WIREWAND X  /  ZASHX

PRIVACY POLICY

Last updated: June 2026

1. Introduction

WireWand X, operating in partnership with ZASHX (together “WireWand X/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 payments, money transfer, and remittance services.

ZASHX is registered as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), Registration No. C10001441. As a regulated MSB, we are required to collect and retain certain customer information in order to meet anti-money laundering (AML) and counter-terrorist financing (CTF) obligations.

By using the WireWand X platform, you consent to the data practices described in this policy.

2. Information We Collect

We collect information you provide to us directly, together with information gathered automatically when you use the platform.

Personal information

  • Full legal name
  • Date of birth
  • Residential address
  • Email address and phone number
  • Government-issued identification (e.g. passport or driving licence)
  • Social Insurance Number (SIN) or Tax Identification Number, where required
  • Photographs used for identity verification

Financial information

  • Bank account details
  • Credit and 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

3. How We Use Your Information

Service delivery

  • Processing payments, transfers, and FX transactions
  • Verifying your identity and preventing fraud
  • Communicating with you about your transactions
  • Providing customer support

Compliance and legal

  • Meeting FINTRAC obligations and AML/CTF requirements
  • Reporting suspicious transactions where required by law
  • Responding to lawful requests and court orders
  • Maintaining records required by regulation

Business operations

  • Improving and optimising the platform
  • Analysing usage patterns and trends
  • Developing new products and features
  • Sending service updates and, with your consent, promotional communications

4. Information Sharing and Disclosure

Your information may be shared in the following circumstances:

Regulatory authorities

  • FINTRAC and other financial regulators
  • Law enforcement agencies, where required by law
  • Tax authorities, as required

Service providers

  • Identity verification providers
  • 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

All third parties are required to protect the security of your personal data and process it in accordance with the law. We do not sell your personal information.

5. International Data Transfers

Because we provide international payment services, your information may be transferred to and processed in countries other than Canada or your country of residence, including countries where your recipients are located.

Where data is transferred internationally, we apply appropriate safeguards, including standard contractual clauses approved by regulatory authorities, data processing agreements with all service providers, and compliance with applicable data protection laws.

Payout partners in destination countries may be subject to local laws governing data retention and disclosure.

6. Data Security

Technical safeguards

  • 256-bit SSL/TLS encryption for data in transit
  • AES-256 encryption for data at rest
  • Multi-factor authentication
  • Regular security audits and penetration testing
  • Secure data centres with physical access controls

Organisational safeguards

  • Employee background checks and security training
  • Role-based access controls
  • Incident response procedures
  • Regular security awareness programmes

While we apply rigorous protections, no method of transmission over the internet is entirely secure, and absolute security cannot be guaranteed.

7. Data Retention

We keep your personal information only for as long as needed to provide our services, satisfy legal and regulatory requirements, and resolve disputes or enforce our agreements.

Specific retention periods

  • Transaction records: minimum of 5 years after the transaction, as required by FINTRAC
  • Identity verification documents: minimum of 5 years after account closure
  • Customer communications: 3 years
  • Marketing preferences: until you opt out

Once the applicable retention period expires, your information is securely deleted or anonymised.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

  • Access — obtain a copy of the personal information we hold about you and details of how it is processed
  • Correction — have inaccurate or incomplete information corrected, and update your account details at any time
  • Deletion — request erasure of your personal information, subject to legal retention requirements, and close your account
  • Restriction — request that processing be limited in certain circumstances
  • Portability — receive your data in a structured, machine-readable format
  • Objection — object to processing for direct marketing and opt out of promotional communications

To exercise any of these rights, contact us using the details in Section 13.

9. Cookies and Tracking Technologies

  • Essential cookies — session management, authentication, security, fraud prevention, and performance
  • Functional cookies — remembering your preferences, including language and currency settings
  • Analytics cookies — understanding how the platform is used so we can improve it
  • Marketing cookies — delivering relevant advertising (with consent) and measuring campaign effectiveness

You can manage your cookie preferences through your browser settings or our cookie consent tool.

10. Children’s Privacy

The platform is not intended for individuals under 18 years of age, and we do not knowingly collect personal information from children. If we become aware that information has been collected from someone under 18, we will delete it promptly. If you believe a minor’s information has been collected, please contact us immediately.

11. Third-Party Links

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

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in legal requirements. Where changes are material, we will notify you by email or in-app notification, update the “Last updated” date above, and give 30 days’ notice for significant changes. Continued use of the platform after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact:

Privacy Officer — ZASHX

231 Oak Park Blvd, Suite 301, Oakville, L6H 7S8, ON, Canada

Email: info@zashx.com  |  Phone: +1 (289) 203 5222

WireWand X platform support: support@wirewandx.com

If you are not satisfied with how your personal information has been handled, you may also contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.