We (S-INTERIO) take your privacy seriously, and have prepared this Privacy Notice to explain how we collect, use, and disclose personal information
through our website (www.s-interio.com). Let’s get down to it, and if you have any questions or concerns, do get in touch with us.

Table of Contents
* Who we are
* Who are you?
* How do we collect your personal information?
* What personal information do we collect, and what do we use it for?
* How do we safeguard and store your personal information?
* Who do we share your personal information with?
* What are your rights and choices?
* What are our privacy governance policies and practices?
* Questions or concerns or complaints
* Other important information
* Final comments

Who we are
We’re a money transfer and payment services provider. We offer a variety of payments solutions through our platform, which you can access through our website (www.s-interio.com; from now on: the “Services”). We are licensed with Gofaizen & Sherle in Canada (crypto license TBD) and registered with Ministry of Public and Business Service Delivery (registration number 1001129514).

Who are you?
This question may sound a little odd, but you could be one of our direct customers, a customer of one of our business clients, a visitor to our website, or a visitor using our Services for the first time. If you are a customer who uses our Services directly, we are responsible and directly accountable to you for our collection, use and disclosure of your personal information as described in this Privacy Notice.
If you are a customer of a company that we provide our Services to (i.e., a customer of one of our business clients), we process your personal information primarily on behalf of and in the course of providing our Services to that company. When doing so, we are a service provider to that company, and that company remains responsible – and is directly accountable to you – for managing and protecting your personal information. We rely on the business to whom we provide our Services to comply with applicable privacy laws when collecting, using, and disclosing personal information through our Services. If you have any questions regarding the personal information we process on behalf of our business clients, we encourage you to visit that company’s website or to contact them directly for details on how they handle your personal information.

How do we collect your personal information?
We collect your personal information either directly from you (online through our Services and forms, including when you register for a S-INTERIO account or communicate with us), from our business clients with whom you have a relationship, and who may pass on your personal information so that we can help them deliver their services to you, or from financial institutions and third party verification services when we’re verifying your identity, during your account verification process (when you call us or make a transaction request, for instance), or when your devices provide us information automatically.

What personal information do we collect, and what do we use it for?
* Account and contact information that you provide when signing up for a S-INTERIO account and when you use our Services, such as your name, contact information (email address, home address and phone number), and date of birth. We use this information to:
create, administer and enable your use of your S-INTERIO account our Services, help us verify your identity, meet our legal and financial regulatory obligations (including compliance with anti-money laundering rules), communicate with you about any important service updates (such as update to our terms or policies) and your transactions, communicate with you to deliver the information and support your request, including technical notices, security alerts, and support, administrative messages, to resolve disputes, collect fees, and provide assistance with any issues you may have, based on your communication preferences, send periodic emails, news, and information, or conduct surveys and collect feedback about our Services, and based on your communication preferences, communicate with you about products, services, contests, promotions, discounts, incentives, and rewards offered by us and select partners.

* ID information that you provide when you register for our money transfer and payment services. We collect this information to verify your identity and evaluate the authenticity of your identity document so that we are able to comply with our legal and regulatory obligations, including compliance with anti-money laundering rules

* Financial, reference and credit information that you provide during onboarding and when you use our Services, such as bank account and payment card numbers, bank statements, employment information (e.g., employer name and employment status), government-issued ID numbers and pictures of your ID, utility bills, and other documents as may be requested by us. We use this information to:
create your S-INTERIO account, enable you to use our Services, process your transactions, check your creditworthiness (as explained further below), meet our legal and regulatory obligations (including compliance with anti-money laundering rules), and obtain or maintain insurance coverage, to manage risks, or obtain professional advice.
* Consumer credit report information we may obtain from credit reference agencies or other service providers solely for the purpose of verifying to your identity, the identity of your recipients or as required for any other purpose related to providing our services;
* Transaction information that we collect when you use the Services, such as information about when and where your transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions. We use this information to:
enable you to use our Services, and to meet our legal and regulatory obligations (including compliance with anti-money laundering rules).
* Device and usage information that we collect when you access our Services including information about the location and specifics of your device, including your hardware model, operating system and version, unique device identifier, mobile network information, information about the device’s interaction with our Services, and information about other software running on the device for anti-fraud and malware-prevention purposes (though we will not collect any content from such software). We also collect information about how you use our Services, including your access time, browser type and language, and Internet Protocol (IP) address. We use this information to:
improve, personalize, facilitate, and track and analyse trends in your use of our Services (for example, when you sign up for a S-INTERIO account, we may associate certain information with your new account, such as information about prior transactions you made using our Services), customize and enhance the design, content, and functionality of our website, and improve our customer services,
administer our internal information processing and other IT systems, protect our rights or property, or the security or integrity of our Services, operate our website and Services, including to ensure their security, and maintain back-ups of our databases and to keep the records in accordance with our internal policies and procedures and the applicable law.
* Cookies information that we collect from your device when you use our Services. Our website uses a technology called “cookies”. A cookie is a tiny element of data that our website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all the website features. For more information on our use of cookies, including to manage your cookies settings, please see our Cookies Policy.
* Analytics information that we collect from your device when you use our Services. We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links: https://policies.google.com/technologies/partner-sites, and https://support.google.com/analytics/topic/2919631.
* Interaction information that we collect when you communicate with us, including the content and metadata (meaning records) associated with these communications, and other information you provide when you participate in contests or promotions offered by us or our partners, or respond to our surveys.
* Marketing communications information that we collect if you sign up to receive email marketing communications, such as your email address as well as other information on an optional basis to help us tailor our communications to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt out of receiving email marketing communications by contacting us at the contact information provided in the “Questions or Concerns” section below. Please note that you may continue to receive transactional or account-related communications from us.

We may also use your personal information as otherwise required or permitted by applicable law or with your consent, to comply with applicable laws and regulations, to establish or defend against legal claims, to comply with our obligations either required by law or by written agreements with third parties, to enforce the provisions of our Terms of Service or other applicable agreements or policies, and to investigate, detect, and prevent fraud, security breaches, and other potentially prohibited or illegal activities.

How do we safeguard and store your personal information?
We take reasonable measures, including administrative, technical, and physical safeguards to protect your personal information in our custody and our control against theft, loss and unauthorized access, use, modification and disclosure. We hold the information at our own premises with the assistance of third-party service providers, or outside our own premises in data hosting facilities where your personal information is encrypted for security. We restrict access to your personal information on a need-to-know basis to our employees, contractors, and agents who require access to fulfil their job requirements. We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.

Who do we share your personal information with?
We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.
Vendors: We share your personal information with our trusted Vendors who provide specialized services on our behalf or assist us in providing our services to you. These Vendors include:
* identification and verification services, who verify your identity
* data management and storage services, where we store your information and backups to the same
* systems applications that we use to manage and store data internally in a structured way
* marketing partners, who assist us in providing you with our marketing content
* financial institutions, who help us process your payments and deliver the same to your recipients
* debt collection agencies, who we may need to instruct in the event of payment deficits
* analytics and search engine providers that assist us in the improvement and optimisation of our site
Our Vendors are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. We and our Vendors may access, store and otherwise process personal information outside of the jurisdiction in which you are located, including in other provinces in Canada, and other foreign jurisdictions, including the UK and the US.
S-INTERIO Affiliates: We share your personal information with other companies within the S-INTERIO group of companies for the purposes of providing our Services, complying with applicable laws and improving the quality of our Services.
Fraud/Crime Prevention Agencies: We may share your personal information with fraud and crime prevention agencies, our business partners, our vendors, law enforcement agencies and regulatory supervisory authorities for where we suspect money laundering, fraud, terrorist financing and other activities of an illegal nature, for the purpose of preventing crime or for actual or suspected breaches of pertinent laws or regulations. Where we suspect there’s a risk of any illegal activity in connection with your S-INTERIO Account, we may suspend your account or restrict or cancel any transaction you make, or restrict your access to your account or your ability to make a transaction.
Other Users of the Services: We may share that you use our Services with other users that have you saved in their phone’s contact list so they know that you’re also using our Services. We only share this information with users if you opt-in to sharing this information with such users. We share this information for the purposes of facilitating your usage of our Services.
Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims or to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of S-INTERIO or as part of a corporate reorganization or other change in corporate control. Your personal information may be transferred outside of Canada and processed by us and our service providers (including our affiliates) in the U.S. or other locations.

What are your rights and choices?
Marketing Communications
As indicated above, if you have signed up to receive our marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the communication, or by changing your notification settings by logging into your S-INTERIO Account. Alternatively, you can opt out of receiving our marketing communications by contacting us using the contact information under “Questions or concerns” below. If you decide to opt out, we may still send you non-promotional communications such as service messages, including digital receipts and updates about your S-INTERIO Account activities.
Exercising Your Privacy Rights Subject to limited exceptions under applicable law, you have the right to access, update, correct inaccuracies in, and withdraw consent (subject to reasonable prior notice and applicable legal and contractual restrictions) to the collection, use and disclosure of your personal information. If you withdraw your consent, we may not be able to provide our Services to you.
To exercise any of these or other rights applicable to you under Canadian privacy laws, please contact us as set out in the “Questions or concerns ” section below. We may require specific information from you to help us confirm your identity and process your request.
If personal information about you has been processed by us on behalf of a business customer and you wish to exercise any rights you have with respect to such personal information, we encourage you to inquire with our business customer directly. If you wish to make your request directly to us, please provide the name of our business customer on whose behalf we process your personal information, and we will refer your request to that business customer. We will assist our business customers wherever possible in responding to your request.

De-activating your S-INTERIO Account
If you wish to deactivate your S-INTERIO Account, you may do so by contacting our customer service. We may retain certain archived copies of information and any transactions or Services in which you may have participated for a period of time that is required by applicable law, or as we believe is reasonably necessary to comply with applicable law, regulation, or legal process, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms and Conditions or other applicable agreements or policies, or to take any other actions consistent with applicable law.

Disabling Location Information
If you do not consent to collection of the device location information, you may be unable to use our corresponding Services. You can stop our collection of location information at any time by changing the preferences on your mobile device.

Opt-out of Cookies
Some of the cookies we use are stored on your device by us, while others may be stored on your device by third parties who deliver services on our behalf. Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is stored on your device. For more information on our use of cookies, including to manage your cookies settings, please see our Cookies Policy.
You may withdraw your consent to us processing your personal information at any time by contacting us via any of the methods set out in the “Questions or concerns” section below.

What are our privacy governance policies and practices?
We are committed to protecting your personal information and have implemented policies and practices that govern our treatment of personal information, including:
* a privacy framework that defines the roles and responsibilities of our employees with respect to the treatment of personal information in our custody and control;
* policies and procedures regarding the protection of personal information, including safeguards designed to protect personal information in our custody and control against loss or theft and unauthorized access, use or disclosure, and processes for handling security incidents and reporting;
* the designation of a Privacy Officer who is responsible for overseeing S-INTERIO’s compliance with applicable privacy legislation;
* practices pertaining to privacy training and awareness for our personnel with access to personal information;
* processes for responding to data subject requests and complaints concerning the handling of personal information in a timely and effective manner; and
* a framework governing the retention and destruction of personal information that is designed to ensure compliance with our legal obligations.
For more information about the policies and practices we have implemented to protect your personal information, please feel free to contact us as set out below under “Questions or concerns or complaints”.

Questions or concerns or complaints
We’ll always try to address your questions or concerns or complaints in a timely manner, but if this does not happen, we would ask you to please contact us in the first instance so that we can address the issue at once.
Where you have questions or concerns or complaints in relation to any of the topics set out in this Privacy Notice or the manner in which we or our services providers (including our service providers outside Canada) treat your personal information, please contact our Privacy Officer at:
S-INTERIO Privacy Officer
dataprotection@s-interio.com
TBD (Toll Free within Canada) available 24/7
For general questions or concerns relating to our Services, please feel free to contact us in any of the following ways:
* By visiting our website: www.www.s-interio.com and tapping Chat icon on the bottom (in development) of each page
* By mailing us at: S-INTERIO, 300 Supertest Road, Unit 1, North York, Ontario, M3J2M2, Canada
When you contact us, you may be asked to provide certain personal information so we can verify your identity.

OTHER IMPORTANT INFORMATION
Children’s Privacy: S-INTERIO does not knowingly collect personal information from children under the age of 13 (or such other age as may be directed by applicable law), and users under the age of 13 (or such other age as may be directed by applicable law) should not submit any Personal Information to S-INTERIO. If you learn that your child has provided us with Personal Information without your consent and he/she is under the age of 13 (or such other age as may be directed by applicable law), please alert us at the contact information detailed in the “Questions or Concerns” section above. We will take prompt steps to remove the personal information from our systems.
Spanish and English Language: If a problem of definition or interpretation arises between the English and Spanish versions of this Notice, the English version will prevail.

FINAL COMMENTS
This Notice and future amendments
This Notice was last updated on March 1st, 2025. We may periodically update this Notice and encourage you to check here regularly for the most up-to-date version.

Thank you
Thanks for reading this Notice and thank you very much for being a S-INTERIO customer.

© S-INTERIO CA Ltd. January 2025