Last Updated: June 9, 2025

1. Overview

This Privacy Policy ("Policy") explains how Dunbridge Financial Inc. ("Dunbridge", "we", "our", or "us") collects, uses, discloses, and protects your personal data when you use our services, including through our websites, mobile applications, APIs, customer portals, and any other platforms we operate (collectively, the "Services").

We are committed to maintaining the accuracy, confidentiality, and security of your personal data and handling it in accordance with applicable privacy laws, including PIPEDA (Canada), the GDPR (EU/UK), and other local data protection laws where applicable.

2. Scope

This Policy applies to any individual or business that uses or interacts with our Services, including website visitors, platform users, financial counterparties, and customer representatives. It does not apply to third-party websites or services that may be linked to our Services.

3. Definitions

• Personal Data: Any information that can identify you directly or indirectly, including name, contact information, identification documents, and financial information.
• Processing: Any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• Services: Dunbridge’s digital platforms, apps, APIs, foreign exchange, payment processing, onboarding, compliance screening, and other features we make available.

4. How We Collect Information

Information You Provide

• Creating an account or onboarding your company
• Submitting identity or business verification documents
• Initiating a transaction or requesting support
• Communicating via chat, email, phone, or forms

Information We Collect Automatically

• IP address, browser type, access time, pages visited
• Device type, OS version, and geolocation (with permission)
• Usage data including clicks, actions, and preferences
• Cookies, web beacons, and similar tracking technologies

Information from Third Parties

• Identity and fraud screening partners (e.g., KYC/AML services)
• Credit bureaus and compliance data providers
• Business partners or banks through whom you access our Services
• Public records and sanction list providers

5. Types of Information We Collect

• Personal & Identification Data: Name, DOB, address, email, phone, ID documents, SIN/TIN.
• Business Data: Company info, beneficial ownership, incorporation documents.
• Financial Data: Bank details, payment methods, transaction history.
• Transactional Data: Recipients, purposes, amounts, currencies.
• Behavioral Data: Preferences and interactions with our Services.
• Device & Technical Data: Device type, identifiers, location.
• Aggregated/Anonymized Data: Used for analytics and industry benchmarking.

6. How We Use Your Information

• To deliver and operate our Services
• To verify identities and conduct compliance checks
• To facilitate FX conversions, payments, and treasury operations
• To personalize content and optimize user experience
• For customer service, technical support, and security alerts
• To comply with laws, regulatory obligations, and audits
• To market Dunbridge services, subject to your preferences
• To conduct internal analytics and reporting

7. Legal Basis for Processing

Where required by law (e.g., GDPR), we process your Personal Data based on:

• Your consent
• Contractual necessity
• Legal obligations (e.g., FINTRAC, FINCEN)
• Legitimate interests (e.g., fraud prevention, system security)

8. How We Share Your Information

• Service Providers: Infrastructure, fraud detection, support, marketing, etc.
• Corporate Affiliates: To streamline operations and deliver Services.
• Legal & Regulatory Bodies: Where required by law or lawful request.
• Business Transactions: Mergers, acquisitions, or restructuring.
• With Your Consent: Third-party apps or integrations you authorize.

9. Cookies & Tracking

We use cookies and similar technologies to enhance your experience and for analytics and marketing purposes. You may manage your preferences via browser settings. For full details, see our Cookie Policy.

10. Your Rights & Choices

• Access & Correction: Request access to or correction of your data.
• Marketing Preferences: Opt out of promotional communications anytime.
• Deletion: Request deletion unless retention is required by law.
• Do Not Track: We do not currently respond to DNT signals.

11. Data Retention

We retain data for a period of 7 years or as otherwise required to comply with laws, fulfill contracts, maintain logs, resolve disputes, or detect/prevent fraud. Data is securely deleted or anonymized thereafter.

12. Cross-Border Transfers

We may store or process data in countries with different privacy laws (including the U.S.). Appropriate safeguards, such as standard contractual clauses, are applied where necessary.

13. Security

We implement technical and organizational measures to protect your data, including encryption, access controls, and regular security reviews. However, no method is 100% secure—keep your credentials private and alert us to any suspicious activity.

14. Children’s Privacy

Our Services are not directed to children under 18. If we become aware that we’ve collected data from a child, we will delete it promptly. Contact us if you believe this has occurred.

15. Policy Updates

We may revise this Policy periodically. We will notify you of material changes via email or a notice on our website. Continued use of our Services constitutes acceptance of the revised Policy.

16. Contact Us

If you have questions or concerns, contact:

Dunbridge Financial Inc.
Attn: Privacy Officer
28 Pintail Lane
Halifax, NS, B3T0E8
Canada
Email: privacy@dunbridgefinancial.com

You may also contact:

Office of the Privacy Commissioner of Canada
30 Victoria Street, 1st Floor
Gatineau, QC K1A 1H3
Phone: 1-800-282-1376
Website: www.priv.gc.ca