Privacy Policy

01Who we are

This Privacy Policy applies to CCYFX PAY INC, a company incorporated in British Columbia, Canada (company no. BC1564200), referred to in this policy as “CCYFX”, “we”, “us” or “our”. We operate the website at ccyfx.com.

This policy covers personal information about our clients and prospective clients, the individuals connected to them (such as directors, beneficial owners, trustees, beneficiaries and signatories), introducers, and visitors to our website.

02Information we collect

Information you provide

• Contact details: name, email address, telephone number, and business name or address
• Identity information: name, date of birth, address, occupation and government-issued identification
• Ownership and control information: details of directors, beneficial owners, settlors, trustees, protectors and beneficiaries
• Financial information: source of wealth, source of funds, bank account details and the purpose of payments
• Business information: licences, regulatory status and compliance policies
• Communications: enquiries, applications and correspondence

Information from other sources

• Public registries, regulators’ public registers, sanctions lists, and identity verification and screening providers
• Fiduciaries, introducers or professional advisers who refer you to us, with your knowledge

Information collected automatically

• Technical information such as IP address, browser type, device information and the pages you visit on our website
• Aggregate website usage statistics (see Cookies and analytics below)

03How we use it

We use personal information to:

• Respond to enquiries and applications: reply to messages and assess applications for an account
• Onboard and serve clients: verify identity, ownership and licences, assess risk, and provide foreign exchange, payment and related services
• Comply with the law: including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and sanctions legislation
• Prevent financial crime: detect and prevent fraud, money laundering, terrorist financing and breaches of sanctions
• Protect our website: maintain the security and proper operation of the website
• Send updates: where you have consented to receive them

04Legal basis

We collect, use and disclose personal information with your consent, or as otherwise permitted or required by law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and British Columbia’s Personal Information Protection Act (PIPA). Where other data protection laws apply to you, we rely on consent, contractual necessity, legal obligation or legitimate interests, as appropriate.

05Sharing

We do not sell personal information. We may share it with:

• CCYFX Limited, our Hong Kong company, which operates our sales office and handles client relationships on our behalf
• Banking and payment partners, to carry out your transactions
• Identity verification, screening, hosting (including Netlify, which hosts this website, and Formspree, which receives form submissions), email, IT and security providers acting on our behalf
• Professional advisers who are subject to confidentiality obligations
• Introducers, where you have consented
• Regulators and law enforcement authorities, including FINTRAC, where required or permitted by law

06International transfers

Because we make cross-border payments and use service providers in several countries, personal information may be stored or processed outside Canada and may be subject to the laws of those jurisdictions. We take reasonable steps to ensure that it receives a comparable level of protection.

07Retention

We keep personal information only for as long as we need it for the purposes described in this policy, or as the law requires. Canadian anti-money laundering law requires us to keep client identification, beneficial ownership and transaction records for at least five years.

08Cookies and analytics

Our website does not set cookies for advertising, tracking or analytics. To understand how the website is used, we use Plausible Analytics, a service that does not use cookies, is designed not to collect personal data and does not track visitors across websites. It records aggregate information such as pages viewed, referring websites, country and device type. You can manage cookies and similar technologies through your browser settings.

09Your rights

Subject to applicable law, you may request access to, or correction of, your personal information, withdraw your consent, ask us to delete information that we are not required to keep, and opt out of marketing. Some of these rights are limited by law. For example, we cannot delete records that we are required to keep, or disclose whether we have made a report to FINTRAC. If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner for British Columbia or the Office of the Privacy Commissioner of Canada.

10Security

We use reasonable technical and organisational safeguards to protect personal information, including encryption in transit, access controls and restricting access to staff who need it.

11Changes to this policy

We may update this policy from time to time. We will post the updated version on this page with a new “Last updated” date.

12Contact

For privacy questions or requests, please contact: