Privacy Policy

Introduction

OTT Financial Inc. (“OTT”, “we”, “us”, or “our”) is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us by our clients.

As a regulated money services business (“MSB”), OTT collects, uses, discloses, and retains personal information to establish and maintain client relationships, provide services, and comply with legal and regulatory obligations, including under the Personal Information Protection and Electronic Documents Act (PIPEDA) and, for our Quebec operations, Quebec’s Act respecting the protection of personal information in the private sector (the “Quebec Privacy Act”).

By opening a foreign exchange (FX) account, using our services, website, or mobile application (“App”), you acknowledge and, where applicable, consent to the collection, use, disclosure, and retention of your personal information as described in this Policy. OTT may collect, use, disclose, or retain personal information without consent where required or permitted by law, including for AML/ATF, sanctions, fraud prevention, regulatory reporting, or legal compliance.

OTT’s services are intended for individuals who have reached the age of majority in their province or territory of residence. OTT does not knowingly collect personal information from minors.

Our Privacy Principles

OTT follows the recognized ten privacy principles reflected in PIPEDA: accountability, identifying purposes, consent, limiting collection, limiting use/disclosure/retention, accuracy, safeguards, openness, individual access, and complaint handling. All OTT employees and authorized representatives shall protect personal information under their control, and designated officers are accountable for compliance with this Policy and applicable law.

Personal Information We Collect

Depending on the products or services you use, OTT may collect:

Legal name, date of birth, residential address, telephone number, and email address
Government-issued photo identification and information used to verify your identity
Occupation, business nature, and employment information
Banking and payment information
Transaction details, including purpose and fund recipients
Source of funds and/or source of wealth information
Website/App data such as IP address, device information, and usage logs

Information may come directly from you, your authorized representatives, financial institutions, service providers, public sources, or other lawful sources. Where identity verification involves comparing your photo ID to a live image (e.g., facial matching), OTT will identify this to you and obtain any consent required by applicable law.

Cookies and Online Tracking Technologies

OTT’s Website and App may use cookies and similar technologies (such as pixels or web beacons) to: operate and secure the Site; improve functionality and user experience; analyze usage trends and performance; and remember your preferences (e.g., language, region). Cookies may be set by OTT or authorized third-party providers (e.g., analytics or hosting providers). You may disable cookies through your browser settings; please note that doing so may affect certain features or services on the Site.

Why We Collect and Use Your Information

OTT collects and uses personal information to:

Verify your identity and establish eligibility for services
Open, administer, and maintain your account and related records
Process transactions and provide requested services
Communicate with you about your account, transactions, and service needs
Prevent fraud and conduct risk/compliance reviews
Meet AML/ATF, sanctions, and other regulatory requirements (e.g., the Proceeds of Crime (Money Laundering) and Terrorist Financing Act)
Improve our services, Website, and App
Comply with applicable law and regulatory obligations

With your consent, or as otherwise permitted by law, OTT may use your contact information for marketing about OTT or affiliate products; you may withdraw this consent at any time. Information collected for AML/ATF, sanctions, fraud-prevention, or regulatory purposes is not used for unrelated marketing unless permitted by law and consistent with applicable consent requirements.

OTT may use automated tools/systems (e.g., sanctions screening, identity verification to prevent fraud) to support business operation and regulatory requirements. Service-related, transactional, regulatory, security, and account communications may be sent by email, telephone, SMS (Short Message Service), App notification, mail, or other permitted communication methods. Marketing communications, where applicable, will be handled in accordance with applicable consent and unsubscribe requirements.

Consent and Withdrawal of Consent

OTT obtains your consent before or at the time personal information is collected, except where collection, use, or disclosure is authorized or required by law.

You may withdraw your consent, subject to legal, regulatory, contractual, or operational requirements. If consent is withdrawn, OTT may be unable to provide certain products/services or maintain your account. Withdrawal of consent does not affect OTT’s ability or obligation to retain, use, or disclose information required for AML/ATF, sanctions, fraud prevention, regulatory reporting, dispute resolution, or legal compliance purposes.

How We Collect Your Information

OTT collects personal information directly from you (e.g., account applications, agreements, transaction documents), through your voluntary disclosures by phone, email, mail, or the Website, and through anyone you authorize in writing to act on your behalf. Please keep OTT informed of any changes to your personal information.

Disclosure of Personal Information and Limited Use

OTT does not sell personal information and does not disclose it to third parties for their own independent marketing without consent, except as permitted or required by law. OTT may disclose personal information, only as needed to provide your services or meet legal requirements, to:

Financial institutions involved in providing FX services
Identity verification and related technology service providers
Payment processors, correspondent institutions, settlement, and payout partners
Regulatory authorities, government agencies, and law enforcement
Other parties where authorized or required by law

Service providers who receive personal information are contractually required to protect it and use it only for the purpose disclosed.

Safeguards

OTT uses administrative, technical, and physical safeguards appropriate to the sensitivity of the information to protect it against loss, theft, unauthorized access, disclosure, or misuse.

Personal information may be processed, stored, or accessed by OTT’s service providers in Canada or other jurisdictions where they operate. When personal information is processed outside Canada, it may be subject to the laws of that jurisdiction. OTT uses contractual and other safeguards to require comparable protection wherever your information is processed.

Retention and Disposal

OTT retains personal information only as long as necessary for the purposes collected and to meet legal, regulatory, and business requirements. Records required under AML/ATF law are generally kept for at least five years from creation, or longer if required by law. Information no longer needed is securely destroyed, anonymized, or otherwise disposed of.

Data Breach Notification

OTT is legally required to report certain privacy breaches, where a breach of security safeguards creates a “real risk of significant harm” (assessed by information sensitivity and likelihood of misuse), OTT will, as soon as feasible: report it to the Office of the Privacy Commissioner of Canada (OPC), notify affected individuals, and notify any other organization that may help reduce resulting harm. OTT has a branch operated in Quebec, where clients are separately protected under the Quebec Privacy Act’s parallel “risk of serious injury” threshold. OTT shall keep a record of every breach as required by applicable laws.

Your Access and Correction Rights

Subject to applicable law, you may request confirmation that OTT holds personal information about you, access to it, information on how it is used or disclosed, and correction of inaccurate or incomplete information. OTT employees are required to record your personal information accurately. However, errors may occur from time to time. If you identify inaccurate information or your information has changed, please notify OTT promptly of any changes or errors.

You can contact OTT by phone, fax, mail or email by using the contact information listed below. When requesting access to your information, normally a full access to your information is provided. However, there may be some legal or administrative limitations for certain cases.

OTT will respond to access, correction, or complaint requests within a reasonable period and in accordance with applicable law. Requests may be subject to identity verification, legal restrictions, and exceptions permitted by law. If you are not satisfied with OTT’s response, you may have the right to contact the Office of the Privacy Commissioner of Canada or another applicable privacy regulator.

Changes to This Policy

OTT may revise this Policy from time to time to reflect changes in our services, technology, or legal and regulatory requirements. The current version, with its effective date, will always be posted on our Website and App. Continued use of OTT’s services constitutes acceptance of the updated Policy.

Questions, Concerns or Complaints

If you have any questions, requests, concerns or complaints regarding this Privacy Policy or your personal information, please contact OTT by using one of the methods below (If a complaint, please send it in writing). OTT has designated a Privacy Officer responsible for privacy compliance and handling privacy inquiries and complaints. Upon receipt of your request or complaint, OTT’s Privacy Officer or authorized staff will review the matter and respond within a reasonable period in accordance with applicable law to address your concerns or resolve problems appropriately.

Contact Information

Phone: (+1) 416-512-1878

Fax: (+1) 416-512–0169

Email: privacy@ott.ca

Mail: OTT Financial Inc. Level 5, 5140 Yonge Street, Toronto, ON, Canada, M2N 6L7