Privacy policy.

1. About this Policy

This Privacy Policy describes how MTX Finance Ltd. ("MTX", "we") collects, uses, discloses, and protects personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy laws.

2. Who we are

MTX Finance Ltd., a British Columbia corporation (BC1556756), registered with FINTRAC as a Money Services Business (C10001332). Address: 702 Russell Avenue, B438 Unit #A1017, Enderby, BC, V0E 1V0, Canada. Email: compliance@mtxfinance.com.

3. Personal information we collect

• Identification data: full name, date of birth, nationality, government-issued ID details, photo, biometric data from liveness checks.
• Contact data: address, email, phone number.
• Corporate role data: directorship, beneficial ownership, signing authority, professional title.
• Financial data: source of funds, source of wealth, expected transaction profile, account and wallet identifiers.
• Compliance data: sanctions / PEP / adverse-media screening outcomes, KYT scores.
• Transactional data: transaction history, counterparties, timestamps, references.
• Technical data: IP addresses, device data, and logs from interaction with MTX systems.

4. How we collect personal information

We collect personal information directly from clients, from authorised representatives, from corporate registries, from sanctions and PEP databases via SumSub, from public sources, and from our service providers (Cublox, Crypto.com, SumSub).

5. Purposes of use

• Onboarding, identification, and verification of clients.
• Sanctions, PEP, and adverse-media screening.
• Provision and administration of the services described in our Terms of Service.
• Compliance with PCMLTFA, PCMLTFR, RPAA, and other applicable law.
• Filing reports with FINTRAC (STR, LVCTR, EFTR, TPR).
• Detection and prevention of fraud, bribery, and other financial crime.
• Communication with clients and relationship management.

6. Lawful basis

MTX collects, uses, and discloses personal information on the basis of: client consent (where consent is required and obtained at onboarding); contractual necessity (provision of services); and legal obligation (PCMLTFA, FINTRAC reporting, sanctions law, tax law).

Disclosure to FINTRAC under the PCMLTFA does not require client consent and is not subject to PIPEDA's consent requirements.

7. Disclosure to third parties

MTX discloses personal information only as necessary for the purposes above, including to:

• Service providers: Cublox (payment processing), Crypto.com (exchange execution), SumSub (KYC / KYT / Travel Rule).
• Regulators and law enforcement: FINTRAC, RCMP, CSIS, Bank of Canada (post-RPAA registration), other competent authorities.
• Auditors and external counsel.
• Counterparty VASPs for Travel Rule purposes (originator/beneficiary data exchange for transfers ≥ CAD 1,000).

8. Cross-border data flows

Personal information may be processed outside Canada (notably in the UK and EU where our providers are based). Where personal information is processed outside Canada, comparable protections are required of the receiving party.

9. Retention

Personal information is retained for a minimum of 5 years from the date of the transaction or end of the business relationship, whichever is later, as required by PCMLTFA. Records may be retained longer where required by other law.

10. Security

MTX applies administrative, technical, and organisational safeguards to protect personal information, including access controls, encryption in transit and at rest where applicable, secure cloud storage, logging, and provider due diligence.

11. Your rights

Subject to PIPEDA and other applicable law, you have the right to: access personal information we hold about you; request correction of inaccurate information; withdraw consent (subject to legal or contractual restrictions); and complain to a privacy regulator.

12. Privacy complaints

Privacy complaints may be submitted to compliance@mtxfinance.com. Where a complaint is not resolved to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada.

13. Cookies and online tracking

See our Cookies Policy.

14. Changes to this Policy

MTX may update this Policy from time to time. Material changes will be notified to clients in writing or through the corporate website.

15. Contact

• Privacy Officer: Alexander Angelov Tomov.
• Email: compliance@mtxfinance.com.
• Web: https://mtxfinance.com.