1. Introduction

Maple PayExchange Inc. (“MPE Inc.”, “we”, “our”, “us”) respects your privacy and is committed to protecting your privacy and safeguarding your personal data. This Privacy Policy explains how we collect, use, store, disclose, and protect your information when you use our mobile application, website, and related services (collectively, the “Services”).

We operate in Canada, Nigeria, and serve users globally. This policy is designed to comply with:

• Canada’s PIPEDA and FINTRAC AML/KYC requirements
• Nigeria Data Protection Regulation / Nigeria Data Protection Act
• General Data Protection Regulation (GDPR) for EU/EEA and UK users
• California Consumer Privacy Act (CCPA/CPRA)

By creating an account and selecting “I agree to the terms and conditions of this service,” you consent to the collection, use, processing and disclosure of your personal data as described in this Privacy Policy.

If you do not agree, you will not be able to create a profile or use our Services.

2. Data Controller

MPE Inc. is the controller of your personal data for the purposes of applicable privacy laws including PIPEDA, NDPR/NDP Act, GDPR, and others.

Contact: privacy@mpexchange.ca

3. Information We Collect

We collect personal data only where necessary for providing our Services and complying with legal requirements.

A. Information you provide

• Identification details: Full name, address, date of birth, occupation.
• Verification documents: Government ID, proof of address.
• Biometric data: Facial images or biometric identifiers (via Veriff).
• Contact info: Email, phone number.
• Account details: Username, password, profile photo.
• Communications: Support messages and transcripts.

B. Information collected automatically

• Device details, IP address, OS, browser type.
• Crash reports, analytics, performance data.
• Location data (with permission).

C. Information from third parties

• Apaylo & FINCRA: Payment processing.
• Veriff: KYC and biometric verification.
• AWS: Cloud hosting.
• Public sources where legally permitted.

4. Legal Basis for Processing

• Consent
• Performance of a contract
• Legal obligation
• Legitimate interests

5. How We Use Your Information

• Verify identity (KYC/AML)
• Process payments
• Send account updates
• Provide customer support
• Ensure legal compliance
• Improve and secure Services
• Analytics and product development

6. Disclosure of Personal Data

• Regulatory authorities (FINTRAC, NDPC, etc.)
• Service providers (Apaylo, FINCRA, Veriff, AWS)
• Business partners (where applicable)
• Law enforcement (when required)
• Corporate transactions

We do not sell your personal data.

7. International Data Transfers

Your data may be stored or processed in Canada, USA, Europe, or Nigeria with appropriate safeguards.

8. Data Retention

• KYC/AML records: 7 years from account closure
• Transactional data: 7 years
• Account information: Until closure + legal requirements
• Support communications: Up to 3 years

9. Your Rights

• Access your data
• Correct/update data
• Delete data (subject to law)
• Restrict/opt-out of processing
• Withdraw consent
• Data portability

Requests: privacy@mpexchange.ca

10. Data Security

• Encryption (TLS, at rest)
• Role-based access controls
• Secure AWS hosting

If you suspect a security issue: security@mpexchange.ca

11. Cookies, SDKs & Tracking

We use cookies and SDKs for core functionality, fraud prevention, and analytics. You may control tracking via device settings.

12. Children's Privacy

Our Services are not intended for individuals under 18.

13. Updates to This Policy

We may update this Privacy Policy periodically and will post changes accordingly.