm your identity, we use personal information you provide us, for example, your name and date of birth, to obtain reports and information from the Credit Agencies about you. We cross reference the information obtained from the Credit Agencies about you with the information you provide us. To access your personal information on file with the Credit Agencies, for the purpose of confirming your identity and matching it with other personal information you provide to us, we may use the services of Trulioo Information Services Inc. (“Trulioo”), who in turn, may conduct the relevant searches with the Credit Agencies. If we cannot verify your identity in reference to information provided by Trulioo and the Credit Agencies, we may refuse to allow you to register for an account on our Service or remove your account access.
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;
- Review usage and performance data, and for diagnostics and analytics purposes.
Identify Verification Providers
As part of our measures to confirm your identity, we may also use third party identification service providers such as Persona Identities Inc. (“Persona”) and others. To learn more about Persona’s privacy practices, please visit https://withpersona.com/legal/privacy-policy. For a full list of our current identification service providers, please contact us using the details online at https://www.newton.co/support.
We may send copies of your identity documents and personal information to such third party providers for the purpose of confirming your identity and preventing fraud.
In some instances, we may need to speak with you via phone to validate your account information and your intent to register an account with us. You agree that we may use the phone number registered with your account for the above purposes. On such phone calls you must not reveal your account passwords or passphrases for our or any other service. Phone calls may be recorded for our own internal quality control and training purposes.
To assist us with account and information validations we may also use third party service providers. Such service providers may have access to your personal information, including for example, your identity documents, photos you upload to the Service and contact information. Third party service providers may also call you and email you, on our behalf, to assist us with your identify and account verification.
Data Hosting Providers
Support Ticketing Software
We also use third party support ticketing software. We may store your personal information with such third party software providers. If you have questions regarding our third party support ticket software, please contact us using the details online at https://www.newton.co/support.
We will not contact you via any email address other than those with domains ending in @newton.co. Emails from other domains purporting to be us are not authorized representatives of Newton Crypto Ltd. Please remain vigilant against potential scams, impersonator accounts and phishing attempts.
While we love staying active on social media and we may interact with you, we will never ask you to provide sensitive information (such as passwords or digital wallet addresses) or personal information through social media accounts (including direct messages).
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.
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.
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 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 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 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 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