Privacy Policy

ZASHX Inc. ("ZASHX," "we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our money transfer and remittance services. As a registered Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), we are required to collect and maintain certain information about our customers to comply with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. By using ZASHX services, you consent to the data practices described in this policy.

We collect information that you provide directly to us, as well as information collected automatically when you use our services. Personal Information: • Full legal name • Date of birth • Residential address • Email address and phone number • Government-issued identification (passport, driver's license, etc.) • Social Insurance Number (SIN) or Tax Identification Number (where required) • Photographs for identity verification Financial Information: • Bank account details • Credit/debit card information • Transaction history • Source of funds information Technical Information: • IP address and device identifiers • Browser type and version • Operating system • Login timestamps and session data • Cookies and similar tracking technologies

We use the information we collect for the following purposes: Service Delivery: • Process money transfers and transactions • Verify your identity and prevent fraud • Communicate with you about your transactions • Provide customer support Compliance and Legal: • Comply with FINTRAC regulations and AML/CTF requirements • Report suspicious transactions as required by law • Respond to legal requests and court orders • Maintain records as required by regulations Business Operations: • Improve and optimize our services • Analyze usage patterns and trends • Develop new products and features • Send service updates and promotional communications (with your consent)

We may share your information in the following circumstances: Regulatory Authorities: • FINTRAC and other financial regulators • Law enforcement agencies when required by law • Tax authorities as required Service Providers: • Identity verification providers (e.g., Sumsub) • Payment processors and banking partners • Payout partners in destination countries • Cloud hosting and data storage providers • Customer support platforms Business Partners: • Correspondent banks and financial institutions • Currency exchange providers We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not sell your personal information to third parties.

As an international money transfer service, your information may be transferred to and processed in countries other than Canada, including countries where your recipients are located. When we transfer data internationally, we ensure appropriate safeguards are in place: • Standard contractual clauses approved by regulatory authorities • Data processing agreements with all service providers • Compliance with applicable data protection laws Please note that payout partners in destination countries may be subject to local laws and regulations regarding data retention and disclosure.

We implement robust security measures to protect your personal information: Technical Safeguards: • 256-bit SSL/TLS encryption for all data in transit • AES-256 encryption for data at rest • Multi-factor authentication • Regular security audits and penetration testing • Secure data centers with physical access controls Organizational Safeguards: • Employee background checks and security training • Role-based access controls • Incident response procedures • Regular security awareness programs While we strive to protect your information, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

We retain your personal information for as long as necessary to: • Provide our services to you • Comply with legal and regulatory requirements • Resolve disputes and enforce our agreements Specific Retention Periods: • Transaction records: Minimum 5 years after the transaction (as required by FINTRAC) • Identity verification documents: Minimum 5 years after account closure • Customer communications: 3 years • Marketing preferences: Until you opt out After the retention period expires, we securely delete or anonymize your information.

Depending on your jurisdiction, you may have the following rights: Access: • Request a copy of the personal information we hold about you • Receive information about how your data is processed Correction: • Request correction of inaccurate or incomplete information • Update your account information at any time Deletion: • Request deletion of your personal information (subject to legal retention requirements) • Close your account Restriction: • Request limitation of processing in certain circumstances Portability: • Receive your data in a structured, machine-readable format Objection: • Object to processing for direct marketing purposes • Opt out of promotional communications To exercise these rights, contact us at privacy@zashx.com.

We use cookies and similar technologies to enhance your experience: Essential Cookies: • Session management and authentication • Security and fraud prevention • Load balancing and performance Functional Cookies: • Remember your preferences • Language and currency settings Analytics Cookies: • Understand how users interact with our services • Improve our website and application Marketing Cookies: • Deliver relevant advertisements (with your consent) • Measure campaign effectiveness You can manage cookie preferences through your browser settings or our cookie consent tool. Please see our Cookie Policy for more details.

ZASHX services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a minor, please contact us immediately at privacy@zashx.com.

Our website and application may contain links to third-party websites, services, or applications. This Privacy Policy does not apply to those third-party services. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you access through our platform.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes: • We will notify you via email or in-app notification • We will update the "Last Updated" date at the top of this policy • We will provide 30 days notice for significant changes Your continued use of our services after changes take effect constitutes acceptance of the updated policy.

If you have questions about this Privacy Policy or our data practices, please contact us: Privacy Officer ZASHX Inc. 231 Oak Park Blvd, Suite 301 Oakville, ON L6H 7S8 Canada Email: privacy@zashx.com Phone: +1 (289) 203 5222 For complaints about our handling of your personal information, you may also contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.