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M1, Rue des Coquelicots Luxembourg, L-1356 Luxembourg
info@sayvins.com
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Privacy Policy

We collect and use information about your visit to our website or use our apps. In general, you can visit our Services without indicating who you are or submitting any personal information. However, we collect and/or maintain the IP (Internet protocol) addresses of all visitors to the Services and other related information such as page requests, browser type, operating system and average time spent on the Services. We use this information to help us understand activity and to monitor and improve the Services.

Cookies & Similar Technologies: The Services use a technology called “cookies”. A cookie is a tiny element of data that the Services can send to your browser, which may then be stored on your hard drive so that you can be recognized when you return. We use cookies on the pages on the Services where you are prompted to log in or that are customizable. If you have registered with the Services, these cookies may let us know who you are and identify your browser as one that has visited the Services before and may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services. We also use cookies to provide us and our service providers with information about your use of the Services that we may use to personalize the Services or other content in accordance with your interests and preferences (e.g. language preference) and improve your user experience. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Services, you may not be able to take advantage of all of the features of the Services.

Tracer Tags & Web Beacons: The Services may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on the Services. These tracer tags are used to help us optimize and tailor the Services for you and other future visitors to the Services.

Analytics: We may use third parties, including Google Analytics, to help us gather and analyze information about the areas visited on the Services in order to better understand, evaluate and improve the user experience and the convenience of the Services.

Social Media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on the Services or our applications and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.

We limit access to clients’ personal information. We record clients’ personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees and service providers to have access to clients’ personal information only on a “need to know” basis in order to fulfill their job requirements.

We implement safeguards to protect personal information. Sayvins maintains reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification and disclosure of. We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign our privacy document that obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information.

Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

We have personal information retention processes designed to retain personal information of our clients and prospective clients for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal requirements.

We restrict disclosure of personal information. We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out in this Privacy Policy.

Service Providers: We may transfer your personal information to our affiliates and other third party service providers who provide various services on our behalf such as identity verification, technology, administration, balance checks, printing, marketing and advertising, hosting, data analysis, legal and accounting.

Business Transactions: We may transfer any information we have about you as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Sayvins or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Securities Regulations: We may share your name, contact information and holdings with issuers of securities that you hold in your account and other persons/companies as required in accordance with securities law. Such issuers may require your personal information in order to deliver financial reports, tax documents and other relevant materials to you or to comply with applicable regulatory obligations. We may also disclose certain personal information, including the number of and purchase price of units purchased, to the applicable Canadian securities regulatory authority where required by law.

Legal: Sayvins and its third party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law (which may include lawful access requests by Canadian, US or other foreign courts, law enforcement or governmental authorities). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

We expect similar safeguards from our service providers. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. Your personal information may be maintained and processed by our affiliates and other third party service providers in the US or other jurisdictions. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions.

We use online advertising. We may use third parties such as ad exchanges and data companies to serve our advertisements on our Services or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our websites and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Services.

To learn more about this behavioural advertising practice or to opt-out of this type of advertising, you can visit the Digital Advertising Alliance website at www.aboutads.info/choices/ or the Digital Advertising Alliance of Canada website at www.youradchoices.ca/choices.

We may provide links to third party websites. Our Services may contain links to other websites that we do not own or operate. Also, links to our Services may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

We take privacy seriously. sayvins's Chief Legal Officer, is responsible for ensuring that Sayvins adheres to its privacy policy. The Chief Legal Officer is also responsible for training our employees in our privacy policies and for monitoring the fulfillment of our privacy commitments. We invite any client or prospective client to contact us at privacy@sayvins.com for any additional clarification desired.

We will provide you with access to your information. Individuals have the right to access, update, and correct inaccuracies in their personal information that is in sayvins's custody and control, subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account and clicking “Settings”. Otherwise, an individual wishing to request access, updating and corrections of inaccuracies in other of his or her personal information in our possession or control may send a request to privacy@sayvins.com. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.