Privacy Policy

Last updated: 2020-08-04

This Privacy Policy discloses the privacy practices for the Coinmiles Platform (collectively, the “Platform”, including the website located at www.coinmiles.io and any mobile app of online services). Coinmiles Technology Ltd., a Canadian corporation, the provider of the Platform (referred to as “Coinmiles”, “us” or “we”), is committed to protecting your privacy online. Please read the following to learn what information we collect from you (the “User” or the “End User”) and how we use that information. If you have any questions about our privacy policy, please email us at info@coinmiles.io.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND TO ALL THE TERMS OF THIS PRIVACY POLICY AND OUR PLATFORM TERMS OF USE. IF YOU DO NOT AGREE TO THESE TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE THE PLATFORM.

Definitions

Advertiser” means a third party promoted by Coinmiles through publicities or any other marketing methods or that is offering marketing related services in connection with those methods.

Affiliate Merchant Partner” means an online merchant participating in Coinmiles Affiliate Offers Program. For example, an online offer in Coinmiles that would require you to click on a link to activate the offer would be an offer from an Affiliate Merchant Partner.

CLO Merchant Partner” means our partners participating in Coinmiles Card Linked Offers Program. For example, an offer in Coinmiles that would require you link an eligible credit card and then use that card to pay to obtain the offer would be an offer from a CLO Merchant Partner.

Merchant Partner” means either a CLO or an Affiliate Merchant Partner.

Payment Card Networks” means either MasterCard or Visa.

Platform” means all Coinmiles products and services, including without limitation any website, web-app, mobile app, widgets, and API.

Qualifying Affiliate Purchase” means an eligible purchase made at an Affiliate Merchant Partner.

Qualifying CLO Transaction” means an eligible purchase made at a CLO Merchant Partners.

Third Party Service Provider” means a third party that perform functions on behalf of Coinmiles, like sending out and distributing administrative and promotional emails.

1. Changes to Privacy Policy

If we decide to change our privacy policy, we will post those changes to this privacy statement, to our Platform and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of notice on our home page.

2. Types of Information Collected and Uses of Collected Information

We collect two types of information about our Platform Users: Personally Identifiable Information and Non-Personally Identifiable Information.

We also collect transaction data from Qualifying CLO Transactions and Qualifying Affiliate Purchases in order to manage the Program, which uses are governed by this Section 2.

Personally Identifiable Information.

Personally Identifiable Information is information that identifies a specific End User. When you engage in certain activities on the Platform, such as creating an account, ordering a product or service from us or our Merchant Partners, interacting with certain Third Party Service Providers, submitting content and/or posting content in discussion forums, entering a contest or sweepstakes sponsored by us, one of our Merchant Partners or Advertisers, filling out a survey, posting a review, sending us or our partners feedback, requesting information about our services, submitting an affiliate agreement, applying for a job, posting a video or signing up for special offers from third parties through the Platform (collectively, “Identification Activities”), we may ask you to provide certain information about yourself. It is optional for you to engage in an Identification Activity. If you elect to engage in an Identification Activity, however, we may ask you to provide us with certain personal information about yourself, such as your first and last name, mailing address (including postal code or zip code), email address, telephone number and date of birth. When you order products or services, we may also ask you to provide us with your credit card number, expiration date and authentication codes or related information (see Section 2 - CLO Transaction Data). Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity.

We use Personally Identifiable Information to provide products and services to you, administer sweepstakes and contests, enhance the operation of the Platform, improve our marketing and promotional efforts, analyze Platform use, improve our product and service offerings, and to tailor your experience with third parties. For example, if you send our customer service an email we may use your comments and feedback to tell others about our services, and may post your comment in our marketing materials or on our Platform. Your comments may contain personal information such as your name, we will obtain consent from you to post your name along with your comment prior to posting your comment for public view. In addition, if you use our Platform to send information or a product to another person, we may store your personal information. We may also use Personally Identifiable Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including our Platform Terms of Use and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities.

Non-Personally Identifiable Information.

Non-Personally Identifiable Information is information that does not identify a specific End User. This type of information may include things like the Uniform Resource Locator (“URL”) of the Platform you visited before coming to our Platform, the URL of the Platform you visit after leaving our Platform, the type of browser you are using and your Internet Protocol(“IP”) address. We, and/or our authorized Third Party Service Providers and Advertisers, may automatically collect this information when you visit our Platform through the use of electronic tools like cookies and web beacons or pixel tags.

We use Non-Personally Identifiable Information to troubleshoot, administer the Platform, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third Party Service Providers and Advertisers to measure the overall effectiveness of our online advertising, content, and programming.

CLO Transaction Data. Information related to a Qualifying CLO Transactions, including amount, time of transaction, location, token attributed to a card, last 4 digits of a card number, status of a transaction, and other similar information.

Coinmiles uses Fidel Ltd. (“Fidel”), a credit cards data API aggregator, as a Third Party Service Provider and in order to obtain and manage CLO Transaction Data on its Platform.

Notwithstanding anything to the contrary in the Terms and Conditions or this Privacy Policy, Coinmiles and Fidel will use transaction information solely as follows:

• Use CLO Transaction Data to confirm a Qualifying CLO Transactions or return to match transactions to confirm whether you qualify for an offer;

• Share CLO Transaction Data with the CLO Merchant Partners where a Qualifying CLO Transaction occurred as needed for the CLO Merchant Partners to confirm that a specific transaction occurred or points should be awarded; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;

• Provide CLO Merchant Partners or Fidel aggregated and anonymized information relating specifically to registered card activity (in the case of participating merchants, solely and specifically registered card activity at their respective locations) solely to allow CLO Merchant Partners or Fidel to assess the results of their campaign;

• Create a record of the CLO Transaction Data and Qualifying CLO Transactions and thereafter maintain and use data in connection with operating the Program;

• Conduct analysis for the improvement and optimization of the Program; and

• Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a CLO Merchant Partner.

You authorize the sharing, exchange and use of transaction data described above and here in by and among us, Fidel, applicable Payment Card Networks and applicable CLO Merchant Partners.

3. Release of Personally Identifiable Information

We will not share, sell, rent, or trade your Personally Identifiable Information with other parties except as provided herein:

We may share your information with Merchant Partners for promotional purposes.

From time to time, we may provide offers from particular Merchant Partners, as part of the offer, require information on Coinmiles customers who purchased the offer in order to aid redemption. In those cases, we may share some of your Personally Identifiable Information with Merchant Partners. However, we will only share Personally Identifiable Information with a Merchant Partners if you engage in an Identification Activity, with your express consent, and then only to the Merchant Partners involved in that Identification Activity. While we contractually require Merchant Partners to respect the applicable local laws, including anti-spam and privacy-related legislations, and to solely communicate with you for the purposes of the specific promotion, we do not have any responsibility for the actions of the Merchant Partners and the actions of the Merchant Partners are not in our control. We specifically disclaim any responsibility or liability for the actions of such Merchant Partners.

We may share your information with Third Party Service Providers.

We provide services and products through third parties. These Third Party Service Providers perform functions on our behalf, like sending out and distributing our administrative and promotional emails. We may share your Personally Identifiable Information with such Third Party Service Providers to fulfill orders, deliver packages, send postal or email, administer contests or sweepstakes, remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit card payments, operate the Platform, troubleshoot, and provide customer service. We may also collect personal information from individuals and companies (“Affiliates”) with whom we have business relationships and may share your information with Third Party Service Providers to accomplish our administrative tasks. For example, when you order a service, we release your credit card information to the card-issuing bank to confirm payment for the service and, if applicable, release your address to the delivery service to deliver the service. Likewise, we may release an Affiliate’s information to our bank to send out a payment. We encourage Merchant Partners and Third Party Service Providers to adopt and post privacy policies. However, the use of your Personally Identifiable Information by such parties is governed by the privacy policies of such parties and is not subject to our control. For clarity, we will never share any CLO Transaction Data with Third Party Service Providers other than as provided in Section 2 – CLO Transaction Data.

We may share your payment card transaction information for transaction monitoring purposes. If you choose to register a payment card in connection with transaction monitoring, you authorize Coinmiles to share your payment card information with Mastercard, Visa or Fidel so they know you enrolled. You authorize Mastercard, Visa or Fidel to monitor transactions on your registered card(s) to identify qualifying purchases, and for Mastercard, Visa and Fidel to share such transaction details with Coinmiles to enable your card-linked offer(s) to be implemented, and to target other offers that may be of interest to you. You may opt-out of transaction monitoring on the payment card(s) you have registered by unlinking your credit card information through our Platform by navigating to your Profile section > My Cards and by pressing on the red "X" button next to the credit card you want to unlink.

We may share your information in a business transfer. As with any other business, we could merge with, or be acquired by another company. If this occurs, the successor company would acquire the information we maintain, including Personally Identifiable Information. However, Personally Identifiable Information would remain subject to this Privacy Policy.

We may share your information for our protection and the protection of others. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Platform; enforce or apply this Privacy Policy, our Platform Terms of Use or other agreements; or protect the rights, property or safety of the Platform, its users or others.

4. Release of Non-Personally Identifiable Information

We may disclose or share Non-Personally Identifiable Information with Merchant Partners, Affiliates and Advertisers. For example, we may share aggregated demographic information which does not include any Personally Identifiable Information.

We may remarket your information. Remarketing is a way for us to connect with users, based upon your past interactions with the Coinmiles Platform. Third-party marketing vendors may be hired by Coinmiles to perform remarketing services. As a result, third-party vendors, including Google, may show Coinmiles ads on sites on the internet. Third-party vendors, including Google, use cookies to serve ads based on a user’s prior visits to Coinmiles’s Platform. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page at http://www.google.com/privacy_ads.html. This information is used only for remarketing purposes and will not be used by them for any other purpose. We will not remarket your CLO Transaction Data in any circumstances.

We may use Third Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information. We may also publish this information for promotional purposes or as a representative audience for Advertisers. Please note that this is not Personally Identifiable Information, only general summaries of the activities of our Users. Such data is collected on our behalf, and is owned and used by us.

5. Updating and Correcting Information

We believe that you should have the ability to access and edit the Personally Identifiable Information you provide us. You may change any of your Personally Identifiable Information by logging into your account on the Platform and accessing the "my account" section, sending us an email at info@coinmiles.io or writing to us at 3 Place Ville-Marie, Suite 400, Montreal, Québec H3B 2E3. Please indicate your name, address and email address, and what information you would like to update when you contact us.

If you choose to enroll an eligible credit card, your credit card is shared with the respective Payment Card Network for the purposes of monitoring for Qualified Transactions. It is never seen or stored by Coinmiles. You may delete your credit card information at any time by going to the "my account" section of your profile, clicking on “My Cards” and then hitting the red “X” button next to the corresponding card you want deleted.

We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on the Platform. In addition, it may be impossible for us to completely delete all of your information because we periodically backup information.

6. User Choices on Collection and Use of Information

As discussed above, you can always choose not to provide information, although it may be required to engage in a certain activity on the Platform. As a condition of use of our services, we will send you Administrative Emails (as defined below) and, if you opt-in, we will send you promotional emails or notifications from time to time.

You cannot opt-out of Administrative Emails. “Administrative Emails” relate to a User’s activity on the Platform, and include emails regarding a particular user’s account, requests or inquiries, and purchases of products and services.

In contrast to Administrative Emails, however, you do have a choice with respect to Promotional Emails. “Promotional Emails” advertise our products and services, including exclusive offers and other offers, and/or the products and services of our Advertisers. If you want to receive Promotional Emails from us, you have to opt-in. You may always elect to opt-out of receiving Promotional Emails at any time by hitting the “unsubscribe” button at the bottom of any of our e-mails, by e-mailing us at support@coinmiles.io or by writing to us at 400-3 Place Ville-Marie, Montréal, QC, H3B 2E3.

7. Security of Information

We take security seriously and take numerous precautions to protect the security of Personally Identifiable Information against accidental or unlawful destruction, loss, change or damage. You can access your Personally Identifiable Information on our Platform through a password and your email address. This password is encrypted. We recommend that you do not share your password with anyone. In addition, your Personally Identifiable Information resides on a secure server that only selected personnel and contractors have access to. We, and our Third Party Service Provider Fidel, encrypt certain sensitive information (such as credit card information) using Secure Socket Layer (SSL) technology to ensure that your Personally Identifiable Information is safe as it is transmitted to us. We also use tokenization as a mechanism to protect your sensitive credit card information and Coinmiles never view, access and/or store your full credit card information. Fidel’s systems are certified as Level 1 PCI compliant and all data retention and credit card information is maintained in accordance with the PCI standards as determined by the PCI Security Standards Council.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and contractually require third parties to do the same, we cannot guarantee the security of any information transmitted to or from the Platform, and are not responsible for the actions of any third parties that may receive any such information.

8. Data Tracking

Cookies. To facilitate and customize your experience with the Platform, we may store cookies on your computer. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes which contains information about that user. We use cookies to save you time while using the Platform, remind us who you are, attribute transactions or allow or Third Party Service Providers to attribute transactions and track and target user interests in order to provide a customized experience. Cookies also allow us to collect Non-Personally Identifiable Information from you, like which pages you visited and what links you clicked on and what items you bought. Use of this information helps us to create a more user-friendly experience for all visitors and may be required to perform certain services. In addition, we may use Third Party Service Providers to display advertisements on our Platform. As part of their service, they may place separate cookies on your computer. We have no access to or control over these cookies. This Privacy Policy covers the use of cookies by our Platform only and does not cover the use of cookies by any Advertiser. Most browsers automatically accept cookies, but you may be able to modify your browser settings to decline cookies. Please note that if you decline or delete these cookies, some parts of the Platform may not work properly.

Other Tracking Devices. We may use other industry standard technologies like pixel tags and web beacons to track your use of our Platform pages and promotions, or we may allow our Third Party Service Providers, excluding Fidel, to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Platform, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on our Platform, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by Advertisers for the same purposes.

9. Privacy Policies of Third Party Platforms

This Privacy Policy only addresses the use and disclosure of information we collect from you from Coinmiles Platform. Other Platforms that may be accessible through this Platform have their own privacy policies and data collection, use and disclosure practices. If you link to any such Platform, we urge you to review the Platform’s privacy policy. We are not responsible for the policies or practices of third parties.

10. Miscellaneous Privacy Issues

Children. Minors under the age of 18 may not use the Platform. We do not knowingly collect personal information from anyone under the age of 18, and no part of the Platform is designed to attract anyone under the age of 18. Coinmiles does not sell products for purchase by children. In certain instances, we may promote children’s products for purchase by adults.

Public Areas. We may provide areas on our Platform where you can publicly post information about yourself, can communicate with others such as discussion boards or blogs, or can review our offers and submit media content. This information may be accessible by other consumers and companies and may appear on other Platforms or web searches, and therefore this information could be read, collected, and used by others. For example, if you post your email address along with a public restaurant review, you may receive unsolicited messages. We have no control over who reads your postings or what other users may do with the information you voluntarily post, so please use caution when posting any personal information. We do obtain consent from our users to post their name along with their reviews.

Facebook Connect. Our Platform allows users to access Facebook Connect to log in, interact with friends and to share on Facebook through Wall and friends’ News Feeds. If you are logged into Coinmiles and Facebook, when you click on "Connect with Facebook" your profiles will merge if the email addresses match. If you are already logged into Coinmiles but not logged into Facebook, when you click on "Connect with Facebook" you will be prompted to enter your Facebook credentials or to "Sign up for Facebook." By proceeding you are allowing the Coinmiles Site to access your information and you are agreeing to the Facebook Terms of Use in your use of Coinmiles Sites.

Conversely, if you are not currently registered as a Coinmiles user and you click on "Sign in Using Facebook," you will first be asked to enter your Facebook credentials and then be given the option to register and join Coinmiles. You have the option to disable Facebook Connect at any time by logging into "My Profile" and clicking on "My Facebook Profile." Further, you can edit privacy settings for the reviews that appear on Facebook or disconnect this service by visiting the Facebook Application Settings page.

11. Contacting Us

Whether you’re a new or loyal customer, a partner or a potential partner, media member or job seeker we’d like to stay connected and want to hear from you!


Corporate Address
Coinmiles
3 Place Ville-Marie, Suite 400
Montréal, Québec
H3B 2E3


For Customers
Customer Service Inquiries | info@coinmiles.io