The following Online Privacy Statement explains why Payline by ICE Limited Partnership (Payline) collects information from you, how we use it, who we may share it with, and the steps we take to protect your privacy while using our website and our services.

Why we collect information from you

Payline collects personal information from you only as necessary to provide our services, comply with legal and regulatory requirements, protect our business and customers from fraud and misuse, and improve your experience with paylinefx.ca.

As a money services business, we are required to collect certain information to verify identity, process transactions, conduct compliance screening, monitor activity, maintain records, and meet our legal and regulatory obligations.

Collection of personal information is limited to what is necessary for identified purposes, including regulatory compliance and operational requirements.

We may also collect limited non-personal information to better understand how visitors use our website and to improve website performance and usability.

Collecting personal information

Payline will ask you when we need information that identifies you, allows us to contact you, or is required to provide our services.

This information may include:

1. User ID and passwords – Used to provide access to secure or profile-based areas of our applications and services. 
2. Account information – Such as your name, address, telephone number, email address, date of birth, and other identifying details needed to create and manage your account.
3. Identity verification and compliance information – Government-issued identification, occupation, source of funds, transaction purpose, and other information required for know-your-client (KYC), anti-money laundering (AML), sanctions screening, fraud prevention, and legal compliance.
4. Customer feedback and support – Information you provide when requesting assistance, providing feedback, submitting complaints, or contacting Payline.
5. Email correspondence – Used to respond to your questions, requests, and service-related communications. With your consent where required, it may also be used to send information about Payline products and services.
6. Transactions – Information relating to the services you request, including payment details, beneficiary information, transaction history, and related records needed to process and support your transactions.

Use & disclosure of personal information

Personal information about you will only be used for the purposes for which it was collected, for purposes reasonably related to those purposes, or as otherwise authorized or required by law.

These purposes may include:

• providing and administering services
• verifying identity and customer information
• processing payments and transactions
• conducting AML/ATF monitoring, sanctions screening, and fraud prevention
• complying with legal and regulatory obligations
• maintaining the security of our website, systems, and records
• investigating unauthorized or illegal activity
• improving our website, services, and internal operations

Disclosure to banking partners and financial institutions

To provide services and meet our regulatory obligations, Payline may share personal information with:

• Banking partners and financial institutions
• Correspondent banks
• Payment networks and clearing systems

This sharing is necessary for:

• Transaction processing and settlement
• Compliance with AML/ATF obligations
• Risk management and fraud prevention
• Meeting legal and regulatory requirements

Service providers and third parties

We may also share information with:

• Identity verification providers
• Technology and cloud service providers
• Compliance and risk management service providers

These parties are required by contract or other appropriate means to safeguard personal information and use it only for authorized purposes.

Regulatory and legal disclosure

Payline may disclose personal information to:

• FINTRAC
• Law enforcement agencies
• Regulators and supervisory authorities (including, where applicable, the Bank of Canada under the Retail Payment Activities Act)

Disclosure without consent

Personal information may be collected, used, or disclosed without your knowledge or consent where permitted or required by law, including for:

• AML/ATF reporting obligations
• Law enforcement or national security requests
• Sanctions compliance
• Fraud detection and investigation
• Regulatory examinations and oversight

Payline is legally prohibited from disclosing certain regulatory reporting activities to clients (“tipping off” restrictions).

Cross-border data transfers

Personal information may be processed or stored outside of Canada by Payline or its service providers, including cloud providers, financial institutions, or banking partners.

As a result, personal information may be subject to the laws of foreign jurisdictions and may be accessible to foreign courts, law enforcement, or regulatory authorities.

No sale of personal information

Payline does not sell personal information and does not disclose personal information to unrelated third parties for their own marketing purposes.

Retention/disposal of personal information

Personal information is retained only as long as necessary to fulfill identified purposes and legal obligations.

• Minimum 5 years (AML requirements)
• Longer where required (e.g., tax or regulatory obligations)

When no longer required, information is securely destroyed, deleted, or anonymized.

Collecting non-personal information

Paylinefx.ca automatically collects non-personal information such as device data, IP address, and website usage to improve functionality, security monitoring, and user experience.

Clickstream data

This data may include general log information such as the full Uniform Resource Locator (URL) of the pages you access on paylinefx.ca, the Internet Protocol (IP) address used to connect your device to the Internet, browser and device information, referral pages, page views, unique visitors, and time spent on the website.

Our use of cookies

Session cookies: A session cookie is a small text file placed on your browser by a web server. Paylinefx.ca may use session cookies to support site navigation, maintain information from page to page, keep secure sessions active, and improve website functionality. Session cookies are generally deleted when you close your browser session.

Persistent cookies: A persistent cookie is a small text file placed on your device by a web server. Persistent cookies may be used to remember preferences, support login continuity where applicable, improve convenience, and help us understand how visitors use our website over time. Persistent cookies remain on your device until they expire or are deleted.

Payline does not use cookies to retrieve information from your computer that is not related to the cookie, nor to install harmful code on your device.

If you do not want cookies stored on your computer, you may set your browser to refuse some or all cookies. Doing so may affect website performance or prevent you from using certain features of paylinefx.ca.

Safeguarding your information

Payline uses physical, technical, and administrative safeguards to protect personal information, including:

• Encryption
• Access controls
• Monitoring and logging
• Secure system configurations
• Employee confidentiality obligations
• Remote access and acceptable use controls

Your rights

You may:

• Request access to your personal information
• Request correction of inaccurate information
• Withdraw consent, subject to legal and regulatory restrictions

You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated.

Requests can be made at: support@paylinefx.ca.

Links to other sites

Paylinefx.ca may from time to time contain links to other websites. While Payline takes reasonable steps to link to reputable websites, we are not responsible for the privacy practices, content, or security of those other websites. We encourage you to review the privacy policies of any external sites you visit.

Privacy Law

Payline handles personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act.

Changes to this privacy statement

This policy may be updated from time to time and will be posted on our website.

Data Security

Payline is committed to protecting the security and integrity of our systems and the information in our custody.

How we protect your information

We use safeguards appropriate to the sensitivity of information, including:

• Encryption in transit and, where appropriate, at rest
• Secure network and system configurations
• Access controls and authentication measures
• Monitoring, logging, and threat detection
• System updates and vulnerability management

Employee access and acceptable use

Access is limited to authorized personnel.

Employees must:

• Follow Acceptable Use and Information Security policies
• Use secure devices and networks
• Maintain confidentiality
• Report security incidents promptly

Third-party security

Service providers are required to maintain appropriate safeguards and security standards through contractual obligations.

Monitoring and risk management

Payline monitors systems and transactions to detect:

• Unauthorized access
• Fraud or misuse
• Security threats

These controls support regulatory compliance and operational risk management.

Incident response

In the event of a security incident, Payline will:

• Investigate and contain the issue
• Mitigate risks
• Notify affected individuals where required
• Report to regulators where applicable

Client responsibilities

Clients are responsible for:

• Protecting login credentials
• Using strong passwords
• Reporting suspicious activity

Continuous improvement

Security practices are regularly reviewed and updated to address evolving risks and regulatory expectations.