1. Controller Of Your Data
The data controller for the MavenPay financial service is Maven Pay Inc., a company incorporated in Canada, with its registered office at 130 Spadina Avenue, Unit 807C, Toronto, ON M5V 2L4, Canada. Maven Pay Inc. is registered as a Money Services Business and provides the regulated currency exchange, money remittance, and payment services that you use as a MavenPay customer.
Privacy Officer contact: compliance@mavenpay.com.
For our concierge travel and flight bookings, the data controller is Maven Pay Concierge Private Limited, a company incorporated in Singapore, with its registered office at 2 Venture Drive, #19-21, Vision Exchange, Singapore 608526. For our eSIM data and mobile top-up services, the data controller is MavenPay Concierge Broker F.Z.E, a company incorporated in the United Arab Emirates, with its registered office at Ajman Free Zone C1 Building, Ajman Free Zone Business District, B.C. 1306178, UAE. Each of these controllers honours the same standards described in this policy.
2. Data We Collect
Account data. Email address, your password in hashed form, and the type of account you opened.
Identity verification data. Government-issued identity documents, your address, and information about the ultimate persons who own or control your account. This is collected to comply with the law that governs money services businesses in Canada and to meet equivalent obligations in the jurisdictions where we serve you.
Transaction data. The amount, currency, counterparty, timestamp, and origin and destination jurisdiction of every payment you instruct.
Service data. The pages and features you use inside the MavenPay product, the device and operating system you use to access it, the network address you connect from, and the timestamps of your actions. We use this data only for fraud detection, sanctions screening, security, and to make the product work correctly.
Customer service data. The messages, calls, and chats you exchange with our team, and the metadata of those interactions.
Travel and concierge data, where you use those services. Passenger names, dates of birth, passport details, traveller preferences, dietary requirements, flight numbers, hotel bookings, and ground-transfer details, collected only for the booking you instruct.
eSIM and mobile top-up data, where you use those services. The phone number to be topped up, the operator, the country, the device identifier where the eSIM is provisioned, and the delivery timestamp.
3. Why We Collect It
To open and maintain your account.
To verify your identity and screen you against the sanctions and watchlists that the law requires us to screen against.
To process the payments, transfers, currency exchanges, card transactions, crypto transactions, travel bookings, and eSIM top-ups that you instruct.
To detect and prevent fraud, money laundering, terrorist financing, and other illicit activity.
To meet our record-keeping, reporting, and audit obligations under the law that applies to a regulated financial service.
To improve the product, fix bugs, and serve you in the language you chose.
To respond to your support requests and to investigate disputes you raise.
4. How We Share Your Data With Service Providers
Maven Pay Inc. uses Plaid Inc. to gather your data from financial institutions when you choose to connect a bank account. By using the bank-connection service, you grant Maven Pay Inc. the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid End User Privacy Policy at https://plaid.com/legal/#end-user-privacy-policy and the Plaid End User Services Agreement at https://plaid.com/legal/#end-user-services-agreement-us.
Maven Pay Inc. uses Bridge for certain stablecoin settlement rails and for regulated identity verification where Bridge is the regulated party. Where your activity is routed through Bridge, you also agree to the Bridge User Agreement and Bridge Privacy Policy applicable to your jurisdiction, available at https://www.bridge.xyz/legal/overview. Maven Pay Inc. is not authorised as a crypto-asset service provider under the European Union Regulation 2023/1114 on markets in crypto-assets. For the Bridge-routed services in scope of that regulation, Bridge is the regulated party in that jurisdiction.
Maven Pay Inc. also engages other regulated infrastructure providers for card issuing, multi-currency banking, broader crypto trading and settlement, sub-account custody, yield products, and travel inventory. These providers process data on documented instructions from Maven Pay Inc. only. Their identity is disclosed to you at the point where you activate the relevant service and in the account-opening documentation for that service.
We do not sell your data to advertisers, brokers, or any other third party.
5. Where We Process Your Data Within The Group
Maven Pay Inc. operates through a small number of registered group operating entities that provide engineering, customer-support, and regional partner-coordination services. Each of these entities acts as a processor under documented instructions from Maven Pay Inc. and processes only the data needed for the function it performs.
Maven Pay Inc. (US), 1111B S Governors Avenue, STE 26126, Dover, DE 19904, USA, provides marketing and business-development support for North America.
Maven Pay Limited, 21 Ellis Street, London, SW1X 9AL, United Kingdom, provides marketing, business-development, and partner-coordination support for the United Kingdom and Europe.
MavenPay OÜ, Veskiposti tn 2-1002, 10138 Tallinn, Estonia, provides engineering, product, and EU-resident data-processing support for the European Union.
Maven Pay Technologies Limited, Unit 1411, 14/F, COSCO Tower, 183 Queen's Road Central, Sheung Wan, Hong Kong, provides engineering and partner-coordination support for the Asia Pacific region.
Maven Pay Concierge Private Limited, 2 Venture Drive, #19-21, Vision Exchange, Singapore 608526, provides concierge travel and flight booking as the data controller for those services.
MavenPay Concierge Broker F.Z.E, Ajman Free Zone C1 Building, Ajman Free Zone Business District, B.C. 1306178, UAE, provides eSIM and mobile top-up as the data controller for those services.
6. International Data Transfers
Your personal data may be transferred between the countries listed above so that we can run the service you signed up for and meet our record-keeping obligations. We rely on Standard Contractual Clauses approved by the European Commission, the United Kingdom International Data Transfer Addendum, and equivalent transfer mechanisms in other jurisdictions to cover transfers outside the European Economic Area and the United Kingdom. You can request a copy of the relevant clauses by writing to compliance@mavenpay.com.
We have appointed a representative in the European Union under Article 27 of the General Data Protection Regulation. The current designation is available on request from compliance@mavenpay.com.
7. Your Rights
Access. You can ask us for a copy of the personal data we hold about you.
Rectification. You can ask us to correct inaccurate or incomplete personal data we hold about you.
Erasure. You can ask us to delete personal data we hold about you. We may have to keep some of it for the period the law requires us to keep records of a regulated financial service.
Portability. You can ask us to give you a copy of the personal data you provided to us in a structured, commonly used, machine-readable format.
Objection. You can object to any processing we carry out for our own legitimate interests, including direct marketing.
Restriction. You can ask us to limit how we use your personal data while a request from you is being resolved.
Withdraw consent. Where the legal basis for our processing is your consent, you can withdraw it at any time without affecting the lawfulness of the processing carried out before you withdrew it.
Lodge a complaint. You can lodge a complaint with the data-protection authority of your country of residence, your place of work, or the place where the issue arose. Lodging a complaint with an authority does not stop you from exercising any of the other rights above.
To exercise any of these rights, write to compliance@mavenpay.com. We respond within thirty days. Where a request is complex or where we receive a high number of requests at once, we may extend that period by up to sixty further days and tell you why.
8. How Long We Keep Your Data
Identity verification data and transaction data are kept for the period the law requires for a regulated money services business, typically up to seven years after you close your account.
Customer service records are kept for up to five years after the last interaction.
Marketing data is kept until you opt out, or for twenty-four months of inactivity, whichever comes first.
Travel and concierge booking data is kept for the period required by the travel-industry rules of your jurisdiction, typically up to six years.
eSIM and mobile top-up records are kept for up to two years after the last top-up.
9. Legal Bases We Rely On
Performing the contract you entered into with us when you opened your account.
Complying with a legal obligation that applies to a regulated financial service, including identity verification, sanctions screening, transaction monitoring, recordkeeping, and regulatory reporting.
Our legitimate interest in preventing fraud, securing the service, improving the product, and responding to your support requests, where that interest is not overridden by your rights.
Your consent, where you have given it for a specific purpose. You can withdraw it at any time.
10. Automated Decision-Making
We use automated systems to detect fraud, screen against sanctions and watchlists, score the risk of a transaction, and prioritise customer-support requests. Where an automated decision has a significant effect on you, you have the right to ask for human review, to express your point of view, and to contest the decision. Write to compliance@mavenpay.com.
11. Children
Where you open an account on behalf of a household member, you act as the responsible adult for that account and you agree to keep that household member's personal information accurate and up to date. We collect only what we need to provide the requested service to that household member.
13. Changes To This Policy
We may update this policy from time to time. When we make a material change, we will notify you in the product or by email at least thirty days before the change takes effect. The current version of this policy and its effective date are shown at the top of this page.
14. Contact
For any privacy question, request, or complaint, write to compliance@mavenpay.com.
Mailing address: Privacy Officer, Maven Pay Inc., 130 Spadina Avenue, Unit 807C, Toronto, ON M5V 2L4, Canada.
