Privacy Policy

1. Introduction

Finglobe.io ("we," "us," "our," or "Company") is committed to protecting your privacy and ensuring you have a positive experience on our website and when using our financial services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (finglobe.io) and use our services.

We are a registered Money Services Business (MSB) licensed by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). This Privacy Policy complies with Canadian federal and provincial privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), and the General Data Protection Regulation (GDPR) for users in the European Union.

2. Information We Collect

We collect information you provide directly and information collected automatically:

2.1 Information You Provide Directly

• Account Registration: Full name, email address, phone number, company name, job title, and business address
• Financial Information: Banking details, transaction history, account balances, and payment methods
• Identity Verification: Government-issued ID, proof of address, and other KYC/AML documentation
• Communication: Messages, inquiries, and feedback submitted through our website or support channels
• Demo Requests: Name, email, company size, and preferred meeting time

2.2 Information Collected Automatically

• Device Information: IP address, browser type, operating system, and device identifiers
• Usage Data: Pages visited, time spent, links clicked, and referral sources
• Cookies and Tracking: Session cookies, persistent cookies, and similar tracking technologies
• Location Data: Approximate geographic location based on IP address (not precise GPS)

3. How We Use Your Information

We use collected information for the following purposes:

• Providing, maintaining, and improving our financial services and website
• Processing transactions and sending related confirmations and receipts
• Verifying your identity and conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
• Communicating with you about account updates, security alerts, and service changes
• Responding to your inquiries and providing customer support
• Sending marketing communications (with your consent)
• Complying with legal obligations and regulatory requirements
• Detecting, investigating, and preventing fraud and financial crime
• Analyzing usage patterns to improve our services and user experience

4. Legal Basis for Processing (GDPR)

For users in the EU, we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide financial services you have requested
• Legal Obligation: Compliance with FINTRAC, AML/KYC regulations, and financial services laws
• Legitimate Interest: Fraud prevention, security, and service improvement
• Consent: Marketing communications and optional analytics (with your explicit consent)

5. Information Sharing and Disclosure

We do not sell or rent your personal information. However, we may share information in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who assist us in operating our website and providing services, including payment processors, email service providers, and analytics platforms. These providers are contractually obligated to use your information only as necessary to provide services to us.

5.2 Legal Requirements

We may disclose information when required by law, court order, or government request, including to FINTRAC, law enforcement, and regulatory authorities.

5.3 Business Transfers

If we are involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.

5.4 Aggregated Data

We may share aggregated, de-identified data that cannot reasonably be used to identify you with third parties for research, marketing, analytics, and other purposes.

6. Data Security

We implement comprehensive security measures to protect your personal information, including:

• End-to-end encryption for data in transit and at rest
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Secure data centers with restricted access
• Employee training on data protection and privacy
• Incident response procedures for potential breaches

While we strive to protect your information, no security system is impenetrable. We cannot guarantee absolute security, and any transmission of data is at your own risk.

7. Your Privacy Rights

7.1 Canadian Rights (PIPEDA)

Under PIPEDA, you have the right to:

• Access your personal information held by us
• Request correction of inaccurate or incomplete information
• Understand how your information is being used
• File a complaint with the Office of the Privacy Commissioner of Canada

7.2 EU Rights (GDPR)

If you are located in the EU, you have the following rights:

• Right to Access: Obtain a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal retention requirements)
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Opt-out of marketing communications and certain processing activities
• Right to Lodge a Complaint: File a complaint with your local data protection authority

7.3 How to Exercise Your Rights

To exercise any of these rights, please contact us at [email protected] with your request. We will respond within 30 days (or as required by applicable law).

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, remember preferences, and analyze website usage. You can control cookie settings through your browser preferences. Disabling cookies may limit functionality of our website.

• Essential Cookies: Required for website functionality and security
• Preference Cookies: Remember your settings and preferences
• Analytics Cookies: Help us understand how you use our website
• Marketing Cookies: Used for targeted advertising (with consent)

9. Data Retention

We retain your personal information for as long as necessary to provide services, comply with legal obligations, and resolve disputes. Retention periods vary based on the type of information:

• Account Information: Retained for the duration of your account plus 7 years for regulatory compliance
• Transaction Records: Retained for 7 years per FINTRAC requirements
• KYC/AML Documentation: Retained for 7 years after account closure
• Marketing Communications: Retained until you unsubscribe
• Website Analytics: Retained for 24 months

10. International Data Transfers

Your information may be transferred to, stored in, and processed in Canada and other countries where we operate. These countries may have different data protection laws than your country of residence. By using our services, you consent to such transfers. We implement appropriate safeguards, including Standard Contractual Clauses and Binding Corporate Rules, to protect your information.

11. Children's Privacy

Our services are not directed to children under 18 years of age. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information and terminate the child's account.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of external sites. We encourage you to review the privacy policies of any third-party services before providing your information.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, and other factors. We will notify you of material changes by updating the "Last Updated" date and, where appropriate, by sending you an email notification. Your continued use of our services constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Data Protection Authority

For EU residents, you may also lodge a complaint with your local data protection authority or the Canadian Office of the Privacy Commissioner of Canada.