Privacy Policy

This Policy applies to Customers ("Users" or "you" or "your"), defined as any Individual Customer or Business Customer utilizing our Services.

By accessing or using our Services, you acknowledge that you have read, understood and agreed to this Policy. If you do not agree with this Policy, you must immediately discontinue all access to and use of the Services.

If you have concerns about any of the terms of this Policy, please contact us so that we can provide further information.

1. Children's Privacy

Children are not eligible to use our Services. We respectfully ask that minors (persons under the age of 13) do not submit any information to us or use our Services. We do not knowingly collect personal information from persons under 13, and we ask that minors do not submit any information to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a person under 13, we will reject the application and delete that information. If you believe we might have any information from or about a child under 13, please contact us at continentalpagoss@gmail.com.

2. Who we are?

The Company is regulated by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA") and, further to PCMLTFA, registered as a Money Service Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) with registration number C100001068.

We determine the purposes and means of processing personal information collected through our Services. We are committed to safeguarding your privacy and handling your information transparently, lawfully, and securely.

If you wish to contact us in relation to questions regarding your personal information, we refer you to the 'CONTACT US' section below.

3. Personal information we collect

We, or our third-party service providers on our behalf, may collect the following categories of personal information:

• Identification and contact data: name, date of birth, address, phone number, email, occupation, nationality, government-issued identification information/identity (ID);
• Compliance and anti-money laundering (AML) information: source of funds, purpose of transactions, beneficiary details, sanctions screening and supporting documentation required by law;
• Photo(s) to compare against provided identity documents (e.g., selfie);
• Technical and usage data: internet protocol (IP) address, browser type, device identifiers, login information, time zone, operating system, login metadata and platform;
• Financial and transaction data: details of the transactions you carry out when using our Services, including geographic location, currency, amounts, and beneficiary details;
• Communications and support data: records of correspondence, complaints, chat logs, inquiries, or feedback submitted via email or in-app support;
• Where required by law or to meet anti-money laundering and fraud prevention obligations, we may collect additional information.

You represent and warrant that all personal information provided to us is true, complete and accurate, and you bear all risk arising from any inaccuracy or omission.

4. How we collect information

a) Information you provide to us

We collect and store any information you provide directly to us in person or through offline correspondence. This includes information given when you:

• Complete physical transaction forms or update your account information;
• Provide financial information, such as bank account details or the reason for payment;
• Submit identification for high-value or high-volume transactions to meet AML obligations under applicable law;
• Communicate with us regarding dispute resolutions or service problems.

b) Information from other sources

We may also obtain information about you from third parties such as identity verification providers and credit bureaus to meet AML/Know-Your-Customer (KYC) obligations.

5. Purposes and Legal Bases for Processing

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use the following information to:

• provide the Services and customer support;
• process and complete Transactions and send related notices;
• verify your identity and meet AML/CFT obligations (PCMLTFA/FINTRAC guidance);
• manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
• detect, prevent or remediate violations of policies;
• improve the Services by customizing your user experience;
• measure the performance of the Services and improve their content and layout;
• maintain accurate business and transaction records as required by FINTRAC;
• provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences;
• contact you at any telephone number, by placing a voice call or through text (SMS) or WhatsApp or email messaging;
• perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties;
• meet legal and regulatory reporting duties.

The Company does not sell or share user personal data with third parties for their direct marketing. Our legal bases include: your consent; legal obligations; and legitimate interests (fraud prevention, security, and service improvement). We will not use personal information for a new purpose without obtaining consent or as otherwise permitted by law.

6. Marketing

We do not sell or rent your personal information to third parties for their marketing purposes. We may combine your personal information with information we collect from other companies and use it to improve and personalize the Services, content, and advertising.

If you have agreed to receive such marketing materials, you may always opt out at a later date. You have the right at any time to stop us from contacting you for marketing purposes.

If you no longer want to receive marketing-related emails from us, you may opt-out by following the instructions in any such email. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt-out, we may still send you important administrative messages, from which you cannot opt-out.

7. Disclosure of personal information

We may share your personal information with:

• Third-Party Financial Institution(s), to execute Transactions and deliver the Services;
• identity verification and fraud prevention providers to fulfill KYC/AML obligations;
• regulatory and law enforcement authorities including FINTRAC, as required by law;
• professional advisers, auditors, and service providers under strict confidentiality; and
• affiliates or successors in the event of a merger or restructuring.

All third-party partners are contractually required to maintain equivalent privacy and security standards.

8. Who handles personal information?

Most personal information that the Company collects is processed by our own employees, but for some purposes, we rely on third parties. We collect and process personal information using the Company employees who have received training in the importance of security, confidentiality, and privacy.

9. Data Security

We maintain technical, organizational, and administrative safeguards to protect your data, including role-based access controls and employee confidentiality training. If a privacy breach creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada (OPC) as required by the Personal Information Protection and Electronic Documents Act (PIPEDA).

10. Access and corrections

You have the right to request access to your personal information, correct inaccuracies, withdraw consent (subject to legal and contractual limits), request deletion where permissible, and complain to the Office of the Privacy Commissioner of Canada. Requests can be submitted to continentalpagoss@gmail.com.

11. Retention of personal information

We retain personal information:

• for a minimum of five (5) years following the end of a business relationship or transaction, as mandated by FINTRAC;
• for as long as necessary to fulfill the purposes for which it was collected; and
• as otherwise required by law, taxation, audits, or investigations.

At the end of the retention period, information is securely destroyed or anonymized.

12. International Transfers

Your information may be transferred and processed in jurisdictions outside of Canada where privacy laws may offer different levels of protection. We ensure that appropriate contractual and technical safeguards are in place to protect your data, consistent with Canadian standards.

13. Changes to this Policy

We may amend this Policy to reflect legal or operational changes. Updates will be made available via email or SMS.

14. Contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or the Company's handling of your personal information, you may contact us using the details below:

We will acknowledge and respond to all legitimate requests within a reasonable timeframe and in accordance with applicable data protection laws.