Last revised: December 23, 2020
At Klanto, we are committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy statement (this “Privacy Statement”) is to inform you about the types of personal information Klanto, Inc. (as follows, “Klanto,” “we” or “us”) collects, uses and discloses, including the personal information collected through our website, mobile app and through our conversations with customers (the “Klanto Platform”). It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information. To contact Klanto about the collection, processing and control of your personal information, please use the information found in question 8 below.
Your privacy is one of our priorities. We are proud to demonstrate our commitment to your privacy by following the laws and regulations under applicable privacy laws.
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat personal information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.
The Klanto Platform may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Klanto Platform. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Klanto Platform. We encourage you to learn about a third parties’ privacy and security policies before providing them with information.
The following topics will be covered in this Privacy Statement:
We will always collect your personal information by fair and lawful means (for example, when you register with us). We may collect personal information from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law. The legal bases for our processing of personal information are primarily that the processing is necessary for providing the Klanto Platform and for facilitating and processing your payments and foreign exchange transactions and related services (the “Services”) and that the processing is carried out in our legitimate interests, which are further explained in the “How do we use your personal information?” section. We may also process personal information upon your consent, asking for it as appropriate.
We may collect standard internet log information about how and when you use the Klanto Platform and the Services. This information may include but not be limited to, your IP address and location data, weblogs, time, date, browser used, referring web addresses, other communication data, searches conducted, and/or pages visited.
We generally use your personal information for the following purposes (the “Purposes”):
By way of this document, we identify to whom, and for what Purposes, we disclose your personal information, at the time we collect such information from you and (if applicable) obtain your consent to such disclosure.
We disclose your information to the following vendors to provide the Klanto Platform:
We disclose your username, contact information and account information within the Klanto Platform to the other users of the Klanto Platform that you send money to and such other persons as may be designated by you from time to time. Your personal information may also become available to our analytical vendors, such as Google Analytics and Facebook Pixel, as well as search engine and performance optimization platforms. We may disclose your personal information to third party service providers, including without limitation your proof of identification, with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes – such as service providers that provide web development, application programming interface, data analytics, data storage or processing, or hosting. When we disclose your personal information to third parties, we take reasonable measures to ensure that these third parties provide sufficient guarantees to implement appropriate technical and organisational measures.
Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using the Klanto Platform, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Statement. For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Information Officer (see question 8 below).
We obtain your consent prior to collecting, and in any case, prior to using or disclosing your personal information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances.
For greater certainty, when you choose to send electronic mail to Klanto or any Klanto representative, agent or employee, you are consenting to the company using the information provided therein, including personal identifying information, in accordance with this notice, unless you expressly state in the e-mail your objection to any use(s).
We may keep a record of your personal information, correspondence or comments, in a file specific to you. We will utilize, disclose or retain your personal information for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.
On written request and subject to proof of identity, you may access the personal information that we hold and ask that any necessary corrections be made, where applicable, as authorized or required by law.
We do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Klanto Platform at any time or in any manner unless you have received parental consent and such consent has been provided to Klanto. If you are a parent or guardian and discover that your child under 16 years of age has provided personal information without the appropriate parent or guardian consent, you may contact our Privacy Information Officer (set out in question 8 below) and request that we delete that child’s personal information from our systems.
The only employees who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information. We have implemented organizational, contractual and technological security measures to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Klanto Platform, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or administrative safeguards. If you believe your personal information has been compromised, please contact our Privacy Information Officer (set out in question 8 below).
If you have any questions or comments about this Privacy Statement or your personal information, to make an access or correction request, to exercise any applicable rights, or to make a complaint, our Privacy Information Officer can be reached using the following contact information:
Attn: Privacy Information Officer