Last Updated: September 24, 2023
Volatility Labs Inc. d/b/a Fig Investments and its subsidiaries, affiliates, associated companies and jointly controlled entities (hereinafter referred to as “Fig Investments”, “we”, “us”, and “our”) are committed to the privacy and security of your personal information. This privacy policy (or “Policy” for short) describes how we collect, use, and disclose your personal information, how we protect it, and the controls you have over it.
This Policy applies to: (i) your use of our website at https://fig.investments or any associated informational websites, electronic communications, APIs, or applications (collectively, the “Site”); (ii) your use of any current and future products, features, and services made available or rendered through the Site, including but not limited to our online investing platform for digital asset investors and any other products, features, and services related to structured investment products (“Structured Notes”), as further described in our Terms of Service (collectively referred to as the “Services”); and (iii) your interactions with us in the course of your use of the Site or the Services, whether by phone, text message, email, online chat, or otherwise. This Policy does not extend to websites, mobile applications or other services of third parties. We are therefore not liable for their privacy policies, procedures, and practices.
BY SUBMITTING PERSONAL INFORMATION TO FIG INVESTMENTS OR ITS SERVICE PROVIDERS AND AGENTS, YOU AGREE THAT WE MAY COLLECT, USE, AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY AND AS PERMITTED OR REQUIRED BY LAW. SUBJECT TO LEGAL AND CONTRACTUAL REQUIREMENTS, YOU MAY REFUSE OR WITHDRAW YOUR CONSENT TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AT ANY TIME BY CONTACTING OUR PERSON IN CHARGE OF THE PROTECTION OF PERSONAL INFORMATION (“PRIVACY OFFICER”), WHOSE CONTACT INFORMATION IS SET OUT BELOW. IF YOU REFUSE OR WITHDRAW YOUR CONSENT, WE MAY NOT BE ABLE TO PROVIDE YOU OR CONTINUE TO PROVIDE YOU WITH SERVICES OR INFORMATION WHICH MAY BE OF VALUE TO YOU.
Please review this Policy before providing us with your personal information, using the Site or our Services, or creating any user account in connection therewith. If you do not agree with this Policy, do not provide us with your personal information, use the Site or our Services, or create any user account.
This Policy is divided into the following sections.
1. Changes to This Policy 2
2. What Personal Information We Collect 2
3. How We Collect Your Personal Information 3
4. Why We Collect and Use Your Personal Information 4
5. Your Consent 5
6. To Whom Do We Disclose Your Personal Information 5
7. Cross-Jurisdictional Transfers 6
8. Protection of Your Personal Information 6
9. How Long We Retain Your Personal Information 6
10. Your Rights 6
11. Links to Other Websites and Advertising 7
12. Social Networks 8
13. Contact 8
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Site and will indicate the date of the latest version. Your continued use of the Site or the Services after any revised Policy has become effective indicates that you have read, understood, and agreed to the current version of the Policy. If you disagree with any changes made to the Policy, please cease to use the Site or the Services.
For the purpose of this Policy, “personal Information” includes any information which relates to a natural person and allows that person to be identified directly or indirectly in combination with other information. It does not include personal information where all references to the identity of the relevant individual have been removed (i.e., anonymized personal information).
We may collect, use, and disclose the following categories of personal information about you, including but not limited to:
● Identification and Contact Information, such as your first name, last name, date of birth, address, telephone number, e-mail address, title, and place of work;
● Account information, such as your username/login email and password;
● Regulatory and Financial Information, such as your government identification numbers, taxpayer identification number, information regarding your bank account (e.g., financial institution, account type, routing number, and account number), and proof of status as an accredited investor;
● Service Information, such as the type of Services Fig Investments provides you with, transactional history, account balances, and information on your investment parameters and portfolio;
● Client Communications, such as messages, opinions, complaints, evaluations, questions, or comments that you provide to us, as well as the content of your message;
● Career Information, such as your resume/CV, cover letter, language proficiency, and other information that you choose to add to your application for one of our roles;
● Technical Information, such as internet protocol (IP) address and geolocation information, cookies, and other technology on the devices you use to access the Site; and
● Internet Activity Information, such as browsing history, browsing behaviour (e.g. the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, and other click-stream data), search history, and interactions with our Site and online advertisements.
Some personal information is provided to us voluntarily by you (for example, when you create an account in order to use the Services) while some personal information is collected automatically (as described below at Section 3.2).
More precisely and without limitation, we collect your personal information in the following circumstances:
● When you create an account or sign up for a waitlist in order to use the Services;
● When you request our Services, such as when you request information about Structured Notes, or when you complete forms, sign agreements, or submit information required to use the Services;
● When you communicate with us by phone, email, online chat, social networks, or otherwise;
● When you apply for a job opening;
● When you sign-up to our newsletter or chat thread updates; and
● When you interact with the digital content on the Site.
If you provide us with personal information of another individual, you represent that you have obtained all necessary consents from such person to enable us to collect and process such personal information for the purposes set forth in this Policy.
As you interact with our Site, we will automatically collect Technical Information and Internet Activity Information about your equipment and browsing actions and patterns. We collect this information by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Information and Internet Activity Information about you if you visit other websites employing our cookies.
A cookie is a small text file that may be stored on the hard drive of your computer when you access the Site. You are free to accept or decline cookies at any time, but by doing so, you may not be able to use certain features on the Site or take full advantage of all our offerings. Check the “Help” menu of your browser to learn how to change your cookie preferences.
We may use your personal information for the purposes for which it was collected, as set out in this Policy, for other purposes permitted by law, or for other purposes with your consent.
We may use the information collected for the following purposes:
|
Purpose |
Type of personal information |
|
1. Manage the account creation process on the Site |
● Identification and Contact Information ● Account Information |
|
2. Provide you with information or Services that you request from us and to carry out our obligations and enforce our rights arising from any agreements that you enter into with us |
● Identification and Contact information ● Regulatory and Financial Information ● Account Information ● Service Information ● Client Communications |
|
3. Provide you with access to our Site, to enhance your convenient use of our Site, and to provide you with personalized content and interest-based advertisements |
● Identification and Contact Information ● Account Information ● Technical Information ● Internet Activity Information |
|
4. Monitor and analyze the usage of our Site and Services, with the goal of improving our Site and Services |
● Technical Information ● Internet Activity Information |
|
5. Respond to any communication we receive from you |
● Identification and Contact Information ● Client Communications |
|
6. Send you our newsletter or other promotional and marketing communications or to notify you about changes to our Site or Services |
● Identification and Contact Information |
|
7. Provide you with access to our online recruitment service and provide you with career opportunities |
● Identification and Contact Information ● Career Information |
|
8. Comply with legal requirements such as anti-money laundering, sanctions, and securities laws |
● Identification and Contact information ● Regulatory and Financial Information ● Account Information ● Service Information ● Client Communications |
We will only collect, use, and disclose your personal information with your consent or as otherwise permitted or required by law. Your consent may be express or implied, depending on the circumstances and the sensitivity of the information.
We do not knowingly collect personal information from anyone under the age of 14 (“child” or “children”). If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to delete that information.
Please consult Section 10.3 to learn about your right to withdraw your consent.
We may communicate your personal information to the following third parties in the following circumstances:
We only provide your personal information to third parties on a “need to know” basis. If we provide your personal information to third parties, then we require that the recipients keep your personal information secure, and only handle it for the limited purposes for which it is provided.
By providing us with personal information, you acknowledge and agree that your personal information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada and in the United States, where laws regarding the protection of personal information may be less stringent than the laws in your jurisdiction. Further, your personal information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information.
To prevent unauthorized access or disclosure, maintain data accuracy and facilitate the appropriate use of data, Fig Investments uses physical, technological and administrative procedures to attempt to protect the integrity of its Site and Services and the confidentiality of personal information that it collects, uses, and discloses.
Fig Investments only keeps personal information for as long as necessary and for the purposes for which it was collected, or for as long as required to comply with any applicable legal obligation. The length of time personal information is kept varies according to the nature of the information, and it may extend beyond the end of the relationship between an individual and Fig Investments.
When the personal information collected is no longer required by Fig Investments, the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form are applied.
In some circumstances, we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes or other legitimate reasons, in which case we may use this information indefinitely without further notice to you.
Subject to certain exemptions, as permitted by law, you have the following rights in relation to the personal information we hold about you.
You have the right to access the personal information we hold about you and to receive a general account of our uses of that personal information. Upon receipt of a written request from you, we will provide you with a copy of your personal information, although in certain limited circumstances, we may not be able to make all relevant personal information available to you, for example, where that personal information also relates to another individual. In such circumstances, we will, upon request, provide you with the reasons for such refusal. We will endeavour to deal with all requests for access to personal information in a timely manner.
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. Where appropriate, such amended personal information will be provided to the parties to whom we are authorized to disclose your personal information. Some information stored in your account profile may be corrected directly by you if necessary. Information collected by cookies is stored in cookie files located on your device, and thus can be modified by you without involving us. In certain circumstances, you may also ask us to delete or remove your personal information, such as when we no longer need your information to fulfill the purposes for which it was collected. We will endeavour to deal with all requests for rectification of personal information in a timely manner.
If we rely on your implicit or explicit consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you, including the Services.
The Site may occasionally contain links to other sites not operated by Fig Investments. Fig Investments is not responsible for the privacy practices or the content of those web sites. Please be sure to review the privacy policies of those sites.
The Site may display advertisements and/or links to third party sites. These advertisements or links may contain cookies placed by those third parties. Fig Investments is not responsible for those advertisements, the sites to which they are linked, or how any other linked sites may use their own cookies. For example, cookies received with banner ads may be collected by the company posting an ad on Fig Investments’ Site. Please refer to that company’s privacy policy for further information.
The use of social networks in connection with the Site may lead to the collection and exchange of some personal information between Fig Investments and such social network. We invite you to read the privacy policy posted on the social networks’ websites to be aware of what personal information can be transmitted to Fig Investments as well as the purposes of processing of your personal information by such social networks, in particular for advertising purposes. You can directly configure and control the access to and confidentiality of your personal information. Fig Investments shall not be responsible for any use of your personal information by social networks on their account.
If you have any questions or comments about this Policy, our privacy policies and practices, including with respect to our use of service providers outside Canada, or if you wish to exercise your rights with respect to your personal information, please communicate with our Privacy Officer by email using the following contact information: support@fig.investments.