Privacy Policy
How AcexPay collects, uses, discloses and protects your personal information.
1. Introduction
SendNaa Inc., trading as AcexPay (“AcexPay,” “we,” “our,” “us”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our website (www.acexpay.com) and our payment, foreign exchange, money transfer and virtual currency services.
By using AcexPay, you consent to the collection and use of your personal information as described in this policy.
2. What Personal Information We Collect
| Category | Examples |
|---|---|
| Identity Information | Full name, date of birth, government-issued ID number (passport, driver’s license), photo of ID. |
| Contact Information | Residential address, email address, phone number. |
| Financial Information | Bank account details, credit card information, source of funds, source of wealth. |
| Transaction Information | Amount, currency, date, time, recipient name, purpose of transfer. |
| Beneficial Ownership | For corporate clients: names and ownership percentages of individuals controlling 25% or more of the entity. |
| Technical Information | IP address, device type, browser type, geolocation (for fraud prevention). |
3. How We Collect Your Information
- Directly from you: When you sign up, verify your identity, make a transaction, or contact support.
- Automatically: Through cookies and similar technologies when you browse our website.
- From third parties: Credit bureaus, sanctions screening databases, and public registries.
4. How We Use Your Information
| Purpose | Legal Basis |
|---|---|
| Verify your identity and prevent fraud. | FINTRAC AML/ATF obligations (PCMLTFA, s. 64-72). |
| Process payments, FX, and money transfers. | Performance of our service agreement. |
| Sanctions and PEP screening. | International sanctions laws and FINTRAC guidance. |
| Report STR / LCTR / LVCTR / EFTR to FINTRAC. | PCMLTFA, s. 7. |
| Improve our website and fraud detection. | Legitimate business interest. |
| Respond to law enforcement or regulators. | Legal obligation. |
5. Disclosure of Your Information
We do not sell your personal information. We may share it only with FINTRAC, payment processors and banks (only the minimum required), law enforcement or regulators when compelled, and third-party service providers under strict confidentiality agreements. We do not share your information for marketing.
6. Data Retention
AcexPay retains your personal information and transaction records for at least 6 years after the record was created or the business relationship ends, as required by the PCMLTFA. After 6 years, data is securely deleted or anonymized.
7. Your Rights
- Access: Request a copy of the personal information we hold about you.
- Correct: Request correction of inaccurate or incomplete information.
- Withdraw consent: Withdraw consent to certain data uses.
- Complain: Lodge a complaint with the Privacy Commissioner of Canada.
To exercise these rights, contact our Compliance Officer: compliance@acexpay.com.
8. Cookies and Tracking Technologies
Our website uses cookies to remember preferences, analyse traffic, and detect fraud. You can disable cookies in your browser, though some features may not work properly. See our cookies policy.
9. Security Measures
- Encryption: TLS 1.3 in transit; AES-256 at rest.
- Access controls: Need-to-know basis for authorized employees.
- Monitoring: 24/7 intrusion detection and fraud monitoring.
- PCI DSS Level 1 certified.
10. International Data Transfers
Your data may be processed outside Canada under a data processing agreement meeting Canadian standards, with providers offering comparable protections to PIPEDA.
11. Children’s Privacy
Our services are not intended for individuals under 18. We do not knowingly collect information from minors.
12. Changes to This Policy
We may update this policy. The “Last Updated” date will change accordingly. Material changes will be communicated by email or on our website.
13. Contact Us & Complaints
Communications officer: info@acexpay.com | +44 7484720082
See our complaints policy.