November 16, 2022
February 16, 2022
3.1 Account Information. In order to use the Services, Users may be required to have a valid Bolster account to log in to the Platform (“Account”). When you register for the Services or create an Account, Bolster collects your name, email address, phone number and address (“Account Information”).
Bolster uses the Account Information to:
3.2 Banking Information and AML. If you conduct any transactions on the Platform. Bolster will collect your banking information in order to process transactions and withdraw transactions fees owed. Users may be required to provide photo identification or other Personal Information (and supporting documentation) to verify their identity in order to process a transaction using the Services, which Bolster will use in order to comply with applicable laws and regulations regarding Anti-Money Laundering.
Bolster processes and stores its data, including Personal Information, on servers located in Canada and the United States. Bolster also transfers data to the third-party service providers described in Section 5.1. By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada and the United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the U.S. under lawful access regimes or court order.
5.1 Service Providers and Business Partners. We may from time to time employ third parties to perform tasks on our behalf and we may need to share Account Information and other Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage includes third party companies and individuals employed by us to facilitate our services, including the provision of database management, payment processing and customer relationship management tools. In particular, Bolster uses the following third-party service providers that process Personal Information on behalf of Bolster: Amazon Web Services, Paysave, Sendgrid and Twilio.
5.2 Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
5.4 As required by law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other End Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.
We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:
The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
Privacy Officer685 Center Street SouthSuite 1900Calgary, Alberta T2G2C7
Last Updated: January 29, 2024