Eigen Fintech Privacy Policy

Policy relating to the Collection, Use and Disclosure of Personal Information

14872525 Canada Inc. operating and doing business as Eigen Fintech Inc. (“Eigen”) is committed to maintaining the privacy and confidentiality of all personal information under our care. In the course of providing data, analytics and trading tools to you as part of our SaaS subscription offering, Eigen is obligated to collect, use and store personal information about individuals. The purpose of this Policy is to answer questions about what personal information we hold and may transfer, the purposes for which we collect it, how we protect it, who it may be disclosed to, and how it can be accessed or modified. This policy applies to all customers of Eigen and is in addition to the Terms of Use agreements governing the services we render for our customer. By subscribing to receive our subscription-based services via our platform, you signify your consent to the terms of this Privacy Policy. This Privacy Policy also serves to govern the conduct of all Eigen employees with regard to personal information.

1. TYPES OF PERSONAL INFORMATION UNDER OUR CARE

When we open and maintain an account, we are obligated to collect the following types of information out of necessity or legal obligation:

2. PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL INFORMATION

We collect and use the personal information we obtain during the account opening and and in the course of providing services to you for the following purposes:

3. PROTECTION OF INFORMATION

We use physical security measures that are technological and administrative to protect the Information we collect from you. We take all useful precautions to preserve the security, integrity and confidentiality of your Information and in particular, to prevent them from being distorted, damaged or accessed by unauthorized third parties. We ensure our employees and partners handle your Information with care at all times and we require them to maintain their obligations of confidentiality even after the end of their contract with us.

We may transfer Information to outside agents or service providers that perform services on our behalf, for example, mailing, call center, billing, collections, skip-tracing, marketing, analytics, information technology and/or data hosting or processing services or similar services, or otherwise to collect, use, disclose, store or process your information on our behalf for the purposes described in this Policy. Some of these service providers may be located outside of Canada, including in the United States, and as a result, your Information may be processed and stored on servers outside of Canada for the purposes described in this Policy. Contractual clauses and other measures we may take to protect your Information while processed, stored or handled by these service providers are subject to applicable Canadian and foreign legal requirements, including lawful requirements to disclose personal information to government and national security authorities in certain circumstances.

We use Google Analytics to collect information about how visitors interact with our platform. This data helps us understand user behavior, track site performance, and improve our services. Google Analytics collects information such as your IP address, device type, browser type, and pages visited on our platform. This information is used to generate reports and analyze trends but does not identify individual users. By using our platform, you consent to the collection and processing of data by Google Analytics. For more information on how Google processes your data, please refer to theGoogle Privacy Policy.

In all cases, we require outside agents, service providers, and partners to protect your Information at the same high level that we have committed to.

4. DISCLOSURE OF INFORMATION

Eigen does not sell personal information to third parties. Eigen does not disclose personal information to third parties other than in the following circumstances and for the following purposes:

(1) In the normal course of business operations to open or service client accounts, including, without limitation, for purposes of facilitating the account opening process and the provision of customer service and processing customer payments (including services rendered by third party processors), and for internal audit and accounting purposes;
(2) To specific Eigen employees in order to offer services to clients, to engage in surveillance of the Eigen platform and/or to ensure disaster recovery services relating to such information (which may include trans-border transfers of information);
(3) To other suppliers or service providers who assist us in serving our clients. Our service providers may at times be responsible for processing payment information, including personal information. Such service providers are provided only with the information necessary for them to perform their services. In addition, we require them to protect the information in a manner that is consistent with our privacy policies and customary security practices. In the event our service provider is located in a foreign jurisdiction they are bound by the laws of the jurisdiction in which they are located and may disclose personal information in accordance with those laws;
(4) To legal counsel for the purpose of obtaining legal advice;
(5) Where we are required or permitted to do so by law.

We will limit our disclosure of your Personal Information to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged. We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal Information solely to provide Eigen with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting us at the addresses provided under “Access to Information”.

By opening or maintaining an account with Eigen, clients consent to the disclosure of personal information to a third party in the circumstances or for the purposes described above. Eigen’ clients must understand, acknowledge and agree that their consent to the disclosure of personal information in connection with a matter referred to above is not a condition of Eigen for transacting with its clients, including the relevant offer or service to be provided, unless the disclosure of the information is necessary in respect of the particular service or required by law. Subject to this qualification, consent to Eigen’ collection, use or disclosure of personal information may be revoked or withdrawn, at any time on reasonable notice, by contacting Eigen’ Support Department by email at support@eigenfintech.com. If consent were to be revoked or withdrawn, Eigen may be unable to provide certain services. Our Support Department personnel will be happy to explain any consequences of revoking or withdrawing consent.

5. ACCESS TO INFORMATION

Eigen makes every reasonable effort to ensure that personal information is accurate and up-to- date. Individuals can also request rectifications, a withdrawal or the destruction of all personal information, that we collect at any time by contacting our Support Department by email at support@eigenfintech.com.

Individuals may also consult and access the personal information Eigen maintains by contacting Eigen’ Support Department by email at support@eigenfintech.com and scheduling an appointment. In your request, please include the relevant account number(s), and the information which you would like to have updated or modified.

6. INQUIRIES OR COMPLAINTS

Eigen’s Chief Regulatory Officer (CRO) is responsible for the monitoring compliance with this Privacy Policy. Inquiries or complaints regarding this Privacy Policy should be directed to support@eigenfintech.com by email support@eigenfintech.com.

7. POLICY UPDATE

We may revise this Privacy Policy from time to time, in response to legal developments, as new technologies become available, or as we introduce new features, products or services.

When we make changes to this Privacy Policy we will revise the “last updated” date at the bottom of the page. You should check back here periodically to find out if any changes have been made. If we make substantial changes we will, as appropriate, prominently post these changes to our website or notify you directly.

If you disagree with any change to the Privacy Policy, you may close your account and refrain from using our services, or in some cases, by opting out. Continuing to use our services, including our websites, after we post or communicate a change signifies that you consent to the revised terms of the Privacy Policy.

On occasion, we may also identify new purposes for the collection or use of Personal Information, such as in connection with a new promotion or service. We will describe such uses in separate notices or other communications.

Last Update: August 2, 2024