GLEEC PAY LTD ("Gleec", "we", "us", "our")
1.1. Gleec is responsible for personal information under its control and has designated a Privacy Officer responsible for our compliance with this Policy and applicable privacy law. You may contact our Privacy Officer at legal@gleec.com.
1.2. Where Gleec transfers personal information to a third-party service provider for processing (see Section 9), Gleec remains accountable for that information and requires such providers, by contract, to provide a comparable level of protection.
2.1. We collect, use, and disclose personal information for the following purposes:
2.2. We identify the purpose for which personal information is collected at or before the time of collection, generally through this Policy, our Terms of Use, or the relevant registration or transaction form.
3.1. By creating a Gleec Account and using the Technology Platform, you consent to the collection, use, and disclosure of your personal information as described in this Policy. Consent may be express (for example, when you provide identification documents) or implied by your continued use of the Services after notice of this Policy.
3.2. You may withdraw consent for optional purposes (such as marketing communications) at any time, subject to legal or contractual restrictions and reasonable notice, by contacting support@gleec.com or using the unsubscribe mechanism in our communications.
Withdrawing consent for information required to provide the Services, or required under the PCMLTFA, may result in Gleec being unable to continue providing the Services to you and may lead to suspension or closure of your Gleec Account.
3.3. Consistent with PIPEDA and the PCMLTFA, we may collect, use, or disclose personal information without your knowledge or consent where permitted or required by law, including for the investigation of a breach of an agreement or contravention of law, to comply with a court order, subpoena, or regulatory demand, or to report suspicious transactions to FINTRAC.
4.1. Identification information: name, date of birth, address, nationality, government-issued identification (e.g., passport, driver's licence), photographs or video used for identity verification (e.g., liveness checks), and, where required by law, other identifiers.
4.2. Contact information: email address, telephone number, mailing address.
4.3. Financial and transaction information: Gleec Account activity, Deposit/Withdrawal and Trade history, crypto asset wallet addresses, source-of-funds information, and, where relevant to AML/KYC obligations, information about your occupation, income, or the purpose of your account.
4.4. Technical information: IP address, device identifiers, browser type, operating system, log files, and information collected through cookies and similar technologies (see Section 10).
4.5. Communications: records of correspondence with our support team, and Feedback you provide, as described in our Terms of Use.
4.6. We collect personal information directly from you, automatically through your use of the Technology Platform, and, where permitted, from third parties such as identity-verification vendors, sanctions and PEP screening providers, and publicly available sources, for AML/KYC and fraud-prevention purposes.
5.1. We collect only the personal information necessary for the purposes identified in Section 2, and by fair and lawful means.
6.1. We use and disclose personal information only for the purposes for which it was collected, unless you provide additional consent or the use or disclosure is permitted or required by law.
6.2. We retain personal information only as long as necessary to fulfil the purposes identified in Section 2, including a minimum retention period of five (5) years for client identification and transaction records, as required under the PCMLTFA and FINTRAC record-keeping rules. Some information may be retained longer where required by other applicable law or to resolve disputes.
6.3. When personal information is no longer required, we securely destroy, erase, or anonymize it in accordance with our internal data retention and disposal procedures.
7.1. We may disclose personal information to:
7.2. We do not sell your personal information.
8.1. We may use automated systems, including rules-based and algorithmic screening tools, to help detect potentially fraudulent, suspicious, or sanctioned activity, or to support identity verification. Where such a system is used to make a decision about you based exclusively on automated processing (for example, an automated account restriction), and that decision has a significant effect on you, you may, on request to legal@gleec.com, be informed of that fact and provided with the personal information used to render the decision and, where applicable, the principal factors and parameters that led to it, and you may request that a member of our staff review the decision.
9.1. Personal information is primarily stored and processed in Canada. In some cases, our service providers (for example, cloud hosting or identity-verification vendors) may store or process personal information outside Canada, including in the United States. Where this occurs, that information will be subject to the laws of the jurisdiction in which it is held, and may be accessible to courts, law enforcement, or national security authorities of that jurisdiction.
9.2. Before transferring personal information to a service provider, whether located in Canada or elsewhere, we use contractual and other means to require a comparable level of protection to that required under this Policy and applicable Canadian privacy law.
10.1. We and our service providers use cookies and similar technologies to operate the Technology Platform, remember your preferences, keep your Gleec Account secure, and understand how the Services are used, including through analytics tools.
10.2. You can manage or disable non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the Technology Platform. We do not currently respond to browser "Do Not Track" signals.
11.1. We will only send you commercial electronic messages where we have your express or implied consent, as permitted under CASL. Every marketing message will identify Gleec, include our contact information, and provide a functioning unsubscribe mechanism.
11.2. You may withdraw consent to marketing communications at any time by using the unsubscribe link in the message or by contacting support@gleec.com. This will not affect transactional or account-related Communications, which are necessary for us to provide the Services.
12.1. We take reasonable steps to ensure personal information is as accurate, complete, and up to date as necessary for the purposes for which it is used. You can help by keeping your Gleec Account information current and promptly notifying us of any changes.
13.1. We use physical, organizational, and technical safeguards appropriate to the sensitivity of the personal information involved, including access controls, encryption of information in transit, and staff training, designed to protect personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification.
13.2. No method of transmission or storage is completely secure. If you believe your Gleec Account or personal information has been compromised, contact support@gleec.com immediately.
14.1. If we become aware of a breach of security safeguards involving personal information under our control that creates a real risk of significant harm to an individual, we will notify the affected individual(s) and report the breach to the Office of the Privacy Commissioner of Canada, and any other applicable regulator, as required by PIPEDA and applicable provincial law. We maintain records of all breaches of security safeguards for the period required by law.
15.1. This Policy, along with our Terms of Use, is made available on our website and describes our policies and practices relating to the management of personal information.
16.1. Subject to limited exceptions permitted by law (for example, information subject to solicitor-client privilege, or that would reveal personal information about another individual), you have the right to:
16.2. To exercise these rights, contact legal@gleec.com. We will respond within thirty (30) days, or notify you if we require additional time as permitted by law. We may need to verify your identity before processing your request. A minimal fee may apply to certain requests, in which case we will provide you with an estimate in advance.
17.1. If you have a concern about our handling of your personal information, please contact our Privacy Officer at legal@gleec.com. We will investigate and respond to your concern.
17.2. If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada (30 Victoria Street, Gatineau, Quebec K1A 1H3; www.priv.gc.ca), or, where applicable, the relevant provincial privacy regulator, such as the Commission d'accès à l'information du Québec, the Office of the Information and Privacy Commissioner for British Columbia, or the Office of the Information and Privacy Commissioner of Alberta.
18.1. The Services are not directed to, and are not intended for use by, individuals under 18 years of age or the age of majority in their jurisdiction, whichever is higher, consistent with our Terms of Use. We do not knowingly collect personal information from minors. If we learn we have collected personal information from a minor, we will take reasonable steps to delete it.
19.1. The Technology Platform may contain links to third-party websites or services, including Third-Party Content as described in our Terms of Use. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy policy of any third-party site you visit.
20.1. We may update this Policy from time to time to reflect changes in our practices or applicable law. We will post the updated Policy on our website and update the "Last Updated" date. Where changes are material, we will provide additional notice, such as by email, as required by applicable law.
21.1. For privacy-related questions, access or correction requests, or complaints, contact our Privacy Officer at legal@gleec.com. For general account or transaction support, contact support@gleec.com.
2026-08-31