Privacy Policy


Privacy Policy and Privacy Statement

STATEMENT:
We at Tuio Payments Inc. (“We”, “Tuio”, “our” or “us”) are firmly committed to privacy and transparency and recognize that the businesses and end users with whom We do business with value their privacy as well. However, in order to provide our services, the collection and certain use of personal information and information is often necessary, and frankly, desirable, and because of that We take great care to collect only the information necessary for the provision of our services. The following discloses our information gathering and disclosure practices for use of our services by customers and end users, including all visitors, browsers, vendors, business users, and/or advertisers, (collectively “you” or “your” or the “Users”). Please be advised that the policy contained herein applies to all Tuio websites, apps, and platforms, made available by Tuio (collectively the “Services”). By utilizing and accessing the Services you consent to the collection, storage, and use of personal information described herein. You may withdraw your consent to the processing/use of personal information at any time. However, withdrawing such consent may result in your inability to continue using the Services. Please read this Privacy Policy (this “Privacy Policy”), our Web Application’s Terms of Service and the Subscription Form carefully, as (i) they all constitute together the same agreement between you and us, and (ii) you are agreeing to be bound by these three documents by using our Services (as further defined under our Web Application’s Terms of Service).
If you do not agree with any part of this Privacy Policy, you must not use the Services. Your continued use of the Services, which includes, but is not limited to, visiting Tuio’s website, using the Services, and/or downloading and installing Tuio’s mobile application, will constitute your acceptance of this Privacy Policy. Any new features or tools that are added to the current Services shall also be subject to this Privacy Policy. You can review the most recent version of this Privacy Policy at any time on Tuio’s website. We reserve the right to update, change, or replace any part of this Privacy Policy, at any time, by posting updates and/or changes. It is your responsibility to check this Privacy Policy periodically for changes. Your continued use of the Service following the posting of any changes constitutes acceptance of those changes.

PURPOSE OF COLLECTION:
In general, Tuio’s processing of your personal information may include using, storing, recording, transferring, sharing, anonymizing and destroying personal information as necessary for the provision of Services, or as otherwise required by applicable law. Specifically, personal information collected through our Services may be utilized for several purposes, including, but not limited to:
• to generate analytics for the improvement of the Services;
• to provide Services to you where We have entered into a contract with you;
• to do so in accordance with the consent you have provide Tuio;
• to market and promote the Services;
• to maintain a commercial relationship with you and to communicate with you (which may include advertising and promotions);
• to identify your needs and/or preferences;
• to meet legal and regulatory requirements;
• administer the Services to diagnose and resolve technical problems;
• send you notifications and communications to the email address that you have provided in relation to the Services;
• generate, create, and review reports and other data about the Users on the Services and to conduct research on the Services and any usage or patterns;
• to administer, maintain, manage, and improve the Services and our business operations; and
• as otherwise required by law.

ACCOUNT CREATION:
Full use of the Service requires that you create an account by providing Tuio with certain information, which may include your full name, a valid email address, company name, mobile number, a password, other personal information, and any information that you provide to us voluntarily. You are responsible for all activity that occurs in association with your account. If you are creating an account as a business User on behalf of your employer or any third-party company or entity, you represent and warrant that you have the authority to act on such party’s behalf and to provide all applicable information to Tuio. Tuio is not liable for any loss or damages caused by your failure to maintain the confidentiality of your account credentials. Please contact us if you discover or suspect any security breach related to the Service or your Account

INFORMATION PRACTICES:
• What Information is Collected
We may collect a selection of personal information that is relevant for the provision of the Services and/or that is otherwise permitted by applicable law. Such information may include an individual’s name, address, phone number, email address, login information, bank account information or payment information (which is discussed further below), and any other information that is voluntarily provided to Tuio.
• Information Collected Automatically
Whenever you use our Service, We collect certain types of information automatically, such as your IP address, referring URL, operating system, cookie information, information about your operating environment, and Internet Service Provider. We may also gather information regarding the date and time of your visit and/or access to the Service and your activity on the Service.
• Mobile Information Collection
When you download or access the Services via a mobile device (i.e., through an application), We may receive information about your mobile device, including various unique identifiers associated with your device, hardware type, and the version of your operating system. We may use this information to provide you with personalized advertising and other content.
We also use mobile analytics software to allow us to better understand the functionality of our applications on your mobile device. This software may record information such as how often you use an application, the events that occur within an application, aggregated usage, performance data, and where an application was downloaded from.
• Business Information
For certain Users, Tuio collects “Business Information.” The collection of Business information is necessary for Tuio to provide the Services to its business Users, and to enable Tuio to respond to requests for Services. For Users of the Services that utilize the Services in the capacity as employees or on a company’s or other entity’s behalf, Business Information is collected about the business in a professional capacity (rather than information about you individually). For these purposes, “Business Information” is defined as any information that identifies or may identify a company or an individual contact at a company or that allows others to contact a company or an individual contact at a company. When any business User utilizes the Services, they may be asked to submit information such as e-mail address, company name, address, and/or phone number.
• Location Information
We collect information about your location when you use our Services.
Your location can be determined with varying degrees of accuracy by:
o GPS
o IP address
o Sensor data from your device
o Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices
The types of location data We collect depend in part on your device. For example, you may be able to turn your device’s location on or off using the device’s settings.
• Payment Information
For certain portions of our Services, and in certain cases, payment information will be required or provided to Tuio. Tuio does not store or directly access any of your payment information or account information. Instead, Tuio utilizes third party payments processors to process your payment information.
By engaging in any kind of activity or transaction on or in the Services that utilizes your financial information, you consent to our providing of such financial information to our third party payment processors, and to such other third parties as We determine necessary to support and process your activities and transactions.
As stated above, Tuio does not directly store your payment information, and Tuio does not have direct responsibility or control over such information. Tuio’s agreements with the third parties service provides that receive your payment information require them to keep the information secure and confidential.
Tuio cannot and does not guarantee that the transmission of your payment information will always be secured against access from unauthorized third parties. There is always the chance that unauthorized third parties will be able to defeat the security measures taken by Tuio or the third parties We have contracted with. Tuio makes no representations or warranties and assumes no liability or responsibility for improper access to or disclosure of your payment information due to unauthorized third-party access, errors in transmission, or other causes beyond Tuio’s control.
• Aggregated and De-Identified Information
Tuio may aggregated and de-identify collected information, including personal information. Tuio may use, process, or disclose any such aggregated and/or de-identified information in accordance with applicable law, which does not generally restrict or prohibit the use of aggregated and/or de-identified information. Accordingly, no such use is prohibited by this Privacy Policy, and all such anonymized and de-identified information may be used and disclosed to third parties without limitation.
• How Your Information is Shared
We do not rent, trade, or share personal information with third parties, except to provide Services which you requested when We have your permission, as disclosed in this Privacy Policy, or under the following circumstances:
o We may share your personal information with third parties for our payment processing functions, when such parties are prohibited from using your personal information for any non-authorized purposes. We may share your personal information with third-party consultants, developers, and authorized service provides, including cybersecurity partners, infrastructure partners, fraud analytics companies, analytics service providers, customer support service providers, payment providers, and similar partners. We may share aggregated personal information with third-party search engines for the purpose of conducting analytics. Please note that We choose these third parties with great care. In addition, third parties will be contractually bound to commercially reasonable security standards and guidelines regarding the handling of information;
o We may share your personal information with affiliates;
o We may share your personal information if required by law and if We believe that the disclosure is required or necessary to protect our rights and/or comply with a judicial processing or legal process served on our Service;
o We may share personal information if We believe that it is required in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, a potential threat to the physical safety of a third party, or as otherwise required by law;
o We may share your personal information in connection with any company transaction, such as a merger, sale of all or a substantial portion of our assets or shares (including a change of control or acquisition of all or a portion of our business), reorganization, or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted in this Privacy Policy by the entity acquiring the information;
o We may share personal information with our legal, financial, and other professional advisors; or
o We may share personal information with third parties upon receiving your consent as required by law.
Except as provided above, We will not share any of your personal information with any third party without your permission.

POLICY REGARDING CHILDREN:
• Not Directed at Minors
Tuio’s Services are not designed for users under the age of 18. As such, the Services are not directed at minors under the age of 18 nor do We knowingly collect or maintain information from children under the age of 18 in the Services.
• A Note to Parents & Children
If you are a child under 16 in the European Union or UK or a child under 13 in the United States, you may access the Service only to the extent that consent is given or authorized by the holder of parental responsibly over you. Please speak with your parent or guardian about this Privacy Policy so you can better understand how We use your personal information. We make reasonable efforts to verify that consent is given or authorized by the holder of parental responsibility over you, and, if We learn or have reason to suspect that We have collected personal information from you without parental consent, We will promptly delete it.
• Parental Access
A parent or legal guardian who has already given Tuio or any other User permission to collect, use, and share their minor child’s personal information can, at any time, do the following: (1) review, correct, or delete the minor child’s personal information that is stored by Tuio; and/or (2) discontinue further collection, use, or sharing of the minor child’s personal information by Tuio. To do so, please contact your child’s school who you provided consent to.

DO NOT TRACK SIGNALS:
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Tuio does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

LINKS TO THIRD PARTY WEBSITES:
The Service may, from time to time, contain links to and from websites owned or operated by third-party companies or service providers. If you follow a link to any of these third-party websites, please note that these services have their own privacy policies and that Tuio does not accept any responsibility or liability for those companies or their privacy practices. You should review the individual privacy policies before you submit any information to those websites or services.

COOKIES:
Cookies and other tracking mechanisms may be used to track information about your use of our Services. We may combine this information with other personal information We collect from you to track content usage and traffic. A cookie is an identifier that We (or a third party acting on our behalf) transfer to your computer’s hard drive through your web browser for record-keeping purposes We may use cookies to help compile aggregate statistics about usage of our Services. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it.

SECURITY OF PERSONAL INFORMATION:
The security of your personal information is very important to us and We take it seriously. We have implemented commercially reasonable technical and organizational measures to support in the protection against accidental or unlawful destruction, and/or unauthorized disclosure or access. Notwithstanding the foregoing, however, please be aware that no data security measures can guarantee 100% security and no method of transmission over the internet or method of electronic storage is 100 % secure. Therefore, We cannot guarantee its absolute security.

COMPLIANCE WITH LAWS:
Canadian law, at the federal and provincial level, has enacted personal information and protection legislation (collectively “Privacy Legislation”). The Privacy Legislation outlines the way personal information may be used in Canada, and Tuio shall comply with applicable Privacy Legislation. The Privacy Legislation defines personal information as anything that identifies an individual, such as, for example, their name, telephone number, age, home address, email address. You may at any time contact us regarding our collection, use, and disclosure of your personal information.

CONTACT US:
If you have any questions or concerns over this Privacy Policy or if you need further information regarding the access to your personal information, or how your personal information is used, you may contact us at:
[email protected]
1 (888) 540-0160
56 Temperance St, 7th Floor
Toronto, Ontario M5H 3V5

Last Updated June 2019.