Privacy Policy

1. Overview and Commitment to Privacy

91 Payments Limited ("91 Payments", "we", "our", or "us") recognizes the importance of privacy and is committed to safeguarding the personal information of all individuals and entities with whom we interact. We understand that maintaining trust requires transparency, accountability, and the responsible handling of personal data.

As a Canadian Money Services Business, we operate within a highly regulated environment and adhere to strict privacy, confidentiality, and data protection standards. Our privacy practices are guided by applicable Canadian laws, including the Personal Information Protection and Electronic Documents Act, as well as regulatory obligations enforced by the Financial Transactions and Reports Analysis Centre of Canada.

This Privacy Policy outlines how we collect, use, process, disclose, store, and protect personal information across all our operations, including our website, digital platforms, and financial services.

2. Scope and Application

This Privacy Policy applies to all personal information collected, used, or disclosed by 91 Payments Limited in the course of its business activities. This includes information relating to:

• Individual customers using our services
• Merchants and corporate clients
• Representatives, directors, and beneficial owners of businesses
• Website visitors and prospective customers
• Individuals interacting with us through support channels, events, or communications

Where 91 Payments Limited processes personal information on behalf of a Merchant, we act as a data processor/service provider, and such Merchant remains the data controller responsible for determining the purposes and means of processing.

This Policy applies regardless of the method of interaction, including online platforms, mobile applications, email communications, and in-person engagements.

3. Accountability and Governance

91 Payments Limited maintains full accountability for personal information under its custody and control. To ensure compliance with applicable laws and internal standards, we have implemented a comprehensive privacy governance framework, which includes:

• Appointment of a Data Protection Officer (DPO) responsible for overseeing privacy compliance
• Development and enforcement of internal privacy policies and procedures
• Regular staff training on data protection, confidentiality, and information security
• Implementation of access controls and role-based data handling protocols
• Periodic audits and assessments to evaluate privacy and security practices

All employees, contractors, and third-party service providers are required to adhere to strict confidentiality obligations.

4. Categories of Personal Information Collected

We collect personal information that is necessary and proportionate for the provision of our services and compliance with legal obligations.

5. Methods of Collection

We collect personal information through lawful and fair means, including:

• Direct collection during account registration and onboarding
• Information provided during transactions and service usage
• Automated collection through cookies and analytics tools
• Third-party sources such as identity verification providers, financial institutions, and public records
• Information received from Merchants or partners

We ensure that individuals are informed of the purpose of collection at or before the time of data collection.

6. Purposes of Processing

Personal information is collected and processed for clearly defined purposes, including:

7. Legal Basis for Processing

We process personal information on the following legal grounds:

• Consent, where individuals provide permission
• Contractual necessity, to fulfill service obligations
• Legal obligations, including regulatory compliance
• Legitimate business interests, such as fraud prevention, system security, and operational efficiency

8. Disclosure of Personal Information

We may disclose personal information only where necessary and in accordance with applicable laws.

All third parties are contractually required to protect personal information.

9. International Data Transfers

Personal information may be transferred, processed, or stored outside Canada, including in jurisdictions with different data protection laws.

Where such transfers occur, we implement safeguards such as contractual protections and risk assessments to ensure an adequate level of data protection.

10. Data Retention

We retain personal information only for as long as necessary to fulfill identified purposes and comply with legal obligations.

In accordance with Canadian AML requirements, certain records may be retained for a minimum of five (5) years following the end of a business relationship or completion of a transaction.

11. Safeguards and Security Measures

We employ comprehensive safeguards, including:

• Encryption and secure data transmission
• Network security controls and firewalls
• Access restrictions and authentication protocols
• Continuous monitoring and system audits

Despite these measures, absolute security cannot be guaranteed.

12. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Enhance user experience
• Analyze website traffic and performance
• Improve service functionality

Users may manage cookie preferences through browser settings.

13. Accuracy of Information

We take reasonable steps to ensure personal information is accurate and up to date. Users are encouraged to notify us of any changes.

14. Your Privacy Rights

Subject to applicable laws, individuals may:

• Access their personal information
• Request corrections
• Withdraw consent
• Request deletion where applicable
• Object to certain processing activities

15. Children's Privacy

Our services are not directed to minors, and we do not knowingly collect personal information from individuals below the age of majority.

16. Third-Party Websites

We are not responsible for the privacy practices of third-party websites linked on our platform.

17. Changes to This Policy

We may update this Policy periodically. Changes will be posted with an updated effective date.

18. Contact – Data Protection Officer

Data Protection Officer (DPO)

91 Payments Limited

1771 Robson Street – 1311

Vancouver, British Columbia, Canada

Email: compliance@91-payments.com

19. Complaints and Regulatory Rights

If concerns are not resolved, individuals may contact the Office of the Privacy Commissioner of Canada.

20. Consent

By using our services, you acknowledge that you have read, understood, and agreed to this Privacy Policy and the collection, use, and disclosure of your personal information as described herein.