Privacy Policy

Date of Last Modified: 2026 – 10 – 16

This Privacy Policy explains how Acanis Major Corp., a corporation incorporated under the laws of the Province of Ontario, Canada ("Acanis", "we", "us" or "our"), collects, uses, discloses, protects and retains Personal Data inconnection with its Website, platform and Services. It should be readwith our General Terms and Conditions. Acanis is responsible for Personal Data under its control under the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy laws. "Personal Data" means information about an identifiable individual; information about a legal entity is coveredby this Policy to the extent that it identifies an individual.

Acanis Major Corp.’s registered office and postal contact address is 30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario, L4B 1B9, Canada. We use Personal Data for the purposes explained in this Policy and apply safeguards appropriate to its sensitivity. Privacy questions, requests and complaints may be addressed to the person responsible for privacy compliance through the Contact section below.

Acanis Major Corp. processes Personal Data in connection with the provision of money services and payment services within the scope of the activities recorded in its FINTRAC registration and subject to applicable legal and regulatory requirements, and to maintain therelated compliance, security and transaction records (the"Services"). The particular Services made available to a client are described in the applicable agreements, terms and service information.

Please read this document carefully in order to understand our approach and policy regarding your Personal Data and how we will use your Personal Data.

This Policy explains our practices; publication of the Policy does not, by itself, constitute your consent to optional uses of Personal Data.

‍What Data We Collect About You

We process Personal Data about individuals connected with those clients or their payments, including directors, authorised representatives,beneficial owners, authorised users, senders and beneficiaries, as well as individuals who contact us or use our Website. An individual’s involvement in a payment, or status as an end user under applicable payment legislation, does not by itself make that individual an onboarded client. The categories below are collected only where reasonably necessary for identified purposes; not every category is collected from every person.

Information You Give to Us

You may provide information to us through forms on our Website, by phone, email, video conference or other communications. This includes Personal Data provided when registering for or using our Services, submitting payment instructions, completing identity verification, communicating with client support, or choosing to participate in a promotion or survey. If a communication is recorded, we explain the recording and its purpose and obtain any required consent before recording begins.

The Data That You Provide to Us As Legal Entity, May Include:
Personal Data About Individuals Connected With Clients or Payments May Include:
Some Personal Data we handle is sensitive, including identity documents, financial information and certain verification or screening information. We limit its collection, use and disclosure to appropriate, identified purposes and apply safeguards proportionate to its sensitivity. We do not seek unrelated information about health, beliefs, sex life or other private matters. Where relevant information is received for a lawful compliance purpose, it is handled only as necessary for that purpose.We use SUMSUB to support remote identity verification and related screening under our Client Onboarding Procedure. This includes obtaining photographs of identity documents and selfies, checking document authenticity and validity, and comparing the document details and photograph with the person being verified. Verification results and relevant decision records are retained in the client file. PEP/HIO, sanctions and adverse-media checks may also be performed through SUMSUB and its relevant screening sources. We assess the results and remain responsible for our client decisions. The information requested depends on the individual’s role and the applicable legal requirements.

Where a verification process uses automated facial comparison, liveness technology or biometric templates, we provide specific information before that processing, including the information involved, purpose, provider’s role, retention, whether an alternative verification method is available and the consequences of declining the proposed method, and obtain express consent where required. The use of a document photograph and selfie does not, by itself, establish which biometric technologies are enabled. Biometric information is not used for advertising or unrelated identification.

If you provide another person’s Personal Data, you should have the authority to do so, provide them with this Policy and obtain any consent required by law. We remain responsible for establishing a lawful basis for our own collection, use and disclosure.

Information We Collect About You
Abouteach of your visits to our Website and use of our Services, we can collect, for example, the following information about you (including automatic collection):
Information We Receive from Other Sources Information We Receive from Other Sources

Where relevant to the purposes in this Policy and permitted by law, we receive Personal Data from banking and payment partners, identity-verification and screening providers, fraud-prevention providers, authorised representatives, public corporate registers and other lawful public sources. Credit-reference, analytics or marketing providers are used only where relevant to the particular activity and with any required consent. Information received may include:
If registration or identity verification is not completed, we may retain the information already provided only for a documented purpose, suchas handling the application, preventing fraud or satisfying a legal record-keeping obligation. An unfinished registration does not, byitself, justify indefinite retention or consent to marketing. Retention is governed by the Retention of Personal Data section.
Cookies

Acanis Major Corp. does not use cookies on its Website or platform. We therefore do not maintain a separate Cookie Policy. If this practice changes, we will update this Policy and provide information about the cookies, their purposes and available choices before they are introduced, and obtain any consent required by applicable law.

Why We Use Your Personal Data
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We are going to use your personal data for the following purposes:
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Provision of Our Services
Informing You About Our Products and Services
Helping Us Improve Our Products and Services
Risk Management and Security
Assuring Legal Procedures
Complying With Legal Regulations
Marketing and Third Parties
We do not make optional marketing consent a condition of receiving the Services. Sharing identifiable information with another organisation for its own marketing requires separate, informed consent where required by law; a consent request identifies the relevant organisation and purpose. We keep appropriate consent and withdrawal records. Withdrawal does not invalidate earlier lawful use or preventretention of a minimal suppression record to respect your choice.
Disclosure of Your Personal Data

We may share Personal Data with relevant affiliates or group companiesonly for identified purposes described in this Policy, such as service administration, compliance or security, where permitted by law and subject to any required consent. Group membership does not give an entity unrestricted access to your information. Access is limited to those with a need to know and subject to appropriate confidentiality and security requirements.

Depending on the Services and processing involved, we may share necessary Personal Data with the following categories of recipients:
Service providers processing information on our behalf are subject to appropriate contractual or other safeguards covering confidentiality, security, permitted purposes, access to records, incident assistance and return or secure disposal when retention is no longer required. We assess relevant providers before engagement and regularly review their suitability and relevant safeguards, and maintain information about their role, processing locations, subcontracting and relevant risks. Provider arrangements require prompt notification of security breaches and cooperation with containment, investigation, recovery and lawful reporting. We remain accountable for information under our control. Banking or payment partners may also act independently for their own legal obligations; their separate notices explain that processing. Further information about relevant recipients and their role may be requested through the Contact section.
We may also disclose your Personal Data to third parties in the following cases:
Cross Border Transfers

The banking and payment arrangements used for the Services, and the location of relevant group companies or service providers, may require Personal Data to be processed or accessed outside Canada. The locations depend on the particular payment route and provider. Information about relevant processing locations and safeguards is available by contacting the person responsible for privacy complianceat info@acanis.io.

When information is transferred to a service provider for processing on our behalf, we remain accountable and use contractual or other means to provide a comparable level of protection. We assess the processing purpose, sensitivity, recipient and risks of the relevant jurisdiction, limit access and require appropriate safeguards. A transfer for a new independent purpose is assessed separately and requires any consent or other authority required by law.

Personal Data processed a broad may be accessible to courts, law enforcement, national security or other authorities under the laws of that jurisdiction. Contractual safeguards cannot override those laws. We provide relevant transparency and apply any additional assessment, notice or consent requirements imposed by applicable provincial or other privacy laws.
Basis for Personal Data Processing

We collect, use and disclose Personal Data for purposes that a reasonable person would consider appropriate in the circumstances. Under PIPEDA, we generally obtain meaningful consent unless a specific legal exception applies. We explain what information is involved, the purposes, relevant recipients and material consequences or risks in a form that is understandable. The following principles apply:
You may withdraw consent by contacting info@acanis.io, subject to legal or contractual restrictions and reasonable notice. We explain the consequences: withdrawal may prevent a particular service where the information is necessary, but does not require us to delete legally required records. Refusing optional marketing does not by itself prevent provision of the core Services.
Your Rights

Subject to applicable law and lawful exceptions, you may contact us to exercise the following rights or make the following requests:
Refuse optional marketing and withdraw marketing consent through the methods described in the Marketing and Third Parties section. This does not affect necessary service or legal notices

We may request proportionate information to verify your identity or authority before acting. We do not request more identification than is reasonably needed. If a request cannot be fulfilled, we explain the reason and available recourse, except where the law restricts that explanation. Access may be restricted, for example, to protect another person’s information, legal privilege or protected regulatory reporting; we consider partial access where lawful.

Our Website may contain active links from/to the Websites of our partners, advertisers and affiliated companies. If you are following an active link, please note that other Websites have their own privacy policies, and we are not responsible for the provisions of these policies. Please review the privacy policies of these Websites before sharing your Personal Data with them.
Access to Personal Data

Send a written access request to info@acanis.io, marked for the attention of the person responsible for privacy compliance. We assist you inidentifying the information requested, verify identity proportionately, and explain the information we hold, its use and the parties to which it has been disclosed, subject to lawful exceptions. We respond as quickly as possible and within 30 days after receipt.Any extension is limited to grounds and periods permitted by PIPEDA; we notify you within the original 30 days of the extension, its reasons and your right to complain to the Office of the Privacy Commissioner of Canada (OPC).

Access is provided at minimal or no cost. If a lawful fee is proposed, we give an advance estimate and confirm that you wish to proceed. If access is refused in whole or in part, we provide written reasons, subject to legal restrictions, and information about recourse to the OPC or another competent privacy authority. We preserve information relevant to an access request for as long as required to allow applicable recourse.
Retention of Personal Data

We retain Personal Data only for as long as necessary for the purposes for which it was collected and to meet applicable legal obligations. Retention depends on the record type, the legal trigger for the period and any properly documented hold. It does not follow a single blanket period for every item of information.

AML/CTF and transaction records are retained under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations for the period applicable to the record. Many transaction records are retained for at least five years from creation; service agreement records are generally retained for at least five years after the last transaction. Copies of suspicious transaction reports are retained for at least five years after submission. The particular statutory trigger governs each category.

Client due diligence, identity and beneficial ownership records are classified according to their legal record type. Information records, corporate-existence records and specified beneficial ownership records are generally retained for at least five years after the last business transaction; other identity-verification and monitoring records follow their applicable statutory rule. Supporting identification images are retained only where necessary for the verification purpose or a specific record-keeping requirement. We do not automatically apply a relationship-end date to every record or retain all images merely because some verification information must be kept.

Records demonstrating compliance with the Retail Payment Activities Act andits regulations, including relevant operational risk, incident,review, testing and provider-assessment evidence, are retained until five years after the day they cease to demonstrate current compliance, subject to applicable conditions, undertakings and longer legal obligations. This is not automatically five years from creation or from the end of a client relationship. Personal Data is includedin these records only to the extent necessary for the relevant compliance evidence. Where more than one lawful retention requirement applies, we retain the relevant record for the period needed to meet those requirements, with access and use appropriately restricted.

Inomplete applications, support correspondence, technical and security logs, and optional analytics information are retained according to their specific purpose, sensitivity and any applicable legal requirement. We review whether they remain necessary; an incomplete application or a general possibility of future usefulness does not justify indefinite retention. Relevant information may be retained longer for a legal obligation, claim, official investigation or documented fraud-prevention need where lawful and proportionate. Any hold is limited to relevant information and reviewed when the reason ends.

If you unsubscribe from marketing, we retain only the identifiers and preference or consent records reasonably necessary to honour and demonstrate your choice, protected from ordinary marketing use. Once information is no longer required, we securely delete, destroy or irreversibly anonymise it, including through appropriate provider instructions. Where immediate removal from backups is not practicable, access and use remain restricted until the backup issecurely overwritten or deleted under its retention cycle.

Security of Personal Data

We apply physical, organisational and technical safeguards appropriate to the sensitivity, amount, format and location of Personal Data and the risks of the processing. These include role-based access restrictions, confidentiality requirements for Company Personnel and relevant providers, authentication and access monitoring, encryption where appropriate for transmission and storage, and secure disposal. Access is limited to authorised persons with a need to know, and safeguards are reviewed as risks and technology change.

For systems supporting payment activities, our operational risk frame workrequires individually attributable access, least privilege, prompt removal of access when no longer needed, strong authentication and multi-factor authentication for privileged, remote andpayment-release access where supported, and documented compensating controls for any limitation. Privileged and payment-release access is reviewed regularly and after role changes. We protect logs, backups and recovery records, control technical changes and verify the integrity of payment records before resuming affected processing.

No system or transmission method can be guaranteed completely secure. You should protect your credentials and promptly report suspected unauthorised account access or disclosure to info@acanis.io.
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Personal Data Breaches
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We assess suspected breaches, take steps to contain them and reduce harm, and keep records as required by law. Where a breach involving Personal Data under our control creates a real risk of significant harm, we report it to the OPC and notify affected individuals as soon as feasible after determining that it occurred, unless the law prohibits notification. We provide information about the breach, potential effects, mitigation and contact arrangements, and notify other organisations or authorities where required to reduce harm. Additional applicable privacy-law requirements are also observed.
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The person responsible for privacy compliance coordinates with the Compliance Officer, incident coordinator and relevant technical oroperational personnel to contain the event and preserve evidence. An event affecting both Personal Data and payment activities is assessed separately under privacy law, the RPAA and any other applicable reporting duties. A Bank of Canada notification does not replace an OPC or individual notification, and an internal recovery target oranother reporting deadline does not postpone a privacy-law obligation. Any AML/CTF or sanctions assessment is referred to the MLRO through the applicable restricted channel. Notifications containonly information appropriate to the recipient and lawful purpose.

Changes to This Privacy Policy
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We may update this Privacy Policy to reflect changes in applicable law, our Services or our data practices. The current version is made available on our Website or platform, with the date of the latest revision shown above. Editorial or clarifying changes that do not alter our data practices may be published without a separate notice. Where applicable law requires additional notice of a change, we provide it through an appropriate channel and within the required timeframe. Where a change requires new or renewed consent, we obtainit before carrying out the relevant processing, unless an applicable legal exception permits otherwise. Publication of an updated Policy or continued use of our Website or Services does not, by itself, replace any consent required by law.

Contact

For privacy questions, requests or complaints, contact the person responsible for privacy compliance at info@acanis.io, using the subject line "Privacy". We acknowledge and investigate complaints, communicate the outcome and take appropriate corrective steps. Access requests follow the time limits explained above. Otherinquiries are handled promptly, taking account of their nature and complexity. You may also complain to the Office of the Privacy Commissioner of Canada at www.priv.gc.ca , or the competent provincial privacy authority where applicable; we can assist with identifying the appropriate channel.
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You can also write to: Acanis Major Corp., Attention: Privacy, 30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario, L4B 1B9,Canada.

Privacy Policy

Date of Last Modified: 2025 – 05 – 06

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This Privacy Policy, together with our Terms of Use and its other essential parts, governs Acanis Major Corp.’s collection, processing and use of your personal data. As used in this Privacy Policy, “we“, “us” or “our” refers to Acanis Major Corp., a company duly incorporated and validly existing under the laws of Canada. Acanis Major Corp. is a Data Controller under this Privacy Policy, which sets out the manner in which a company, as a Data Controller, may use your Personal Data.

Acanis Major Corp. is a corporation formed according to the Canada Business Corporations Act (R.S.C., 1985, c. C-44) in Canada. Acanis Major Corp. and its affiliates undertake to make maximum efforts to protect your privacy. Acanis Major Corp. uses the collected information about you to fulfil its contractual obligations and improve client Service.

Please read this document carefully in order to understand our approach and policy regarding your Personal Data and how we will use your Personal Data.

This Privacy Policy should be read in conjunction with our Cookie Policy. For the additional information regarding the our Cookie Policy, please contact us via email: info@acanis.io.

‍What Data We Collect About You

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We may collect and process the following data about you:
Information You Give to Us

You can provide us with information about yourself by filling out the relevant forms on our Website or by providing us with such information. By the phone, email, during a video conference or in any other manner. This information includes Personal Data which was specified when registering on our Website, when subscribing to our Service, opening an account and verifying the identity of the account holder or persons authorized to use it, as well as the payment instruments used by the person, when searching for a Product, using any Services provided by us on our Website, by participating in discussions in chat or using any other communication functions on our Website, during participation in draws, promotions, or surveys, and also when you inform us about issues regarding our Website.

The Data That You Provide to Us As Legal Entity, May Include:
The Data That You Provide to Us As Individual Client, May Include Your:
Acanis Major Corp. does not collect nor process sensitive personal users’ data such as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health, sex life or sexual orientation information.

Information We Collect About You

About each of your visits to our Website and use of our Services, we can collect, for example, the following information about you (including automatic collection):
Information We Receive from Other Sources

We may receive information about you if you use any of the other Websites we operate or the other Services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery Services, advertising networks, analytics providers, due diligence providers, and credit reference agencies) and may receive information about you from them. Such information may include:
Your Personal Data, such as your email, and phone number that you provide to us during the registration at our Website is stored by us, regardless of whether your registration process is finished or not. The same is applied to your Personal Data during an unfinished KYC procedure.

Use of Cookies

We use cookies to gather information about you and your activity on our site. Cookies are small data files stored on your computer, accessed each time you visit our Website and Service, allowing us to understand your usage patterns and serve personalized content or save your specified settings.

If you prefer not to accept cookies from us, you can set your browser to reject them. However, be aware that this may limit our ability to provide some Services you desire. This Policy applies solely to our use of cookies between your computer and our Website and Service and does not include the use of cookies by third-party advertisers.

Cookies help us enable certain features (e.g., logging in), track site usage (e.g., analytics), store your preferences (e.g., time zone, notification settings, usernames), and personalize your content.

Types of Cookies and Their Uses

Cookies set by the Website you visit are known as "first-party cookies" and usually track your activity solely on that site. Conversely, cookies set by other Websites or companies, known as "third-party cookies," can track your activity across different Websites that utilize the same third-party Services.

Essential Cookies

Essential cookies are vital for your Website experience, supporting core features such as user logins, account management, and payment processing. We utilize these cookies to ensure the proper functionality of our Website and Service.

Performance Cookies

Performance cookies track your Website usage during visits without collecting personal information. This data is typically anonymous and combined with data from other users to help companies understand usage patterns, identify issues, and make strategic improvements to the overall Website experience. These cookies can be set by the Website you're visiting (first-party) or by third-party Services. We employ performance cookies on our Website and Service.

Functionality Cookies

Functionality cookies gather information about your device and any settings you configure on the Website, such as language and time zone preferences. This allows Websites to offer you customized, enhanced, or optimized content and Services. These cookies can be set by the Website you're visiting (first-party) or by third-party Services. We use functionality cookies to support selected features on our Website and Service.

Targeting/Advertising Cookies

Targeting/advertising cookies help determine the most relevant promotional content for you based on your interests. Websites use them to deliver targeted ads or to limit how often you see an advertisement, enhancing campaign effectiveness and content quality. These cookies can be set by the Website you're visiting (first-party) or by third-party Services, and third-party cookies can track your activity across different Websites using the same Services. We employ targeting/advertising cookies on our site.

Third-Party Cookies on Our Site

We may engage third-party companies and individuals on our Website, such as analytics providers and content partners. These third parties may access selected information and set cookies to perform specific tasks on our behalf. Third-party cookies can track your activity across other Websites using the same Service. Since we do not control third-party cookies, they are not covered by Acanis Major Corp.’s Cookie Policy. To prevent third-party cookies from tracking your usage, you should disable cookies in your browser settings.

Why We Use Your Personal Data

We are going to use your personal data for the following purposes:

Provision of Our Services
Informing You About Our Products and Services
Helping Us Improve Our Products and Services
Safeguarding Vested Interests
Assuring Legal Procedures
Complying With Legal Regulations
Marketing and Third Parties
Disclosure of Your Personal Data

We may share your personal information within Acanis Major Corp., which includes our subsidiaries, affiliates, our ultimate holding company and its subsidiaries.

We may share your information with selected third parties including:
We may also disclose your Personal Data to third parties in the following cases:
Basis for Personal Data Processing

We collect and process your Personal Data only when we have a legitimate reason for such processing. Legal grounds may include:
In cases where the basis for Personal Data processing is your consent, you have the right to withdraw it at any time.

Your Rights

By contacting us you can use the following rights:
In addition, you have the right to prohibit the use of your data for marketing purposes. Before requesting your data, we usually request your consent to disclose it to third parties for marketing purposes. You can use the right to prohibit the processing of your data for marketing purposes by putting a tick in the relevant field in the questionnaire. You can also exercise this right by contacting us at any time.

Please note that the implementation of some of your rights, depending on the situation, may limit, complicate or completely exclude the possibility of further cooperation with us.

Our Website may contain active links from/to the Websites of our partners, advertisers and affiliated companies. If you are following an active link, please note that other Websites have their own privacy policies, and we are not responsible for the provisions of these policies. Please review the privacy policies of these Websites before sharing your Personal Data with them.

Access to Personal Data

You have the right to access the information we hold on you. Your right of access can be exercised in accordance with The Personal Information Protection and Electronic Documents Act, and subject to your written request, sent to the email, we will provide you with the data we hold about you. In case your request will be manifestly unfounded or excessive or you will request further copies of your personal data following your initial request, we may charge you a fee of 20 CAD.

Retention of Personal Data

Making sure your Personal Data is safe and secured is of the highest priority to us. We use secure storage facilities ensuring the safeguard of your Personal Data you share with us at all stages of interaction with our platform using our Products and Services. All appropriate measures to secure your Personal Data from potential hacking attacks, loss or misuse are implemented by our security team.

We will hold your Personal Data only for the duration of you using our Products and Services via your account, having regard to the purposes described in this Privacy Policy as well as legal and regulatory obligations that we comply with. In accordance with our record keeping obligations, we will retain your account information and your Personal Data for at least a period of 5 (five) years from the moment you cease to carry on the use of our Services or the moment you end of your client relationship with us unless otherwise required for legal or regulatory reasons.

We may access your Personal Data or retain it for a longer period if it will be subject to an official request or legal obligation, an investigation by governmental bodies or investigation into possible violations of our user agreement and its essential parts, or in other cases to prevent possible harm based on our reasonable considerations.

If you will cancel your subscription to our email newsletter, we will hold your email on an inactive email list.

Changes to This Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, a notification will be sent to you by email. We encourage you to check this page frequently to be aware of any updates or changes to the Privacy Policy.

Contact

In case you will have any questions, complaints or concerns regarding our Privacy Policy, Cookie Policy or the way or purpose for which we handle your Personal Data – you can contact us. For that purpose, please contact us via email:info@acanis.io who will try to assist you promptly.

You can also reach us by postal mail at: “Acanis Major Corp.”, 1 - 300 Supertest Rd, North York, Ontario, Canada, M3J2M2.
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