2.1 Introduction
NEMOPAY GLOBAL CORP. (“NEMOPAY”, “we”, “us” or “our”) is committed to protecting the privacy and security of the personal information in its custody or control. This Privacy Policy describes how NEMOPAY collects, uses, discloses, retains and protects personal information in accordance with applicable Canadian privacy law.
NEMOPAY is subject to the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and, where applicable, provincial privacy legislation. Our activities as a FINTRAC-registered Money Services Business and Bank of Canada-registered payment service provider also give rise to specific legal obligations regarding the collection, use and retention of customer information.
2.2 Personal Information We Collect
NEMOPAY may collect the following categories of personal information:
- Identity information: Full legal name, date of birth, nationality, government-issued identification numbers and copies of identification documents.
- Contact information: Residential or business address, telephone number and email address.
- Corporate and ownership information: Business registration details, corporate structure, director and officer information, beneficial ownership information, ownership percentages and nature of control.
- Financial information: Source of funds, source of wealth (where required), bank account details, transaction history and payment information.
- Verification and screening information: Information obtained in the course of identity verification, sanctions screening, PEP screening and adverse media checks.
- Technical information: IP address, browser and device type, website usage and interaction data, and information collected through cookies and similar technologies.
- Correspondence and communications: Records of communications between you and NEMOPAY, including emails, messages and support requests.
- Compliance information: Any information collected or generated in the course of meeting NEMOPAY’s legal, regulatory or risk-management obligations.
2.3 How We Collect Personal Information
- Directly from you during the onboarding process, account registration or service use.
- Through your communications and correspondence with NEMOPAY.
- From third-party identity verification and KYC/KYB providers.
- From sanctions screening and adverse media databases.
- From public registers, company registries and other publicly available sources.
- From financial institutions, banks and payment partners involved in processing transactions.
- Through automated means such as cookies, server logs and usage tracking where applicable.
2.4 Purposes for Which We Use Personal Information
- Providing, administering and improving our services.
- Verifying your identity, business information and beneficial ownership in accordance with AML/CTF requirements.
- Processing, monitoring, routing and settling transactions.
- Detecting, preventing and investigating fraud, money laundering, terrorist financing, sanctions violations and other financial crime.
- Conducting sanctions screening, PEP screening and ongoing monitoring of business relationships.
- Meeting our legal and regulatory obligations, including obligations under PCMLTFA, RPAA, PIPEDA and applicable sanctions regimes.
- Filing required reports with FINTRAC and other competent authorities where required by law.
- Responding to service requests, support queries and complaints.
- Protecting the security and integrity of NEMOPAY’s systems and operations.
- Maintaining records as required by applicable law.
2.5 Legal Basis for Processing and Disclosure
NEMOPAY processes personal information on the basis of contract performance, legal and regulatory obligations, and our legitimate interests in operating a compliant financial services business. NEMOPAY may disclose personal information to:
- FINTRAC, the Bank of Canada, law enforcement agencies, courts or other competent authorities where required or permitted by applicable law.
- Regulated banking, payment, compliance and technology service providers engaged by NEMOPAY to deliver services or meet compliance obligations.
- Other financial institutions and payment counterparties in connection with transaction processing.
- External auditors, legal advisors and regulatory consultants under appropriate confidentiality obligations.
NEMOPAY does not sell, rent or trade personal information. Disclosures are made only where required or permitted by applicable law or where necessary to deliver services.
2.6 Canadian Privacy Law
NEMOPAY complies with PIPEDA and, where applicable, provincial privacy legislation. In accordance with PIPEDA, we:
- Collect only the personal information necessary for identified purposes.
- Obtain consent where required by law and inform individuals of the purposes for which their information is collected.
- Protect personal information with appropriate safeguards.
- Retain personal information only as long as necessary for the purposes for which it was collected and to meet legal, regulatory and contractual requirements.
- Provide individuals with reasonable access to their personal information and the right to request correction of inaccuracies, subject to applicable legal limitations.
2.7 International Transfer of Personal Information
NEMOPAY may use service providers located outside Canada to process or store personal information. Where personal information is transferred outside Canada, NEMOPAY will maintain reasonable contractual, organizational and technical safeguards appropriate to the nature of the information. Personal information processed outside Canada may be subject to lawful access under the laws of the jurisdiction in which the service provider operates.
2.8 Retention
NEMOPAY retains personal information for as long as is necessary for the purposes for which it was collected and to satisfy applicable legal, regulatory, contractual and record-keeping requirements. In particular:
- Customer identification and due diligence records are retained for a minimum of five years after the end of the business relationship, in accordance with AML/CTF requirements.
- Transaction records are retained for a minimum of five years from the date of the transaction.
- Correspondence and compliance records are retained for the periods required by applicable law.
2.9 Security
NEMOPAY maintains administrative, technical and physical safeguards appropriate to the nature and sensitivity of the personal information in its custody. These measures are designed to protect personal information against unauthorized access, collection, use, disclosure, loss or destruction. No method of electronic transmission or storage is completely secure. NEMOPAY takes reasonable steps to notify affected individuals and regulators in the event of a privacy breach, as required by applicable law.
2.10 Your Privacy Rights
Subject to applicable law, you have the right to:
- Request access to the personal information NEMOPAY holds about you.
- Request correction of personal information that is inaccurate, incomplete or outdated.
- Withdraw consent where processing is based on consent, subject to legal or contractual limitations.
Requests for access or correction may be limited where disclosure would: interfere with a legal or regulatory obligation; be prohibited by applicable law; or relate to information about another person.
To exercise your privacy rights, please contact: support@nemopayglobal.com
2.11 Privacy Complaints
If you have concerns about NEMOPAY’s handling of your personal information that have not been resolved to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or the relevant provincial privacy regulator.
2.12 Changes to This Policy
NEMOPAY may update this Privacy Policy from time to time. Material changes will be notified on the website with a revised effective date. Continued use of NEMOPAY services after any update constitutes acceptance of the revised policy, to the extent permitted by applicable law.
2.13 Contact
Privacy Officer / Compliance Contact NEMOPAY GLOBAL CORP., 1100 W 73rd Ave, Vancouver, BC V6P 6G5, Canada Email: support@nemopayglobal.com