Privacy Policy

A. What Is This Policy?

This is the privacy policy for Tenor, a service explained in the applicable User Agreement. This policy also covers the website, social media channels, customer support features, and other aspects of the Tenor Platform, including the collection and use of information. It explains how we balance your privacy rights, what we must do to operate the Tenor Platform, our general approach to privacy issues, and other important matters related to privacy.

B. Privacy Is a Human Right

Our starting point is that privacy is a human right. We have aimed to build the Tenor Platform in a manner that respects your privacy, while balancing the operational needs of a service that provides the features that users want. There are also a number of relevant laws in Canada which apply to us and may apply to your data or personal information.

C. Who We Are

We are Les Entreprises Shippoor Inc., a company incorporated under the laws of Canada, and headquartered in Québec City.

The person in charge of the protection of personal information can be reached at: legal@tenor.finance. You may also contact us at this address to ask questions about this Privacy Policy, exercise your privacy rights, submit a complaint regarding our privacy practices, or request information about the third parties to whom we communicate your personal information.

D. Eligibility

The Tenor Platform is intended for individuals who are at least 18 years of age, or the age of majority in the jurisdiction in which they reside, whichever is higher. By accessing or using the Tenor Platform, you represent and warrant that you meet this requirement. We do not knowingly collect personal information from individuals below the applicable age of majority.

E. Personal Information We Collect

We collect the following information when you use the Tenor Platform:

We consider the above to be personally identifying information (“PII”), even if it does not identify you because it may be combined with other data sources to uniquely identify you, whether by us or by third parties that are integrated into the Tenor Platform. We err on the side of considering information to be PII when in doubt.

It is possible that you may provide additional PII to us as part of your interactions with the Tenor Platform, on an optional basis, in relation to a stated purpose at the time of collection.

F. Airdrops

We may disclose your blockchain network address, without any associated personal information, as part of an airdrop by a third party to users of the Tenor Platform. We will only disclose your wallet address for this purpose and will not include any other personal information in connection with airdrop disclosures.

G. Purpose of Collection

If a purpose is not stated explicitly at the time of collection then the purpose shall be the provision of services to you, operating our business, and improving the services provided to you and others.

Where applicable law requires a legal basis for processing, we may rely on one or more of the following: your consent; performance of a contract with you; compliance with a legal obligation; our legitimate interests, or those of a third party, where those interests are not overridden by your rights and freedoms; or another legal basis permitted by applicable law. Where consent is relied upon as a legal basis, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

H. What We Do With PII

PII is stored within our software systems, which are available to our employees and contractors who have a need to access the information in order to develop and maintain those software systems. We do not rent, sell, lease, or otherwise exchange PII for consideration with third parties, other than as part of the sale of all or substantially all of our business.

As part of offering the Tenor Platform we make use of suppliers to carry out business functions, such as sending emails or other notifications to you (e.g. Twilio), which require us to send your PII to these suppliers. You may write to us to obtain a list of our current suppliers and links to their privacy policies.

I. Cookies

The Tenor Platform makes use of cookies, and may also make use of other similar methods to store data on your device in relation to your use of the platform, such as local storage/session storage, or IndexedDB.

Where required by applicable law, we will obtain consent before using non-essential cookies or similar tracking technologies. Where your browser or device transmits a privacy preference signal (such as a Global Privacy Control signal), we will seek to honour that signal to the extent required by applicable law.

J. Third Party Analytics And Telemetry

The Tenor Platform includes computer code that connects to third parties (i.e. integrations, widgets, etc.) and that may send analytics/telemetry to third parties. You may write to us to obtain the current list of third parties that gather this sort of information. In some cases, the purpose of the connection to the third party is to provide us with behaviour information about users, or specific information about you. For example, we make use of third party analytics vendors, which change on a regular basis in accordance with our business needs (e.g. Google Analytics).

Information gathered within the Tenor Platform that is sent to third parties is subject to the privacy policies of the third parties, and the laws of the jurisdictions in which they operate.

K. Optional Messaging Feature

You may be provided with messaging functionality within the Tenor Platform (for contacting us). Messaging functionality may take place using third-party services (e.g. Intercom) that will have access to any message that you send, governed by their own terms and privacy practices and our legal agreement with them. Customer support is an optional feature within the Tenor Platform and you may wish to not make use of this functionality to minimize exposure of your personal information.

L. Global Data Processing

We cannot guarantee that your data or PII will remain in Canada, because we make use of cloud services to deliver the Tenor Platform and have third party integrations that may store or process data outside Québec. When personal information is communicated outside Québec, we assess the transfer and implement appropriate contractual and operational safeguards where required by law.

M. Deletion & Retention of Data

We retain PII only for as long as reasonably necessary for the purposes for which it was collected. Personal information associated with your account or use of the Tenor Platform is retained for a period of five (5) years following the date your account becomes inactive or is closed, whichever is earlier, unless a longer period is required by applicable law or is reasonably necessary for our legitimate purposes.

Please note that information recorded on a public blockchain, including wallet addresses and transaction records, is inherently immutable and persists indefinitely by the nature of the underlying technology. We have no ability to alter or delete data recorded on-chain. The retention period above applies only to personal information held in Tenor’s own systems.

When personal information in our systems is no longer required, we will delete it, anonymize it, or securely dispose of it in accordance with applicable law and our retention practices.

N. Confidentiality Incidents And Breach Notification

We maintain a register of confidentiality incidents involving personal information under our control, as required by applicable law.

In the event of a confidentiality incident that presents a risk of serious injury to an individual, we will notify the Commission d’accès à l’information as soon as reasonably possible after becoming aware of the incident, notify any affected individuals whose personal information is involved and whose interests are at risk, as soon as reasonably possible, and take reasonable steps to mitigate the incident and reduce the risk of harm.

O. Disclosures To Law Enforcement

Notwithstanding any part of this privacy policy, we retain the right to disclose your PII or any information we have to law enforcement if we believe that it is necessary to prevent a crime that may occur, bring a person to justice who has committed a crime, or to provide voluntary assistance in response to a law enforcement request. We may disclose your PII or other information in response to a production order or similar lawful order to produce information to law enforcement.

P. Making Requests Of Us

You have certain rights under applicable privacy laws, and we may also optionally grant a request that we are not required to in relation to your personal privacy. For example, you may request to:

• obtain a copy of PII that we hold about you;
• correct PII we hold;
• delete PII;
• opt out of email lists or marketing communications;
• receive PII you have provided to us in a structured, commonly used technological format, where technically feasible and as required by applicable law; and
• request the de-indexation or suppression of PII that is disseminated online if it causes you serious injury, was collected in violation of applicable law, or where you have withdrawn the consent on which dissemination was based.

To make a request you may write to us at: legal@tenor.finance. We will respond to rights requests within 30 days of receipt. Where a request is complex or we have received a high volume of requests, we may extend this period by up to an additional 30 days, with notice to you.

Q. Algorithmic Decision Making

The Tenor Platform may make use of algorithmic decision making, either to detect abuse (e.g. blocking excessive bot requests to endpoints) or to analyse our user base for marketing or business development purposes.

R. Questions And Complaints

If you have questions or complaints about this privacy policy, our practices, or your rights, please contact us at: legal@tenor.finance.

S. Your Legal Rights

For information about your legal rights with respect to privacy you may wish to contact your local privacy office. For example, if you are located in Québec, the Commission d’accès à l’information.

T. Changing This Policy

We may change this policy in response to changes in the law, our practices, or evolving business standards. Where appropriate or where required by law, we will provide notice of changes by appropriate means before those changes take effect. Please check this privacy policy periodically to review our current practices and approach.