Privacy Policy
1. Introduction
FIN TWIN Technologies Inc., operating as FINTWIN PAY ("we," "us," or "our"), is committed to protecting the privacy and security of personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services.
We are a registered Money Services Business (MSB) in Canada (Registration Number: C10001675) and comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy legislation.
2. Information We Collect
2.1 Personal Information
We collect the following categories of personal information:
- Identity Information: Full legal name, date of birth, government-issued identification numbers and documents
- Contact Information: Email address, phone number, mailing address
- Financial Information: Bank account details, payment card information, transaction history, source of funds
- Employment Information: Occupation, employer name (for business accounts)
- Technical Information: IP address, device information, browser type, login data
2.2 Information from Third Parties
We may receive information about you from third parties, including:
- Identity verification services
- Credit bureaus and financial institutions
- Government databases and sanctions lists
- Business partners and referral sources
3. How We Use Your Information
We use your personal information for the following purposes:
- Service Delivery: To process transactions, provide foreign exchange services, execute money transfers, and deliver our financial services
- Regulatory Compliance: To comply with KYC (Know Your Customer) requirements, AML (Anti-Money Laundering) regulations, and other legal obligations
- Account Management: To create and manage your account, verify your identity, and communicate with you about your account
- Security: To detect and prevent fraud, unauthorized access, and other illegal activities
- Improvement: To analyze usage patterns and improve our services
- Legal Obligations: To comply with court orders, regulatory requests, and other legal requirements
4. Legal Basis for Processing
We process your personal information based on:
- Contract: Processing necessary to provide our services to you
- Legal Obligation: Processing required to comply with Canadian laws, including PCMLTFA, FINTRAC reporting requirements, and tax laws
- Legitimate Interest: Processing necessary for fraud prevention and security
- Consent: Where you have provided explicit consent for specific processing activities
5. Information Sharing and Disclosure
We may share your personal information with:
- Regulatory Authorities: FINTRAC, tax authorities, and other government agencies as required by law
- Financial Partners: Banks, payment processors, and correspondent financial institutions necessary to complete your transactions
- Service Providers: Third parties who assist us in providing services (identity verification, cloud hosting, customer support)
- Legal Requirements: When required by law, court order, or to protect our legal rights
We do not sell your personal information to third parties for marketing purposes.
6. Data Retention
We retain your personal information for as long as necessary to:
- Provide our services to you
- Comply with legal obligations (minimum 5 years for MSB records under PCMLTFA)
- Resolve disputes and enforce our agreements
When retention is no longer required, we securely delete or anonymize your information.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal information, including:
- Encryption of data in transit and at rest
- Access controls and authentication requirements
- Regular security assessments and monitoring
- Employee training on data protection
- Incident response procedures
8. Your Rights
Under Canadian privacy law, you have the right to:
- Access: Request a copy of the personal information we hold about you
- Correction: Request correction of inaccurate or incomplete information
- Withdrawal of Consent: Withdraw consent where processing is based on consent (note: this may affect our ability to provide services)
- Complaint: Lodge a complaint with the Office of the Privacy Commissioner of Canada
To exercise these rights, contact us at privacy@fintwinpay.com.
9. International Transfers
Your information may be transferred to and processed in countries other than Canada, including countries where our financial partners and service providers operate. We ensure appropriate safeguards are in place for such transfers.
10. Cookies and Tracking
Our website uses cookies and similar technologies to:
- Enable essential website functionality
- Remember your preferences
- Analyze website usage and performance
You can control cookies through your browser settings.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the new policy on our website and updating the "Last Updated" date. Your continued use of our services after changes constitutes acceptance of the updated policy.
12. Contact Us
If you have questions about this Privacy Policy or our privacy practices, please contact us:
FIN TWIN Technologies Inc.
Privacy Officer
1025 King Street East, Unit 107-1587
Cambridge, Ontario, N3H 3P5, Canada
Email: privacy@fintwinpay.com