Privacy Policy

UREEQA Inc. (“UREEQA”, “we”, “us”, or “our”) wants you to be familiar with our privacy practices, which seek to comply with applicable legislation, including the Personal Information Protection and Electronic Documents Act and, in case of data processing falling within its territorial scope, the European Union’s regulation No. 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, also known as the general data protection regulation (the “GDPR”). This privacy policy (“Policy”) describes how we collect, use, transfer and disclose personal information that you provide to us when you visit our website: ureeqa.io (“Website”), when you register for an account and use our platform (“Platform”) and during any other interactions with us.

By visiting our Website, registering for an account and using our Platform, or otherwise interacting with us, you consent to – or, for GDPR purposes, you acknowledge you are informed of – the collection, use, transfer and disclosure of your personal information by UREEQA in accordance with the terms of and for the purposes set out in this Policy, as they may be amended from time to time.

Please review this Policy periodically.

SUMMARY OF PRIVACY POLICY

We may collect the following personal information when you provide it to us, visit our Website, register for an account and use our Platform, complete forms or emails, enquiries or requests, or as otherwise stated in this Policy:

  • Legal name;
  • Email address;
  • Credit card information;
  • Personal information, related to authorship, ownership and originality, uploaded onto our Platform by Validator’s as part of their review of third party databases during the validation process;
  • Creators will need to complete a KYC (Know Your Client) form and will be required to provide us with their legal name, address, email, phone number, government-issued identification, and proof of address.

We use Cookies, Hotjar and Google Analytics to collect Website usage information, which is either not linked to your personal information, pseudonymized or aggregated into statistical reports which allows us to optimize Website and Platform content and user experience. We may also collect and use anonymized data for statistical purposes in order to improve the Website and Platform.

We may use your personal information for the following purposes:

  • To provide you with access to and use of our Website and Platform;
  • To complete transactions and process payment (via our payment processors; Crypto.com and Utrust)
  • To provide you with support and handle enquiries;
  • To improve the quality and functionality of the Website and Platform;
  • To communicate with you about our services, including updates or newsletters;
  • To conduct surveys and market research and to generate statistical data;
  • To ensure that our Website and Platform remain functioning and secure;
  • To investigate, prevent or act on any illegal activities or violations of our Terms of Use and otherwise defend our rights;
  • To obtain funding from investors and lenders (e.g., in case of receivable financing); and
  • To comply with any applicable law and assist law enforcement agencies as required.

We may disclose your personal information to the following parties:

  • Individuals or organizations who are our advisers or consultants;
  • Our payment processors for the purposes of completing transactions with respect to your use of the services on our Platform:
  • The following analytics service providers:
  • Acuant (https://www.acuant.com/general...) for our “know-your-client” identification verification process;
  • Postmark (https://wildbit.com/privacy-policy) for our email server;
  • Other service providers, including individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our systems, procedures and infrastructure including testing or upgrading our computer systems, providing hosting or email services;
  • Investors and lenders including in the event of a change in ownership of the grant of a security interest over client receivables; and
  • Administrative and judiciary authorities to which we are required by law or an order to provide this information or before which we would assert our legal rights.

Validator’s will have access to Creator’s personal information for the purposes of validating the Creator’s work (i.e. identifying residency for copyright purposes, name to verify authorship with metadata). The information sharing process is outlined in detail within the Full Privacy Policy.

You have the following choices:

  • We will request your opt-in for the use of cookies and similar tracking technologies on our Website and Platform. You may opt-out or disable cookies and other tracking technologies thereafter through the settings in your browser.
  • You may opt-out of the use or sharing of your personal information by contacting us at the email below.
  • You may opt-out of interest-based advertising, Hotjar’s tracking cookies, and Google Analytics’ tracking cookies at the links provided within this Policy.
  • You can unsubscribe from our newsletter and/or marketing emails by contacting us at the email address below or by clicking on the unsubscribe link in the emails.

If you are in the European Economic Area and your personal data is being processed by us, you have the following rights:

  • The right to correct any mistake in one’s personal data;
  • The right to access one’s personal data;
  • The right to object to the processing of personal data based on our legitimate interests, in the absence of compelling grounds for continuing such processing (including the right to object to processing for direct marketing purposes);
  • The right to withdraw one’s consent to the processing of personal data when consent is the sole legal basis of such processing, without affecting the lawfulness of processing based on consent before its withdrawal;
  • The right to restrict processing of personal data in limited circumstances;
  • The right to data portability of personal data in limited circumstances;
  • The right to erasure in limited circumstances;
  • The right to lodge a complaint with a competent supervisory authority in Europe.

Contact Us:

For more information our Policy, our privacy practices, or to obtain access to or correction of your personal information or exercise any of your rights, please contact us at [email protected].

FULL VERSION OF PRIVACY POLICY

TYPES OF PERSONAL INFORMATION AND PURPOSES OF COLLECTION

Personal information means any information about an identifiable individual, which means any information that relates to you and identifies you personally, either alone or in combination with other information. UREEQA may collect and use various types of personal information, as described below.

  • Information that You Provide to Us: For the purposes of using our platform, Creators and Validators are required to go through a “know-your-client” process via Acuant.com. Acuant will collect your legal name, date of birth, address, phone number and email address; in addition to an image of your identification (selected by you from a drop down), an image of a utility bill for providing proof of address and also a selfie made at the time of completing the form. UREEQA will have access to the information you provide to Acuant. In order to register for an account and use our Platform, Creators and Validators who have completed the Acuant KYC process will need to provide us with your legal name and email address.
  • We may occasionally request from you and you may otherwise voluntarily provide us with information that personally identifies you (including, but not limited to, user support, feedback, surveys and forums).

We may receive personal information about you from a broad range of activities through our Platform, including, but not limited to, your inputs to the Platform and general correspondence with us. As part of the validation process, Validator’s will search third party databases (such as a Creator’s website, YouTube channel, or other third party databases) in order to determine whether the Creator’s creative work is original or not. The Validator will report its findings on our Platform. Such findings should primarily contain information associated with the creative work, but may include personal information of Creators, related to authorship, ownership and originality.

  • Payment and Transaction Information: The use of our Platform requires payment. When you pay for our services on the Platform, we may collect personal information, such as your name, email address, mailing address, and payment information.

If you pay via fiat currency, we will collect your credit card information through our payment processor and do not store it on our website or platform,

If you pay via crypto currency, we use Utrust (https://utrust.com/privacy-policy/) and crypto.com (https://crypto.com/privacy/global) and no personal information will be collected.

  • Automatically Collected Information: We collect and use certain information and data regarding your access and use of our Website and Platform. When you visit our Website or Platform via a web browser, our servers record the information that your browser automatically sends whenever visiting or using a website, including your web request, the Internet Protocol (“IP”) address and browser configuration of your device, the date and time of your request, the uniform resource locator of the referring and/or exiting websites.
  • Cookies: We use cookies to collect usage information when you visit our Website and Platform, to improve functionality, and to serve advertisements to users. Cookies are small text files placed on your hard drive that assist us in providing a more customized Website/Platform experience. Cookies help us to enhance functionality and navigation for users, to count users and to recognize users, and to personalize the services and improve your experience.

Strictly Necessary Cookies. We use cookies that are strictly necessary to operate our Website and Platform without your specific consent, including:

  • user‑input cookies (session-id) such as first‑party cookies to keep track of the user's input when filling online forms, shopping carts, etc., for the duration of a session or persistent cookies limited to a few hours in some cases;
  • authentication cookies, to identify the user once he has logged in, for the duration of a session;
  • user‑centric security cookies, used to detect authentication abuses, for a limited persistent duration;
  • multimedia content player cookies, used to store technical data to play back video or audio content, for the duration of a session;
  • load‑balancing cookies, for the duration of session;
  • user‑interface customisation cookies such as language or font preferences, for the duration of a session (or slightly longer);
  • third‑party social plug‑in content‑sharing cookies, for logged‑in members of a social network.

Performance Cookies. We use performance cookies enabling us to tell how users use our Website and Platform, such as the Google Analytics Cookies here and Hotjar Cookies here.

Disabling Cookies. You may disable cookies using the Cookies control panel. If you wish to disable specific cookies, please refer to your browser help menu to learn how to disable cookies. Please note that if you disable specific cookies, you may be unable to access some customized features on our Website or Platform, however disabling cookies (other than those strictly necessary to operate our Website) will not prevent you from transacting with us.

  • Hotjar: We use a technology service called Hotjar on our Website and Platform to analyze user browsing patterns to enable us to understand our users’ experience and improve our Website and Platform. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (such as technical data (including Internet Protocol address in anonymized form), geographic location (country), and language preference). This information is stored in a pseudonymized user profile. We will not use this information to identify individual users or to match it with further data on an individual user.
  • Google Analytics: Our Website and Platform use Google Analytics. Google Analytics allows us to analyze and enhance user experience by better understanding how you interact with our Website and Platform. For more information on how Google Analytics collects and processes information, as well as how you can control the information sent to Google, please review Google’s site “How Google uses data when you use our partners’ sites or apps” located at google.com/policies/privacy/partners/

Google Analytics also uses cookies to collect standard internet log information and visitor behaviour information in an anonymous form. The anonymous information generated by Google Analytics cookies about your use of our website (including your IP address) is transmitted to Google and compiled into aggregated statistical reports that are used by UREEQA to optimize Website and Platform content. You may control your advertising preferences or opt-out of certain Google advertising products (i.e. the Google Analytics cookies) by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.

  • User Communications: When you send email, Telegram, Website Chat or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve the Website and Platform. This may include any ratings, comments or direct messages you post or send via our Website or Platform.

UREEQA identifies the purposes for which we collect, use and disclose your personal information. We only collect personal information for purposes that would be considered reasonable in the circumstances and only such information as is required of the purposes of providing our services or Website/Platform. We use only fair and lawful methods to collect personal information.

We collect and use your personal information only for the following purposes or purposes compatible therewith and (to the extent the GDPR applies) pursuant to the following legal bases:

  • to provide you with access to and use of our Website and Platform, it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that it is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (or, in case the contracting party is a company, that it is necessary for the purposes of the legitimate interests pursued by us in entering into and/or performing such contract);
  • to complete transactions and process payment (via our payment processors Crypto.com and Utrust), it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that it is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (or, in case the contracting party is a company, that it is necessary for the purposes of the legitimate interests pursued by us in entering into and/or performing such contract);
  • to provide you with support and handle enquiries, it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is (depending on the nature of the support or enquiry) that it is necessary for the performance of a contract to which the data subject is party (or, in case the contracting party is a company, that it is necessary for the purposes of the legitimate interests pursued by us in entering into and/or performing such contract) or that it is necessary for the purposes of the legitimate interests pursued by us in improving our services;
  • to improve the quality and functionality of the Website and Platform, or for statistical purposes, it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that it is necessary for the purposes of the legitimate interests pursued by us in improving our services;
  • to communicate with you about our services, including updates or newsletters, it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that we have obtained your consent or, in case of marketing of services similar to those purchased by you or in case of non-electronic marketing, that it is necessary for the purposes of the legitimate interests pursued by us in marketing our services;
  • to conduct surveys and market research and to generate statistical data, it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that it is necessary for the purposes of the legitimate interests pursued by us of gaining insight on our market;
  • to ensure that our Website and Platform remain functioning and secure, it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that it is necessary for the purposes of the legitimate interests pursued by us in ensuring our services are functional;
  • to investigate, prevent or act on any illegal activities or violations of our Terms of Use and otherwise defend our rights, it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that it is necessary for the purposes of the legitimate interests pursued by us of asserting our legal rights;
  • to obtain funding from investors and lenders (e.g., in case of receivable financing), it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that it is necessary for the purposes of the legitimate interests pursued by us of funding our business; and
  • to comply will any applicable law and assist law enforcement agencies as required, it being noted that the legal basis under the GDPR (to the extent that it applies) for this purpose is that it is necessary for compliance with a legal obligation to which we are subject or that it is necessary for the purposes of the legitimate interests pursued by law enforcement agencies.

We may also use statistical or aggregated information about the Website and Platform’s use and share, publish, post, disseminate, transmit or otherwise communicate or make available such information, to business partners, affiliates and other third parties, at our sole discretion, for the above purposes or purposes compatible therewith.

Our use of personal information is limited to the purposes described in this Policy. UREEQA does not otherwise sell, trade, barter, exchange or disclose for consideration any personal information we have obtained.

SHARING OF YOUR INFORMATION

UREEQA may disclose your personal information to the following parties:

  • Individuals or organizations who are our advisers or consultants;
  • Our payment processors for the purposes of completing transactions with respect to your use of the services on our Platform:
  • The following analytics service providers:
  • Acuant (https://www.acuant.com/general...) for our “know-your-client” identification verification process;
  • Postmark (https://wildbit.com/privacy-policy) for our email server;
  • Other service providers, including individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our systems, procedures and infrastructure including testing or upgrading our computer systems, providing hosting or email services;
  • Investors and lenders including in the event of a change in ownership of the grant of a security interest over client receivables; and
  • Administrative and judiciary authorities to which we are required by law or an order to provide this information or before which we would assert our legal rights.

SHARING OF INFORMATION WITHIN OUR PLATFORM

Validator’s will have access to Creator’s personal information for the purposes of validating the Creator’s work (i.e. identifying residency for copyright purposes, name to verify authorship with metadata). The information sharing process will works as follows:

  • Validators will login to the Platform;
  • Validators click on the creation they wish to validate;
  • When Validator’s open the creation to being validation, they will see: (1) authorship and ownership details provided by the Creator and provided by UREEQA (i.e. residency information at the time of creation, names of authors, metadata associated with the file); and (2) creation details (including the file itself, supporting files, URL links to where the work is posted);
  • This information will be available and presented to Validator’s on UREEQA’s Platform, in a location where only the Validators associated with that creation will have access;
  • After or during review of the creation, Validators can message Creators and other Validators to request more information.

CONSENT

As required by applicable law, UREEQA will obtain your consent – or, for GDPR purposes, inform you – before, or when, we collect, use, transfer and/or disclose your personal information. By visiting our Website, registering for an account and using our Platform, or otherwise interacting with us, you consent to – or, for GDPR purposes, you acknowledge you are informed of – the collection, use, transfer and disclosure of your personal information by UREEQA in accordance with the terms of and for the purposes set out in this Policy, as they may be amended from time to time. Otherwise, UREEQA will obtain your express consent (by verbal, written or electronic agreement) – or, for GDPR purposes, inform you – before we collect, use or disclose your personal information for any new and additional purpose.

At any time, subject to contractual and legal restrictions, you may withdraw your consent to our use of your personal information.

It should be noted that in certain circumstances, our Platform can only be offered if you provide us with personal information. If you choose not to provide us with the required personal information, we will not be able to provide you with access or use of our Platform (i.e. personal information is required to register for an account). We will inform you of the consequences of the withdrawal of consent, if applicable.

Under certain exceptional circumstances, UREEQA may have a legal duty or right to collect, use or disclose your personal information without your knowledge or consent. In accordance with applicable laws, we may disclose your personal information without your consent – where your information is required to be disclosed:

  • for the purposes of completing a business transaction, such as a sale of our business, merger, amalgamation or similar transaction;
  • for law enforcement purposes;
  • for the purpose of complying with a legal requirement;
  • where information is public as defined by applicable law;
  • where it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or
  • where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain.

UREEQA will also request your specific consent when required by the GDPR (e.g., for storing cookies that are not strictly necessary for the operation of our Website, or when using electronic communications services for the purposes of sending direct marketing communications to end-users who did not purchased similar services). Such consent can be withdrawn at any time.

STORAGE, CROSS-BORDER TRANSFER AND SAFEGUARDING YOUR PERSONAL INFORMATION

Information that we collect is stored on servers managed Amazon Web Services (hosted in Canada), using standard physical, technical and organizational security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification, or disclosure.

We further protect personal information by restricting access to it to those employees that require access to the information in order to provide our Website and Platform. Confidentiality and security can never be 100% assured when information is transmitted or stored electronically.

UREEQA may transfer personal information to a service provider which is located outside of Canada where privacy laws may offer different levels of protection from those in Canada. Your personal information may also be subject to access by and disclosure to law enforcement agencies under the applicable foreign legislation.

Individuals protected by the GDPR are informed that their personal information can be transferred outside the European Economic Area to, in addition to Canada, the U.S.A. as well as other countries where such service providers are located. An adequacy decision from the European Commission pursuant to Directive 95/46/EC avails under article 45 of the EU GDPR in case of transfers to private-sector organisations in Canada governed by the Personal Information Protection and Electronic Documents Act as well as organisations in Andorra, Argentina, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay, it being noted that the United Kingdom is expected to join this list shortly. In other cases, unless one of the exemptions of article 49 of the GDPR avails, appropriate safeguards are in place in accordance with article 46 of the GDPR – namely standard contractual clauses as approved by the European Commission. A copy of any standard contractual clauses in place can be requested.

RETENTION OF YOUR INFORMATION

We keep your personal information indefinitely using it to fulfill the purpose for which it was collected and to meet our legal and contractual obligations. Your personal information is kept indefinitely until you notify us in writing that you wish your data to be removed. The data will be removed from our production website and platform immediately upon your notification, however copies will exist in automatic backups performed by our hosting provider AWS for a period no greater than 60 days. The data is maintained beyond the end of your relationship with us but it allow us to have sufficient information to respond to any issues that may arise at a later date and to defend any court action or prosecution that could be commenced against us or that we may want to commence (taking into account the applicable limitation period).

We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to conclude that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. We will take due care when destroying personal information so as to prevent unauthorized access to the information.

MANAGING YOUR INFORMATION

  • If you demonstrate any inaccuracy or incompleteness of your personal information, we will amend the information as required. If appropriate, we will send the amended information to third party service providers to whom the information has been disclosed.
  • UREEQA permits the reasonable right of access to your personal information. Upon written request and authentication of identity, we will provide you with access to your personal information under our control, subject to any legal requirements and applicable exceptions to the right of access. Where an access request is refused, we will notify you in writing and provide our rationale for refusal along with a list of next steps available to you.

Depending on your use of our Website and Platform, you may have the following choices:

  • Cookies Settings and Preferences. You may disable cookies and other tracking technologies through the Cookies control panel or the settings in your browser. While doing so may negatively affect your experience with the use of our website, it will not prevent us from transacting with you (unless the disabled cookies are strictly necessary to operate our Website).
  • Marketing e-mails. You may sign up for our mailing lists in order to receive promotional and other materials that may be of interest to you. If you no longer wish to receive marketing e-mails from us, you may choose to unsubscribe at any time by clicking on the “unsubscribe” link in our emails or by contacting our Privacy Officer at [email protected]
  • Opt-Outs. You may contact us to opt-out of the use or sharing of your personal information, including for marketing or advertising purposes, and/or the provision of your personal information to our business partners for such purposes.
  • Online behavioural advertising. You can opt-out of the use of your Personal Information for the purposes of Online Behavioural Advertising by contacting or by visiting Your Ad Choices at http://youradchoices.ca/choices.

You can opt-out of the creation of a user profile by Hotjar, Hotjar’s storing of data about your usage of our Website and Platform, and Hotjar’s use of tracking cookies on other websites here (https://www.hotjar.com/legal/policies/do-not-track/).

You may control your advertising preferences or opt-out of certain Google advertising products (i.e. the Google Analytics cookies) by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.

If you are in the European Economic Area and your personal data is processed by us in relation to the offering of goods or services to them or the monitoring of your behaviour, you are informed that you have the following rights under the GDPR, which you may exercise by contacting our Privacy Officer at [email protected]:

  • the right to correct any mistake in one’s personal data;
  • the right to access one’s personal data;
  • the right to object to the processing of personal data based on our legitimate interests, in the absence of compelling grounds for continuing such processing (including the right to object to processing for direct marketing purposes);
  • the right to withdraw one’s consent to the processing of personal data when consent is the sole legal basis of such processing, without affecting the lawfulness of processing based on consent before its withdrawal;
  • the right to restrict processing of personal data in limited circumstances;
  • the right to data portability of personal data in limited circumstances;
  • the right to erasure in limited circumstances;
  • the right to lodge a complaint with a competent supervisory authority in Europe.

LINKS TO THIRD PARTY SITES

We may provide links to, or automatically produce search results for, third-party websites or resources, or third-party information referencing or linking to third-party websites or resources. UREEQA has no control over such third-party websites and resources, and you acknowledge and agree that UREEQA is not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by our Policy, and we encourage you to read the privacy statements or other disclaimers of such other parties. UREEQA is not responsible for the privacy or security practices or the content of external websites, services or products.

Creators will have the ability to link their social media profiles to the Platform (i.e. under the Creator’s profile picture there will be social media buttons/plugins that users can click and be redirected to that Creator’s social media profile). When you access such social media plugins (i.e. Twitter, Facebook, Instagram), you will be redirected to and your data will be collected by the respective social media company. As the Platform provider, we have no direct knowledge of the content of the data transmitted or how it will be used by Twitter, Facebook or Instagram. Again, UREEQA has no control over such social media company’s website or resources and you acknowledge and agree that UREEQA is not responsible for the content or information contained therein. For more information on the privacy practices of the third-party social media sites, please review their privacy policies:

MINORS

In order to use the Platform, you must register for and maintain an active account. You must be at least 18 years of age, or the age of legal majority in your jurisdiction (if higher than 18), to obtain, maintain, and use an account. Accordingly, UREEQA does not knowingly permit persons under the age of 18 (or age of legal majority) to register for an account and use our Platform, and does not knowingly collect or solicit personal information of such individuals.

HOW TO CONTACT US

UREEQA responds in a timely manner to your questions, concerns and complaints about the privacy of your personal information and our Policy and procedures.

Please contact our Privacy Officer by emailing us at [email protected] or at:

UREEQA Inc.

55 Victoria St. N., Unit J

Kitchener, ON

N2H 5B7

Please note that if we are unable to resolve your privacy concerns, you may have the right to complain to the Office of the Privacy Commissioner of Canada or the appropriate provincial Information and Privacy Commissioner.