1. INTRODUCTION
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This Privacy Policy (the “Policy”), as may be amended, modified and supplemented from time to time, applies to all users or visitors (“you”) accessing or using our services including the FlexPowered wallets, mobile apps and website comprising all webpages located at www.flexm.com (collectively, the “Site”). It describes how FLEXM FINANCIAL TECHNOLOGIES LTD. (thereafter referred to as “FLEXM”), and its subsidiaries (“we”, “us”, “our”) collect, use, disclose, transfer and store your personal information. All capitalized terms used in this Policy have the same meaning as those ascribed in the Terms & Conditions unless otherwise stated or defined herein.
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2. CONSENT
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By accessing the Site, sharing your information or registering as a user of our Services, you are accepting this Policy and consenting to the collection, use and disclosure of your information disclosed to us in the manner as described in this Policy.
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3. UPDATES TO PRIVACY POLICY
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We may update this Policy from time to time by posting a revised version on our website. The revised version will be effective at the time we post it. We encourage you to review this Policy whenever you use our Services to stay informed about our privacy practices and the choices made available to you. Your continued use of the Site and/or Services after we post any changes to this Policy means that you agree to be bound by such changes.
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4. COLLECTION OF PERSONAL INFORMATION
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As part of accessing and using the Site and the Services, we may ask you to provide us with certain personally identifiable information (“Personal Information”). While providing certain Personal Information to us is optional, certain services can only be offered if you provide Personal Information to us and we may not be able to offer you certain services if you choose not to provide us with any required Personal Information.
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You must ensure that all the Personal Information you provide to us is accurate and complete. You may request access to your Personal Information within our possession or under our control at any time. Where there is any change to or inaccuracies in your Personal Information, you must promptly update us or correct your Personal Information in your User Account.
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Depending on your interactions with us, we may collect the following information about you which we have grouped together as follows:
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(a) User Information includes your name, email address and telephone number.
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(b) Identity verification information includes your date of birth, nationality, gender, proof of residential address, government identification including identity card number, photograph(s)/video(s) of your face for identification, or similar identifier/personal information that you provide us with.
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(c) Financial information includes your bank account information and transaction information if you choose to link your bank account.
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(d) Usage Data includes information about how you use the Site or Services. As you interact with our Site or Services, we may automatically collect Usage Data. This may include information such as your internet protocol (IP) address, browser type and version, time zone setting, location, the pages of our Site that you visit, the date and time of your visit, the time spent on those pages, and unique device identifiers.We may also collect information about you from third parties, particularly in instances where identity verification is necessary.
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5. COOKIES
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By accessing and using the Site and our Services, you consent to our use of cookies. For details, please refer to our Cookie Policy.
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6. USES OF PERSONAL INFORMATION
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FLEXM uses the collected Personal Information for various purposes, including, but not limited to:
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(a) verify your identity;
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(b) fulfill the specific purpose for which the Personal Information was provided such as but not limited to: account registration; employment; vendor/ supplier/ other partnerships; merchant acquiring, etc.;
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(c) provide, maintain, and improve the Site and the Services;
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(d) communicate with you regarding the Site and the Services;

(e) engage in marketing activities;
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(f) notify you about changes to the Site and the Services via short message service, e-mail, in-app notifications, or push notifications/pop-ups;
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(g) assess your overall risk to our business;

(h) provide customer care and support;

(i) monitor the usage of the Site and the Services;

(j) detect, prevent, and address technical issues;

(k) detect and protect against harmful, unauthorized, unethical or illegal activity, such as money laundering, terrorist financing, fraud, or any other crimes (including tax crimes);

(l) enforce our terms and conditions;

(m) to audit our internal processes for compliance with legal and contractual requirements or our internal policies;

(n) carry out any other purposes that are related or incidental to any of the foregoing purposes; and

(o) any other purpose with your consent.

7. MARKETING AND PROMOTIONS
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We may use your Personal Information, as permitted by law, to send you marketing and promotional materials in relation to products and Services offered by us by notifications such as short message service, electronic mail, in-appnotifications, or push notifications/pop-ups. If you wish to unsubscribe to such notifications, you may click on the “unsubscribe” link in the relevant notification.
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8. DISCLOSURE OF PERSONAL INFORMATION
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FLEXM works with third party companies and individuals to facilitate the provision of the Site and Services, provide the Services on our behalf, perform related services (e.g. payment processing, identity verification), and assist us in analyzing how the Site or Services are used (“Service Providers”). While we may disclose your Personal Information
to our Service Providers, such disclosure will be limited to the extent reasonably necessary for the above purposes and will be done in compliance with applicable laws, including The Personal Information Protection and Electronic Documents Act (“PIPEDA”). We have also taken reasonable measures to ensure that our Service Providers do not
disclose or use your Personal Information for any other purpose except as described in this Policy. FLEXM may also disclose your Personal Information as follows:
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(a) to comply with its legal obligations. This includes disclosing Personal Information to financial institutions such as Bank of Canada and regulatory agencies such as FINTRAC to meet legal obligations and responding to valid legal requests from courts, law enforcement agencies, regulatory agencies and other public and government authorities;
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(b) to protect and defend the rights or property of FLEXM or users of the Site or Services;
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(c) to prevent or investigate possible wrongdoing in connection with the Site or Services;

(d) to protect the personal safety of users of the Site or Services or the public;

(e) to protect FLEXM against legal liability;

(f) to protect the security or integrity of our Site or Services;

(g) to assess or complete a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event where we expect that your Personal Information will be part of the transferred assets; and

(h) to conduct inquiries as necessary with third parties such as credit reference agencies, fraud prevention or financial crime agencies.

9. TRANSFER OF PERSONAL INFORMATION
Personal Information may need to be transferred out of your country of residence, whether in the course of providing you with any Service or when storing your Personal Information on servers located outside of your country of residence. In creating a User Account and accessing and using the Site or Services, you are deemed to agree to the
transfer of your Personal Information outside of your country of residence. Your Personal Information will not be transferred to another organization or country unless there are adequate controls in place, including controls relating to the security of your Personal Information. However, if your Personal Information needs to be transferred to countries that have less stringent personal data protection laws than your country of residence, in order to provide you with the Services, you are deemed to consent to such transfer in providing your Personal Information to us during your use of the Site or the Services.
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10. RETENTION OF PERSONAL INFORMATION
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We retain your personal information as long as necessary to fulfill the purpose(s) for which such information was collected or as required by law. Once the retention period has expired, we take reasonable steps to securely dispose of or anonymize your information.

11. SECURITY OF PERSONAL INFORMATION
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The security of your Personal Information is important to us. We take reasonable security measures to keep your Personal Information safe and to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or other similar risks. However, no method of electronic transmission or electronic storage is fully secure. You hereby acknowledge and accept that while we strive to protect your Personal Information, we cannot guarantee its absolute security.
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12. ACCESS, QUESTIONS AND CONCERNS
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You may access, update or correct your personal information by making a request to us using the contact information below. We may need to verify your identity before granting access or otherwise updating or correcting your personal information.

Please contact us if you have any concerns or questions regarding this Privacy Policy.

FLEXM FINANCIAL TECHNOLOGIES LTD.
[Insert name or title of individual]
[Insert address]
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cs_canada@flexm.com