Privacy Policy

1. Who we are

QapuPay is operated by Arcus Fintech Inc. (“Arcus Fintech”, “we”, “us”), incorporated in British Columbia, Canada (incorporation number BC1574109) and registered with FINTRAC as a money services business (MSB registration number N300000911).

We handle personal information in line with British Columbia’s Personal Information Protection Act (PIPA) and, where it applies, the Personal Information Protection and Electronic Documents Act (PIPEDA). Our Privacy Officer is accountable for how we handle personal information.

2. Information we collect

We collect only what we need for the purposes described in this policy.

• This website. Our hosting provider processes technical data your browser sends, such as IP address, browser type, the page requested and the time of the request, to deliver the site and protect it from abuse. Analytics are described in section 3.
• When you contact us. Your name, your email address and the message you write. We also record when you wrote and the country your connection comes from. To limit abuse, we keep a one-way, salted hash of your IP address, not the address itself.
• When you use QapuPay. Identity information (full name, date of birth, address, occupation and government-issued ID details and, where required, a photo or video of you to confirm that the ID belongs to you); contact details; wallet addresses and transaction history; card transactions if you use the card; device, login and security information; and, if a friend invited you, who invited you.
• From other sources. Where the law requires or permits it, information from identity verification services, sanctions and politically exposed person screening lists, and public blockchain data.

3. Cookies and analytics

• Cloudflare Web Analytics. We use it to count visits and measure page performance in aggregate. It does not set cookies.
• Google Analytics. It runs only if you select “Allow” in the analytics banner. If you allow it, Google Analytics sets cookies whose names start with _ga to count visits and understand how the site is used. We have turned off Google signals and ad personalization, and we do not use advertising cookies.
• Your choice. We store your Allow or Decline choice in your browser’s local storage. You can change it at any time with “Privacy choices” at the bottom of every page, which also removes Google Analytics cookies.
• Spam protection. The contact form uses a hidden check field and rate limits to filter automated submissions. It does not use a third-party CAPTCHA service.

4. How we use it

• To answer your enquiries and send you messages about the service.
• To provide, operate and support QapuPay and the account you hold with us.
• To verify your identity and meet our obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, including client identification, record keeping, ongoing monitoring and reporting to FINTRAC.
• To detect and prevent fraud, unauthorized access and other misuse, and to keep QapuPay secure.
• To understand how the website is used, in aggregate, and improve it.
• To comply with the law and respond to lawful requests from authorities.
• To send you marketing messages, only with your consent. You can unsubscribe at any time.

5. Consent

We collect, use and share personal information with your consent, except where the law permits or requires otherwise. You can withdraw your consent at any time, subject to legal and contractual limits. If you withdraw consent for information the law requires us to collect, we may not be able to provide QapuPay to you. Where we use a photo or video of your face to confirm your identity, we will ask for your express consent at that time and will not use it for any other purpose.

6. How we share it

We do not sell personal information. We share it only as follows:

• Service providers that work on our behalf, such as Cloudflare for hosting and security, Google for analytics if you allow it, and providers of email delivery, identity verification, card issuing, payment processing and professional advice. They may use the information only to provide services to us, and must protect it under written agreements.
• FINTRAC, law enforcement and other authorities, where the law requires or permits it. The law may prevent us from telling you that we have made a report.
• A buyer or successor, if all or part of our business is sold or reorganized, under a duty of confidentiality.
• Anyone else, with your consent.

7. Where your information is stored

Our service providers may store or process personal information outside Canada, including in the United States. Information held in another country is subject to that country’s laws and may be accessed by its courts, law enforcement and national security authorities.

8. How long we keep it

We keep personal information only as long as we need it for the purposes above, or as long as the law requires. Records we must keep as a money services business, such as identity verification and transaction records and reports to FINTRAC, are kept for at least five years. When we no longer need information, we destroy it securely or remove what identifies you.

9. How we protect it

We use physical, organizational and technical safeguards appropriate to the sensitivity of the information, including encryption in transit and access limited to people who need it for their work. If a breach of our safeguards creates a real risk of significant harm to you, we will notify you and the relevant privacy commissioner, as the law requires or as we otherwise consider appropriate.

10. Your rights

You can ask to see the personal information we hold about you, ask us to correct it if it is inaccurate or incomplete, and ask how it has been used and shared. We will reply within 30 days and may first ask you to confirm your identity. If the law allows us more time, we will write to you before the 30 days end, explain why, give you the new date and remind you that you can complain to the privacy commissioner named in section 13. In some cases the law permits or requires us to withhold information, for example information about reports made to FINTRAC; if so, we will tell you why where we are allowed to.

11. Children

QapuPay is not intended for anyone under the age of majority in their province or territory, and we do not knowingly collect their personal information.

12. Changes to this policy

We may update this policy. The current version is always published on this page with its effective date. If you use QapuPay, we will tell you about material changes before they take effect.

13. Contact us

For any question or request about your personal information, write to our Privacy Officer at hello@qapupay.com with “Privacy” in the subject line.

If you are not satisfied with our response, you can complain to the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca) or, where PIPEDA applies, to the Office of the Privacy Commissioner of Canada (priv.gc.ca).