Contact

Privacy Policy

Introduction and Scope

SINVERON Inc. is a legal entity formed pursuant to the Canada Business Corporations Act (R.S.C., 1985, c. C-44), with its registered office at 700-602 12 Avenue SW, Calgary, Alberta, T2R 1J3, Canada (“We“, “Our“, “SINVERON Inc.” or the “Company“) and is committed to protecting Personal Information and handling it in accordance with applicable Canadian privacy laws. This Privacy Policy (the “Policy”) explains how the Company collects, uses, discloses, retains, protects and otherwise handles Personal Information in connection with the Company’s website and services.

This Policy applies to Personal Information relating to current and prospective clients, website users, individuals who communicate with the Company, and individuals associated with a corporate or other legal-entity client or prospective client, including directors, officers, authorized representatives and beneficial owners. It does not apply to information about a legal entity itself unless that information identifies, relates to, or is otherwise connected with an identifiable individual.

Applicable Privacy Laws

The Company handles Personal Information in accordance with applicable Canadian privacy laws, including, where applicable, the Personal Information Protection Act (Alberta) (“PIPA”) and the Personal Information Protection and Electronic Documents Act (“PIPEDA”). The specific law applicable to a particular processing activity may depend on the nature of the activity, the location of the individuals concerned and other relevant circumstances. 

Key Terms

  • “Personal Information” means information about an identifiable individual.
  • “Client” means any person or legal entity accepted by the Company for the provision of its services (“Client”). Where a Client is a legal entity, references in this Policy to “You” or “Your” in relation to Personal Information refer to the individual whose Personal Information is being processed.
  • “Prospective Client” means a person or legal entity whose request to receive the Company’s services is under review and who has not yet been accepted as a Client (“Prospective Client”). Where a Prospective Client is a legal entity, references in this Policy to “You” or “Your” in relation to Personal Information refer to the individual whose Personal Information is being processed.
  • Know Your Customer (“KYC”) means a process used to identify and verify the identity of customers and assess relevant risks before and during the business relationship.
  • Know Your Business (“KYB”) means a process used to identify and verify a business customer, its ownership and control structure, and the nature and purpose of the business relationship.

Accountability and Privacy Officer

The Company is responsible for Personal Information under its control, including Personal Information transferred to service providers for processing on the Company’s behalf. The Company uses contractual or other appropriate measures designed to require such service providers to provide a level of protection for Personal Information comparable to that required under applicable Canadian privacy law.

The Company has designated a Privacy Officer to oversee compliance with this Policy and applicable privacy requirements. Questions, requests and complaints concerning the Company’s privacy practices may be directed to the Privacy Officer using the contact details set out at the end of this Policy.

Information We May Collect

  • Identity and contact information – name, residential or mailing address, date of birth, email address, telephone number, nationality or country of residence, and government-issued identification information.
  • Account and onboarding information – account details, login credentials, information provided during registration, and information required to verify and maintain Your account.
  • Transaction and financial information – transaction history, transaction amounts and currencies, payment and settlement information, wallet addresses, and related financial information.
  • KYC and KYB and verification information – information necessary to verify Your identity or, where applicable, a business, including information about directors, authorized representatives and beneficial owners, together with verification, compliance and screening results generated as part of the Company’s onboarding and ongoing compliance procedures.
  • Source of funds information – information about the origin of funds or assets and supporting documentation, where required by applicable law or necessary for Our services.
  • Technical information – IP address, device and browser information, login activity, server logs and information collected through strictly necessary cookies and similar technologies used to operate and secure the Website and Services. 
  • Communications information – correspondence with us, including emails, customer support requests, inquiries, complaints and other communications.
  • Information from third parties – information we may receive from identity verification providers, payment providers, fraud prevention services, public sources and other service providers.

How We Collect Personal Information

We may collect Personal Information:

  • directly from You when You create or maintain an account, request or use services, communicate with Us, submit documents or information, or otherwise interact with the Company;
  • automatically when You use Our Website or online Services, including through server logs, strictly necessary cookies and similar technologies used for essential technical and security purposes; and
  • from third parties and other lawful sources, including identity and business verification providers, payment and financial service providers, fraud prevention and compliance service providers, public records and publicly available sources, and other service providers used in connection with Our services.

How and Why We May Use Your Personal Information

We may use Personal Information for purposes that are identified to You, reasonably related to the provision and administration of Our services, or otherwise permitted or required by applicable law, including:

  • to create, administer and maintain Your account and Our relationship with You;
  • to verify identity, business information and eligibility, and to complete KYC/KYB, fraud prevention, sanctions and other compliance checks;
  • to process and facilitate transactions, payments, currency exchanges and transfers, and to maintain related transaction, billing and accounting records;
  • to comply with anti-money laundering and anti-terrorist financing (“AML/ATF”), sanctions, record-keeping, reporting and other legal or regulatory obligations; 
  • to provide, operate, maintain, secure and improve Our website and services;
  • to communicate with You regarding Your account, transactions, services, inquiries, complaints and other matters relating to Your relationship with the Company;
  • to provide customer support and respond to questions, comments and complaints;
  • to conduct internal analysis and service-improvement activities, where appropriate and permitted by applicable law; and
  • to detect, prevent, investigate and respond to suspected fraud, security incidents, misuse of Our services or other unlawful or unauthorized activity.

Consent

Where consent is required under applicable privacy law, the Company seeks consent that is appropriate to the sensitivity of the Personal Information and the circumstances in which it is collected, used or disclosed. Consent may be expressed or implied where permitted by law. In certain circumstances, applicable law permits or requires the Company to collect, use or disclose Personal Information without consent.

You may withdraw consent to the collection, use or disclosure of Personal Information that is based on consent, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent does not affect processing that occurred before the withdrawal. Where particular Personal Information is necessary for the Company to provide a service or comply with legal or regulatory obligations, withdrawal of consent may limit or prevent the Company from providing or continuing that service.

How We May Share Your Personal Information

We may disclose Personal Information to the following categories of recipients where reasonably necessary to provide Our services, operate Our business, comply with legal obligations, or protect Our rights and legitimate interests:

  • Service Providers. We may disclose Personal Information to third parties engaged to support Our operations, including providers responsible for identity and business verification, fraud prevention, AML/ATF and sanctions screening, blockchain analytics, technology infrastructure and data hosting, payment processing, accounting, and customer support. Such providers receive Personal Information only as reasonably necessary to perform the relevant services and are subject to contractual or other appropriate measures designed to protect that information.
  • Financial Institutions and Payment Providers. We may disclose Personal Information to banks, payment institutions and other financial service providers where necessary to execute transactions, enable payment processing, settlement or related financial services.
  • Legal, Regulatory and Law Enforcement Authorities. We may disclose Personal Information where required or permitted by applicable law, including in response to lawful requests from courts, government authorities, FINTRAC, tax authorities, regulators or law enforcement agencies.
  • Professional Advisers. We may share Personal Information with Our legal, accounting, auditing, compliance and other professional advisers where reasonably necessary to obtain professional services, comply with legal obligations or protect Our legal interests.
  • Parties Involved in Corporate Transactions. We may disclose Personal Information in connection with a proposed or completed merger, acquisition, restructuring, financing, sale of assets, insolvency, bankruptcy or other corporate transaction, subject to applicable legal requirements.
  • Other Parties With Your Consent or Direction. We may disclose Personal Information to other parties where You have consented to or directed the disclosure, or where the disclosure is otherwise permitted or required by law.

The Company does not sell Personal Information or disclose Personal Information to third parties for their own independent marketing, advertising or promotional purposes unless permitted by applicable law and, where required, with Your consent.

Cross-Border Processing and Service Providers

The Company may use service providers or other recipients located outside Your province of residence or outside Canada. As a result, Personal Information may be transferred to, stored in, or processed in other jurisdictions. While Personal Information is in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law enforcement, national security authorities or other government authorities in accordance with those laws.

Where the Company transfers Personal Information to a third party for processing, the Company remains accountable for the Personal Information under its control and uses contractual or other appropriate measures designed to provide a level of protection comparable to that required under applicable Canadian privacy law.

Individuals may obtain information about the Company’s policies and practices relating to service providers located outside Canada, including information regarding the countries or jurisdictions in which such service providers may process Personal Information and the purposes for which they are authorised to process it, by contacting the Privacy Officer using the contact details set out at the end of this Policy. 

How Long We Retain Your Personal Information and When We Delete It

We retain Personal Information only for as long as reasonably necessary to fulfil the purposes for which it was collected and to satisfy applicable legal, regulatory, accounting, security, fraud-prevention, dispute-resolution and record-keeping requirements. Retention periods may therefore vary depending on the type of information, the nature and duration of Our relationship with You, the relevant transaction or service, and applicable legal obligations.

When Personal Information is no longer required, the Company will delete, securely destroy or anonymize it, as appropriate, subject to applicable legal requirements and reasonable technical or backup-retention limitations.

How We Keep Your Personal Information Safe

The Company maintains administrative, technical and physical safeguards designed to protect Personal Information against loss, theft, unauthorized access, use, disclosure, copying, modification or destruction. The safeguards applied are proportionate to the sensitivity of the Personal Information, the amount and distribution of the information, the format in which it is stored, and the risks associated with the Company’s activities.

The Company also requires service providers that process Personal Information on Our behalf to maintain appropriate security and confidentiality measures and uses contractual or other appropriate means to protect Personal Information while it is being processed by such providers.

No method of transmission or storage is completely secure. Accordingly, while the Company takes reasonable measures to protect Personal Information, absolute security cannot be guaranteed.

Your Privacy Rights and Requests

Subject to applicable law and any lawful exceptions, You may:

  • request information about the existence, use and disclosure of Personal Information held by the Company about You;
  • request access to Your Personal Information;
  • request correction of Personal Information that is inaccurate or incomplete;
  • withdraw consent where the Company’s collection, use or disclosure of Personal Information is based on consent, subject to legal or contractual restrictions and reasonable notice; and
  • ask questions about, or challenge, the Company’s privacy practices and compliance with this Policy and applicable privacy law.

Requests should be submitted to the Privacy Officer using the contact details below. 

If You are not satisfied with the Company’s response to a privacy concern, You may have the right to make a complaint to the Office of the Information and Privacy Commissioner of Alberta, the Office of the Privacy Commissioner of Canada, or another competent privacy regulator, as applicable. 

We Do Not Provide Services to Children or Minors

The Website and the Company’s Services are not intended for persons under eighteen (18) years of age or persons who otherwise lack legal capacity to use the Services under applicable law. The Company does not knowingly provide services to minors. The Company may collect information necessary to verify age and identity as part of its onboarding and compliance procedures.

If the Company becomes aware that it has collected Personal Information from a person under the age of 18 in circumstances inconsistent with this Policy or applicable law, it will take reasonable steps to review the matter and, where appropriate and legally permitted, delete or securely dispose of the information. If You believe that a minor has provided Personal Information to the Company, please contact the Privacy Officer.

How We Respond to Security Incidents and Data Breaches

The Company maintains procedures to identify, assess, contain, investigate, document and respond to security incidents involving Personal Information. Where an incident occurs, the Company will take reasonable steps to mitigate the risk of harm and address the cause of the incident.

Where a security breach involving Personal Information gives rise to a reporting or notification obligation under applicable privacy law, the Company will notify the competent privacy regulator and affected individuals as required by law. Where PIPEDA applies and the breach creates a real risk of significant harm, this includes reporting the breach to the Office of the Privacy Commissioner of Canada and notifying affected individuals as soon as feasible. Where Alberta PIPA applies, the Company will comply with the applicable breach-reporting requirements to the Office of the Information and Privacy Commissioner of Alberta.

The Company maintains a record of every breach of security safeguards involving Personal Information under its control for the period required by applicable law. Where PIPEDA applies, such records are maintained for at least 24 months after the date on which the Company determines that the breach occurred.

Additional Jurisdiction-Specific Privacy Requirements

This Policy primarily describes the Company’s privacy practices under applicable Canadian privacy law. Where the Company determines that another jurisdiction’s privacy or data protection law applies to a particular processing activity or relationship, the Company may provide additional or jurisdiction-specific privacy notices or disclosures as required by that law.

Where the Company’s processing of Personal Information falls within the territorial scope of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Company will process such Personal Information in accordance with the GDPR to the extent applicable.

Effective Date and Updates to This Privacy Policy

The Company may update this Policy from time to time to reflect changes in its practices, services, legal requirements or other relevant circumstances. The updated version will be posted on the Company’s website with a revised “Last Updated” date. Where a change requires additional notice, consent or another form of individual choice under applicable law, the Company will provide such notice or obtain such consent as required.

Contact

To exercise Your privacy rights, make a privacy-related request or complaint, or ask questions about this Policy or the Company’s privacy practices, please contact:

Email: sinveron.official@gmail.com 

Effective Date: 2026-09-14

Last Updated: 2026-09-14