Privacy Policy

1. App Operator and Data Controller

The App is operated by:

CF Technologies Canada Ltd, a company incorporated in Canada, acting as a technology platform provider.

CF Technologies Canada Ltd does not provide regulated financial services, does not execute cryptocurrency transactions, and does not hold or safeguard user funds or digital assets.

If you have any questions regarding the processing of personal data through the App, you may contact us at:
Email: [email protected]
Company: CF Technologies Canada Ltd
Address: 500-666 Burrard Street, Suite 500, Vancouver, British Columbia, V6C 3P6, Canada

Cryptocurrency transaction services for U.S. users are provided by licensed third-party financial service providers, including:

• Zero Hash LLC
• Zero Hash Liquidity Services LLC
• Zero Hash Trust Company LLC

Depending on the context, CF Technologies Canada Ltd may act as a data controller (for account, app, and user interface data) and/or a service provider/processor on behalf of licensed financial partners.

2. Scope of This Addendum

This Addendum applies solely to personal data collected through the App from users located in the United States.

3. Categories of Personal Data Collected Through the App

We collect the following categories of personal data:

A. Identifiers

• Full name, date of birth
• Email address, phone number
• Government-issued identification details

B. Sensitive Personal Information

• Government-issued ID documents
• Biometric data (e.g., facial images/selfies used for identity verification)
• Financial account and payment information

C. Commercial Information

• Transaction records and activity related to services accessed through the App

D. Internet or Network Activity

• IP address
• Device identifiers
• App usage logs and interaction data

E. Geolocation Data

• Approximate location derived from IP address (country/state level)

4. Purposes of Processing

We process personal data collected through the App for the following purposes:

• to create, manage, and maintain user accounts;
• to perform identity verification and compliance checks, including through third-party identity verification service providers
• to enable access to cryptocurrency services provided by licensed third-party financial service providers;
• to prevent fraud, unauthorized access, and illegal or suspicious activity;
• to comply with applicable legal and regulatory obligations;
• to operate, secure, and improve the functionality and performance of the App.

Sensitive personal information is used only as necessary for identity verification, fraud prevention, security, and legal compliance.

We do not use sensitive personal information for marketing purposes.

5. Sharing of Personal Data

We may disclose personal data to: Identity verification and fraud prevention providers, including Sumsub (Sum & Substance Ltd), which provides identity verification and compliance technology services;

• Licensed financial service providers, including Zero Hash LLC, Zero Hash Liquidity Services LLC, and Zero Hash Trust Company LLC, which provide cryptocurrency transaction execution, custody, settlement, and regulatory compliance services for U.S. users;
• Payment processors used to process card and funding transactions;
• Analytics, cloud hosting, and infrastructure providers supporting the App security and performance.

We do not sell or share personal data as those terms are defined under applicable U.S. state privacy laws, including the California Consumer Privacy Act (CCPA/CPRA).

6. Mandatory Data Collection

Certain personal data collected through the App is required to comply with legal, regulatory and compliance obligations, including identity verification requirements performed by third-party service providers. Failure to provide such information may result in limited or restricted access to the App features and services or inability to create or maintain an account.

Certain categories of personal data, including identity and verification data, are mandatory in order to comply with legal and regulatory requirements, while other data may be optional and collected to improve App functionality.

7. Data Retention

We retain personal data collected through the App only as long as necessary to:- fulfill the purposes described in this Addendum and the Privacy Policy,

– comply with legal, regulatory and contractual obligations’

-meet record keeping requirements applicable to financial services providers.

Retention periods vary depending on the type of the and applicable law.

8. U.S. Privacy Rights

Depending on your state of residence (e.g., California, Colorado, Virginia, Texas), you may have the following rights:

• Right to access personal data we collect about you
• Right to correct inaccurate personal data
• Right to request deletion of personal data
• Right to obtain a copy of your data (data portability)
• Right to limit the use of sensitive personal information
• Right to opt out of sale or sharing (note: but we do not sell or share data)
• Right to non-discrimination for exercising your rights

9. Exercising your Rights

You may submit privacy requests via:

• Email: [email protected] OR
• Email: [email protected]

We will:

• Verify your identity before processing requests
• Respond within applicable legal timeframes

You may request access to, correction of, or deletion of personal data collected through the App by contacting us at [email protected].

Requests for account deletion and data erasure are subject to applicable legal and regulatory retention requirements. There may be instances where certain data may need to be retained to comply with financial regulations, anti-money laundering obligations and record-keeping requirements.

10. Data Security

We implement appropriate technical and organizational measures designed to protect personal data collected through the App against unauthorized access, disclosure, alteration, or destruction.

Data transmitted from the App is encrypted in transit using industry-standard security protocols, with access controls and stored securely in accordance with applicable laws and best practices.

11. International Data Transfers

Personal data collected through the App may be transferred to and processed in jurisdictions outside your country of residence, including the United States and Canada.

Where required, we implement appropriate safeguards, including contractual protections and legally recognized transfer mechanisms.

12. Age Restriction

The App is not intended for individuals under the age of twenty-one (21). We do not knowingly collect personal data from individuals under the age of twenty-one (21).

13. Updates to This Addendum

We may update this Addendum from time to time to reflect changes in the App, applicable laws, or regulatory requirements. Any material changes will be communicated through the App or by other appropriate means.