The following 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 information while using our website and services.

Why we collect information from you

Payline collects personal information only as necessary to:

• Provide our services
• Meet legal and regulatory requirements
• Protect our business and clients from fraud and misuse
• Improve your experience with paylinefx.ca

As a regulated money services business, we are required to collect certain information to:

• Verify identity
• Process transactions
• Conduct compliance screening
• Monitor activity
• Maintain records
• Meet anti-money laundering, sanctions, and regulatory obligations

Collection of personal information is limited to what is necessary for these purposes.

Collecting personal information

We will ask for information when it is required to identify you, contact you, or provide our services.

This may include:

• Account information – name, address, contact details, date of birth
• Identity verification and compliance information – government ID, occupation, source of funds, transaction purpose
• Transactions – payment details, beneficiary information, transaction history
• Customer support and communications – inquiries, feedback, and correspondence
• Login credentials – user IDs and passwords for secure access

We may also collect limited non-personal information to improve website performance and usability..

Use & disclosure of personal information

We use personal information only for the purposes it was collected, for related purposes, or as required or permitted by law.
This includes:

• Providing and administering services
• Verifying identity and customer information
• Processing transactions
• Conducting AML/ATF monitoring, sanctions screening, and fraud prevention
• Meeting legal and regulatory obligations
• Maintaining the security of our systems and services
• Investigating unauthorized or illegal activity
• Improving our services and operations

Disclosure to banking partners and financial institutions

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

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

This is required for:

• Transaction processing and settlement
• Compliance with AML/ATF and sanctions obligations
• Risk management and fraud prevention

Service providers and third parties

We may also share information with trusted service providers, including:

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

All third parties are:

• Subject to risk-based due diligence
• Contractually required to protect your information
• Required to use information only for authorized purposes

Payline remains responsible for all information shared on its behalf,

Regulatory and legal disclosure

Payline may disclose personal information to:

• FINTRAC
• Law enforcement agencies
• Regulators and supervisory authorities (including the Bank of Canada, where applicable)

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
• Sanctions compliance
• Fraud detection and investigation
• Law enforcement or national security requests
• Regulatory examinations and oversight

Payline may be legally prohibited from disclosing certain reporting activities to clients (for example, suspicious transaction reporting).

Cross-border data transfers

Personal information may be processed or stored outside of Canada by Payline or its service providers.

As a result:

• Information may be subject to foreign laws
• It may be accessible to foreign regulators or authorities

Payline ensures appropriate safeguards are in place and remains responsible for protecting your information.

Retention/disposal of personal information

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

• Minimum 5 years for AML/ATF and regulatory requirements
• Longer retention where required (e.g., investigations, audits, or legal obligations)

Information will not be deleted where:

• A regulatory requirement exists
• An investigation or review is ongoing

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

Cookies and website data

Paylinefx.ca uses cookies and similar technologies to:

• Support website functionality
• Maintain secure sessions
• Improve user experience
• Understand how visitors use our website

You may disable cookies through your browser settings, though this may affect functionality.

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

We regularly review and update our security practices.

Your rights

You may:

• Request access to your personal information
• Request correction of inaccurate information
• Withdraw consent (where applicable)

Limitations

These rights are subject to legal and regulatory restrictions.

We may not be able to fulfill requests where doing so would:

• Violate AML/ATF or sanctions laws
• Interfere with regulatory reporting obligations
• Compromise fraud detection or investigations
• Result in unlawful “tipping off”

You may also contact the Office of the Privacy Commissioner of Canada if you have concerns.

Links to other websites

Our website may contain links to third-party websites. Payline is not responsible for their privacy practices. We encourage you to review their policies.

Changes to this privacy statement

This statement may be updated from time to time to reflect changes in legal requirements or business practices.

The most current version will always be available on our website.

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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.