Forexcrow Inc. ("Forexcrow," "we," "us," or "our") is a Canadian Money Services Business registered with FINTRAC. We are committed to protecting your personal information and handling it responsibly, transparently, and in full compliance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and all applicable provincial privacy legislation.
By downloading the Forexcrow app, creating an account, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.
Forexcrow operates a peer-to-peer currency exchange and escrow platform. Because we handle real financial transactions and are regulated by FINTRAC, we are legally required to collect, verify, and retain certain personal information about our users. Certain information is required for Forexcrow to comply with applicable legal, regulatory, security, and operational obligations, including obligations under Canadian anti-money laundering and anti-terrorist financing laws.
This policy explains exactly what we collect, why we collect it, how we protect it, how long we keep it, and what rights you have over it.
We collect personal information only for legitimate, disclosed purposes. The categories of information we collect are:
When you register and complete our KYC (Know Your Customer) verification process, we collect:
This information is required by FINTRAC regulations. We cannot onboard you as a user without it.
To facilitate transactions and comply with our regulatory obligations, we collect:
Every transaction conducted through Forexcrow generates a record including:
When you use the Forexcrow app, we automatically collect certain technical information including:
If you contact our support team or communicate within the platform, we collect and retain records of those communications to resolve disputes, improve our service, and maintain our compliance obligations.
We maintain a complete log of every consent you provide within the platform — including when you consented, the exact language presented to you, and the action you took. This is required for regulatory accountability.
Where required for identity verification, fraud prevention, account security, or regulatory compliance, Forexcrow and its authorized verification providers may collect and process facial images, liveness verification data, biometric indicators, and related identity verification information.
Such information is used solely for identity verification, fraud prevention, account protection, regulatory compliance, and risk management purposes. We do not use biometric information for advertising, marketing, profiling, or behavioral targeting purposes.
Biometric information is protected using security measures appropriate to its sensitivity and is retained only for as long as necessary to fulfill legal, regulatory, security, and operational requirements.
We collect and use your personal information only for the following purposes:
To verify your identity and comply with FINTRAC regulations: As a registered Money Services Business, Forexcrow is required to conduct customer identification, verification, screening, monitoring, and due diligence activities in accordance with applicable laws and regulatory requirements. Depending on the nature of a transaction, account activity, risk indicators, regulatory requirements, or other circumstances, we may verify your identity before, during, or after your use of the platform. This includes conducting KYC checks, sanctions screening, and Politically Exposed Person (PEP) screening.
To operate the escrow and currency exchange service: We use your information to create and manage your account, process transactions, hold funds in escrow, release funds upon completion, and maintain accurate records of every financial event.
To detect and prevent fraud and financial crime: We monitor transaction patterns, device behavior, and account activity to identify and prevent fraud, money laundering, terrorist financing, sanctions violations, account compromise, unauthorized activity, and other prohibited conduct. This is both a regulatory obligation and a core commitment to our users.
To communicate with you: We use your contact information to send you transaction notifications, account updates, security alerts, and responses to your support requests. We do not send marketing communications without your consent where such consent is required by law. You may withdraw your marketing consent at any time without affecting your access to the platform or your ability to use Forexcrow's services.
To comply with legal and regulatory obligations: We are required by FINTRAC and Canadian law to retain certain records and to report certain transactions. Your information may be used to fulfill these obligations including filing Large Virtual Currency Transaction Reports (LVCTR) and Suspicious Transaction Reports (STR) where required.
To improve our platform: We use aggregated, anonymized data to understand how our platform is used and to improve our services. This data cannot be used to identify you individually.
To comply with Canadian and international legal obligations, Forexcrow may screen users, counterparties, transactions, beneficial owners, and associated parties against sanctions lists, politically exposed person (PEP) databases, adverse media sources, and other compliance and risk intelligence databases.
Such screening may occur at onboarding, during transactions, periodically throughout the customer relationship, or whenever required by applicable laws, regulations, or risk management procedures.
Forexcrow continuously monitors account activity and transactions to identify indicators of fraud, money laundering, terrorist financing, sanctions violations, account compromise, unauthorized activity, and other prohibited conduct.
Monitoring activities may include transaction pattern analysis, behavioral analysis, device-based risk assessment, account activity reviews, and other compliance and security measures necessary to protect users and satisfy regulatory obligations.
We process your personal information on the following legal bases:
Forexcrow may use automated systems, risk-scoring tools, and fraud detection technologies to assess account activity, identify suspicious behavior, detect potential fraud, evaluate transaction risk, and support compliance obligations.
These systems assist our compliance and security teams in making informed decisions. Significant actions affecting users, including account restrictions, transaction holds, or enhanced due diligence measures, may be subject to human review where appropriate.
We do not sell your personal information. Ever.
We share your information only in the following circumstances:
Regulatory and legal authorities: As a FINTRAC-registered MSB, we are required by law to report certain transactions and to provide information to regulatory authorities upon lawful request. This includes FINTRAC, law enforcement agencies, and courts where required by applicable Canadian law.
Identity verification and compliance providers: We use third-party service providers to conduct identity verification, sanctions screening, PEP screening, and adverse media checks. These providers process your information strictly on our behalf, under our instructions, and are contractually bound to our privacy and security standards. They may not use your information for any other purpose.
Payment and banking partners: To process deposits and withdrawals, we share necessary financial information with our banking and payment partners. These partners are independently regulated financial institutions.
Fraud prevention and security: We may share information with fraud prevention services and other financial institutions where necessary to detect, prevent, or investigate fraud or financial crime.
Business transfers: If Forexcrow is acquired, merged, or substantially reorganized, your personal information may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and the privacy terms governing your information will be maintained.
With your explicit consent: For any other sharing not described above, we will ask for your specific consent first.
Forexcrow may engage trusted service providers located within or outside Canada to assist with identity verification, compliance monitoring, fraud prevention, cloud hosting, analytics, customer communications, security monitoring, and other operational functions.
As a result, your personal information may be processed, stored, or accessed in jurisdictions outside your province or country of residence. Privacy laws in those jurisdictions may differ from those applicable in Canada.
When personal information is transferred across borders, Forexcrow implements contractual, technical, and organizational safeguards designed to ensure an appropriate level of protection and security.
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, subject to the following legally mandated minimums:
| Data Type | Retention Period | Legal Basis |
|---|---|---|
| KYC identity records | 5 years from last transaction | PCMLTFA s.6 |
| Transaction records | 5 years from transaction date | PCMLTFA s.6 |
| Escrow records | 5 years from completion | PCMLTFA s.6 |
| Suspicious transaction reports | 5 years | PCMLTFA s.6 |
| Consent logs | 5 years | PIPEDA accountability |
| Support communications | 3 years | Legitimate interest |
| Technical/security/device logs | Up to 24 months | Security monitoring, fraud prevention, dispute resolution, regulatory compliance, and risk management. |
Certain records may be retained beyond the periods listed above where required by law, regulatory obligations, ongoing investigations, dispute resolution processes, fraud prevention activities, litigation holds, law enforcement requests, or legitimate business purposes permitted by applicable law.
After the applicable retention period, we securely delete or anonymize your personal information in accordance with our data retention and disposal procedures.
Users may request closure of their Forexcrow account at any time, subject to any outstanding transactions, disputes, investigations, legal obligations, or compliance reviews.
Closing an account does not automatically result in deletion of personal information. Certain information must be retained to satisfy anti-money laundering requirements, financial reporting obligations, fraud prevention obligations, tax requirements, legal obligations, security requirements, and other regulatory responsibilities.
Where permitted by law, users may request deletion of certain personal information.
However, Forexcrow may decline, delay, or limit deletion requests where retention is required to comply with legal, regulatory, security, fraud prevention, accounting, tax, dispute resolution, recordkeeping, or anti-money laundering obligations.
Forexcrow was built with security as a foundation, not an afterthought. The measures we implement include:
No system is perfectly impenetrable. In the event of a data breach that poses a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as required by PIPEDA.
As a Canadian resident, you have the following rights regarding your personal information:
Right to Access: You may request a copy of the personal information we hold about you. We will respond within 30 days.
Right to Correction: If any information we hold about you is inaccurate or incomplete, you may request that we correct it.
Right to Withdraw Consent: Where our processing is based on your consent, you may withdraw that consent at any time. Note that withdrawing consent for mandatory KYC information will result in account closure as we cannot operate without it under our regulatory obligations.
Right to Complaint: If you believe we have mishandled your personal information, you may file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.
To exercise any of these rights, contact us at privacy@forexcrow.com with your full name, registered email address, and a clear description of your request. We may need to verify your identity before processing the request.
The Forexcrow mobile app does not use browser cookies. However, we do use the following technologies:
We do not use your data for interest-based advertising. We do not allow third-party advertising networks to track you through the Forexcrow app.
The Forexcrow platform may contain links to third-party websites or services. Once you leave our platform, this Privacy Policy no longer applies. We encourage you to review the privacy policies of any third-party services you access. We are not responsible for the privacy practices of third parties.
Forexcrow is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will delete it immediately. If you believe a minor has registered on our platform, please contact us at privacy@forexcrow.com.
We may update this Privacy Policy from time to time to reflect changes in our practices, our services, or applicable law. When we make material changes, we will notify you through the app and update the "Last Updated" date at the top of this policy. Your continued use of Forexcrow after a policy update constitutes your acceptance of the revised terms.
We encourage you to review this policy periodically.
Where required by applicable law or where changes materially affect how we collect, use, disclose, or protect personal information, we may request renewed consent or provide additional notice before such changes take effect.
For any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact our Privacy Officer:
Privacy Officer
Forexcrow Inc.
Email: privacy@forexcrow.com
Website: forexcrow.com
Our Privacy Officer is responsible for overseeing Forexcrow's privacy management program, responding to privacy requests, investigating privacy complaints, monitoring compliance with applicable privacy laws, and ensuring that Forexcrow maintains appropriate safeguards for personal information.
For complaints that we have not resolved to your satisfaction, you may contact:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: priv.gc.ca
This Privacy Policy is intended solely to explain Forexcrow's privacy practices and information handling procedures.
Nothing in this Privacy Policy constitutes legal, financial, tax, regulatory, compliance, cybersecurity, or professional advice. Users should seek independent professional advice regarding their individual rights, obligations, or circumstances where appropriate.
This Privacy Policy is governed by the laws of Canada and applicable provincial legislation.