Basics

1. A Little About Us

We are IFC PAYFIN PAYMENTS CORPORATION. Our registered address is 422 RICHARDS ST, SUITE 170, VANCOUVER BC V6B 2Z4, CANADA. Our company number is BC1393799, dated December 29, 2022. We are registered with FINTRAC under license number 169897.

IFC PAYFIN PAYMENTS CORPORATION is an electronic money institution authorized and regulated by the relevant authorities in Canada. Registered address: 422 RICHARDS ST, SUITE 170, VANCOUVER BC V6B 2Z4, CANADA.

3. Why This Document Is Important

Data protection law calls us the “controller” of your personal data. This comes with certain responsibilities regarding how we use it. We have tried to explain everything as clearly as possible in this document. If you have any questions about how we use your data, please contact our Data Protection Officer at [email protected].

Your Rights

Your rights regarding personal data are protected by law. Here`s how we respect those rights.

4. What Your Rights Mean to Us

Your Right	What It Means
You have the right to know how we use your data.	This Privacy Policy is here to explain as clearly as possible how exactly we use your data.
You can request to see the data we hold about you. You can also ask for detailed information about what data we process and why.	If you submit a data subject access request, we will provide you with a copy of all your data that we hold. We cannot provide you with any information about other individuals, ongoing criminal investigations, fraud cases, or settlement negotiations. We also cannot provide you with any information regarding our consultations with lawyers.
You can ask us to correct your data if you believe it is incorrect.	When you ask, we will correct incomplete or inaccurate data. We may need to verify the accuracy of any new information you provide before we update your data.
You can ask us to delete your data.	You can request that we delete your personal data if: • we no longer have a valid reason to use it; • you gave us consent to use it but have now withdrawn that consent; • you object to its use; • we used it unlawfully; • we are required to delete it by law; We may not always be able to fulfill your request. If you have closed your nahart account, but applicable laws require us to retain your personal data, we may not be able to delete your entire file.
You can object to the processing of your data for marketing purposes.	You can ask us to stop using your data for marketing. Simply go to settings in your browser or app, click "Privacy," and adjust your communication channels.
You can object to the processing of other information (if we use it for legitimate interests).	If we use your data for "legitimate interests" and you do not want us to use it, you can object. But if there is a stronger reason (e.g., legal) for using this information, we may decline your request. If you object to the use of data essential for our services, we may not be able to provide those services to you and may have to close your account.
You can ask us to restrict the use of your data.	You can ask us to pause the use of your data if: • you want us to verify its accuracy; • our use of your data is unlawful, but you do not want us to delete it; • we no longer need your data, but you want us to keep it for a legal claim; • you have objected to our use of your data (see above), but we need to verify if we have a stronger legal reason to use it.
You can ask us to transfer your personal data to you.	If possible and not prohibited by law, we will provide your personal data in a structured, commonly used, machine-readable format.
You can withdraw your permission.	You can withdraw your permission. You can withdraw your consent at any time. Just change your settings on the nahart website or app or send an email to [email protected]. (Remember: our use of your personal data is lawful from the time you give consent until you withdraw it.)

5. How to Exercise Your Rights

If you wish to exercise any of these rights, write to us at [email protected]. When you do, we may ask you to provide identification to ensure it`s you so we can securely process your request. If you are dissatisfied with how we handle your data, you can file a complaint with your local data protection authority.

Our Responsibilities

6. Collecting Your Data

We collect your personal data when you use:

our website https://www.nahart.org or the nahart app. The table below explains exactly what data we collect, how, and when.

Data Type	How We Collect the Data
You provide us with data when you: • register with nahart; • fill out any forms; • communicate with us	You provide us with data when you: • register with nahart; • fill out any forms; • communicate with us Your name, address, citizenship, and date of birth. Your email address, phone number, and device data (e.g., your phone, computer, or tablet). Your username, password, and other registration details. Your bank account details, including account number, bank code, and IBAN. Your debit and credit card details, including card number, expiration date, and CVV code. Identity documents (e.g., passport or international ID), copies of any documents you provide for identification, and any other information to verify your right to use our services. Records of our communication if you contact us or we contact you. Your photos or videos taken during the identity verification session.
Each time you use the nahart website or app	Technical data, including: — IP address from which your computer connects to the Internet; — login data, browser type and version; — time zone settings; — operating system and platform; — device type; — unique device identifier (e.g., your device`s IMEI number, MAC address of the device`s wireless network interface, or the mobile phone number used by the device); — mobile network data; — mobile operating system; — type of mobile browser used, etc. 2. Data about your visit, including: — links you clicked from our site (including date and time); — services you viewed or searched for; — page response times; — download errors; — length of visits to certain pages; — page interaction data (e.g., scrolling and clicks); — exit methods from the page. 3. Transfer data, including: — date, time, and amount of transfer; — currencies used and exchange rate; — recipient data; — payment method used. 4. Data stored on your device, including: — contact data from the address book (if you grant us access); — login data; — photos, videos, and other digital content; — check-ins (sometimes we call them content data). Our app regularly collects this data to stay up to date.
We track your location using GPS (if location services are enabled in the nahart app)	Sometimes we track your location — for example, to determine where you are sending money from.
When you submit documents for verification or make a transfer	This may include identity checks or financial transaction data.

7. Why We Need Your Data

We cannot use your data without a lawful basis (a valid legal reason). Lawful bases can be:

To fulfill our contract and agreements with you

We simply cannot provide our services without certain data about you.

To fulfill our legal obligations

Some laws require us to collect and store certain data about you, such as anti-money laundering laws.

For legitimate interests

Sometimes we collect and use your data or share it with other organizations. We do this only when there is a reasonable legal reason, agreed with your right to privacy. For example, you asked us to use a new card and we need to send your data to a partner providing the service.

You gave us your consent

You agree to the collection of your data when you use the nahart website or app or when you tick the box agreeing that we can use your personal data in certain ways.

We use your personal data only in these cases. Below is a description of how exactly we use it.

Providing Our Services

To use nahart, we need some of your personal data at different stages.

When you register, we use it to:

• • verify your identity and decide whether to approve your request to use nahart. This is part of our KYC (Know Your Customer) process and obligations.

When you become a nahart customer, we use your data to:

• • fulfill our obligations for any transfers you make;
• • inform you about our products and services;
• • help us develop new products and services.

We also use your data to provide you with support via phone and email. We may record these calls and emails, but only for training and monitoring our staff to help you best.

Fraud Protection

We use your data to verify your identity. This helps protect against fraud, comply with the law, and confirm that you have the right to use our services. We also use your data to understand your financial situation and manage fraud risks associated with your nahart account.

Information About New Products and Services That May Interest You

With your consent, we also use your data to:

• • inform you about other nahart products and services similar to those you have used or inquired about;
• • analyze our advertising and make it more relevant to you;
• • process applications for products and services we offer and decide whether to approve them.

Remember: you can ask us to stop sending you marketing messages. To do so, change your privacy settings.

Service Maintenance

As we regularly update our service, we use your data to:

• • manage the nahart website and app (including troubleshooting, data analysis, testing, research, collecting statistics, and conducting surveys);
• • ensure our site content is displayed most appropriately for you and your device (see "Cookies" section for more details);
• • enable you to use our interactive features;
• • inform you about changes in our services;
• • secure the nahart site and app.

Ensuring Social Interaction

We use your data for social interaction or to add additional features that make our product even more convenient. For example, we can use your contacts to allow you to send money directly to your friends.

Fulfilling Our Legal Obligations

There are circumstances when we may need to share some data about you:

• • with other organizations (e.g., fraud prevention agencies);
• • to comply with our legal obligations or in connection with legal claims;
• • to help detect or prevent crime.

9. Using Your Data for Marketing

When you register with nahart, you can choose whether you want to receive messages about special offers and promotions. If you agree, we use your data to tailor offers that may interest you. You can opt out at any time by going to the "Settings" section in your app or browser. You can change your choice at any time or let us know that you no longer want to receive our newsletter. Simply go to the "Settings" section of the nahart app, select "Privacy," or click the unsubscribe link in any marketing message we sent you. We will not share your data with any other organizations for their marketing purposes without your permission.

10. Sharing Your Data with Others

Besides the IFC PAYFIN PAYMENTS CORPORATION companies, sometimes we share your data with:

• • service providers; ;
• • for legal reasons;
• • social media platforms.
  Here are the possible.

Type of Provider	Why We Share Your Data
Our IT service providers	So we can provide our online services.
Our partners in banking and financial services, and payment systems	So we can transfer your money abroad.
Advertisers	So we can promote our services. (We provide only anonymous information: for example, "76 women over 40 clicked on this ad.")
Analytics and search service providers	So we can develop our website and app.
Customer support service providers, survey companies, and developers	So we can provide you with our services.
Communication service providers So we can send you emails, push notifications, and SMS.	So we can send you emails, push notifications, and SMS.
So we can send you emails, push notifications, and SMS.	Fraud prevention agencies