Privacy Policy

1. Accountability

CobbyPay is responsible for personal information under its control and maintains policies, technical safeguards and organizational measures appropriate to the sensitivity of the information. Privacy enquiries, access/correction requests and complaints may be sent to the Privacy Officer at the contact address below.

2. Information we collect

• Identity and contact data: name, date of birth, address, nationality, telephone, email and government identification.
• Business and KYC/KYB data: occupation, corporate records, directors, authorized persons, beneficial owners, ownership/control information and business activities.
• Financial and transaction data: account details, balances, payment instructions, counterparties, transaction history, invoices, source of funds/source of wealth and wallet addresses.
• Compliance data: PEP status, sanctions screening, adverse-media results, fraud indicators, risk assessments and records required by law.
• Technical data: IP address, device identifiers, authentication records, cookies, logs and cybersecurity information.
• Communications and support records.

3. Purposes

We use information to onboard and identify Clients; provide accounts and payment services; execute and reconcile transactions; authenticate users; prevent fraud; comply with AML/ATF, sanctions, tax and regulatory requirements; conduct monitoring and investigations; manage operational risk and incidents; maintain cybersecurity; provide support; improve Services; enforce agreements; and establish, exercise or defend legal rights.

4. Consent and other legal authority

CobbyPay obtains meaningful consent where required. Certain collection, use, retention or disclosure may occur without consent where permitted or required by law, including regulatory reporting, suspicious transaction reporting, sanctions compliance, fraud prevention, legal process and investigations. Refusal to provide information required to provide a Service or meet legal obligations may prevent CobbyPay from providing that Service.

5. Disclosure and service providers

Information may be disclosed to banks, payment processors, card or electronic-money partners, correspondent institutions, identity-verification and screening providers, cloud and cybersecurity providers, auditors, professional advisers, affiliates where legally permitted, regulators, FINTRAC, the Bank of Canada, law-enforcement agencies and other competent authorities. We require service providers to handle information under appropriate confidentiality and security obligations.

6. International processing

Because payment services are international, personal information may be processed or stored outside Canada. Information in another jurisdiction may be subject to lawful access by courts, regulators, law enforcement or government authorities in that jurisdiction. CobbyPay uses contractual, technical and organizational measures appropriate to the circumstances.

7. Retention

CobbyPay retains information for as long as reasonably necessary for the identified purposes and for periods required by applicable law, including AML/ATF, payment, tax, accounting, dispute, fraud and regulatory obligations. At the end of the applicable period, information is securely destroyed, deleted or anonymized, subject to lawful holds.

8. Safeguards and incidents

CobbyPay uses administrative, technical and physical safeguards proportionate to the sensitivity of information, which may include access controls, authentication, encryption, monitoring, logging, segregation of duties, secure backups and incident-response procedures. Where a breach creates a real risk of significant harm and applicable law requires notification, CobbyPay will notify affected individuals and the appropriate privacy authority and maintain required records.

9. Access and correction

Subject to legal exceptions, individuals may request access to personal information held about them and correction of inaccurate or incomplete information. CobbyPay may verify identity before responding. Certain information may be withheld where disclosure is prohibited or where an applicable exception applies.

10. Cookies and analytics

The website may use essential cookies and, where implemented, analytics or similar technologies. CobbyPay will provide appropriate notice and consent controls where required by applicable law. Disabling certain cookies may affect functionality.

11. Marketing

Where CobbyPay sends commercial electronic messages, it will do so in accordance with applicable Canadian anti-spam requirements. You may withdraw marketing consent through the unsubscribe method provided, without affecting operational, security, legal or regulatory communications.

12. Complaints

Privacy questions or complaints should first be submitted to the Privacy Officer at info@cobbypay.com. Individuals may also have the right to complain to the Office of the Privacy Commissioner of Canada or another competent privacy authority.

13. Changes

We may update this Policy to reflect changes in law, technology, Services or business practices. The current version and effective date will be posted on the website.

14. Contact

Privacy Officer
COBBY PAY LTD.
Email: info@cobbypay.com

Registered office
1907 Baseline Road, Unit 104
Ottawa, Ontario K2C 0C7, Canada