1. Children’s Privacy

Children are not eligible to use Switch Hub Services. We respectfully ask that minors (persons under the age of 18) do not submit any information to us or use Switch Hub. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on this Resources or through any of its features, register on the Resources, make any purchases through the Resources, use any of the interactive or public comment features of this Resources, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18, we will reject the application or close the account and delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@switchhub.ca.

2. Who we are?

Switch Hub is a Canadian MSB registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) with registration number M22578161, authorized to provide remittance and related financial services in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)and other applicable Canadian laws and regulations.

Switch Hub determines the purposes and means of processing personal information collected through our Resources. We are committed to safeguarding your privacy and handling your information transparently, lawfully, and securely.

If you wish to contact us in relation to questions regarding your personal information, we refer you to the ‘CONTACT US’ section below.

3. Personal information we collect

We, or our third-party service providers on our behalf, may collect the following categories of personal information:

1. Identification and contact data – name, date of birth, address, phone number, email, occupation, nationality, government-issued ID;
2. Compliance and AML information- source of funds, purpose of transactions, beneficiary details, sanctions screening and supporting documentation required by law;
3. Photo(s) to compare against provided identity documents (e.g., selfie);
4. Technical and Usage Data – IP address, browser type, device identifiers, login information, time zone, operating system, login metadata and platform);
5. Financial and Transaction Data – details of the transactions you carry out when using our Services, including geographic location, currency, amounts, and beneficiary details); and
6. Communications and support Data – records of correspondence, complaints, chat logs, inquiries, or feedback submitted via email or in-app support.
7. Where required by law or to meet anti-money laundering and fraud prevention obligations, we may collect additional information.

You represent and warrant that all personal information provided to us is true, complete and accurate, and you bear all risk arising from any inaccuracy or omission.

4. How we collect information

1. Information you provide to us: We may collect and store any information you provide to us when you use the Services, including when you add information on our website, mobile platform, add or update your account information, or dispute resolutions, or when you otherwise correspond with us regarding the Services. We may also collect and store your information when you participate in discussion boards or other social media functions on our website or App, enter a competition, promotion or survey, and when you report a problem with the services. The information you give us may include your name, address, e-mail address, phone number, financial information (including bank account information), payment reason, geographical location, personal description and photograph. We may also need additional commercial and/or identification information from you e.g., if you send or receive certain high-value or high-volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.
2. Information from other sources: We may also obtain information about you from third parties such as identity verification providers and credit bureaus to meet AML/KYC obligations.
3. Information from social networks: If you log in to our services using your social media account (for example, Facebook, Instagram) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account, so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this policy.
4. Automatically through cookies, device analytics, and usage tracking.

5. Purposes and Legal Bases for Processing

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use the following information to:

1. provide the Services and customer support;
2. process and complete transactions and send related notices;
3. verify your identity and meet AML/CTF obligations (PCMLTFA/FINTRAC guidance)
4. manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
5. detect, prevent or remediate violations of policies or applicable user agreements;
6. improve the Services by customizing your user experience;
7. measure the performance of the Services and improve their content and layout;
8. Maintain accurate business and transaction records as required by FINTRAC;
9. manage and protect our information technology infrastructure;
10. provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences;
11. contact you at any telephone number, by placing a voice call or through text (SMS) or WhatsApp or email messaging, as authorized by our User Agreement;
12. perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties.
13. Meet legal and regulatory reporting duties.

Switch Hub does not sell or share user personal data with third parties for their direct marketing, except with Users’ consent. Our legal bases include: your consent; legal obligations; and legitimate interests (fraud prevention, security, and service improvement). We will not use personal information for a new purpose without obtaining consent or as otherwise permitted by law.

6. Marketing

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your personal information with information we collect from other companies and use it to improve and personalize the Services, content, and advertising.

If you have agreed to receive such marketing materials, you may always opt out at a later date. You have the right at any time to stop us from contacting you for marketing purposes.

If you no longer want to receive marketing-related emails from us, you may opt-out by following the instructions in any such email. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt-out, we may still send you important administrative messages, from which you cannot opt-out.

Switch Hub does not sell or share User personal data with third parties for their direct marketing purposes, except with Users’ consent.

7. Disclosure of personal information

We may share your personal information with:

1. Financial institutions and payment processors, to execute transactions;
2. Identity verification and fraud prevention providers to fulfill KYC/AML obligations;
3. Regulatory and law enforcement authorities including FINTRAC, as required by law;
4. Professional advisers, auditors, and service providers under strict confidentiality; and
5. Affiliates or successors in the event of a merger or restructuring.

All third-party partners are contractually required to maintain equivalent privacy and security standards.

8. Who handles personal information?

Most personal information that Switch Hub collects is processed by our own employees, but for some purposes, we rely on third parties. We collect and process personal information using Switch Hub employees who have received training in the importance of security, confidentiality, and privacy.

9. Data Security

We maintain technical, organizational, and administrative safeguards, including encryption in transit and at rest, role‑based access controls, secure development practices, and employee confidentiality training. If a privacy breach creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada (OPC) as required by PIPEDA.

10. Access and corrections

You have the right to request access to your personal information, correct inaccuracies, withdraw consent (subject to legal and contractual limits), request deletion where permissible, and complain to the Office of the Privacy Commissioner of Canada. Requests can be submitted to privacy@switchhub.ca.

11. Retention of personal information

We retain personal information:

• for a minimum of five (5) years following the end of a business relationship or transaction, as mandated by FINTRAC;
• for as long as necessary to fulfill the purposes for which it was collected; and
• as otherwise required by law, taxation, audits, or investigations.

At the end of the retention period, information is securely destroyed or anonymized.

12. Cookies and Tracking Technologies

We use cookies and similar tools for session management, fraud detection, analytics, and personalization. You can control or disable cookies via browser settings; some features may not function properly if cookies are disabled.

13. International Transfers

Your information may be transferred and processed in jurisdictions outside of Canada where privacy laws may offer different levels of protection. We ensure that appropriate contractual and technical safeguards are in place to protect your data, consistent with Canadian standards,

14. Third-Party Links

Our website or app may contain links to other websites not operated by Switch Hub.
We are not responsible for their privacy practices. Please review their policies before submitting personal information.

15. Changes to this Policy

We may amend this Policy to reflect legal or operational changes. Updates will be posted on our website with a new “Last Updated” date. Material changes will be communicated via email or in‑app notice.