‍1. Definitions
‍The following section covers the basic definitions used in this Privacy Policy. It describes what is meant by your personal data and who controls and processes your personal data.

‍1.1. Personal Data
‍«Personal Data» means any information that may be used to identify you as an individual, directly or indirectly. Such information includes your personal name, identification number, location data, and any information found online that may reveal your physical, genetic, mental, economic, cultural or social identity.

‍1.2. Information about the Deceased
‍Personal Data requires a person to have legal capacity, meaning they can exercise their rights, give consent and enter into agreements. Legal capacity begins at birth and is lost upon death. Therefore, in this Policy, any information related to a deceased person is not seen as Personal Data and is excluded from its meaning.

Nevertheless, we will ensure that your personal data collected from you during your life is kept securely and safely with us after your death. We will not share or disclose it in any manner that is not defined in this Policy or not otherwise permitted by applicable privacy laws.

Treatment of personal data after death of the data subject may differ depending on applicable laws in your jurisdiction.

‍1.3. Controller of your Personal Data
‍As defined in applicable privacy laws, Fearless Solution is the Controller of your personal data. It means that we determine what information we collect, how and why we collect it, how it is shared and disclosed and what means we use to process this information.

‍1.4. Processing of your Personal Data
‍We use specific vendors and partners that are responsible for processing your personal information. For more specific information, please check further sections of this Privacy Policy to learn how your data is processed, what vendors we use for processing your personal data and what countries we may send your data to for processing.

‍2. Information We Collect
‍To provide our Services and offer our Products, we must collect information about you.

‍2.1. Information that You Provide
‍This category includes content and information that you provide when you use our Services and Products. Fearless Solution will never ask you to submit any information related to your racial or ethnic origin, sex life or sexual orientation, political opinions, philosophical or religious beliefs, biometric or genetic data and trade union membership.

‍2.1.1. Account Registration
‍When you create your personal account, we may ask for your contact information, including your full name, personal address, e-mail address and phone number. In addition, in order to further verify your identity for the purposes of compliance measures imposed by us under applicable anti-money laundering and counter-terrorist financing regulations (AML/CTF), we may collect the following personal information from you:

• Formal identification information, such as identity documents issued by competent government authorities in your country of domicile and/or birth, e.g. passport, national ID card, residence permit, driver’s license, birth certificate, visa information, and other relevant identification documents necessary to determine your identity and comply with legal obligations;
• Financial information, such as bank account details, payment card information, transaction history, trading data, tax information, and other relevant financial data;
• Information about your business, such as certificate of incorporation, commercial registry extracts, tax/VAT numbers, Articles or Memorandum of Association, Certificates of Incumbency, information about ultimate beneficial owners (UBOs), shareholders and management, as well as source of funds information;
• Employment information, such as job title, employer details, and job description;
• Transaction information, such as details about transaction amounts, recipients, and related activity.

‍2.1.2. Communications
‍If you contact us directly, we may request additional information such as your name, e-mail address, personal address, phone number, and other relevant details. We will always inform you of the purpose of collecting such information.

‍2.1.3. Payment Information
‍Our Services allow users to choose a preferred payment method to execute Orders and Transactions via third-party payment processors. We do not store your financial account information. It is processed and stored by our payment processors.

‍2.2. Cookie Files
‍We use cookies on our website to gather information about user interaction with our Services. Information collected via cookies may include website usage, frequency of visits, interaction with features, and other relevant data.

Cookies are small text files sent by your web browser by a website you visit. Cookies may store user preferences and other information. They provide a convenience feature to save time or recognize returning users. Cookies are stored in your browser and allow the Service or a third-party to recognize you and improve your experience.

Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your device after you go offline, while session cookies are deleted when you close your browser.

Cookies set by us are called “first-party cookies”. Cookies set by third parties are called “third-party cookies” and may enable additional features or functionality.

You may learn more about cookies at http://www.aboutcookies.org/ and http://www.allaboutcookies.org/.

‍2.3. Log Files
‍We use log files to store information gathered from your use of our Services. We use this information to enhance the functionalities of the website, acquiring detailed information about traffic to optimize website performance and improve the overall quality of provision of our Services. The information stored in log files may include Internet Protocol (IP) addresses, browser type, operating system (OS), Internet Service Provider (ISP), referring/exit pages, landing pages, time and date stamps and clickstream data. Please note that this information may be considered Personal Data under certain circumstances in accordance with applicable privacy legislation.

‍2.4. Information from Partners and Third Parties
‍Our partners that have been authorized by us to provide our Services may provide your Personal Data to us. In this case, the information forwarded to us is collected by our partners and shared with us. We require our partners to have lawful rights to collect, use and share your Personal Data before disclosing it to us. Such partners and third parties include but are not limited to the following sources:

• Public Databases, Identity Verification Partners and Credit Institutions: we gather information from the above-mentioned partners to verify your identity as required by applicable laws and regulations. Identity verification may involve collecting personal information such as your name, address, employment information, credit history, affiliation with restricted, sanctioned or prohibited groups as defined by applicable law, as well as other relevant data. We are obliged to collect and store such information as part of our obligations under anti-money laundering and counter-terrorist financing regulations (AML/CTF) aimed at monitoring, detecting and preventing financial crimes.
• Blockchain Data: we collect publicly available blockchain data to detect and prevent illegal activities, including those defined under applicable AML/CTF regulations, as well as to analyze blockchain network trends.
• Marketing Partners, Advertisers and Analytics Partners: we may collect personal data from such partners and third parties for the purposes of analyzing how you use and interact with our website, Services and Products, as well as to understand what Services and Products may be of interest to you.

‍3. Anonymized Data
‍As defined by applicable privacy laws, anonymization is a technique that alters personal information to the point where it may no longer be directly or indirectly linked to an identifiable individual.

Fearless Solution may employ anonymized data for the purposes of conducting research on the quality of our Services, understanding customer needs and demands, conducting marketing activities, detecting and preventing security vulnerabilities and breaches, and other relevant business purposes.

‍4. How We Use Information
‍We use information we collect in various ways, including the following:– Providing, operating and maintaining our Services;– Processing payments, executing Orders, Trades and Transactions in a manner consistent with the rules of market fairness, transparency, competitiveness, and genuineness;– Detecting and preventing loss of funds, including losses occurring as a result of fraud and abuse of our Services;– Ensuring compliance with relevant laws and regulations to prevent anti-money laundering, terrorism financing, fraud and other financial crimes;– Complying with anti-financial crime regimes and obligations regulated and imposed by competent authorities of Canada and applicable provincial regulators, including financial intelligence and reporting requirements where applicable;– Communicating with you, including direct means or through our partners, to perform customer support activities, to inform you of changes and updates related to the Services, to notify you of important information related to the Services and for marketing and promotion;– Sending you e-mails, including notification e-mails, reminders and confirmations;– Improving the quality of our Services;– Conducting research and development related to our Services to develop new features and functionalities and introduce new products and services;– Performing measurement and analytics activities to learn how our users interact with our Services and understand user behaviour and preferences;– Promoting safety, security and integrity of your funds, our Services and data.

‍5. How We Share This Information
‍We may share the information we collect in various ways and with third parties.

‍5.1. Vendors and Service Providers
‍We provide information we collect to vendors and service providers that help us keep our business running. Such vendors include (but are not limited to) payment platforms, web and mobile analytics services, advertisers, IT partners such as hosting and software providers, as well as sales and marketing services.

‍5.1.1. Non-EU/EEA Vendors
‍Please note that some of our service providers may be located outside of Canada. For further information on how your data is handled when sharing it with third parties outside of Canada, please see the relevant sections of this Policy.

‍5.2. Payment Platforms
‍As a merchant, we share your information with payment services and platforms such as payment processors to process your transaction and complete your order. Payment providers collect information specifically for the purposes of processing your transaction. Fearless Solution may forward your information to payment platforms in order to finalize your order; however, we do not store your payment card details and use them only for transaction processing purposes.

‍5.3. Identity Verification Services
‍We use third-party verification services such as SUMSUB to verify your identity for the purposes of complying with AML/CTF legal requirements and to ensure safety, transparency and lawful nature of your activities. By using the services of our verification partners, we compare personal information you or other third parties provide with their databases and/or public records. To learn how SUMSUB collects, stores and uses your personal information, please read https://sumsub.com/privacy-notice/.

‍5.4. Advertisers
‍To ensure you see ads that may be of interest to you, we work with third-party advertising partners. These partners may receive information from us to personalize ads to your interests. They may also collect information about you and use it in accordance with their own privacy policies. We never sell your personal information to advertisers.

‍5.5. Partners that Work with Us
‍Due to the nature of our business, we communicate and establish business relationships with various partners in banking, legal services, compliance, accounting, and other relevant fields. We may provide your information to them to ensure uninterrupted and accurate provision of our Services and to support our business operations.

‍5.6. Law Enforcement and Compliance
‍In some circumstances, we may need to disclose your personal information in accordance with applicable law to law enforcement authorities, government officials or other relevant third parties. This may include court proceedings, compliance with legal orders or other legal processes, as well as prevention of financial crime, money laundering and terrorism financing where we have reasonable grounds to suspect such activity.

‍5.7. Business Transfers
‍In cases of insolvency, bankruptcy, acquisition, transfer of ownership, sale of assets or corporate restructuring of Fearless Solution, your personal information may be disclosed to the new owner, acquirer or successor entity or other relevant third parties as part of such transaction.

‍6. How We Secure This Information
‍At Fearless Solution, we understand the importance of keeping your personal information in a secure and integral manner, as any breach of personal data may lead to detrimental consequences to you and your funds. Therefore, we employ various physical, technical and administrative safeguards to ensure integrity, security and confidentiality of your personal data.

Your personal information is secured with the help of Transport Layer Security (TLS) protocol that is designed to protect and secure your information from unauthorized access and breaches of privacy. TLS protocol is mainly used for encrypting the information exchanged between our website and servers. We also use TLS to encrypt all emails and messages exchanged with us. We use modern and industry-standard TLS versions and apply updates as new secure versions become available.

In addition, your transaction and other personal information is stored by us in an encrypted manner. Such encrypted data is stored and maintained with the use of relevant service providers that help us maintain physical, technical, electronic and administrative safeguards. Please note that some of such vendors may be located outside of Canada.

At the same time, even with all the security and safety measures imposed by us, we cannot guarantee that your data may not be breached, accessed without authorization or otherwise compromised. We ask you to acknowledge that a significant part of data security also depends on you. It is strongly recommended to ensure your password includes a combination of letters, numbers and symbols and sufficient length; it is also advised to check the security of your connection (lock icon in the browser URL bar) to avoid fraudulent or spoofed websites.

Should you become aware of any attempt to misuse your personal information, or should you believe your personal information is not stored, handled or maintained securely, please notify us immediately at support@fearless.solutions‍

‍7. Retention of Personal Information
Your personal information is stored securely for as long as your account is active. We retain personal data only for the period necessary to fulfill the purposes for which it was collected. Retention periods may vary depending on the type of personal information and legal requirements, such as:

• Personal information related to legal obligations under anti-money laundering and counter-terrorist financing laws (AML/CTF) may be stored for as long as required by applicable law;
• Contact information used for marketing purposes is retained for as long as consent is valid and is deleted upon withdrawal of consent;
• Telephone call records and correspondence may be retained for up to five years;
• Information collected via technical means is retained for up to one year.

‍8. Legal Basis and Legitimate Interests
‍Our legal basis to collect, use and share your personal data varies depending on the context. We process personal data in the following cases:

• When we have your consent, meaning you have agreed to specific processing purposes, such as marketing communications and personalization of services;
• When we need to perform a contract with you, meaning processing is necessary to provide our Services, execute Orders, process payments, and deliver customer support;
• When we have a legal obligation, meaning we are required to comply with applicable laws, regulations, or lawful requests from authorities;
• When we have a legitimate interest, meaning processing is necessary for business operations, service improvement, fraud prevention, and security, provided it does not override your fundamental rights.

‍9. Rights of the Data Subject
As a data subject, you have rights under applicable privacy laws.

‍9.1. Access, Update, Correct or Erase Your Information
‍You have the right to request access, correction or deletion of your personal data by contacting us at support@fearless.solutions

‍9.2. Objecting to and Restricting Processing of Information
‍You may object to or restrict processing of your personal data by contacting us at support@fearless.solutions

‍9.3. Data Portability
‍You may request a copy of your personal data in a structured format by contacting us at support@fearless.solutions

‍9.4. Opt-Out of Marketing Messages
‍You have the right to opt out of marketing communications at any time by using the unsubscribe link in emails or contacting us at support@fearless.solutions

‍9.5. Withdraw Your Consent
‍You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.

‍9.6. Complaining to a Data Protection Authority
‍You have the right to lodge a complaint with a supervisory authority in your jurisdiction regarding the processing of your personal data. Relevant authority information can be found via official government privacy portals or international data protection resources.

10. Automated Processing and Decision-Making
‍We may employ automated tools to determine fraud or financial crime risks associated with any Order, Trade, Transaction or Customer. However, we do not perform any decision-making based on means of fully automated processing, or automated processing that relies solely on decisions and conclusions generated by the machines and the line of code and does not involve any human control, assessment and/or intervention. Similarly, we do not employ any algorithmic and automated systems to make decisions that have serious life-affecting consequences, except for the cases laid down by relevant data protection provisions.

‍11. International Transfer of Data
‍We strive to enhance the security of personal information you are entrusting us with. Therefore, Fearless Solution opts for the most secure and diligent data processors to do the task. Some of such processors are located overseas outside of the EU/EEA area in countries that have different regulations on personal information. However, our partners follow the requirements and safeguards of the GDPR when receiving and handling your personal information that Fearless Solution shares with them.For transfers of information to and from processors located in the UK, the European Commission adequacy decision has been adopted, meaning that data may flow freely from the EU/EEA to the UK and back since the EU considers the data protection regime in the UK essentially equivalent to the regime of the GDPR.For transfers of information into the EU from other countries covered by the European Commission adequacy decisions, such as Andorra, Argentina, Canada, Faroe Islands, Guernsey, Isle of Man, Israel, Japan, Jersey, New Zealand, Switzerland and Uruguay, Fearless Solution is required to comply with the local legal requirements and regulations on transfers of personal data, therefore we make sure the specific arrangements are being followed when receiving data from any of the aforementioned countries.For transfers of information to processors located in the US, Fearless Solution no longer relies on processors that are certified under the EU-US Privacy Shield Framework because it has been invalidated in 2020 by the decision of the European Court of Justice.

‍12. Children’s Privacy
‍Fearless Solution does not knowingly collect and process any personal information from children under 13 years of age. Please note that for any collection and processing of personal information of a child under 13, Fearless Solution requires explicit consent from the child’s legal representative, such as a parent or a guardian.If you suspect that a child under 13 has provided us with their personal information without explicit consent, please contact us at support@fearless.solutions‍

‍13. Changes to the Policy
‍Fearless Solution may modify this Policy from time to time to adapt it to the changing regulations and new developments. Changes will be posted on our Website fearless.solutions. Additionally, we will notify you of changes via e-mail.

‍14. Contact information
‍If you have any questions or concerns regarding this Policy, your personal data rights and how to invoke them, or any other question about your personal information, please feel free to contact us at support@fearless.solutions