Privacy Policy

1. Company Information

PAYMENTGUYS FINANCE LTD. (“Company”, “we”, “us”, “our”) is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and related regulations.

2. Scope of This Policy

This Privacy Policy applies to personal and corporate data collected by PAYMENTGUYS FINANCE LTD. in connection with foreign exchange dealing, payment initiation and payment service provider infrastructure services provided exclusively to corporate clients.

This Policy is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

3. Data We Collect

3.1 Corporate Client Data

• Full legal name and operating name of the company
• Certificate of incorporation, articles of association and good-standing documents
• Business registration number and jurisdiction of incorporation
• Registered and mailing addresses
• Business purpose and description of activities

3.2 Individual Data

• Full name, date of birth, country and city of birth
• Government-issued photo identification
• Residential address and contact information
• Ownership structure and beneficial ownership percentage

3.3 Transaction Data

• Payment instructions and transaction details, including amount, currency, sender and recipient
• Electronic funds transfer information captured before completion of a transfer
• Transaction history and records required by FINTRAC

3.4 Technical and Usage Data

• IP address and device information
• Access logs relating to our platform and services
• Communications, including emails and support tickets

4. Purpose of Data Processing

5. Data Sharing and Disclosure

We do not sell, rent or trade personal data. We may share data with:

• Regulated payment service providers and banking institutions involved in executing transactions
• Identity verification providers used for KYC/KYB purposes
• FINTRAC, Canadian authorities and other regulators where required by law
• Professional advisers, including lawyers, auditors and compliance consultants, subject to confidentiality obligations

Third-party service providers are required to process information only as instructed and in accordance with applicable data protection laws.

6. International Data Transfers

PAYMENTGUYS FINANCE LTD. operates internationally. Personal data may be transferred to and processed outside Canada. Where this occurs, we apply contractual and organisational safeguards consistent with PIPEDA requirements.

7. Data Retention

• AML/KYC records: at least 5 years from the date of the last transaction
• Transaction records: at least 5 years
• Contractual documentation: for the business relationship plus 7 years
• Correspondence and support records: 3 years

After the applicable retention period expires, information is securely deleted or anonymised, unless continued retention is required by law.

8. Data Security

We use appropriate technical and organisational measures designed to protect information against unauthorised access, disclosure, alteration or destruction, including:

• Encryption in transit and at rest
• Access controls and role-based permissions
• Security reviews and incident-response procedures
• Business continuity and disaster-recovery planning

9. Your Rights

Subject to applicable law, you may request access to or correction of your personal data, withdraw consent where processing relies on consent, and submit a complaint to the Office of the Privacy Commissioner of Canada.

Certain records may need to be retained despite a request for deletion or withdrawal because of obligations under Canadian anti-money-laundering laws.

10. Contact: Compliance Officer

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or applicable law. The current version will be published at pay-guys.com/privacy-policy with a revised “Last updated” date.