Privacy
Policy.

Scope and accountability

This Privacy Policy applies to personal information collected by PAYNOMIC FINANCE CORP. through this website, mandate inquiries, onboarding and related service communications. PAYNOMIC FINANCE CORP. is a corporation incorporated in British Columbia, Canada.

We manage personal information in accordance with applicable Canadian privacy laws, including British Columbia’s Personal Information Protection Act and, where applicable, the Personal Information Protection and Electronic Documents Act (PIPEDA). We are accountable for personal information in our control, including information processed by service providers on our behalf.

Questions, access requests or privacy concerns may be directed to our Privacy Officer at compliance@paynomic.finance.

Personal information we collect

We collect information that you provide directly when you submit a mandate inquiry or otherwise contact us. Depending on the relationship and transaction, this may include:

• your name, business email address, company information and jurisdiction;
• client type, transaction parameters, settlement currency and approximate notional;
• identity, beneficial ownership, KYC/KYB and AML/ATF information;
• Source of Funds, Source of Wealth and transaction-context information where required;
• screening, risk-management, fraud-prevention and regulatory-compliance information; and
• information included in your message or correspondence.

Please do not submit private keys, passwords, wallet credentials or identity documents through the public contact form. If additional information is required, we will provide appropriate instructions through a separate onboarding process.

How we use and disclose personal information

We may collect, use and disclose personal information to:

• respond to your inquiry and assess whether a mandate can be reviewed;
• perform KYC/KYB, AML/ATF, sanctions, PEP, adverse-media, fraud-prevention and risk-management controls;
• communicate about onboarding, compliance, transaction settlement and operational requirements;
• maintain records, manage website communications and protect our systems;
• meet legal, regulatory, compliance, audit, reporting or law-enforcement obligations; and
• establish, exercise or defend legal rights where necessary.

We collect, use and disclose personal information only for purposes that are identified, reasonable and connected to our operational activities, unless otherwise permitted or required by law.

Consent and choices

By submitting information through this website or providing it during onboarding, you provide express consent to the collection, use and disclosure of that information for the purposes described in this Policy. We seek meaningful consent and will identify the purposes of collection, use and disclosure in a manner intended to be understandable.

You may withdraw consent, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer. Withdrawal of consent may affect our ability to respond to an inquiry, complete onboarding, review a transaction or continue a service relationship. Consent is not required for a collection, use or disclosure that is permitted or required by applicable law.

Disclosure, service providers and international transfers

We do not sell personal information. We may disclose personal information to service providers supporting website inquiries, communications, technology, screening, professional services or compliance operations; to advisers; to counterparties where necessary for an approved transaction; to competent authorities; or where otherwise required or permitted by law.

Personal information may be processed or stored outside Canada by service providers. It may therefore be subject to the laws of the jurisdiction in which it is processed, including lawful access by foreign courts, governments, regulators or law-enforcement authorities. We require service providers to process personal information only for authorised purposes and to apply appropriate safeguards.

Retention and safeguards

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, to meet legal or compliance obligations, or to resolve disputes. Certain information may be retained despite account closure or deletion requests where required by AML, fraud prevention, legal, regulatory or law-enforcement obligations.

We use administrative, technical and organisational safeguards appropriate to the sensitivity of the information. No method of electronic transmission or storage is completely secure; you should not send sensitive credentials or documents through the public contact form.

Access, correction and complaints

Subject to applicable law, you have a right to request access to personal information we hold about you and to request correction of information that is inaccurate or incomplete. You may also raise a concern about our privacy practices or our handling of your personal information.

To submit a request or complaint, email compliance@paynomic.finance with enough information for us to verify your identity and locate the relevant records. We may need to request additional information before responding. If a concern is not resolved, you may have the right to complain to the Office of the Privacy Commissioner of Canada or another applicable privacy regulator.

Links and changes to this Policy

This website may link to third-party websites. We are not responsible for their privacy practices, and you should review their policies before providing personal information.

We may update this Privacy Policy from time to time to reflect changes to our practices, operations or applicable requirements. The updated version will be posted on this page with a revised “Last updated” date.