QuiQX Pay Inc. (“Company,” “we,” “us,” or “our”) is committed to protecting the personal information of our customers, users, merchants, partners, vendors, applicants, employees, contractors, and other individuals whose personal information we collect, use, or disclose in the course of providing our fintech payment services.

This Privacy Policy explains how we collect, use, disclose, store, transfer, and protect personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 and any substantially similar provincial legislation, including where applicable in British Columbia and Québec. If you are located in a province with privacy legislation that applies to us, we will comply with that law to the extent applicable.

This Policy also applies subject to our obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, S.C. 2000, c. 17, related regulations, and reporting, recordkeeping, and compliance requirements administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

I. Scope
This Policy applies to personal information collected in connection with: the opening and administration of accounts;  payment processing and related financial services; identity verification, fraud prevention, risk management, and security; customer support and communications; marketing and service improvement; employment and contractor relationships; and regulatory, legal, and compliance activities. This Policy applies to information collected through our websites, applications, APIs, portals, devices, and other communications with us, whether online, in person, or otherwise.  

II. Definitions
For purposes of this Policy:
“Personal information” means information about an identifiable individual, including contact information, identity information, payment information, account information, device and usage data, and other information that can identify or reasonably relate to an individual.

“Sensitive information” includes government-issued identification, financial information, biometric information, authentication credentials, and other information that, if misused, could cause significant harm.“Personnel” means any individual performing services for the Company, including employees, contractors, and individuals engaged through staffing agencies or similar arrangements.

III. Accountability
We are responsible for personal information under our control. We have designated a Privacy Officer who is responsible for overseeing our privacy program, including: privacy governance; handling access and correction requests; responding to complaints; managing privacy incidents and breaches; overseeing vendor privacy practices; and maintaining and updating this Policy and related procedures.
Contact information for our Privacy Officer: [ Shadi Darbani at privacy@quiqxpay.com]

IV. Collection of Personal Information
We collect personal information only for purposes that a reasonable person would consider appropriate in the circumstances and to the extent permitted by law.

We may collect personal information directly from you, from your device or browser, from financial institutions and payment networks, from identity verification and fraud prevention service providers, from government or regulatory authorities, from employers or merchants where applicable, and from other lawful third-party sources.

Depending on the service and applicable law, the personal information we may collect includes: name, address, email address, telephone number, date of birth, and government identifiers; account credentials and authentication information; banking, payment, and transaction information; device identifiers, IP address, and usage information; business and beneficial ownership information; employment or contractor information, where relevant; communications with us; information required for know-your-customer, anti-money laundering, sanctions, fraud, and risk screening purposes; and any other information necessary to provide our services or satisfy legal obligations.  

V. Purposes for Collection, Use, and Disclosure
We may collect, use, and disclose personal information for the following purposes: to verify identity and maintain account security; to provide, operate, and improve our products and services; to process payments, transfers, refunds, chargebacks, and related transactions; to detect, prevent, investigate, and respond to fraud, cyber threats, misconduct, and misuse; to conduct customer due diligence, identity verification, sanctions screening, and anti-money laundering and anti-terrorist financing compliance; to comply with legal, regulatory, tax, audit, and recordkeeping requirements; to communicate with you about accounts, transactions, support, and service notices; to administer employment, payroll, benefits, and contractor relationships; to personalize and improve user experience and product performance; to manage disputes, claims, investigations, and litigation; to send permitted marketing communications; and for any other purpose to which you consent or that is otherwise permitted or required by law.  

VI.Consent
We will obtain consent for the collection, use, and disclosure of personal information where required by law and where consent is the appropriate legal basis. Consent may be express or implied depending on the sensitivity of the information, the context, and the applicable law. You may withdraw consent, subject to legal or contractual restrictions and reasonable notice. If you withdraw consent, we may be unable to provide certain products or services. Where required by applicable provincial law, including in Québec, we will obtain consent in a manner that is clear, free, and informed, and separate consent may be sought for certain secondary uses or disclosures.

VII. AML/ATF, Sanctions, and Regulatory Reporting
We may collect, use, retain, and disclose personal information as required or permitted by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, S.C. 2000, c. 17, its regulations, FINTRAC guidance, and other applicable anti-money laundering, counter-terrorist financing, sanctions, tax, and financial services laws. This may include: customer identification information; beneficial ownership information; transaction records and account activity; suspicious activity or suspicious transaction information; sanctions screening results; source-of-funds or source-of-wealth information; device, account, or access logs related to compliance review; and related supporting documentation. Where required or authorized by law, we may disclose information to FINTRAC, law enforcement, regulators, tax authorities, payment networks, financial institutions, or other authorized entities without further notice to you. In some cases, we may be prohibited by law from notifying you of such disclosures.

VIII. Disclosure to Third Parties
We may disclose personal information to: service providers, processors, and subcontractors who perform services on our behalf; financial institutions, payment networks, card brands, and settlement partners; identity verification, fraud prevention, and risk management vendors; legal, accounting, audit, and consulting professionals; regulators, law enforcement, courts, and government authorities; affiliates and related entities, where permitted by law; prospective buyers, successors, or investors in connection with a corporate transaction; employers, merchants, or business clients, where applicable and lawful; and other third parties with your consent or as otherwise permitted or required by law. We require third parties that process personal information on our behalf to protect it with appropriate safeguards and to use it only for authorized purposes.

IX. Cross-Border Transfers
Your personal information may be transferred to, stored in, or accessed from jurisdictions outside your province or outside Canada, including the United States and other countries where our service providers or affiliates operate. As a result, personal information may be subject to the laws of those jurisdictions, including lawful access by courts, regulators, or government authorities. We use contractual, technical, and organizational safeguards appropriate to the sensitivity of the information and the nature of the transfer.

X. Safeguards
We maintain safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. These safeguards may include: access controls and least-privilege permissions; encryption in transit and at rest where appropriate; authentication and logging controls; secure development and change management practices; employee and contractor confidentiality obligations; vendor due diligence and contractual protections; physical security measures; and incident response and business continuity procedures.  

XI. Retention
We retain personal information only as long as reasonably necessary to fulfill the purposes for which it was collected, to comply with legal, tax, accounting, regulatory, AML/ATF, and recordkeeping requirements, and to resolve disputes or enforce agreements. In particular, records required under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, S.C. 2000, c. 17 and related regulations may be retained for the periods required by law or longer where necessary to comply with investigations, legal holds, or regulatory obligations. When personal information is no longer required, we securely destroy, delete, anonymize, or de-identify it in accordance with our retention schedule and applicable law.

XII. Accuracy and Access
We take reasonable steps to ensure that personal information is accurate, complete, and up to date for the purposes for which it is used. Subject to limited legal exceptions, you may request access to your personal information, request correction of inaccurate or incomplete information, and request additional information about our privacy practices. We may require verification of identity before responding to a request.

XIII. Marketing Communications
We may send you marketing communications where permitted by law. You may opt out of certain marketing communications at any time by following the unsubscribe instructions or contacting us directly. We will honor opt-out requests as required by applicable law.  

XIV. Employment and Contractor Information
Where we collect personal information in connection with employment or contractor relationships, we use that information for recruitment, onboarding, administration, payroll, benefits, performance management, security, compliance, and legal obligations. Personnel must provide accurate information and promptly notify us of changes relevant to their role or eligibility.

XV. Complaints
If you have a privacy concern or complaint, please contact our Privacy Officer. We will investigate complaints and respond within a reasonable time. If you are not satisfied with our response, you may have the right to contact the applicable privacy commissioner or other regulatory authority.

XVI Children and Minors
Our services are not directed to children under the age permitted by applicable law to provide consent. We do not knowingly collect personal information from minors except as permitted by law, with appropriate consent, or where necessary to provide services lawfully requested by an authorized adult or legal representative.  

XVII. Policy Changes
We may update this Policy from time to time to reflect changes in our practices, technology, business operations, or applicable law. The revised Policy will be effective when posted or otherwise communicated to you, unless a different effective date is stated.

XVIII. Contact Us
If you have any questions about this Policy or our privacy practices, please contact:
Shadi Darbani
QuiQX Pay Inc.  
4 Robert Speck Parkway, Suite 1620, Mississauga, ON L4Z 1S1  
privacy@quiqxpay.com  
+1-888-634-0535

We collect, use, disclose, and retain personal information in accordance with applicable Canadian privacy laws, including PIPEDA and, where applicable, provincial privacy legislation. We also process and disclose information as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, its regulations, and FINTRAC reporting obligations. For more information, please review our full Privacy Policy or contact our Privacy Officer.