Privacy Policy for Coterie Finance Technology Limited, Canada, incorporated BN 733232417RC0001 and Corporation Number 1528505.

Coterie Finance Technology Limited (“Coterie,” “we,” “us,” or “our”) is committed to protecting your privacy and the confidentiality of your personal information in our possession and control. This Privacy Policy describes our practices regarding the personal information we handle as part of operating our business, including providing our website at coterie.com (the “Site”), our web-based application, our Mobile App (collectively, and together with the Site, the “Platform”) and any of our products or services provided via the Platform (collectively along with providing the Platform, the “Services”).

The terms of this Privacy Policy apply in all your interactions with us, including when you access the Platform, apply for or receive our products and services, visit our Site, or communicate with us.

What Information Do We Collect and Why?

The types of information we collect depend on what you choose to provide when you interact with us, and the Services we are providing. Information is collected through your interactions and use of our Services, Platforms, and interactions with partners. This information is used to provide our services to you. Coterie collects the following types of information:

• Contact information, which allows us to communicate with you. This can include information like your name, email, residential address, and telephone number;
• Authentication and account information, which allows us to verify your identity and create your account. This includes your login information, date of birth, and government ID information;
• Background and biographical information to assess and manage risk, comply with legal requirements and help us serve you better. This includes details about your occupation and employer;
• Records of your interactions with us, such as recordings of phone calls for quality assurance, dispute resolution, and training purposes;
• Your preferences and online activity, such as your contact and language preferences which allow us to improve and personalize your experience. We use cookies and similar tools to improve our Site and services. We also use them to promote our products or services that may be relevant to you. See Website Use and Technologies below for more information;
• Any other information you choose to provide to us, such as family details, life events, goals, and issues you may have encountered.

When you provide personal information to us about someone else, you are required to have the proper authority to do so. We assume you have the authority to do so unless we are told otherwise.

Our Platform is not directed to children under the age of 18, and we do not knowingly collect information from children under the age of 18 on our Site. If we become aware that we have inadvertently received information from a visitor under the age of 18 on our Site, we will delete the information from our records. If you believe we may have your child’s information in our possession without this consent, please contact us using the information under “Contact Us” below.

How We Use Your Information

We primarily use the information listed above to provide our Services, operate our business, and comply with legal and regulatory obligations. Here is a more detailed list of how and why we may use your information:

• To create your account, provide the Services and maintain the Platform;
• To verify your identity, to authenticate you when you contact us, to manage our relationship with you;
• To protect you, your community, and us against error, as well as fraud, financial abuse, or other malicious activities;
• To understand how communities and our users use the Services and resources provided on our Platform, which includes research and analytics to improve the Services, to improve the usability, function, and engagement of our Platform including the creation of statistical, anonymized aggregated, or other reports, for the purpose of internal analysis;
• To operate and improve our business and minimize any errors or disruption to our Services;
• To comply with legal and regulatory obligations, manage our risks and operations, and protect us, our stakeholders, and our legal interests;
• To communicate with you about your account; any benefit, feature, or other information about our services;
• To respond to your communications, including addressing your requests and concerns.

If you create an account, you agree that we may verify your name, address, phone number, and other account details with information about you held by a third party or publicly available sources (such as identity verification providers, fraud prevention services, government registries, and your mobile service provider) to verify your identity and help protect against potential fraud. You provide your consent for them to disclose and/or compare your information for this purpose. Your personal information will not be shared with these third parties for any other purpose.

Website Use and Technologies

We use a common web technology called cookies. A cookie is a small piece of information that sits on your computer. As you use our Site, cookies are passed back and forth between our server and your browser. You can control which cookies are accepted and how your browser uses them. For more information on cookies, please review the help section of your browser to learn more about its control features.

When you use the Services, third parties on our behalf may collect your information via the use of pixels, programs, cookies, and other similar technologies.

We also use service providers to perform specialized services such as data hosting, processing services, banking, payment processing services, digital support, and mail distribution. Our service providers may be responsible for processing personal information. They are provided only the information necessary to perform the service. We require that our service providers protect your information in accordance with our Privacy Policy and security practices.

Sharing Your Information

We do not sell, rent or lease our customer lists to third parties.

We may share your information for the following two main purposes:

Operating Our Business

As part of operating our business, we may:

• Transfer your information to service providers and affiliates, who help us perform internal business functions and help us provide you with our Services;
• Share information with payment networks and other companies that we partner with to offer our Services;
• Disclose information about you with others who are authorized to access information about your account (what is provided to them depends on the scope of their authorization);
• Exchange your information with credit bureaus (i.e. Equifax and TransUnion) to provide our Services and help you build a credit history. This may include your name, address, and information about your loan balance and payments. We update your information with credit bureaus to help maintain the integrity of the credit reporting system. The information provided to credit bureaus may be used in consumer credit reports. Both positive and negative payment history are reported to the credit bureaus.

Protecting Our Legal Interests

• We may also share your information to protect our legal interests. We may disclose your information:
• When we have reason to believe that disclosing this information is necessary to identify or contact you or bring legal action against someone who may be causing injury to you, Coterie, or someone else;
• When we believe the law requires it, in response to any demand by domestic and international authorities, as well as any other valid legal demand;
• To meet any other legal obligations, or as part of investigating a potential breach of a legal requirement or our policies;
• To another company or individual as part of considering or completing a transaction;
• For the purposes of fraud or other crime prevention, suppression, or detection, including managing our security risks.

How You Share Your Information

Users assume all risks associated with user-submitted information, including, but not limited to, any third party’s reliance on its quality, accuracy, or reliability, or any disclosure of information in your user content that makes you or others personally identifiable. Because of the Community wallet features of the Platform, information, including personal information, that you enter into the Platform may be visible and accessible by other users of the Platform who are part of your community. This includes information related to your payments into the Group Rotating Savings to members of the communities that you have joined on the Platform and any scores, achievements, or badges associated with your activity on the Platform. The visibility of this information is limited to members of your community.

Your Consent and Your Privacy Options

Your Consent

By using the Site, registering for or obtaining a Service, and/or providing us with personal information, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. Without information about you, we may not be able to provide you with the Services or the support you request.

You at any time have the right to withdraw consent to our collection, use, and disclosure of personal information, subject to contractual and legal restrictions and reasonable notice. If you withdraw your consent, certain functionality of the Site may not be available to you, and we may not be able to provide you with certain Services.

Your Privacy Options

You can withdraw your consent to collect, use, and disclose your information in certain circumstances, but in other circumstances, you may not be able to withdraw consent. If we are required to use or retain your personal information due to legal or regulatory requirements, we will respect your request not to use the information for other purposes.

Exercising Your Privacy Options

At any time, you can contact us and let us know about your privacy and communication preferences, including if you wish to opt-out of certain communications or request to withdraw your consent. If you wish to withdraw your consent to the collection, use, or disclosure of your information, please contact us using the contact information in the “Contact us” section below.

International Transfers of Information

We share your information with third parties located outside of Canada. These third parties are subject to the laws of the regions they are operating in and may be required to disclose your information in accordance with those laws, including to law enforcement.

Security of your Personal Information

Your safety and privacy are important to us. While the security of information can never be guaranteed, we have enabled various tools and technologies to assist with the reactive and proactive protection of your information. Some of these include physical and electronic security for information we have in our possession, careful destruction of your information when we no longer require it, and requirements for third parties to protect your information in accordance with this policy when we transfer your information to them. Generally, we apply safeguards that we believe are appropriate to the sensitivity of the information we’re handling.

It is also essential for us to have your partnership in building a strong and effective defense against potential fraud, money laundering, and associated criminal activities. Some (but not necessarily all) of the steps you can take to protect yourself include:

• Ensure you have a strong and unique password for each account and device. Never write it down or save it anywhere;
• When it comes to emails, texts, or other electronic messages, avoid clicking a link without validating the sender and confirming that it’s from a trusted source;
• Never download or open attachments from an unfamiliar sender;
• Never accept an invitation from a user you do not know or have a connection with;
• Never share any personally identifiable information or financial information. Coterie will only, through official contact, ever request that you share your personal or financial information.

Retention

We will only retain your information for as long as reasonably necessary to comply with legal and regulatory requirements or to fulfill a legitimate purpose, after which point it will be removed from our records in accordance with our record retention and destruction policies.

Requests Regarding Your Information

You can request to access, correct, or delete your information. Much of the information you can request to access, correct, or delete is available online or through the Coterie app. You can also submit a request to us using the information provided under “Contact us” below.

Accessing your information

You can request access to your information. You can access a lot of the information we hold about you online or through the Coterie app. If the information you are looking for is not available online or through the Coterie app, please contact us using the contact information below.

Correcting and updating your information

We will do our best to keep your personal information up to date. From time to time, we may contact you and request that you update the personal information you have provided us. You can also update your personal information anytime online or through the Coterie app.

Contact us

If you have any questions or concerns about how we handle your personal information, or if you would like to make a request to access or correct your information, please contact us at info@usecoterie.com

Updates To Our Privacy Policy

We may update this Privacy Policy from time to time to meet legislative changes, to provide greater transparency, or in response to changes in our products, services, or data processing activities or policies. If there are material changes to this Privacy Policy, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.

We encourage you to periodically review our Privacy Policy to learn how we are protecting your personal information.