Privacy Policy

1.1 This Privacy Policy explains how Pure Payments collects, uses, discloses, retains, protects, and transfers personal information when you:

• Visit the Website;
• Register for or use the Pure App;
• Use our Services listed under section 3.1 of Terms of Service;
• Communicate with us;
• Submit a complaint.

1.2 This Privacy Policy applies together with our Terms of Service, Crypto Terms, Cookie Policy, Complaints Policy, and other policies published on the Website.

1.3 If you do not agree with this Privacy Policy, you should not use the Website, Pure App, or Services.

Depending on how you interact with us and the Services you use, we collect and process the following personal information:

2.1 Identity, contact, and verification information, including identification and contact details, government issued identification documents, and information used to verify your identity. Where biometric verification is used, this includes selfies, liveness check images or videos, and facial biometric identifiers or templates used to verify your identity and prevent fraud.

2.2 Business and financial information, including information about business activities, ownership and control, directors, beneficial owners, and authorised representatives, bank and payment details, and information and documents concerning your source of funds and source of wealth.

2.3 Transaction and service information, including payment instructions, transaction history, sender and recipient details, wallet addresses, blockchain transaction identifiers, conversion details, fees, and records relating to staking allocations, rewards, and redemptions, where those services are used.

2.4 Compliance and risk information, including verification results, sanctions and politically exposed person screening results, relevant adverse media information, risk assessments, transaction monitoring records, and information generated during fraud-prevention, financial crime, and compliance investigations.

2.5 Technical and communications information, including device and connection information, IP addresses, authentication and security records, information about your use of the Website and Pure App, and emails, in-app chats, support requests, complaints, and related correspondence.

2.6 Information about legal entities falls within this Privacy Policy to the extent that it identifies or relates to an individual, such as a director, beneficial owner, or authorised representative.

We collect personal information:

• Directly from you when you register, complete onboarding, submit documents, make a transaction, or contact us;
• Automatically through the Website cookies and Pure App;
• From Third-Party Payment Providers, banks, payment institutions, correspondent banks, and payment systems;
• From Third-Party Service Providers engaged for identity verification, screening, fraud prevention, or compliance;
• From publicly available sources, where permitted by law;
• From regulators, law enforcement authorities, financial institutions, or other competent authorities.
• From blockchain networks, blockchain analytics providers, virtual currency service providers, and other third parties, where necessary to provide crypto asset services, prevent financial crime, or comply with applicable law

We use personal information to:

• Assess whether you are eligible to use the Services;
• Open, administer, and manage your business relationship with us;
• Verify your identity and, for legal entities, verify ownership and control;
• Conduct sanctions, politically exposed person, adverse media, fraud, and other risk screening;
• Process fiat payments, transfers, deposits, and withdrawals;
• Prevent, detect, and investigate fraud, money laundering, terrorist financing, sanctions evasion, and other unlawful activity;
• Comply with applicable Canadian AML/CTF, sanctions, tax, regulatory, recordkeeping, and reporting requirements;
• Respond to enquiries, support requests, and complaints;
• Operate, secure, maintain, and improve the Website and Pure App;
• Detect technical issues, prevent misuse, and protect the security of our systems;
• Communicate with you about the Services, security, changes to terms, fees, limits, and service availability;
• Exercise or defend legal rights;
• Meet audit, recordkeeping, and regulatory obligations.

Where applicable law requires a legal basis for processing, we rely on one or more of the following:

• Performance of a contract: to provide the Services you request and administer business relationship with you.
• Legal obligation: to comply with AML/CTF, sanctions, tax, regulatory reporting, recordkeeping, and other legal requirements.
• Legitimate interests: to prevent fraud, secure our systems, improve the Services, manage risk, respond to complaints, and protect our legal rights.
• Consent: where required, for certain cookies or other optional processing.
• Public interest or official authority: where processing is required by a competent authority or permitted by applicable law.

Where we rely on consent, you may withdraw it at any time, subject to legal and contractual restrictions. Withdrawal of consent does not affect processing carried out before withdrawal.

We may disclose personal information to:

• Third-Party Payment Providers, including banks, payment institutions, electronic money institutions, payment processors, correspondent banks, and payment systems, to process payments, hold or safeguard funds, execute transfers, and comply with financial crime requirements;
• Third-Party Service Providers, including identity verification, screening, fraud prevention, cloud hosting, communication, and IT security providers;
• Professional advisers, including lawyers, auditors, accountants, and insurers;
• Regulators and authorities, including FINTRAC, tax authorities, financial intelligence units, law enforcement agencies, courts, and other competent authorities, where required or permitted by law;
• Other financial institutions, where necessary to execute, investigate, or recall a payment;
• Affiliates, where necessary for administrative, compliance, technology, or business support purposes;
• Other recipients, where you consent or where disclosure is otherwise permitted or required by law.

7.1 Pure Payments is established in Canada. Your personal information may be processed in Canada and may be transferred to, stored in, or accessed from other countries.

7.2 Because our Service Providers and their subcontractors may be located outside your country, your personal information may be transferred to jurisdictions with different data protection laws.

7.3 Where required by applicable law, we use appropriate safeguards for international transfers, which may include standard contractual clauses, adequacy decisions, derogations, or other lawful transfer mechanisms.

7.4 By using the Services, you acknowledge that your personal information may be transferred internationally as described in this Privacy Policy.

8.1 We retain personal information only as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

8.2 Retention periods depend on the nature of the information, the Services used, regulatory requirements, and our need to establish, exercise, or defend legal rights.

8.3 As a Canadian money services business, we may be required to retain certain customer identification, transaction, beneficial ownership, and compliance records for at least five years from the relevant date under applicable Canadian law.

8.4 We may retain information for longer where necessary to:

• Comply with legal, regulatory, or tax obligations;
• Respond to regulatory or law enforcement requests;
• Resolve complaints or disputes;
• Prevent fraud or financial crime;
• Establish, exercise, or defend legal claims.

9.1 We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, destruction, or misuse.

9.2 Safeguards may include access controls, encryption, secure networks, authentication measures, monitoring, staff training, and contractual protections with service providers.

9.3 No method of transmission or storage is completely secure. You are responsible for keeping your login credentials, passwords, devices, and account access secure.

9.4 If you believe your account has been accessed without authorization, or if you become aware of a security incident, contact us immediately at support@purewallet.global.

10.1 Subject to applicable law, you may have the following rights:

• Access the personal information we hold about you;
• Request correction of inaccurate or incomplete personal information;
• Request deletion or erasure of personal information, where applicable;
• Object to or restrict certain processing, where applicable;
• Withdraw consent where processing is based on consent;
• Request a copy of personal information you provided to us, where applicable;
• Receive information about the purposes, categories, disclosures, and retention of your personal information;

10.2 We may need to verify your identity before responding to a request.

10.3 We may refuse or limit a request where permitted or required by law, including where compliance would breach legal obligations, reveal confidential information, prejudice an investigation, or affect the rights of another person.

10.4 To exercise your rights, contact us at support@purewallet.global.

11.1 The Website and Pure App may use cookies, pixels, local storage, SDKs, and similar technologies to operate the services, remember preferences, maintain security, analyze usage, and improve performance.

11.2 We may use strictly necessary cookies without consent where permitted by law. Non-essential cookies may be used only with your consent, where required by applicable law.

11.3 Further information is set out in our Cookies Policy.

12.1 We may use automated tools and risk-scoring systems to support identity verification, screening, fraud prevention, transaction monitoring, and risk management.

12.2 Automated tools may assist our decisions, but significant decisions with legal or similarly significant effects are generally subject to human review, where required by applicable law.

12.3 Where required by law, you may request information about the logic involved, the significance and consequences of processing, and human intervention in relation to an automated decision.

13.1 The Services are not permitted for individuals under 18 years of age.

13.2 We do not knowingly collect personal information from individuals under 18.

13.3 If you believe that a person under 18 has provided personal information to us, contact us at support@purewallet.global and we will take appropriate action.

14.1 We may update this Privacy Policy from time to time.

14.2 We will publish the current version on the Website and indicate the effective date.

14.3 Where required by law, we will notify you of material changes before they take effect.

14.4 Continued use of the Website or Pure App after the effective date of an updated Privacy Policy constitutes acceptance of the updated version, to the extent permitted by law.

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact:

Pure Payments Inc.

30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario, Canada

Email: support@purewallet.global

Website: https://purewallet.global/