Privacy Policy

                                                            Protecting Your Privacy Details on how Swiftier collects, uses, and protects user data:

1. Introduction

This Privacy Notice (the "Notice") represents the data protection and privacy practices of Swiftier Inc. (referred to as "Swiftier," "we," "us," or "our") regarding the collection, use, and management of personal information belonging to:

. Website Visitors - Individuals who visit our website at https://www.swiftier.ca (the "Website").

.App Users - Individuals who download or use the Swiftier mobile application (the "App").

. Clients - Individuals who enroll for and use the Services provided by Swiftier.

For the purposes of this Notice, "Services" refers to your current and future use of any of Swiftier's existing or future products, including but not limited to the delivery, management, marketing, and processing of such Services, whether provided directly by Swifter or through third-party service providers.

 Personal Information means any data relating to an individual who can be identified, directly or indirectly, based on that information. This may include, but is not limited to, names, contact details, identification data, financial information, transaction history, device identifiers, IP addresses, and other characteristics specific to that individual.

Website Visitors, App Users, and Clients are collectively referred to as "Users" or "you" in this Notice. The Website, App, and all related Services and content are collectively referred to as the "Resources", as further described in the Customer Agreement.

Please read this Notice carefully to understand our policies and practices for collecting, processing, and storing your personal information. If you do not agree with our policies and practices, your choice is not to use the Resources. 

2. Who We Are

Swiftier Inc. is a Canada-based financial technology company, registered as a Money Services Business ("MSB") with the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC") under registration number C100000386. Swiftier?s registered office is located at 33 Ellen Street, #1303 Barrie, Ontario, L4N 6E9 Canada. 

 Swiftier provides cross-border money transfer and foreign exchange services through the Swiftier App and website https://www.swiftier.ca, offering a seamless way for individuals to send, receive, and convert money globally

For the purposes of this Privacy Notice, Swiftier Inc. is the main Data Controller responsible for the collection and processing of personal data through our platforms, including the Swiftier App and Website. This means that Swiftier determines the purposes and means of processing your personal information in connection with the Services we offer

We are committed to safeguarding the personal information of our customers, users, employees, and other stakeholders, while providing a secure and reliable platform for international money transfers.

If you have any questions or concerns regarding your personal information, or if you wish to exercise your rights under applicable data protection laws, please refer to the "Contact Us" section of this Privacy Notice for further guidance. 

3. What Data Do We Collect?

The information we may collect about you depends on how you interact with Swiftier and the Services we provide. This data may include, but is not limited to, the following categories: 

a) Personal Identification Information

.  Full name

.  Date of birth

.  Place of birth

.  Nationality

.  Gender

.  Email address

. Physical address (which may be verified through utility bills or electronic address verification)

.  Phone number

.  Demographic information

b) Supplemental Identification Information

. Government-issued identity documents (e.g., passport, driver?s license, national ID)

 . Live photo images for identity verification (e.g., facial recognition or biometric data)

. Social Insurance Number (SIN), Social Security Number (SSN), or other taxpayer identification numbers (as applicable)

. Source of income and employment information, including employment status and history

c) Financial Information

. Bank account details

. Account statements

. Income or wealth verification documents

. Credit references and credit history

. Credit analysis reports

. Automated decisions related to credit facility applications (where applicable)

d) Device and Technical Information

. Browser type and version

. IP address

. Device name, model, and unique identifier

. Device language and time zone settings

. Operating system and software version

. Location data, including GPS coordinates and IP-based location data

. Device timestamps

e) Behavioral and Usage Data

. Pages viewed, links clicked, and actions taken on the Swiftier Website or App

.  Keystrokes, copy/paste actions, and session activity

.  User engagement patterns, including dormant account status

. Transaction information, including types of services requested, dates, times, and payment methods

f) Communication Data

. Messages, comments, and file transmissions sent through Swiftier?s platforms

.  Email and phone interactions with customer support

. Social media interactions and user-generated content

. Feedback provided through surveys or promotions



g) Beneficiary and Transfer Information

? Information related to the individuals to whom you wish to transfer funds, including their names, contact details, and banking information

? Any individuals you introduce to Swiftier who may download the Swiftier App or use the Services
h) Additional Verification Data

? Real-time facial recognition images for identity verification

? Other information required to verify a user?s identity, as determined by Swiftier in its sole discretion
i) Other Personal Information

? Any additional personal information you provide to us through any channel, including social media, email, phone, or in-person interactions

? Data collected as part of promotions or special offers held by Swiftier or its partners
j) Location Data

? Real-time or historical location data collected through GPS, Wi-Fi, or IP-based location tracking, where permitted by law

This data is collected to provide you with secure, personalized, and efficient services, and to comply with legal and regulatory obligations.
4. Personal Information of Minors

Swiftier?s Services are intended for use only by individuals who are 18 years of age or older. We do not knowingly collect, use, or store personal information from anyone under the age of 18.

If you are under 18, please do not attempt to register for a Swiftier Account, make transactions, or provide any personal information through our Website, App, or any other part of our platform. This includes, but is not limited to:

? Creating an account or registering for our Services

? Making purchases or conducting financial transactions

? Using interactive features, chat services, or submitting public comments

? Providing any personal details, such as your name, address, phone number, email address, screen name, or any other identifying information

If we become aware that we have inadvertently collected personal information from a person under 18, we will take immediate steps to delete the data and close the associated account.

If you believe that we may have collected personal information from or about a child under 18, please contact us as soon as possible at dataprivacy@swiftier.ca so we can address the issue promptly.
5. How We Collect Your Data

Swiftier may collect personal information about you in a variety of ways, depending on how you interact with our Services. This data may be collected directly from you, through our independent partners, or from third-party service providers.
a) Data You Provide Directly

We collect data directly from you when you:

? Register for a Swiftier Account or sign up for our Services

? Participate in promotions, referral programs, or special offers

? Place an order for our products or Services

? Complete customer surveys, provide feedback, or submit reviews

? Download or use the Swiftier App

? Submit content to the Website or App, such as comments, reviews, or messages

? Communicate with us via email, phone, in-app messages, or social media

? Opt to use products and Services offered in conjunction with third-party partners

? Agree to share information obtained through third-party platforms, including open banking services or credit reference agencies
b) Data Collected Automatically

We may also collect certain data automatically when you use the Swiftier Website or App, including:

? Cookies and tracking technologies that capture browsing behavior, pages viewed, links clicked, and session duration

? Device information, including IP address, device type, operating system, and unique device identifiers

? Location data, if you enable location tracking on your device, whether the App is running in the foreground (open and visible) or background (open but not visible)
c) Data Collected from Third Parties

In some cases, we may obtain personal data about you from third parties to verify your identity, assess your creditworthiness, or comply with legal requirements. This may include:

? Credit reference agencies

? Fraud prevention services

? KYC (Know Your Customer) and AML (Anti-Money Laundering) providers

? Open banking platforms

? Sanctions screening services
d) Data Collected During Regulatory Checks

To meet our compliance obligations, Swiftier may also collect data from third-party sources before providing Services to you. This may include checks for

? Fraud prevention

? Money laundering detection

? Sanctions list screening

? Creditworthiness assessments

This data collection is necessary to verify your identity, manage financial risk, and comply with legal and regulatory requirements.
6. How Will We Use Your Data?

Swiftier collects and processes Users? data, including personal information, for a variety of business, operational, and legal purposes, including but not limited to the following:
? To Provide the Services:

o To deliver the Services you request, including processing financial transactions, issuing digital cards, and enabling partner products like savings and investment accounts.

o To administer your account and manage your access to Swiftier?s Services.
? To Enhance Security and Prevent Fraud:

o To protect you and Swiftier from fraud, errors, misrepresentations, and criminal activity

o To detect, investigate, and prevent suspicious or unauthorized transactions.
? To Verify Identity and Financial Stability:

o To confirm your identity as part of the account registration process.

o To conduct credit checks, financial assessments, and risk analyses.
? For Customer Support:

o To provide technical support, resolve customer service requests, and improve overall customer experience.

o To communicate with you about your account, transactions, and service updates.
? For Research and Development:

o To improve our Services, develop new products, and personalize your experience through data analysis and user feedback.

o To invite you to participate in surveys or focus groups aimed at enhancing our Services.
? For Marketing and Advertising:

o To send you marketing and promotional communications, including personalized offers and targeted advertising, with your consent.

o To measure and improve the effectiveness of our marketing campaigns.
? For Legal and Regulatory Compliance:

o To comply with applicable laws and regulatory requirements, including tax reporting, anti-money laundering (AML), and know-your-customer (KYC) obligations.

o To enforce our rights and fulfill our obligations under any contracts with you, including billing and collections.
? For Communications and User Engagement:

o To facilitate communication between you and other users, where applicable.

o To send you non-marketing communications, such as service updates and account notifications.
? To Measure Advertising Effectiveness:

o To understand how effective our advertisements are and deliver relevant ads to you.
? To Provide Third-Party Services:

o To work with independent third-party service providers to deliver certain Services in conjunction with Swiftier.
? For Promotions and Rewards:

o To offer prizes, bonuses, cashback, or other benefits during promotions or loyalty programs.
? For Legal Proceedings:

o To manage and resolve legal disputes, enforce our rights, and protect Swiftier?s interests in court or other legal processes.
? For Any Other Purpose:

o To fulfill any other purpose for which you have provided your consent.

o To use your data as described at the time it was collected or as disclosed to you separately.
No Sale of Personal Data:

Swiftier does not sell or share your personal data with third parties for their direct marketing purposes without your explicit consent.
7. Data Usage and Processing

Swiftier collects and processes personal data based on one or more lawful grounds, as required under applicable privacy laws. These grounds may vary depending on the User's location but generally include the following:
A. To Provide Requested Services and Features

In order to deliver the Services you request, Swiftier must collect and use certain personal information, including:

? User Profile Data: Information used to establish and maintain your Swiftier Account, verify your identity, communicate with you about your account, and enable you to make or receive payments.

? Usage Data: Information necessary to maintain, optimize, and enhance our Services, including analytics on how you interact with our App and Website.

? Transaction Data: Records of your financial transactions, including payments, transfers, and currency conversions.

? Customer Support Data: Information related to customer service inquiries, technical support, and dispute resolution.

? Additional Products and Services: Data collected in connection with optional features, partner services, and future product offerings.
B. For Legitimate Business Interests

Swiftier may also process personal data to protect its legitimate business interests or those of its partners, including:

? Enhancing the safety and security of our Users and Services.

? Preventing fraudulent activity, financial crime, and unauthorized account access

? Retaining data of banned or blocked users to prevent repeat offenses.

? Conducting research, analytics, and product development to improve our Services.

? Enforcing the terms of our Customer Agreement and other legal contracts.

? Protecting the rights and safety of our Users, employees, and the general public.

? Facilitating direct marketing, including personalized offers and promotions (with your consent).
C. To Fulfill Legal Obligations

Swiftier may use your personal data to comply with its legal and regulatory obligations, including:

? Conducting Know Your Customer (KYC), Anti-Money Laundering (AML), and sanctions screening.

? Reporting to government authorities or financial regulators as required by law.

? Sharing information with law enforcement in connection with criminal investigations, public safety concerns, or legal requests.

? Retaining transaction records and user identification data to meet record-keeping requirements.
D. With Your Consent

In some cases, Swiftier may process your personal data based on your explicit consent, including:

? Collecting voluntary survey responses or feedback to improve our Services.

? Verifying your identity using real-time facial recognition or biometric data.

? Sending marketing communications and personalized advertisements.

? Offering new or experimental Services through pilot programs or beta testing.

You may provide this consent in writing, verbally, electronically, or through authorized representatives. In some cases, consent may be implied based on your actions, as permitted by applicable privacy laws
Revoking Consent:

You may withdraw your consent to the collection or use of your personal data at any time, subject to legal or contractual restrictions. However, doing so may limit your ability to use certain features or Services that rely on this data.
8. How Do We Transfer and Store Your Data?

The security of your personal information is a top priority for Swiftier. We use a combination of physical, electronic, and administrative measures to protect your data from accidental loss, unauthorized access, misuse, alteration, and disclosure.
a) Data Storage and Encryption

? All personal information you provide to Swiftier is stored on secure servers protected by firewalls and access controls.

? Payment transactions are encrypted using Transport Layer Security (TLS) technology to protect your financial data during transmission.

? User passwords are encrypted, and we strongly encourage you to keep your password confidential and secure.
b) User Responsibility for Data Security

? The security of your data also depends on you. Where we have provided you (or you have chosen) a password to access certain parts of the Resources, you are responsible for keeping this password confidential.

? Do not share your password with anyone, and avoid using the same password across multiple services.

? Notify us immediately if you suspect unauthorized access to your account.
c) Data Transfers to Third Parties and International Transfers

Swiftier may transfer your personal data to third parties, partners, or affiliated entities located outside the country where you reside. This may include transfers to:

? Canada

? United States

? United Kingdom

? European Union member states

? Nigeria

? Kenya

? Ghana

? Philippines

These countries may have different data protection laws than your home jurisdiction, and in some cases, these laws may not provide the same level of protection.

To ensure that your personal data is adequately protected during international transfers, Swiftier implements appropriate safeguards in accordance with applicable data protection laws. These safeguards may include:

? Standard Contractual Clauses (SCCs) approved by relevant authorities,

? Binding Corporate Rules (BCRs),

? Privacy certifications,

? Adherence to industry codes of conduct, and

? Other legally recognized transfer mechanisms.
d) Third-Party Data Protection Requirements

All third parties that receive personal data from Swiftier are required to use appropriate safeguards to protect your information. These parties can only access the personal data necessary to perform their specific tasks on our behalf and must comply with applicable data protection laws.
e) Requesting Information About Data Transfers

You have the right to request additional information regarding data transfers outside of your home jurisdiction, including a copy of the safeguards we use to protect your data. To exercise this right, please refer to the "Your Rights" section of this Privacy Notice.
9. Access to Your Contact List

With your explicit consent, Swiftier may request access to the contact list on your mobile device. This allows you to easily identify friends and family who also use Swiftier, enabling you to quickly send money by searching for their phone number, email address, or username.

We access this information solely to:

? Help you find contacts who are also using Swiftier,

? Enable faster and more convenient transactions with your friends and family, and

? Allow you to filter your contacts to identify potential Swiftier users.

We will only access your contact list information if you grant us explicit permission through your device settings or app preferences. We do not store this data permanently, send unsolicited messages to your contacts, or use it for any purpose other than facilitating your transactions.

If you choose to disconnect your contact list from your Swiftier account, we will stop accessing this information immediately.
10. Data Retention and Deletion

Swiftier retains user profile, transaction, and other personal information for as long as your account remains active. We only retain this data for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, accounting, and regulatory obligations.
a) Retention for Legal and Security Purposes

Swiftier may retain certain information even after your account is closed if it is necessary for:

? Safety, security, and fraud prevention,

? Complying with legal, tax, insurance, or regulatory requirements,

? Resolving disputes and enforcing our Customer Agreement,

? Preventing banned users from creating new accounts in the future.

For example, if your account was deactivated for violating our policies or engaging in fraudulent activity, Swiftier may retain certain data to prevent you from reopening an account in the future.
b) User-Initiated Account Deletion

You have the right to request the deletion of your Swiftier account at any time. Upon receiving such a request, Swiftier will delete the data it is not legally required to retain. However, some data may need to be retained for a minimum period, such as 7 years, for regulatory, tax, insurance, litigation, or other legal requirements.

If there are any outstanding credits, unresolved claims, or disputes associated with your account, we may be unable to process your deletion request until these issues are resolved. Once resolved, your account and associated data will be deleted as described above.
c) Anonymization of Personal Data

In some cases, Swiftier may anonymize your personal data so that it can no longer be associated with you. This anonymized data may be used for research, analytics, and other legitimate business purposes without further notice to you or your consent.
d) Data Correction and Updates

If you wish to update or correct your personal information, or if you no longer want Swiftier to retain your data, please contact us. We will make the necessary updates or deletions as required, in accordance with this Privacy Notice and applicable laws.
11. Data Sharing and Disclosure

Swiftier may share your personal data with various third parties in certain situations, including to provide you with Services, comply with legal obligations, and protect your interests. This data sharing is done in accordance with applicable data protection laws and our commitment to safeguarding your privacy.
A. With Swiftier Subsidiaries and Affiliates

We may share your personal data with our subsidiaries and affiliated companies to help us deliver our Services, conduct data processing, or perform support functions on our behalf. For example, Swiftier may process and store data in Canada or other jurisdictions as needed to support its international operations.
B. With Swiftier Service Providers and Business Partners

Swiftier may share personal data with a variety of third-party vendors, consultants, and business partners, including:

? Payment Processors and Financial Institutions: Partners involved in processing payments, managing transfers, and providing savings or investment products.

? Background Check and Identity Verification Providers: Companies that assist with identity verification, KYC (Know Your Customer) checks, and credit assessments.

? Cloud Storage Providers: Companies that securely store data on behalf of Swiftier.

? Customer Support and Call Centers: Service providers that handle customer inquiries, support tickets, and account management.

? Marketing and Advertising Partners: Companies that help us deliver targeted marketing and advertising, including social media platforms.

? Data Analytics Providers: Partners that assist in analyzing user behavior and improving our Services.

? Research Partners: Organizations conducting surveys or research projects in collaboration with Swiftier.

? Security and Fraud Prevention Providers: Vendors that help protect our platforms and prevent fraud or unauthorized access.

? Professional Service Providers: Consultants, lawyers, accountants, and other professional advisors.

? Insurance and Financing Partners: Companies that offer financial products, insurance, or investment services in partnership with Swiftier

? Card Program Partners: Banks and financial institutions that support Swiftier?s card programs and related services.

These partners are required to use your personal data only for the purposes specified by Swiftier and must implement appropriate safeguards to protect your information.
C. For Legal Reasons or in the Event of a Dispute

Swiftier may share your personal data if required or permitted by law, regulation, legal process, or governmental request. This includes sharing data to:

? Comply with legal obligations, including tax reporting, regulatory requirements, and record-keeping.

? Respond to law enforcement requests, court orders, or subpoenas.

? Protect the rights, property, or safety of Swiftier, its users, employees, or the general public.

? Enforce our Customer Agreement, Privacy Notice, or other legal agreements.

? Investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of our policies.

? Facilitate corporate transactions, such as mergers, acquisitions, divestitures, restructuring, or the sale of company assets.

If Swiftier is involved in a merger, acquisition, or sale of all or part of its business, your personal data may be transferred to the buyer or successor entity as part of the transaction.
D. With Your Consent

Swiftier may also share your personal data for any other purpose disclosed to you at the time of data collection or with your explicit consent.
12. Marketing

Swiftier may send you information about our products and Services, including promotions, discounts, and special offers, if you have provided your consent to receive such communications. You may provide this consent when you enroll for the Services as part of the Customer Agreement.
a) Opting Out of Marketing Communications

? You have the right to stop receiving marketing communications from Swiftier at any time.

? To opt out, you can follow the instructions provided in any marketing email you receive, or update your communication preferences within the Swiftier App or Website.

? We will process your opt-out request as quickly as possible, but please note that you may continue to receive non-marketing, administrative messages (such as account updates and transaction notifications) even after opting out of marketing emails.
b) Referral Programs and Rewards

? If you were referred to Swiftier by another customer as part of a referral program, your referrer may be eligible to earn bonuses, cashback, or rewards based on your transactions.

? Your transaction details will not be disclosed to your referrer as part of this program.
c) No Sale of Personal Data

Swiftier does not sell or share your personal data with third parties for their direct marketing purposes without your explicit consent.
13. What Are Your Data Protection Rights?

As a global organization, Swiftier is committed to respecting your privacy rights in accordance with applicable data protection laws. Depending on your jurisdiction, you may have the following rights:
a) Right of Access

? You have the right to request an overview of the personal information that Swiftier holds about you.
b) Right to Rectification

? If your personal information is inaccurate or incomplete, you have the right to request that we correct or update your data.
c) Right to Erasure (Right to be Forgotten)

? You have the right to request that we delete your personal information, to the extent permitted by applicable law.

? In some cases, this may not be possible, such as when we need to retain your data to comply with legal obligations, resolve disputes, or enforce our agreements.
d) Right to Data Portability

? You have the right to request that we transfer your personal information directly to you or to another organization of your choice, where technically feasible.

? This applies to certain data if it is processed by automated means and based on your consent or a contract.
e) Right to Restrict Processing

? You have the right to request that we restrict the processing of your personal information in certain circumstances, such as if you contest the accuracy of your data or object to its processing.

? In some cases, this request may not be possible if the processing is necessary for legal compliance or other compelling legitimate grounds.
f) Right to Object

? You have the right to object to the processing of your personal information for reasons related to your particular situation, particularly where the processing is based on legitimate interests.

? In some cases, you may have an unconditional right to object, such as in the context of direct marketing activities.
g) Right to Withdraw Consent

? If you have provided consent for the processing of your personal data, you have the right to withdraw that consent at any time.

? Withdrawal of consent will not affect the lawfulness of any processing carried out prior to the withdrawal.
h) Exercising Your Rights

To exercise any of these rights, or if you have questions about how your personal information is handled, please refer to the "Contact Us" section below.

If you feel that Swiftier has not adequately addressed your concerns, you also have the right to lodge a complaint with a data protection supervisory authority in the country where you reside, where Swiftier is based, or where an alleged violation of data protection law has occurred.
Additional Information for Quebec and Canadian Residents

If you are a resident of Quebec or any other Canadian province, your personal information may be transferred to other jurisdictions, including the United States, that may not provide the same level of data protection as Canada. Swiftier is committed to ensuring that your data is protected regardless of where it is processed, in compliance with applicable Canadian privacy laws.
Verifying Your Identity

To exercise your rights under applicable privacy laws, Swiftier may need to verify your identity. This may involve:

? Logging into your Swiftier account,

? Providing additional identifying information, or

? Matching the information you provide with data already on file.

Swiftier may deny a request if it cannot verify your identity, if the data has been anonymized or deleted in accordance with our data retention policies, or if the request is prohibited by law.

You consent to Swiftier conducting electronic database searches or other verification methods as part of this process. Swiftier will retain records of these verification activities in compliance with this Privacy Notice and applicable laws.
14. Cookies

Swiftier uses cookies and similar tracking technologies to improve your browsing experience, enhance website functionality, and provide personalized content. Cookies are small text files that identify your browser and collect information about how you use our Website and Services.
a) How We Use Cookies

? To remember your login information and manage your session.

? To understand how you interact with our Website, including pages viewed, links clicked, and time spent on the site.

? To improve our Services and optimize your browsing experience.

? To collect analytics data for performance monitoring and site improvement.

? To deliver personalized content and advertisements, where applicable.

For more information about how we use cookies and your options for managing them, please see our Cookie Notice.
15. Privacy Policies of Other Websites

Swiftier?s Website and App may contain links to third-party websites. This Privacy Notice applies only to Swiftier?s Resources. If you follow a link to any other website, we encourage you to review the privacy policies of those websites, as Swiftier has no control over their data collection practices.
16. Changes to Our Privacy Notice

Swiftier may update this Privacy Notice from time to time to reflect changes in our data practices or legal requirements. When we make significant changes to how we collect, use, or share your personal information, we will notify you through the Website, App, or other appropriate means.

The date this Privacy Notice was last updated is indicated at the top of this page. You are responsible for ensuring that we have your most current and active email address, and for regularly reviewing this Privacy Notice for updates.
17. Contact Us

If you have any questions about this Privacy Notice, the personal information we hold about you, or if you would like to exercise your data protection rights under applicable privacy laws, please contact our Data Privacy Manager at dataprivacy@swiftier.ca.