Privacy Policy

Introduction

Sendnova (“we”, “us”, “our”) is operated by Velial Finance Limited, a Money Services Business (MSB) registered with FINTRAC (registration number M123456789) and incorporated in British Columbia, Canada.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our website (sendnova.com), mobile applications, or any of our money-transfer, foreign-exchange, or virtual-currency services (collectively, the “Services”).

We are committed to protecting your privacy and handling your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

Contact Us / Data Protection Officer

If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Officer at: Email:privacy@sendnova.com

Mailing address: Velial Finance Limited, [Your Full Canadian Address], British Columbia, Canada

What Personal Information We Collect

We may collect the following categories of personal information:

• Full name, date of birth, nationality, and contact details (email, phone, messenger IDs)
• Government-issued identification documents (passport, driver’s licence, etc.) and selfies/biometric data used for identity verification
• Residential address and proof of address
• Financial information (bank account details, source of funds, source of wealth)
• Employment and business information
• Transaction history and records
• IP address, device information, browser fingerprint, and logs of your activity on our platform
• Any other information required under our AML/CTF Program or by applicable law

How We Use Your Personal Information (Purposes & Lawful Bases)

PurposesLawful Bases under PIPEDA

To verify your identity and perform KYC/AML checks	Legal obligation (PCMLTFA & FINTRAC)
To provide and manage the Services you request (money transfers, currency exchange, crypto services)	Performance of contract
To process payments and settlements	Performance of contract / Legal obligation
To detect, prevent, and investigate fraud, money laundering, terrorist financing, or other illegal activities	Legal obligation + Legitimate interest
To comply with sanctions screening and regulatory reporting	Legal obligation
To communicate with you (support, service updates, marketing with consent)	Consent (for marketing) / Legitimate interest (for service messages)
To improve our Services and for internal analytics	Legitimate interest
To defend or establish legal claims	Legitimate interest

Automated Decision-Making

Some onboarding, risk-scoring, and transaction-monitoring decisions are made automatically (including profiling). You have the right to request human review of any fully automated decision that produces legal or similarly significant effects on you.

Who We Share Your Personal Information With

We may share your personal information with:

• Our affiliates and service providers (identity-verification providers, fraud-prevention vendors, cloud hosting, payment processors, banks, and correspondent banks)
• Law enforcement, regulators (including FINTRAC), or courts when required or permitted by law
• Other financial institutions for sanctions screening or transaction execution

International Transfers of Personal Information

We transfer personal information to service providers located in the United States, European Union, and other jurisdictions. All transfers are protected by appropriate safeguards such as Standard Contractual Clauses, adequacy decisions, or Binding Corporate Rules, in accordance with PIPEDA requirements.

Personal Data Retention

We retain your personal information only as long as necessary for the purposes set out above and to comply with our legal obligations.

• Transaction records and KYC documents are kept for a minimum of five (5) years after the end of the business relationship (or after the transaction date for occasional transactions), as required by FINTRAC.
• Where we have indicated a 7-year retention period for certain records, we will securely delete or anonymize the data after that period unless longer retention is required by law.

Your Privacy Rights

Under Canadian privacy law you have the right to:

• Access your personal information
• Correct inaccurate information
• Withdraw consent (where processing is based on consent)
• Request deletion or restriction of processing (subject to legal restrictions)
• Data portability
• Object to processing based on legitimate interests

Please note: Because we are a FINTRAC-regulated MSB, certain rights (especially deletion and objection) may be limited where we have a legal obligation to retain or process the data under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. We will explain any limitations if you make a request.

To exercise any right, contact privacy@sendnova.com. We will respond within 30 days.

Children’s Privacy

Our Services are not directed to individuals under the age of 19 (or the age of majority in your province). We do not knowingly collect personal information from minors.

Security

We implement industry-standard technical and organizational measures (including SSL/TLS encryption, access controls, and regular security assessments) to protect your personal information.

Changes to this Policy

We may update this Policy from time to time. We will notify you of material changes by posting the new Policy on our website and, where appropriate, by email.

Complaints

If you believe we have not handled your personal information in accordance with Canadian privacy law, you may file a complaint with us at privacy@sendnova.com or directly with the Office of the Privacy Commissioner of Canada.