Privacy Policy

PARADISO VENTURES INC. O/A Balance is committed to protecting the privacy and confidentiality of personal information (the "Personal Information") in our possession and control. This Privacy Policy explains the measures we take to fulfill these commitments and describes the manner in which Balance collects, uses, discloses and otherwise treats personal information through our website, any of our APIs, and mobile applications made available at balance.ca, balancenow.ca, balancecustody.ca, balancepay.ca, paradiso.ventures and through online application stores. This includes all subpages, successor pages, application screens, and API endpoints (collectively referred to as the "Platform") as well as any other interactions with our clients and prospective clients.

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This statement may be updated periodically to reflect changes to our personal information practices by giving you notice on this page and possibly within the Platform and/or - as far as technically and legally feasible - sending you a notice via any contact information available to us. Should the changes affect processing activities performed on the basis of your consent, Balance shall collect new consent from you, where required. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Balance needs to collect personal information from our clients and prospective clients in order to provide services to you and fulfill our legal obligations. Balance is committed to protecting our clients' privacy and the confidentiality of their personal information in our possession. This memorandum explains the measures we take to fulfill these commitments.

We collect your first name, last name, and email address when opening an account. The information is used for the following purposes:

• account setup and administration in order to provide our services to you as a client;
• delivering marketing and other transactional communication;
• internal research & development purposes, including analytics;
• verifying your identity and other information you may have provided to us;
• meeting legal and regulatory requirements as otherwise required by applicable law.

Identity Verification: At the point of purchase or from time to time, we ask for authentic, valid, and current documentation to verify your identity, phone number, occupation, ascertain the source of funds, and perform any and all necessary determinations required to fulfill our obligations pursuant to our internal Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) Compliance Policy (the "Anti-Money Laundering Policy"). Additionally, we ask for banking information in the course of providing some of our services to you (e.g. purchasing virtual currency from you in exchange for fiat currency). We keep these documents on file for five (5) years from the date of their creation, for record keeping and reporting purposes with the appropriate authorities, as applicable and required by law.

Marketing Communications: At registration or from time to time, we may obtain your consent to send you emails and other communications about Balance products, services, or events that may be of interest to you. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained in each of our email communications. Please note that you will continue to receive email regarding your account and transactions with us. Alternatively, you can unsubscribe from all of our marketing communications by emailing unsubscribe@balance.ca

Customer Service/Relationship Manager: If you contact a customer service agent with a comment, question or complaint by email, text message, telephone or video chat, you may be asked for information that identifies you (such as your name, address and phone number) along with additional information we need to help us promptly answer your question, or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service, and product and service offerings.

Employment: If you inquire about or apply for a job with Balance, you may provide us with certain Personal Information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

You are responsible for any third party Personal Information obtained, published, or shared through this Platform and confirm that you have the third party’s consent to provide the data to us. Except as otherwise set out in this Privacy Policy, we collect Personal Information directly from you.

Your Personal Information shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal Information collected for purposes related to the performance of a contract between the Balance and you shall be retained until such contract has been fully performed;
• Balance may be obliged to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority;
• Balance may be allowed to retain Personal Information for a longer period when given consent to such processing, as long as such consent is not withdrawn.

Once the retention period expires, the Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

We record your Personal Information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees and service providers to have access to the information only on a “need to know” basis in order to fulfill their job requirements. The updated list of these parties may be requested from Balance at any time.

Balance maintains reasonable administrative, technical and physical safeguards in an effort to protect Personal Information in our custody and control against unauthorized access, use, modification and disclosure. We train our employees to keep clients’ Personal Information strictly private and confidential. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients' Personal Information.

The hosting facilities for our website are situated in Canada and the US. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to Canada and the US will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out in this Privacy Policy.

Service Providers: We may transfer your personal information to our affiliates and other third party service providers who provide various services on our behalf such as identity verification, technology, administration, printing, marketing and advertising, hosting, data analysis, legal and accounting.

Business Transactions: We may transfer any information we have about you as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Balance or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Legal: We and our Canadian, US and other affiliate and third party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law (which may include lawful access requests by Canadian, US or other foreign courts, law enforcement or governmental authorities). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent an actual or suspected loss or harm to persons or property.

Our service providers are given only the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. Your personal information may be maintained and processed by our affiliates and other third party service providers in the US, Canada, or other jurisdictions. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions.

You may exercise certain rights regarding your Personal Information processed by us. As such, you can:

• Withdraw your consent at any time. You have the right to withdraw consent where you have previously given consent to the processing of your Personal Information.
• Object to the processing of your Personal Information. You have the right to object to the processing of your Personal Information, if the processing is carried out on a legal basis other than consent, or legal and regulatory requirements. Where Personal Information is processed for a public interest, in the exercise of official authority vested in us, or for the purposes of the legitimate interests pursued by Balance, you may object to such processing by providing a ground related to their particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification.
• Access your Personal Information. You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Personal Information undergoing processing.
• Verify and seek rectification. You have the right to verify the accuracy of your Personal Information and ask for it to be updated or corrected.
• Restrict the processing of your Personal Information. You have the right, under certain circumstances, to restrict the processing of your Personal Information. In this case, Balance will not process your Personal Information for any purpose other than storing it.
• Have your Personal Information deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Personal Information from Balance.
• Receive your Personal Information and have it transferred to another controller. You have the right to receive your Personal Information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
• Lodge a complaint. You have the right to bring a claim before your competent data protection authority.

Balance's Chief Compliance Officer, Gheorghita Catalin Bordianu, is responsible for ensuring that Balance adheres to this Privacy Policy. The Chief Compliance Officer is responsible for training our employees in our privacy policies and for monitoring the fulfillment of our privacy commitments. You can exercise any of your rights to the Personal Information by sending a written request to this effect using the contact information provided below. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one (1) calendar month.

In general, you can visit our Platform without indicating who you are or submitting any personal information. However, the hosting provider of our website, Amazon Web Services (AWS) automatically collects and stores various information in so-called server log files that your browser transmits to us. The information/data mentioned is neither assigned to specific persons nor linked to data from other sources. This technical data will be recorded by us, as usual with every connection with a web server, without your intervention, and stored by us until automatic deletion after no later than twelve months. Our legitimate interest in collecting and processing this technical data is for enabling the use of our website, continuously ensuring system security and stability, optimising our website, and for internal statistical purposes.

We collect and/or maintain the IP (Internet protocol) addresses of all visitors to the Platform and other related information such as page requests, browser type, operating system and average time spent on the Platform. We use this information to help us understand Platform activity and to monitor and improve the Platform.

Cookies & Similar Technologies: The Platform uses a technology called “cookies”. A cookie is a tiny element of data that the Platform can send to your browser or device, which may then be stored locally so that you can be recognized when you return. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies. We use cookies on the pages and screens on the Platform where you are prompted to log in or that are customizable. If you have registered with the Platform, these cookies may let us know who you are and identify your browser or device as one that has visited the Platform before and may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services. We also use cookies to provide us and our service providers with information about your use of the Platform that we may use to personalize the Platform or other content in accordance with your interests and preferences (e.g. language preference) and improve your user experience. You may set your browser or device to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Platform, you may not be able to take advantage of all of the features of the Platform.

Tracer Tags & Web Beacons: The Platform may also use a technology called "tracer tags" or "Web Beacons". This technology allows us to understand which pages or screens you visit on the Platform. These tracer tags are used to help us optimize and tailor the Platform for you and other future visitors to the Platform.

Platform Analytics: We may use third parties to help us gather and analyze information about the areas visited on the Platform in order to better understand, evaluate and improve the user experience and the convenience of the Platform.

Social Media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plugins and applications. When you engage with our content on or through third-party social networking websites, plugins and applications, you may allow us to have access to certain information associated with your social media account (e.g. name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on the Platform and on the third-party social networking websites, plugins and applications, and to provide you with other products or services you may request.

Our Platform may contain links to other websites that we do not own or operate. Also, links to our Platform may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your Personal Information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

Last reviewed: October 2nd 2023