The following privacy policy outlines the types of personal information that NB 685209 Inc., (“Four Eyes Financial”, “we” or “us”) collects, through the Four Eyes Financial Intelligent Compliance Platform and/or website, and all content available thereon (collectively referred to herein as the “Site”).  It also explains why we collect your information and how we use it.

Privacy is important to Four Eyes Financial and we are committed to the protection of your privacy. We recognize that keeping your information secure and confidential is critical to earning and keeping your trust. We NEVER rent, sell or trade your personal information to anyone.

You become a User when you access the Site, pursuant to Four Eyes Financial’s Terms of Use. This Privacy Policy establishes the policies and procedures we use to collect, utilize,  and disclose user and/or client information provided to us through the use of our web sites, applications or other communications with representatives of Four Eyes Financial. Together with our Terms of Use, this Privacy Policy governs your use of our services.

Data Encryption & Security

Protecting your personal information from unauthorized access is an important part of providing services to you. Not only do we use security measures that comply with relevant laws, we use multiple layers of security in every component of our services.

De-Identify & Encryption

We anonymize your data by separating your financial data and your identifying information (email, name) and storing the information in different databases. Databases are encrypted and have the identifying fields replaced with new encrypted id tokens. AES-256 encryption is used for all data at rest with multi-layer key management, including rotated user-specific keys.

Bank Level Security

Information in transit is encrypted at rest with AES 256‐bit encryption and encrypted in transit using Transport Layer Security (TLS). Secure File Transfer Protocol (SFTP) servers and/or AWS CLI S3 Sync are used in instances where files are transferred. 

Data Center and Network

Our services are exclusively hosted within Amazon AWS data centers, which are trusted by leading global financial institutions, including Capital One, Barclays, Thomson Reuters, and Nasdaq.

Information We Collect

In order to provide a high-quality service, we may collect various types of information when you visit the Site, use our platform, sign-up as a customer, or otherwise engage with Four Eyes Financial. This may include: 

• Your name.
• Your email address.
• Other optional information which may include but are not limited to; age, name, salary, financial institution, contributions, investment holdings and preferences, and risk tolerance.

Visitor Information

We collect various types of anonymous information about visitors to our website, such as device-related information (including browser type and IP address) and server log information (including the date and time of day of your visit, average time spent on the site, browsing activity, and any site that referred you to Four Eyes Financial). We also collect information that you input into our website, e.g., by beginning the registration process or by commenting on the Four Eyes Financial blog. We use this information to better understand our visitors and our business, facilitate site navigation, provide the services or information you request, and enhance our service.

Other Ways We Collect Information

Apart from through the account registration process and from visitors to the site, we may collect various other types of personal information. We may collect personal information if you enter it into our live chat program or contact us or otherwise give it to us (e.g., in an email, phone call, or live chat with a member of our customer support team). Further, we may collect information regarding your browsing activity when you visit our website and actions you take within your Four Eyes Financial account while logged into our Intelligent Compliance Platform. 

Uses of Your Personal Information

In order to provide a high-quality service, we may collect various types of information when you visit the Site, use our platform, sign-up as a customer, or otherwise engage with Four Eyes Financial. This may include: 

Providing Services to You

We collect information to optimize, secure and simplify your experience with us. We may compile data, excluding personally identifiable information, for purposes of demographic analysis and research.

Advertising

Four Eyes Financial advertises our services on websites not affiliated with Four Eyes Financial, and we contract with third-party advertising companies to display these ads. These third-party advertising companies, along with data exchanges and similar providers, may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, IP address, and pages visited.  We do not provide any information to these advertising companies that could personally identify our users or clients, and they do not collect such information on our behalf.

Four Eyes Financial and third-party advertising companies may use the data collected to provide you with ads relevant to you and personalized content while you are on our website or other sites. If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information by visiting the NAI Opt-Out Page. Please note that even if you choose to remove your information by opting out, you will still see advertisements while you are browsing online.

Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Because mobile devices may vary in how they operate and may not use cookies, the choice management options listed above may not work for all mobile devices and mobile apps.

Analytics Services

We use our own internally hosted analytics tool (collectively referred to as “Analytics Services”) to collect information about the usage of our website & Platform.  The Analytics Services collect information about how often users visit the site, what pages they visit when they do so, and what other sites they used prior to coming to this site, among other information. We use the information we get from these Analytics Services to improve the user experience.

The Analytics Services collect the IP address assigned to you on the date you visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the site), but not your name or other personally identifiable information. 

You can prevent Analytics Services from recognizing you on return visits to this site by clearing & disabling cookies on your browser. 

General Data Protection Regulation 

The General Data Protection Regulation (GDPR), referred to as DSGVO in German and RGPD in French, is a comprehensive regulation that aims to enhance data protection for individuals within the European Union (EU). It applies globally to companies, non-profit organizations, and public entities that handle the personal data of EU residents.

Our on premises Analytics Services is configured to be GDPR compliant using:

• Data anonymization.
• GDPR Manager.
• Users can opt out of all tracking.
• First-party cookies by default.
• Capabilities to delete visitor data when requested.

Third Party Operation

When we use third parties to assist us in processing your personal information, we require that they comply with our Privacy Policy and any other appropriate confidentiality and security measures. As part of standard operations and maintenance, Four Eyes Financial’s vendors and suppliers may have access to personal information but this limited access is reasonably necessary to perform maintenance to our Platform and/or website. We may share aggregated non-personal information with these third parties outside of Four Eyes Financial.

Protecting Children’s Privacy

The Site is not directed to individuals under the age of eighteen (18), and we do not knowingly solicit information from these individuals. We request that these individuals not provide Personal Information through our Site. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his or her consent, he or she should contact privacy@foureyesfinancial.com, and we will delete it from our records. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website, or the Office of the Privacy Commissioner of Canada and the Personal Information Protection and Electronic Documents Act (PIPEDA).  

How Personal Information Is Protected

Four Eyes Financial works diligently to protect your personal information and we use our reasonable best efforts to protect our Users’ personally identifiable information from unauthorized access, use or disclosure.  We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for Four Eyes Financial to agree to keep your information confidential. Furthermore, if an account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here.

If you possess login credentials to access our website or Intelligent Compliance Platform, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.  Despite best efforts, no method of transmission over the Internet or electronic storage can be guaranteed to be 100% secure. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

Your Choices

Controlling Your Personal Information

Our service relies on accurate and up-to-date information about yourself and your account to work effectively for you.  When creating an account, it is your responsibility to protect your username and password. Use a mix of upper-and lowercase letters and at least one number to secure your password but always create a password that is easy for you to remember but difficult for someone else to figure out. Please do not use your name, address, initials, phone number, license plate or birthday. Do not use the names of your friends, family, pets, company names, common numerical sequences or the word “password”. If you suspect that your password has been compromised in any way, immediately go to the User Settings area of the Platform, click on Change Password, and change your password.

Limit Information

We offer you choices when we ask for personal information, whenever reasonably possible.  You may decline to provide personal information to us and/or refuse cookies in your browser, although some of our features or services may not function properly as a result.

Email and Opt-out

Registered Users of the Site can opt-out of receiving notifications by accessing the User Settings area of the Site. By providing us with your email address, you agree to receive all required notices electronically, at that registered email address. To continue receiving emails, it is your responsibility to update your information in the event that your email address has changed. Users that do not wish to receive emails may opt-out of receiving any communications by following the instructions contained in all emails from us.

Deletion and Legal Requirements of Personally Identifiable Information

Upon written request, we will remove all your personally identifiable information to the extent possible by law or regulation that may dictate the information we must retain about you and for how long. We may also share information with third parties in limited circumstances, including when complying with legal process, preventing fraud or imminent harm, and ensuring the security of our network and services.

Links to Other Sites

Our Site may provide you links to third-party web sites. None of your personal information is passed on to these sites, and Four Eyes Financial is not responsible for the privacy policies of these sites nor do we control the privacy of any personal data collected while on third-party sites.

Other Important Information

Former Customers

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

How You Accept This Policy

By using and continuing to use the Four Eyes Financial website(s), platform(s), mobile app(s) and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version. Our Terms and Conditions take precedence over any conflicting privacy policy provision. If you do not agree with these terms, you should not use any of our services or websites.

Changes To This Policy

We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. Please check the effective date above to determine if there have been any changes since you have last reviewed the privacy policy.

International Visitors

This Service is hosted in Canada. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to Canada which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy policy.

Questions

If you have questions about this policy, site data collection, its use, and Four Eyes Financial’s disclosure practices, you may send us an email.  Four Eyes Financial will make reasonable efforts to respond promptly to privacy questions that are directed through our Privacy Officer. Except where required by law, Four Eyes Financial cannot ensure a response to questions or comments regarding topics unrelated to this policy.