Privacy Policy

1. Introduction

Welcome to Fluxora Paiements (“we”, “us”, “our”, or the “Company”). We take privacy

and the protection of personal information very seriously and are committed to

conducting our business in full compliance with applicable privacy and data protection

laws in Canada, including the Personal Information Protection and Electronic

Documents Act (PIPEDA) and other applicable provincial privacy laws.

This Privacy Policy (the “Policy”) describes our practices regarding the collection, use,

disclosure, retention, destruction, and other forms of processing of personal information

that we, our affiliates, or our service providers may collect when conducting our business

activities or when you use our website or services.

For the purposes of this Policy, “Personal Information” refers to information about an

identifiable individual, including any information that can identify a person directly or

indirectly. This may include names, phone numbers, email addresses, financial data, or

other identifying information.

We may update this Policy from time to time to ensure continued compliance with

applicable privacy laws or when reasonably necessary. When changes are made, we will

post the updated Policy on our website www.fluxorapay.com. Continued use of our

website or services after any updates will be considered acceptance of those changes.

2. How We Collect Personal Information

2.1 Information You Provide

We may collect personal information directly from you when you voluntarily provide it

to us through our website, during communications with us, or when using our services.

2.2 Information from Third Parties

We may also receive personal information from third parties in certain circumstances,

including:

• Third-party clients for whom we provide order processing or payment-related

services.• Third-party service providers that provide payment processing, credit verification,

or registration services.

• Public platforms where users may leave reviews or feedback regarding our

services.

2.3 Cookies and Similar Technologies

Where permitted by applicable privacy laws and, where required, with your consent, we

may collect personal information when you visit our website or use our services through

cookies and similar technologies.

These technologies may collect technical and usage information to improve our services

and enhance user experience.

2.4 Consent

We will obtain your consent to collect, use, disclose, or otherwise process your personal

information whenever required by applicable privacy laws, except where permitted or

required by law.

Your consent may be express or implied and may be given verbally, in writing,

electronically, or through your continued use of our services.

You may withdraw your consent at any time, subject to legal or contractual restrictions.

3. Types of Personal Information We Collect

In accordance with applicable privacy laws, we may collect the following categories of

personal information:

a) Identifiers

• Full name

• Date of birth

• Social Insurance Number (SIN)

• Health card number

• Driver’s licence number

• Passport number

• Residential address

• Email address

• Phone number

• Gender

• Marital status

• Nationalityb) Technical Information

• IP address

• Cookies and device identifiers

• Mobile device identifiers

• Social media account identifiers

• Profile photos

• Last login information

• Browser type and operating system

• Device information

• Website browsing history

• Voice biometric data

• Usage data including interactions with our services, preferences, and feedback

c) Financial Information

• Bank statements

• Banking information

• Salary or income information

• Payment details

• Credit information

• Credit card or bank account information

• Purchase or transaction history

• Credit score and credit history

4. Purposes for Collecting Personal Information

We may collect, use, disclose, and process personal information for the following

purposes:

• To operate and maintain our website and services.

• To provide the products or services you request.

• To notify you about changes to our services.

• To enable account creation and management.

• To assess creditworthiness and manage agreements or contracts.

• To respond to inquiries, support requests, or complaints.

• To monitor compliance with our terms and policies.

• To improve our website, services, and customer experience.

• To understand our clients and markets and facilitate business operations.

• With your consent, to send marketing communications about products or services

that may interest you.

• To provide personalized content or targeted advertising.

• To protect against fraud, errors, or security threats.

• To enforce legal rights or recover debts owed to the Company.• In connection with business transactions such as mergers, acquisitions, asset sales,

financing, or restructuring.

• To comply with applicable legal and regulatory obligations.

Where permitted by applicable laws, we may also use personal information without

consent for purposes compatible with those described above.

5. Who May Access Personal Information

5.1 Within the Company

Within Fluxora Paiements, personal information is accessible only to employees or

representatives who reasonably require access to perform their duties.

5.2 Affiliates

Personal information may be shared with our affiliated companies where necessary for

the purposes described in this Policy.

5.3 Third-Party Service Providers

We may engage third-party service providers to support our business operations. These

may include:

• Information technology providers, including cloud service providers

• Cybersecurity and information security specialists

• Legal, financial, or professional advisors

• Marketing and advertising service providers

• Regulatory authorities or government bodies

• Other service providers required for our business operations

When we share personal information with third parties, we only provide the information

necessary for them to perform their services and require them to protect the information

in accordance with applicable privacy laws.

5.4 Business Transactions

Personal information may be disclosed in connection with a corporate transaction such as

a merger, acquisition, financing, restructuring, or sale of assets.

5.5 International TransfersTo fulfill the purposes described in this Policy, personal information may be transferred

outside of your province or country of residence, including to jurisdictions with different

privacy laws.

In such cases, we will ensure that appropriate safeguards are implemented in accordance

with applicable privacy legislation.

5.6 Third-Party Websites

Our website may contain links to third-party websites or services. Once you leave our

website, your interactions with those third parties are governed by their own privacy

policies and terms of use.

6. Security Measures

We implement reasonable administrative, technical, and physical safeguards designed to

protect personal information from loss, misuse, unauthorized access, disclosure,

alteration, or destruction.

However, no method of data transmission over the Internet is completely secure. Users

should take reasonable precautions when accessing services online, including using

strong passwords and secure browsers.

For secure document transmission, users may contact us at:

contact@fluxorapay.com

7. Retention and Deletion of Personal Information

We retain personal information only for as long as reasonably necessary to fulfill the

purposes outlined in this Policy and to comply with applicable laws.

Generally, personal information will be deleted or anonymized no later than three (3)

years after your last interaction with us, unless a longer retention period is required or

permitted by law.

Personal information used to make decisions about an individual will be retained for at

least one year after the decision is made.

Once retention periods expire, personal information will be securely destroyed or

anonymized.8. Your Privacy Rights

You may have certain rights regarding your personal information, including:

Access

You have the right to request access to the personal information we hold about you.

Correction

You may request correction of inaccurate or incomplete personal information.

Withdrawal of Consent

You may withdraw your consent for the use or disclosure of your personal information at

any time, subject to legal or contractual restrictions.

Data Portability (Quebec Residents)

Residents of Quebec may request a machine-readable copy of their personal information

or request its transfer to another organization where applicable.

De-indexing (Quebec Residents)

Residents of Quebec may request the removal or de-indexing of certain personal

information under specific legal circumstances.

To exercise your rights, please contact us using the contact information below.

9. Contact Us

Fluxora Paiements has designated a privacy officer responsible for compliance with

privacy laws and the protection of personal information.

If you have questions, concerns, or complaints regarding this Privacy Policy or our

privacy practices, you may contact us at:

Email: contact@fluxorapay.com

Website: www.fluxorapay.com

You also have the right to file a complaint with the appropriate privacy authority in

Canada if you believe your personal information has been mishandled.