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Privacy Policy

Last updated on August 28, 2026

INTRODUCTION

This Privacy Policy (hereinafter – “Policy”) provides a clear and comprehensive explanation of how BLACKVERGE FINANCIAL Inc., a company incorporated under the laws of Canada, under company number 2028407001, having its registered and business address at 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada (hereinafter – “Company”, “We”, “Us”, or “Our”), collects, uses, discloses, retains, safeguards and otherwise processes personal information in connection with the provision of its services.

The Company intends to provide over-the-counter services (hereinafter – “OTC Services”) involving virtual currencies, including the direct purchase, sale and exchange of virtual currencies with its Clients on a principal-to-principal basis, following completion of the registrations required under applicable law.

The Company is in the process of applying for registration with the Financial Transactions and Reports Analysis Centre of Canada (hereinafter – “FINTRAC”) as a Money Services Business (hereinafter – “MSB”) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (hereinafter – “PCMLTFA”).

References in these Policy to “You”, “Your” and “User” mean any person accessing or using the Website. Where a person independently contacts the Company and is accepted by the Company for onboarding, verification, or further transaction-related communications, such person may also be referred to as a “Client”.

Given the nature of the Company’s activities, the provision of the OTC Services requires the collection and processing of certain personal information, including information necessary for Client identification and verification, compliance with applicable anti-money laundering and anti-terrorist financing requirements, transaction processing and monitoring, fraud prevention, recordkeeping and other regulatory and legitimate business purposes.

The Company is committed to protecting the privacy, confidentiality and security of personal information entrusted to it and processes such information in accordance with applicable Canadian privacy and data protection legislation. The specific legal framework applicable to the processing of personal information and the scope of this Policy are described in the following section.

1. APPLICABLE PRIVACY FRAMEWORK AND SCOPE

The Company processes personal information in accordance with applicable Canadian privacy legislation. In particular, the Personal Information Protection Act (Alberta) (hereinafter –“PIPA”) applies to the Company’s processing of personal information within the scope of that Act. The Personal Information Protection and Electronic Documents Act (hereinafter – “PIPEDA”) may apply to personal information collected, used or disclosed in the course of interprovincial or international commercial activities and in other circumstances within its scope. Other federal or provincial privacy requirements may apply depending on the particular processing activity.

Where the processing of personal information falls within the territorial scope of the General Data Protection Regulation (EU) 2016/679 (hereinafter – “GDPR”), the Company will process such personal information in accordance with the GDPR to the extent applicable.

The Company may provide services to persons located in the European Economic Area (hereinafter – “EEA”) only where such services may lawfully be provided, including, where applicable, where the relationship has been initiated exclusively by the Client.

This Policy applies to personal information collected, used, disclosed or retained by the Company in connection with its website, OTC Services and other business activities, including information relating to Clients and prospective clients, directors, officers, beneficial owners, authorized representatives and other individuals associated with corporate Client.

It covers personal information collected directly from individuals, through the Company’s website and onboarding procedures, in connection with OTC transactions, or from third parties and publicly available sources where permitted by applicable law.

Where the processing of personal information is subject to the privacy or data protection laws of another jurisdiction, the Company will comply with such requirements to the extent applicable.

2. PERSONAL INFORMATION WE COLLECT

For the purposes of this Policy, “personal information” means any information about an identifiable individual, as defined under applicable Canadian privacy legislation. This includes information that identifies an individual directly or that may reasonably allow an individual to be identified when considered together with other available information.

Personal information does not generally include information that has been anonymized or aggregated in such a manner that an individual can no longer reasonably be identified, or information that is excluded from the definition of personal information under applicable law.

The type of personal information We collect depends on the nature of Your interaction with the Company and the OTC Services You use. We may collect the following categories of personal information:

  • Request data: full name, contact details, requested transaction amount and requested exchange pair.
  • Communication data: messages and correspondence exchanged with the Company’s representatives, transaction-related instructions and confirmations, timestamps and other communication metadata available to the Company.
  • KYC/KYB data: identity document data, proof of address, selfie and liveness verification data where applicable, date of birth, nationality, country of residence, occupation or nature of principal business, corporate documents for legal entities, information concerning directors, authorized representatives and beneficial owners, source of funds and source of wealth information where required, as well as sanctions, PEP/HIO, adverse media and fraud-screening results.
  • Transaction and AML/ATF data: virtual currency wallet addresses, blockchain transaction hashes, fiat payment information, bank account and payment details where applicable, transaction amount, asset type, exchange pair, applicable rate and execution status, KYT and blockchain analytics results, risk assessments, onboarding decisions, reasons for rejection or escalation, AML/ATF case notes, alerts, internal compliance decisions and supporting documentation.
  • Technical and usage data: IP address, device type, browser information, general usage data, geolocation indicators, jurisdiction screening results, VPN/proxy detection results and access-control logs used for compliance, fraud prevention and jurisdictional restriction purposes.
  • Cookies and similar technologies: information collected through cookies and similar technologies where applicable.

We take reasonable steps to ensure that personal information used by the Company is accurate, complete and up to date as necessary for the purposes for which it is used. Clients are encouraged to inform Us of any changes to their personal information.

3. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

We may collect personal information from the following sources: 

  • Directly from You when You contact the Company, request or use the OTC Services, provide information or documents, submit transaction instructions, complete verification procedures or otherwise communicate with Us.
  • From persons acting on Your behalf or associated with You, including authorized representatives or representatives of corporate Clients.
  • From third-party service providers, including identity verification, KYC/KYB, fraud prevention, blockchain analytics and other compliance service providers engaged by the Company.
  • From financial institutions and payment service providers involved in processing or settling transactions.
  • From public and regulatory sources, including corporate registers, sanctions lists, PEP/HIO databases, publicly available records and other sources used for verification and compliance purposes.
  • Automatically through Our website, including through cookies and similar technologies and through the collection of technical information relating to Your device, browser and interaction with the website.

Our main purpose in collecting personal information is to ensure the secure, efficient and appropriate provision of Our Services. We limit the collection and use of personal information to what is reasonably necessary for the following purposes:

  • to provide, administer and facilitate Our OTC Services, including processing requests, executing transactions and arranging settlement;
  • to identify and verify Clients and other relevant persons and conduct KYC/KYB and Client due diligence procedures;
  • to comply with applicable AML/ATF, sanctions, recordkeeping, reporting and other legal and regulatory obligations;
  • to assess Clients and transaction risks, conduct transaction monitoring and blockchain analysis, and detect suspicious or potentially unlawful activity;
  • to prevent and investigate fraud, unauthorized activity, misuse of Our Services and security incidents;
  • to communicate with Clients, provide support, respond to inquiries and complaints and deliver transaction-related information;
  • to protect and enforce the Company’s legal rights and respond to lawful requests from courts, regulators, law enforcement agencies and other competent authorities;
  • to operate, maintain, secure and improve Our website and Services; and
  • for other purposes that are identified to You and permitted by applicable law, or where the collection, use or disclosure is otherwise required or authorized by law.

We will only use personal information for the purposes for which it was collected or for other purposes permitted or required by applicable law.

4. CONSENT

Where consent is required under applicable privacy legislation, We will obtain Your consent to the collection, use or disclosure of personal information for the purposes identified in this Policy or otherwise communicated to You.

Consent may be express or implied, depending on the circumstances, the sensitivity of the personal information and the purposes for which it is collected, used or disclosed. Where required, We will obtain Your consent at or before the time personal information is collected or before it is used for a new purpose.

You may withdraw Your consent at any time, subject to applicable legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect Our ability to provide some or all of the Services to You.

Withdrawal of consent does not affect personal information that the Company is required or permitted to retain, use or disclose without consent under applicable law, including information maintained to comply with AML/ATF, recordkeeping, reporting or other regulatory obligations.

In certain circumstances, applicable law permits or requires the Company to collect, use or disclose personal information without consent, including for specified regulatory, investigative, fraud prevention, law enforcement or other legal purposes.

5. DISCLOSURE AND SHARING OF PERSONAL INFORMATION

The Company does not sell or rent Your personal information. We may disclose or share personal information only where reasonably necessary to provide Our Services, operate Our business, comply with applicable legal and regulatory requirements, or for other purposes permitted by applicable law.

We may disclose personal information to the following categories of recipients:

  • identity verification and compliance service providers, including providers supporting KYC/KYB procedures, sanctions and PEP/HIO screening, fraud prevention, transaction monitoring and other compliance functions;
  • banks, financial institutions and payment service providers involved in processing payments, transfers or settlement in connection with Our OTC Services;
  • blockchain analytics and virtual currency service providers, where necessary to assess wallet or transaction risks, facilitate transactions or support Our compliance procedures;
  • technology and infrastructure providers, including hosting, cloud storage, cybersecurity, communications and other service providers supporting the operation of Our business and website;
  • professional advisers, including lawyers, accountants, auditors, consultants and other professional service providers where access to personal information is reasonably necessary for the services they provide;
  • regulatory, governmental and law enforcement authorities, including FINTRAC, where disclosure is required or permitted under applicable law or necessary to fulfil Our regulatory and reporting obligations;
  • parties involved in a corporate transaction, including a merger, acquisition, financing, restructuring, sale of assets or similar transaction, subject to appropriate confidentiality and privacy safeguards; and
  • other persons where required or permitted by law, including where disclosure is necessary to comply with a court order or other lawful request, protect the Company’s legal rights, prevent fraud or unlawful activity, or protect the security of Our Clients and Services.

Where We engage third-party service providers to process personal information on Our behalf, We take reasonable measures to require them to handle such information in accordance with applicable privacy requirements and only for the purposes for which it was disclosed.

Personal information may be transferred to, processed or stored by service providers or other recipients located outside Alberta or Canada. Where personal information is transferred to a service provider, the Company remains responsible for personal information under its control and uses contractual or other appropriate measures to provide a comparable level of protection while the information is being processed by the service provider. Personal information processed outside Canada may be subject to the laws of the applicable foreign jurisdiction and may be accessible to courts, law enforcement or governmental authorities in accordance with those laws.

You may obtain information about the Company’s policies and practices relating to service providers located outside Canada, including information regarding the countries in which such service providers may process personal information and the purposes for which they are authorized to process such information, by contacting the individual responsible for the Company’s privacy compliance using the contact details set out in this Policy.

6. RETENTION OF PERSONAL INFORMATION

The Company retains personal information only for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal and regulatory requirements.

Upon commencement of activities subject to the applicable Canadian MSB requirements, the Company will be required to retain certain records relating to Client identification, transactions, AML/ATF compliance, regulatory reporting and ongoing monitoring, generally for a period of at least five years, depending on the applicable record category and the event from which the statutory retention period is calculated.

Personal information that is not subject to a prescribed statutory retention period will be retained only for as long as reasonably necessary for the purposes described in this Policy. Once personal information is no longer required, We will take reasonable steps to securely delete, destroy or anonymize it, unless further retention is required or permitted by applicable law.

7. SECURITY OF PERSONAL INFORMATION

We maintain reasonable technical, administrative and organizational safeguards designed to protect personal information from loss, misuse, unauthorized access or disclosure, alteration and destruction.

The security measures applied by the Company may include:

  • controlled access – access to personal information is limited to authorized personnel and service providers who require such information to perform their functions;
  • technical safeguards – appropriate security solutions, which may include secure hosting environments, encryption, authentication mechanisms, firewalls and monitoring tools;
  • data minimization – personal information is collected and processed only to the extent reasonably necessary for the purposes described in this Policy;
  • secure data handling – appropriate measures are used when personal information is transmitted, stored or shared with authorized recipients; and
  • incident management – procedures are maintained to identify, assess and respond to suspected or confirmed privacy and security incidents.

Although We take reasonable measures to safeguard personal information, no electronic transmission or storage system can guarantee absolute security. Clients should therefore also take reasonable precautions when providing information to the Company or communicating with Us electronically.

8. PRIVACY AND SECURITY INCIDENTS

The Company maintains procedures designed to identify, assess, contain and respond to privacy and security incidents involving personal information.

Where a breach of security safeguards involving personal information occurs, the Company will assess the circumstances and potential risk of harm to affected individuals and will take appropriate measures to mitigate such risk.

Where required by applicable privacy legislation, the Company will notify affected individuals and report the breach to the competent privacy authority or other relevant organization within the applicable statutory requirements.

The Company will maintain records of privacy and security breaches as required by applicable law and will take reasonable steps to address identified vulnerabilities and reduce the risk of recurrence.

9. YOUR PRIVACY RIGHTS

Subject to applicable privacy legislation and certain legal limitations, You may have the right to:

  • request confirmation as to whether the Company holds personal information about You, access such personal information, and obtain information about how it has been used and to whom it has been disclosed, subject to applicable legal restrictions and exceptions; 
  • request correction of personal information that is inaccurate or incomplete;
  • withdraw Your consent to the collection, use or disclosure of personal information, where processing is based on consent and subject to applicable legal or contractual restrictions;
  • request the deletion, destruction or anonymization of personal information where applicable law provides for such a request and subject to the Company’s legal and regulatory retention obligations; 
  • raise a privacy concern or complaint regarding the Company’s handling of Your personal information.

Certain rights may be restricted where the Company is required to retain or process personal information to comply with applicable AML/ATF, recordkeeping, reporting, legal or regulatory obligations.

Requests relating to Your personal information may be submitted using the contact details provided in this Policy. We may take reasonable steps to verify Your identity before processing a request and will respond within the timeframes required by applicable law.

Where the GDPR applies to the processing of personal information of an EEA Client, such Client may also exercise any additional data protection rights available under the GDPR, to the extent applicable.

10. THIRD-PARTY LINKS

Our website may contain links to third-party websites, platforms or services that are not operated or controlled by the Company. This Privacy Policy does not apply to the collection, use or processing of personal information by such third parties.

The Company is not responsible for the privacy practices, content or security of third-party websites or services. We encourage You to review the applicable privacy policies before providing personal information to any third party.

11. MINORS

Our Services are not intended for individuals under the age of 18. You must be at least 18 years old and have reached the applicable age of majority in Your province, territory or jurisdiction of residence to use Our Services.

The Company does not knowingly provide OTC Services to or collect personal information from individuals who do not meet these age requirements. If We become aware that such personal information has been collected, We will take reasonable steps to delete it, subject to applicable legal and regulatory retention requirements.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in Our Services, business practices, legal or regulatory requirements, or the way We process personal information. Any updated version will be published on Our website together with the date of the latest update. Where a change involves a new purpose for the collection, use or disclosure of personal information, We will obtain consent where required by applicable law.

You should review this Policy periodically to remain informed of any changes to Our privacy practices.

13. CONTACT US AND PRIVACY COMPLAINTS

The Company has designated an individual responsible for overseeing compliance with applicable privacy legislation and for handling privacy-related inquiries, requests and complaints.

If You have any questions, concerns or requests regarding this Policy, the processing of Your personal information, or the exercise of Your privacy rights, You may contact the Company at:

Company name: Blackverge Financial Inc.

Registered address: 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada.
Email: blackverge.financial@gmail.com

We will review and respond to privacy-related requests and complaints in accordance with applicable privacy legislation. We may request additional information where reasonably necessary to verify Your identity or properly address Your request.

If You are not satisfied with Our response, You may have the right to submit a complaint to the Office of the Information and Privacy Commissioner of Alberta or, where PIPEDA applies, to the Office of the Privacy Commissioner of Canada.