1. Introduction
M-Pay (operating name of Media Pay, registered MSB C100000603) (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our fiat-to-cryptocurrency conversion services and platform (collectively, the “Services”).
By accessing or using our Services, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our Services.
We reserve the right to make changes to this Privacy Policy at any time. We will notify you of any material changes by updating the “Last Updated” date and, where appropriate, by email or platform notification.
2. Information We Collect
2.1 Personal Information You Provide
We collect information you provide directly to us, including:
- Account Registration: Full name, email address, phone number, date of birth, nationality, residential address
- Business Information: Company name, registration number, business address, tax identification number, industry sector, beneficial ownership information
- Identity Verification (KYC): Government-issued ID (passport, driver's license, national ID), proof of address documents, selfie photographs, biometric data
- Financial Information: Bank account details (IBAN, account number, SWIFT codes), cryptocurrency wallet addresses, transaction history, source of funds documentation
- Communication Data: Any information you provide when contacting customer support, including correspondence, chat logs, and support tickets
2.2 Information Collected Automatically
When you access our Services, we automatically collect certain information:
- Device Information: IP address, browser type and version, operating system, device identifiers, screen resolution
- Usage Data: Pages visited, features used, time spent on pages, click patterns, session recordings (anonymized)
- Location Data: General geographic location based on IP address
- Cookies and Tracking Technologies: See Section 8 for detailed information
- Transaction Data: Details of all conversions, timestamps, amounts, currencies, blockchain transaction hashes
2.3 Information from Third Parties
We may receive information about you from third-party services, including:
- KYC/AML Verification Providers: Identity verification results, sanctions screening data, PEP (Politically Exposed Person) checks, adverse media screening
- Banking Partners: Payment confirmation, account verification, beneficiary validation
- Blockchain Networks: Transaction confirmations, wallet address validation, on-chain transaction data
- Compliance Databases: Sanctions lists, fraud databases, risk scoring information
3. How We Use Your Information
We use the information we collect for the following purposes:
- Service Provision: To create and manage your account, process transactions, execute conversions, and provide customer support
- Compliance and Legal Obligations: To verify your identity (KYC), conduct anti-money laundering (AML) checks, screen against sanctions lists, detect and prevent fraud, and comply with regulatory requirements including FINTRAC reporting
- Security: To protect against unauthorized access, maintain platform security, detect and prevent security incidents, and monitor for suspicious activity
- Communication: To send transaction confirmations, account notifications, security alerts, service updates, and respond to your inquiries
- Analytics and Improvement: To analyze usage patterns, improve our Services, develop new features, and enhance user experience
- Risk Management: To assess transaction risk, prevent money laundering, detect fraudulent activity, and manage operational risks
- Marketing: With your consent, to send promotional materials, newsletters, and service updates (you may opt-out at any time)
- Legal Proceedings: To enforce our Terms of Service, respond to legal requests, and protect our rights and property
4. Legal Basis for Processing (GDPR)
For users in the European Economic Area (EEA), UK, and Switzerland, we process your personal data based on the following legal grounds:
- Contractual Necessity: Processing is necessary to provide our Services and fulfill our contractual obligations to you
- Legal Obligation: Processing is required to comply with AML/KYC regulations, financial crime prevention laws, FINTRAC requirements, and other applicable laws
- Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, security, service improvement) provided these interests are not overridden by your rights
- Consent: Where we have obtained your explicit consent for specific processing activities (e.g., marketing communications)
5. Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
M-Pay (Media Pay)
Email: privacy@m-pay.io
Support: support@m-pay.io
Address: 5240 – 1A Street SE, Unit 201, Calgary, AB, T2H 1J1, Canada
MSB Registration: C100000603