FrontFundr Financial Services Inc. (“FFS”) collects data from users of its platform (the “Platform”) in order to provide its Services (the “Services”). FFS is committed to respecting your privacy and using your information carefully and sensibly. The term, “personally identifiable information,” refers to information that specifically identifies you as an individual and is provided to or collected by us. This Privacy Policy describes what information we may collect about you, why we do so and the ways we may use or share such information. By using FrontFundr Financial Services Inc. (the “Site” and/or the “Service”), you accept all of the practices described in this Privacy Policy, as they may be updated by us from time to time in our sole discretion.
This Privacy Policy has been developed in specific reference to British Columbia's Personal Information Protection Act ("PIPA") and recognizes guidance provided within the Personal Information and electronic Documents act (“PIPEDA”), and the General Data Protection Regulation (“GDPR”).
If you have questions about the Privacy Policy or would like to suggest improvements, please contact us at support@frontfundr.com.
User-Provided Data: You provide us with personally identifiable or non-personally identifiable information, as the case may be, about yourself, such as your name and e-mail address, when you sign-up as a member of the Service. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.
FFS acts on behalf of its subscribers and other clients in the capacity of a data controller.
FrontFundr Financial Services Inc. processes your personal data as needed for the following purposes:
(i) Provision of services – this includes the creation and management of your user account or delivery of digital content (legal basis: processing necessary for contractual performance or for the implementation of measures taken before a contract is concluded);
(ii) Processing payments – this includes the maintenance of payments, together with payment processors (legal basis: processing necessary for contractual performance);
(iii) Marketing activities – this includes the delivery of personalized content, targeting of advertising or the sending of newsletters (legal basis: legitimate interest);
(iv) Determination and enforcement of FrontFundr Financial Services’ legal claims (legal basis: legitimate interest); and
(v) Compliance with legislation.
If necessary, FrontFundr Financial Services Inc. will ask you for permission to process your personal data. Using the Services provided by FFS may require, but is not exclusive to, the collection of the following data:
(i) Name, surname, and date of birth;
(ii) Username and password;
(iii) Address, telephone number, and email;
(iv) Payment details (payment card information);
(v) Your preferences and opinions on products and services; and
(vi) Your browsing activity on our website.
Further, if you register with the Service as an authorized investor, we will also ask you to provide us with additional information about yourself, such as your finances and employment record. We are obligated by securities legislation to make a determination whether or not a proposed investment is suitable for you. To assess the suitability of proposed investments, FrontFundr Financial Services Inc. may ask you for additional information related specifically to, but not exclusive of, your investment objectives, risk tolerance and investment knowledge and such other information which FFS deems necessary to provide its Services.
If you register with the Service as an issuer, we will ask you to provide us with information about your company, such as its officers and directors, owners and shareholders, jurisdiction of incorporation and financial information. Canada’s National Instrument 31-103, Registration Requirements, Exemptions and Ongoing Registrant Obligations, requires that we collect such information from you in order to comply with our own “know your product” responsibilities to you and our “know your client” obligations under applicable laws and securities regulations.
Your knowledge and consent are required before we collect personally identifiable information about you. Your consent is deemed to have been provided or revoked when you opt-in or opt-out within an appropriate box, click on a tab, link, enter personally identifiable information in an Investor Information Form or such other form as we may ask you to complete; or use an S-Signature to complete an agreement, acknowledgement or instruction. The electronic record thereof will be considered conclusive evidence of you having accepted, declined, or otherwise acknowledged such matter, absent manifest error by the Service. In line with the guidelines provided by CASL (Canadian Anti-Spam Legislation), your consent is implicitly provided for receiving communications from the firm and you may only opt-out from receiving certain communications, in accord with applicable Canadian securities laws.
All data that we receive is obtained directly or indirectly from you when you choose to use our Service. This includes the following situations:
(i) When you register on our website;
(ii) When you subscribe to our newsletter(s);
(iii) When you browse our website;
(v) When you share content from our website; or
(vi) When you interact with us thru email, chatroom, via social media platforms, or by other means not outlined here.
Cookies: When you visit the Service, we may send one or more cookies – a small text file containing a string of alphanumeric characters – to your computer that uniquely identifies your browser, enables us to help you log in faster and enhances your navigation through the Site. A cookie does not collect personally identifiable information about you. The Service may use both session cookies and persistent cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site may not function properly if the ability to accept cookies is disabled.
Log-In File: Log file information is automatically reported by your browser each time you access a web page. When you view or sign-up with the Site, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
Clear Gifs: When you use the Service, we may employ clear gifs (a.k.a. Web Beacons) which are used to track the online usage patterns of our users anonymously. No personally identifiable information from your FrontFundr Financial Services Inc. account is collected using these clear gifs. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened by recipients. The information is used to enable more accurate reporting, improve the effectiveness of our marketing and make the Service better for our users.
Biometric data: FFS, through 3rd parties, may utilize biometric data in determining identity of its clients. FFS will not disclose, disseminate and/or transmit any client’s Biometric Data to any person or entity other than authorized licensors or vendors.
We collect and use the information you submit to operate, maintain and provide to you the features and functionality of the Site or as otherwise permitted or required by PIPA or other applicable laws.
Some of the information or content that you voluntarily disclose for posting to the Site (for instance, in profiles or other user content you post) becomes available to the public. If you remove such content, copies may remain viewable in cached and archived pages or if other users have copied or stored your user content.
Certain pages of the Site are available only to investors who have been authorized to access those web pages on the Site. Such authorization requires completion of an investor information form and satisfactory background information screening and/or identification verification. Only authorized users of the Service may access such web pages.
By providing FrontFundr Financial Services Inc. with your email address you consent to our using the email address to send you service-related notices, including any notices required by law, in lieu of communication by postal mail. You may not opt out of some service-related communications. We may also use your email address to send you other messages, including changes to features of the Site and special offers. If you do not want to receive such email messages, you may opt out at any time by clicking “Unsubscribe” in any e-mail we send you. If you e-mail us directly, we may e-mail you back and keep records of all of our correspondence.
Opting out may prevent you from receiving email messages regarding updates, improvements or offers.
FrontFundr Financial Services Inc. may use certain personally identifiable information about you and/or your user content. We do this for such purposes as analyzing how the Service is used, diagnosing service or technical problems, maintaining security, and personalizing advertisements and promotions.
FrontFundr Financial Services Inc. reserves the right, but has no obligation, to monitor the user content you post on the site. FrontFundr Financial Services Inc. has the right to remove any such information or material for any reason or no reason, including without limitation, if in its sole opinion, such information or material violates, or may violate, any applicable law, including anti-money laundering legislation, or our Terms of Use agreement or to protect or defend its rights or property or those of any third party. FrontFundr Financial Services Inc. also reserves the right to remove information upon the request of any third party.
We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information and services; (c) monitor the effectiveness of our service; (d) monitor aggregate metrics such as total number of visitors and traffic; (e) diagnose or fix technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP; and (f) help you efficiently access your information after you sign in.
In order to provide you with the services you request, your personal data may be provided to:
(i) Selected employees of FFS;
(ii) Service providers – those ensuring provision of the services provided by FFS, in particular software services providers, 3rd party identification service providers, background search providers, marketing providers, customer service providers, and distributors of marketing and other materials such as newsletters, including employees of such entities;
(iii) Tax advisors, professional advisers (e.g. auditors, lawyers), including employees of such entities;
(iv) Entities providing payment services; and
(v) Social media providers – using the services of FFS together with a social network may require FFS to share your personal data with social media providers.
Personally Identifiable Information: FrontFundr Financial Services Inc. may share your personally identifiable information with third parties for the purpose of providing services to you. We may also provide personally identifiable information to issuers to which you have initiated an investment for the purpose of completing an investment. We may store personally identifiable information in locations outside the direct control of the Service (for instance, on servers or databases co-located with hosting providers).
As we develop our business, we may buy or sell assets or business offerings. Customer, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution.
We may share your personally identifiable information with business partners who assist us by performing services such as ID verification or data storage as well as security related to our operation of the Site. Those business partners have all agreed to uphold the same standards of security and confidentiality that we’ve promised to you in this Privacy Policy; and they will only use your personally identifiable information to carry out their specific business obligations to us.
FrontFundr Financial Services Inc. may be required to disclose personally identifiable information by law or subpoena or if we believe that such action is necessary to (a) conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our site; and (c) to exercise or protect the rights, property, or personal safety of FrontFundr.com, our users or others.
We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain FrontFundr Financial Services Inc. services.
Non-personally identifiable information may be collected about your usage of the Site and aggregated with data from other users (“Aggregate Data”). This Aggregate Data is anonymous. Aggregate Data is collected to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users. We may provide statistical information based on this data to advertisers and other current and potential business partners.
As required by PIPA, we will keep personally identifiable information used to make a decision that directly affects you for at least one year after we make that decision. Subject to the one-year retention requirement under PIPA, we will only retain personally identifiable information for as long as necessary to fulfil the identified purposes under this Privacy Policy or for as long as required by applicable laws or for another legal or business purpose. Under Canadian securities legislation, FrontFundr, as an Exempt Market Dealer (EMD), must retain data associated with its securities business for a minimum of 7 years. After the 7 years following an identified transaction, a client may opt to delete data associated with this transaction but may not delete information associated with any subsequent transactions unless this data has reached the 7-year period stipulated for its retention.
FrontFundr Financial Services Inc. uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personally identifiable information. We cannot, however, ensure or warrant the security of any information you transmit to FrontFundr Financial Services Inc. and you do so at your own risk. Please note that we cannot guarantee the security of account information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time; there is no guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from FrontFundr.com, at all times.
We strictly limit who is allowed to access the information and we keep this number to a minimum. In addition, we maintain physical and cyber safeguards, such as partial anonymization of data, server protection devices, and software to minimize possible loss, misuse, or alteration of your data.
Your personal data may be stored and processed in countries where FFS carries out business or where its service providers are located. These countries may apply different privacy rules than Canada. FFS has put in place appropriate contractual and other measures to protect your personal data when personal data are transferred to related parties or third parties located in other countries.
In the event that personally identifiable information is compromised as a result of a breach of security, FrontFundr Financial Services Inc. will promptly notify those persons whose personally identifiable information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.
You may decline to submit personally identifiable information through FrontFundr Financial Services Inc. and may withdraw your consent to us collecting, using or disclosing your personally identifiable information at any time by giving us reasonable notice, unless doing so will frustrate performance of a legal obligation (such a contract between you and our organization).
If you decline to submit information through FrontFundr Financial Services Inc. or withdraw your consent for us to collect, use or disclose personally identifiable information you have previously provided to us, we may not be able to provide certain services to you.
You have the following rights in relation to your data:
(i) To request access in order to correct or delete your personal data, as well as to restrict its processing; however, your right to delete or restrict processing is applicable only if FFS is not required to process it on another legal basis (i.e. compliance with a legal obligation);
(ii) Depending on the extent of processing of your data in order to manage your user account and comply with purchase or other contracts, you are entitled to the portability of your personal data; and
(iii) If you have not completed an investment through FrontFundr, you can delete your profile through your settings page. If you have a completed investment, your data must be saved for 7 years from the date of your investment in accord with Canadian Securities Law. After the 7 year period, you may request to have your data deleted by reaching out to us at support@frontfundr.com.
The information that FFS is required to provide to you regarding the processing of your personal data may change over time or become outdated. For this reason, FFS reserves the right to modify and change these conditions at any time. If these conditions are changed, FFS will alert you, e.g. by a general announcement on this website, by email, or through your user account.
We will make reasonable efforts to ensure that the personally identifiable information we collect, use or disclose is accurate and complete, but cannot necessarily verify the personally identifiable information you provide to us. If you wish to correct any errors or omissions in your personally identifiable information that is under our control, contact us using the information below.
If we are satisfied that your request for correction is reasonable, we will, as soon as reasonably possible, correct the personally identifiable information and send the updated personally identifiable information to each organization it was disclosed to in the year before the correction is made. If we do not correct your personally identifiable information, we will note the requested correction on copies of the personally identifiable information under our custody or control.
You have the right to access your personally identifiable information under our custody or control. A request for access to your personally identifiable information must be made in writing to the address below or accessed through your personal account for the Service.
We will provide you with: your personally identifiable information under our control, information about the ways in which such information is or has been used, and the names of the individuals and organizations to which such information has been disclosed. We will provide the requested personally identifiable information within 30 business days after it is requested or give you written notice if we need more time to respond.
PIPA allows us to charge a minimal fee for providing you with access to your personally identifiable information. If a fee is required, we will give you a written fee estimate in advance. We may require payment the fee before releasing the requested personally identifiable information. In some cases, we may not give an individual access to certain personally identifiable information where authorized or required by PIPA to refuse access. If we refuse an access request, we will inform you in writing, stating the reasons for our refusal and outlining further steps that are available to you.
We are not responsible for the practices employed by Web sites linked to or from our Web site nor the information or content contained therein. Please remember that when you use a link to go from our Web site to another Web site, our Privacy Policy is no longer in effect. Your browsing and interaction on any other Web site, including a Web site that has a link on our Web site, is subject to that Web site’s own rules and policies. Please read over those rules and policies before proceeding.
It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on our Website page, as determined by FrontFundr Financial Services Inc. in its sole discretion. We reserve the right to determine the form and means of providing notifications you, provided that you may opt out of certain means of notification as described in this Privacy Policy.
By using the Site, you agree that this Privacy Policy is governed by British Columbia law and that any and all controversies arising under this Privacy Policy shall be resolved exclusively by the provincial or federal courts located in Vancouver, British Columbia.
PIPA sets out rules for how we may collect, use and disclose your personally identifiable information and requires that we collect, use and distribute your personally identifiable information only for the purposes identified in this Privacy Policy or to meet our obligations under securities, anti-money laundering or other applicable legislation. PIPA is enforced by the Office of the Information and Privacy Commissioner for British Columbia (the “Privacy Commissioner”), which you may contact at www.oipc.bc.ca
This Policy is concurrently informed by the Personal Information and Electronic Documents Act (“PIPEDA”), and the General Data Protection Regulation (“GDPR”).
If we change our privacy policies and procedures, we will post those changes on our website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. You are bound by changes to the Privacy Policy when you use the site after those changes have been posted.
If you have any questions about this Privacy Policy, the practices of this Service, or your dealings with this Web site, please contact our Chief Compliance Officer at support@frontfundr.com or at c/o WeWork, 555 Burrard Street, Vancouver, British Columbia, V7X 1M8. If you are not satisfied with our response, you may contact the Privacy Commissioner.
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