Payments International Inc.
Data Protection Policy

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Last Updated July 29^th, 2025

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Payments International Inc. is committed to handling your personal data accurately and in accordance with the highest standards of Data Protection Law.

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When this policy mentions “Payments International Inc.,” “we,” “us,” or “our,” it refers to the company Payments International Inc. (registered in Ontario, Canada) that you have contacted or been contacted by. When this policy mentions “Global Currency Exchange Network LTD T/A Global Currency Exchange Network LTD T/A GC Partners,” it refers to the company that provides payment services to you and with which you will be contracted for these services.

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This Data Privacy Policy (“Policy”) describes the types of personal data Payments International Inc. may collect about you and how we manage your information. It also explains the steps we take to protect your data and outlines your rights regarding the personal data we hold. For the purposes of Data Protection Law, Payments International Inc. will be considered a data controller of your personal data. Please see the “Definitions” section to understand the meaning of certain terms used in this Policy.

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Please note that data is retained for at least 5 years, in accordance with regulatory requirements.

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We adhere to applicable data protection laws, including PIPEDA (Canada), GDPR (EU/UK), and other local regulations as required. 

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What types of personal data do we collect?

Personal data such as your name, residential address, date of birth, telephone number, mobile number, email address, occupation, bank account details, information in your identification documents (e.g., passport, social insurance number, or other tax identification number), utility bill, and/or driver’s licence, visa, and copies of any other documents you provide to verify your age or identity so we can comply with our ‘Know Your Customer’ checks.

When you initiate transactions with us, we need to gather information about the other parties involved, including the beneficiary's name, account number, and address (“Beneficiary Details”), the source of funds, the reason for the transaction, and the devices and payment methods used to complete the transaction. By providing this information to Payments International Inc., you agree that you have obtained the payee’s consent for their personal data to be processed by Payments International Inc. in its role as a Processor. This is necessary for us to make a payment to them, and you confirm that you know they agree or that you are otherwise authorized to give us this information and will inform them of the contents of this Privacy Policy.

If you are using our services on behalf of a business entity, we need to collect information about the business, including its organisational structure and details of involved individuals, such as their name, address, job title of the signatory, email, phone number, identity documents of the signatory, proof of bank account details, and similar information for other authorized personnel. We may also gather entity formation documents or other corporate records, such as company registration details.

Payments International Inc. is required under AML/CTF Laws to collect the personal data of individuals who ultimately own or control corporate clients, directly or indirectly (“Beneficial Owners”). This ensures they have the authority to act on behalf of the business entity and provide that information. Such information may include the Beneficial Owner’s name, date of birth, title, mailing address, phone number, email address, nationality, occupation, and social security number or other tax identification number. You confirm that you know the Beneficial Owners agree or that you are otherwise permitted to give us this information and will inform the Beneficial Owners of the contents of this Privacy Policy.

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When do we collect personal data about you?

Payments International Inc. only collects Personal Data when it is reasonable and practicable to do so, or when authorised by applicable laws.

We collect Personal Data when you:

• Complete an application or register for an account.
• Communicate with Payments International Inc. by phone or email.
• Make payments using the online platform.
• Report a problem, submit a query, or file a complaint about our Services.
• When you download a copy of our marketing materials online.
• Grant a third-party permission (e.g., a Referring Partner) to share your personal data with us.
• Connect with us via your social media account.

Information gathered from third parties

We gather personal information about you from our service provider, Global Currency Exchange Network LTD T/A GC Partners, in accordance with our terms of business.

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The "Lawful basis" we depend on to process your personal data

Data Protection Law details the main lawful bases that organizations, businesses, and governments can rely on to collect and process personal data. Money Mechanix primarily depends on the following:

• Consent: processing your personal data only when you have explicitly authorised us to do so.
• Performance of a Contract: handling your personal data to meet our contractual duties with you.
• Legal Obligations: processing your personal data when required by compliance with legal or regulatory obligations to which we are subject.
• Legitimate Interests: processing your personal data when we or a third party have a legitimate interest. We ensure we consider and balance any potential impact on your rights before processing your personal data for our legitimate interests. If our interests are outweighed by an adverse effect on your privacy rights, we will not process your personal data.

How do we use your information?

We collect and use data lawfully at all times. We use your personal information to provide details about the services you've requested or the products you've ordered. Data is collected and used legally when our interests do not outweigh your interests, as explained below. 

We use your data to:

• With Service Providers: For payment processing, verification, support, etc.
• With Regulatory Bodies: As required to meet legal and compliance obligations.
• With Business Partners: When facilitating services on your behalf.
• In Business transfers: In the event of a merger or acquisition.
• To Prevent Fraud or Misuse: With authorities or fraud agencies if misuse is suspected.
• With Your Consent: Where you’ve authorized a third-party integration or referral. 

With your consent, we will:

• Send you marketing communications.
• Share your personal data with others or organizations when you request us to do so.
• Process any special categories of personal data upon your request.
• How long do we keep your information?

Other reasons to retain data.

• Until your query is resolved.
• For as long as you may legally file a claim against us
• After your account has been closed or otherwise terminated in accordance with our legal and regulatory requirements.

How We Protect Your Personal Data

Data shared with Service Provider Global Currency Exchange Network LTD T/A GC Partners is secured and used solely for the authorized purpose as outlined here. As a data processor, Global Currency Exchange Network LTD T/A GC Partners may engage with the Sub-Processors listed on the following “Technology Partners” webpage, which may be updated from time to time.

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What are your rights?

Under PIPEDA (Canada), GDPR (EU/UK), and other local regulations as required, you have:

• The right to be informed
• The right of access
• The right of rectification
• The right of erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision-making and profiling

Fraud prevention and anti-money laundering procedures

We may use your personal details to carry out identity checks as required by law, as a measure to prevent money laundering.

The personal data we collect from you at the application stage, or any subsequent stage may be shared with fraud prevention agencies. We are required by law to review transactions and report any that may be suspected of being connected to money laundering activities.

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Automated decision making

We may process your personal data automatically to assess your personal situation, such as transactional history and account-opening anniversary events. We may use this approach to determine which marketing communications are suitable for you, analyze statistics, and assess risks.

This is all based on our ‘legitimate interests’ to protect our business and to develop and improve our products and services. If we use automated decision-making, including profiling, to evaluate your application, this will be done because it is necessary to fulfill the contract.

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Sharing your information

We will not sell, share, or rent your information to others except as outlined in this policy.

We may share your information with:

• Organizations that offer operational services related to the services you use. Our strategic partners are, when required by law, authorized and regulated to the necessary standards.
• The purchaser of the company or its assets in the event of a sale.

Although our website may have links to other sites, we are not responsible for their privacy practices or content.

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Transferring your information overseas

Your information may be stored or processed in jurisdictions outside your country, including the United Kingdom, the United States, and the European Union, where data protection laws might differ. We ensure appropriate safeguards, such as standard contractual clauses, are in place for international transfers.

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Opting out of marketing preferences

You may choose to stop receiving all marketing communications from us and our strategic partners at any time by contacting us.

If you choose to receive email correspondence, each email we send includes an unsubscribe link. Using this link will prevent us from sending any unsolicited mail to your registered email address.

Communications regarding changes to existing products or services, as well as our terms, conditions, and policies, are important and sometimes critical. You may not opt out of receiving these communications.

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Reviewing, correcting, or updating your personal information

If any of your details are recorded incorrectly and need updating, please contact us by email with the necessary changes and the reasons for them. Proof of address change may be required.

Alternatively, you can contact the Data Protection Officer (DPO) regarding access to your personal data or any part of this privacy policy by emailing DPO@piifx.com.

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Definitions

“Controller or joint controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Personal Data” means information that can be used to directly or indirectly identify a living person. It is also known as ‘personal information’, ‘personally identifiable information’, and ‘non-public personal information’.

“Processor” means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the Controller.

“Process, Processing, Processed” means the operation or set of operations performed on data. This includes collecting, viewing, recording, organising, structuring, storing, using, and destroying.

“Security Breach” means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information. A Security Breach includes a “personal data breach,” a “breach of security of a system,” or similar term (as defined in any other Applicable Data Protection Law), as well as any other event that compromises the security, confidentiality, or integrity of Personal Information.

“Services” refers to foreign exchange and international payment services offered by Global Currency Exchange Network LTD T/A GC Partners.

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Changes to the Privacy Policy

If we update our privacy policy, we will notify you by email at your registered address, so you are always aware of what information we collect, how we use it, and under what conditions, if any, we disclose your personal data.

If we want to change how we use personal information we have already collected about you, we will notify you by email. If you have not provided us with your email address, you must regularly check the website for the most current version of the privacy policy. It is then your decision whether to allow us to use your information in this manner. We will use information in accordance with the most recently published privacy policy.

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Complaints

If you have any complaints about this policy notice or the personal data we hold about you, please don't hesitate to contact us at compliants@piifx.com.

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