1. Who We Are
This Privacy Policy applies to CCYFX Pay Inc., registered in British Columbia, Canada as a Money Services Business, and CCYFX Limited, incorporated in Hong Kong (Company No. 51615505), collectively referred to as "CCYFX", "we", "us", or "our". We operate the website at ccyfx.com and provide corporate and personal banking, foreign exchange, and payment services.
Questions about this policy should be directed to our compliance team at privacy@ccyfx.com.
2. Information We Collect
2.1 Information you provide directly
- Identity documents: passport, government-issued ID, proof of address
- Business documents: certificates of incorporation, articles of association, ownership charts
- Contact details: name, email address, phone number, business address
- Financial information: bank account details, source of funds declarations, transaction history
- Communications: enquiries, support requests, correspondence with our team
2.2 Information collected automatically
- IP address, browser type, device information, and pages visited on our website
- Cookies and similar tracking technologies (see Section 8)
- Transaction data generated through your use of our services
3. How We Use Your Information
We process your personal data for the following purposes:
- Account onboarding and KYB/KYC compliance: verifying your identity and business as required by anti-money laundering (AML) and counter-terrorist financing (CTF) regulations
- Service delivery: processing payments, FX transactions, card issuance, and account management
- Regulatory obligations: complying with applicable laws including FINTRAC (Canada), JFIU (Hong Kong), FATF guidance, and other applicable financial regulations
- Fraud prevention and security: monitoring for suspicious activity and protecting our systems
- Communications: responding to enquiries, providing account updates, and sending service-related notifications
- Marketing: where you have consented, sending news and updates about our products and services
4. Legal Basis for Processing
We rely on the following legal bases to process your personal data:
- Contractual necessity: processing required to deliver the services you have engaged us for
- Legal obligation: processing required by AML, CTF, and financial services regulations
- Legitimate interests: fraud prevention, security monitoring, and improving our services
- Consent: for marketing communications and non-essential cookies
5. Sharing Your Information
We do not sell your personal data. We may share your data with:
- Regulatory authorities: FINTRAC, JFIU, and other competent authorities where required by law
- Banking partners: correspondent banks, payment networks, and settlement partners required to process your transactions
- Compliance service providers: identity verification, sanctions screening, and KYB/KYC providers
- Technology providers: cloud infrastructure, security, and operational software providers under strict data processing agreements
- Professional advisers: lawyers, accountants, and auditors under confidentiality obligations
6. International Data Transfers
As an international financial services provider operating across Canada and Hong Kong, your data may be transferred to and processed in jurisdictions outside your country of residence. Where such transfers occur, we apply appropriate safeguards and ensure recipient jurisdictions provide adequate data protection.
7. Data Retention
We retain personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with legal obligations. Financial services regulations typically require us to retain KYC documentation and transaction records for a minimum of five (5) years following the end of a client relationship. We may retain data for longer where required by law or where we have legitimate interests in doing so.
8. Cookies
Our website uses cookies and similar technologies to ensure the website functions correctly and to analyse usage. You may control non-essential cookies through your browser settings. Disabling cookies may affect the functionality of certain features on our website.
9. Your Rights
Subject to applicable data protection law, you may have the following rights in relation to your personal data:
- Right of access — to obtain a copy of the personal data we hold about you
- Right to rectification — to request correction of inaccurate data
- Right to erasure — in certain circumstances, to request deletion of your data
- Right to restrict processing — to request that we limit how we use your data
- Right to object — to processing based on legitimate interests or for marketing
Note that certain rights may be limited where we have overriding legal obligations to retain data. To exercise any of these rights, contact us at privacy@ccyfx.com.
10. Security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, or destruction. These include encryption in transit and at rest, access controls, and regular security assessments.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be notified to existing clients by email or by prominent notice on our website. Continued use of our services after changes take effect constitutes acceptance of the revised policy.
12. Contact
For any privacy-related queries, please contact us at privacy@ccyfx.com.