Privacy Policy

1. Overview

Adopto Technologies is a non-custodial exchange desk: we hold neither your crypto assets nor your funds, and you have no online account with us. We collect only the information needed to verify your identity, execute your transactions and comply with the law. We do not sell or rent your personal information.

2. Terms You Need to Know

"Privacy Laws": Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, for our activities and clients in Quebec, and the Personal Information Protection and Electronic Documents Act (PIPEDA) for our clients elsewhere in Canada.

"Financial Laws": the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Quebec's Money-Services Businesses Act. They require us to verify our clients' identity, keep certain records and file certain reports.

"Personal information": any information about a natural person that allows that person to be identified, directly or indirectly.

3. Who Handles Your Information

Your information is handled by 11639064 Canada Inc., doing business as Adopto Technologies and Adopto, a federal corporation headquartered in Québec City. Adopto is registered with FINTRAC (No. M19600702) and holds a money services business licence from Revenu Québec (No. 11992).

For any question about this policy or to exercise your rights, write to our Chief Compliance Officer, who is the person in charge of the protection of personal information: info@adopto.ca, or Adopto Technologies, 2828 Laurier Boulevard, Suite 700, Québec City, Quebec G1V 0B9.

4. Why We Use Your Information

We use your information only for the purposes listed in the overview: verifying your identity, executing and confirming your transactions, answering you, sending you our communications, preventing fraud and complying with the financial laws. By sending us your information, you consent to these uses. You may withdraw your consent at any time; we will then no longer be able to serve you, but we must keep the records the law requires us to keep. You can unsubscribe from our communications at any time, through the unsubscribe link in each message or by writing to info@adopto.ca.

5. Where Your Information Is Kept

We hold neither your funds nor your crypto assets. Your information, however, is kept in online tools that we choose and oversee:

1. Zoho (CRM): our client list (name and contact details) and the sending of our communications; your documents are not stored there;
2. Google Workspace (Gmail, Drive, Sheets): emails, attachments and transaction log;
3. Telegram: our conversations with you and the StrongHodl chatbot;
4. Cloudflare: hosting of the website and of StrongHodl, and its transaction data; form protection (Turnstile) and cookie-free traffic measurement (Web Analytics);
5. Resend: delivery to our mailbox of contact form messages and account opening requests, personal or business, with your documents.

These providers act on our behalf. Some keep data outside Quebec and Canada, including in the United States, where authorities may access it under their laws. Only the employees who need it for your transactions or our legal obligations can access it. A copy of your client file is also kept on an offline medium; the online copies (emails and attachments) are kept as set out in section 10.

6. Who Receives Your Information

We do not sell or rent your information. We share it only:

1. with the providers named in section 5, which process it on our behalf and on our instructions;
2. with the financial institutions that process a transfer, yours and ours, to confirm the amount and source of a payment;
3. with FINTRAC, Revenu Québec, the Canada Revenue Agency, the police, a court or another authority, when the law requires or permits it;
4. for some transactions, especially large ones, with a liquidity or execution partner (for example your banking information), to facilitate and execute the transaction, and for our compliance obligations;
5. with our professional advisors (accountant, lawyer, auditor), who are bound by confidentiality.

The law may prohibit us from telling you that information was shared with an authority.

7. Cookies and Analytics

The website uses no advertising or tracking cookies. To count visits and see which pages are viewed, we use Cloudflare Web Analytics, which sets no cookies and is not used to identify you. Our forms are protected against bots by Cloudflare Turnstile, which analyzes technical signals from your browser, such as your IP address. The website is hosted by Cloudflare, which processes IP addresses to protect the site against attacks. The website also infers your province from your IP address, through Cloudflare, only to show the French version and the local banner to visitors in Quebec; this information is not stored. You can block cookies in your browser without losing access to the site.

8. Security

We protect your information with measures suited to its sensitivity, including access limited to the employees who need it. If a confidentiality incident presents a risk of serious injury, we notify the Commission d'accès à l'information du Québec and, where applicable, the Office of the Privacy Commissioner of Canada, as well as the people affected, and we keep a register of incidents.

9. Your Rights

By writing to our person in charge, you can:

1. find out what information we hold about you and get a copy;
2. have inaccurate or incomplete information corrected;
3. withdraw your consent;
4. ask us to delete information we are no longer required to keep;
5. get your information in a structured, commonly used technological format.

We respond within 30 days. The law may require us to refuse access to some information, including information related to our obligations to FINTRAC.

10. Data Retention

We keep your client file and transaction history for six years after your last transaction, as the financial and tax laws require. Messages received through the contact form are kept for as long as needed to answer you. The information is then securely destroyed.

11. Automated Decision-Making

We do not make any decision about you based solely on automated processing. With the StrongHodl chatbot, each order is received by an Adopto agent. When you buy, the agent checks that your transfer was received, executes the order, sends you the crypto assets manually, then closes the transaction. When you sell, the agent checks that your crypto assets were received in Adopto's wallets, then prepares the Interac e-Transfer to your bank account.

12. Minors

Our services are for people 18 years of age or older. We do not knowingly collect information about minors.

13. Changes to This Policy

We may change this policy. The date at the top of the page shows the last update. If a change affects how we use your information, we will tell you before it applies.

14. Complaints

If you are not satisfied with how we handle your information, first write to our person in charge. You can also contact the Commission d'accès à l'information du Québec or, outside Quebec, the Office of the Privacy Commissioner of Canada.