Easy Transfers Inc. (“we”, “us”, or “our”) is a Money Services Business (MSB) registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This Privacy Policy outlines how we collect, use, disclose, and protect your personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws.
1. Information We Collect
To provide our services and comply with legal obligations, we collect the following personal information:
- Identity Information: Full name, date of birth, government-issued identification (e.g., passport, driver’s license).
- Contact Information: Email address, phone number, mailing address.
- Financial Information: Bank account details, transaction history, and payment information.
- Technical Information: IP address, device type, browser, and usage data when interacting with our website.
2. Purpose of Collection
We collect and use your personal information for the following purposes:
- To verify your identity in accordance with Know-Your-Client (KYC) and anti-money laundering (AML) requirements.
- To process and complete stablecoin-to-CAD and CAD-to-stablecoin transactions.
- To comply with reporting obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
- To communicate with you regarding your transactions, account status, or service updates.
- To detect, prevent, and investigate fraudulent or unauthorized activities.
3. Legal Basis for Processing
Our processing of personal information is justified under the following grounds under PIPEDA:
- With your knowledge and consent, where applicable.
- As necessary to fulfill a contract with you.
- To comply with legal and regulatory obligations.
- For legitimate business purposes, including fraud prevention and risk management.
4. Disclosure of Information
We do not sell or rent your personal information. We may disclose your information only in the following circumstances:
- Service Providers: Third parties who assist us in delivering services (e.g., identity verification platforms, IT support, payment processors), subject to confidentiality agreements.
- Regulatory Authorities: FINTRAC, law enforcement, or other government agencies when required by law.
- Legal Requirements: In response to court orders, subpoenas, or other legal processes.
- Business Transfers: In the event of a merger, acquisition, or sale of assets, subject to confidentiality obligations.
5. Data Retention
We retain personal information only as long as necessary to fulfill the purposes for which it was collected or as required by law. Specifically:
- Client identification records are retained for a minimum of 5 years after the end of the business relationship.
- Transaction records are retained for a minimum of 7 years as required by the PCMLTFA.
6. Security of Information
We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, disclosure, alteration, or destruction. These include encryption, secure access controls, and employee training. However, no method of transmission over the internet is 100% secure.
7. Your Rights
Under PIPEDA, you have the right to:
- Access the personal information we hold about you.
- Request correction of inaccurate or incomplete information.
- Withdraw consent to processing, subject to legal and contractual restrictions.
- Lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) if you believe your privacy rights have been violated.
To exercise these rights, contact us at: info@easytransfers.ca.
8. Third-Party Links
Our website may contain links to third-party websites, such as FINTRAC or OPC. We are not responsible for the privacy practices or content of these sites.
9. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be posted on our website with a revised effective date.
10. Contact Us
If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact:
Easy Transfers Inc.
9 Valhalla Inn Rd, M9B 0B2
Toronto, Ontario, Canada
Email: info@easytransfers.ca
Phone: +1 (437) 262-1025
Supervisory Authority
If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada (OPC):
Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec K1A 1H3
https://www.priv.gc.ca