Effective Date: 26 October 2025

Last Updated: 26 October 2025

1. INTRODUCTION

This Privacy Policy explains how Maven Pay Inc. (“MavenPay”, “we”, “us”, “our”) collects, uses, discloses, and protects your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws.

MavenPay is registered as a Money Services Business (MSB) under Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), registration number C1000000640, supervised by FINTRAC, and has submitted a registration under the Retail Payments Activities Act (RPAA) to the Bank of Canada.

By accessing or using our Services, you agree to this Privacy Policy. If you do not agree, please discontinue use immediately.

2. DATA CONTROLLER AND CONTACT INFORMATION

Maven Pay Inc.

130 Spadina Avenue, Unit 807C

Toronto, Ontario, M5V 2L4, Canada

📧 contact-us@mavenpay.com

Our appointed Data Protection Officer (DPO) oversees all privacy-related matters and may be contacted through the same email address.

3. INFORMATION WE COLLECT

We collect and process the following types of information:

3.1 Information You Provide

• Contact details: name, email, phone number, address
• Identity verification details (for AML/KYC compliance)
• Transaction details and payment information
• Communications and feedback you provide

3.2 Information Collected Automatically

Through cookies and analytics tools, we collect:

• IP address, browser, and device data
• Access times and usage behavior
• Location (where permitted)
• For more details, see our Cookie Policy.

3.3 Information from Third Parties

We may receive limited information from verified financial and compliance partners to fulfill AML, fraud detection, and onboarding obligations.

4. HOW WE USE YOUR INFORMATION

We use personal information to:

• Verify identity and perform AML/KYC checks under FINTRAC rules
• Process and facilitate payments and remittances
• Provide customer support and improve our services
• Comply with legal and regulatory obligations
• Detect, prevent, and report suspicious activity
• Communicate updates, offers, and relevant product information (only with consent)

We do not sell, rent, or trade your personal data.

5. DISCLOSURE OF INFORMATION

We may share information with:

• Licensed financial and payment partners
• Technology and analytics providers acting under confidentiality agreements
• Legal or regulatory authorities when required by law
• Service providers assisting with hosting, communications, or security

In the event of corporate restructuring or merger, we may transfer personal data in accordance with PIPEDA safeguards.

6. CROSS-BORDER DATA TRANSFER

Personal data may be stored or processed in jurisdictions outside Canada.

Where data is transferred internationally, MavenPay ensures adequate data protection measures consistent with Canadian standards.

7. DATA RETENTION

As required under FINTRAC and Canadian law, MavenPay retains:

• Identification and transaction records for a minimum of five (5) years;
• Other personal data only as long as necessary for legitimate business or legal purposes.

Upon expiry of retention periods, data is securely deleted or anonymized.

8. DATA SECURITY

We implement strong security protocols, including:

• Encryption (SSL/TLS) for all transmissions
• Firewalls, access controls, and intrusion detection
• Employee confidentiality training
• Despite these measures, no system is completely secure; users assume risk of transmission over the internet.

9. YOUR RIGHTS

You have the right to:

• Access, correct, or delete your personal data
• Withdraw consent (where processing is based on consent)
• Restrict or object to processing in certain cases
• Request data portability
• File a complaint with the Office of the Privacy Commissioner of Canada (OPC) if you believe your privacy rights are violated.

Requests may be sent to contact-us@mavenpay.com, and responses will be provided within 30 days.

10. ANALYTICS AND TRACKING

We use Google Analytics to understand usage patterns and improve our Services.

All data is processed in anonymized, aggregate form. See our Cookie Policy for full details.

11. CHILDREN’S PRIVACY

MavenPay does not knowingly collect or process data from individuals under the age of majority in their jurisdiction.

If such information is discovered, it will be deleted immediately upon verification.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically.

Significant updates will be communicated before taking effect. Continued use of our Services after an update constitutes acceptance of the revised Policy.

13. GOVERNING LAW

This Privacy Policy is governed by the laws of Canada and the Province of Ontario.

Disputes shall be resolved exclusively in the courts of Ontario, Canada.