Privacy Policy
1. INTRODUCTION
1.1 This Privacy Policy explains how personal data is collected, used, disclosed, stored and otherwise processed in connection with the Valens Pay website, platform, onboarding flows, applications, payment interfaces and related services (the “Services”).
1.2 Valens Pay is a trading name, website and platform brand used in connection with onboarding, compliance, payment-related, fintech and digital asset-related services made available by entities within the Valens Pay group and/or authorised third-party service providers.
1.3 The Valens Pay group includes, among others:
Valens Pay Inc.
30 N Gould St Ste R
Sheridan, WY 82801
United States
Company No. 2026-001939891
Valens Pay Inc. is registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN), United States.
Valens Pay Limited
302-540 Lawrence Avenue
Kelowna V1Y 6L7
British Columbia
Canada
Company No. BC1278918
1.4 Valens Pay Global Limited acts as the parent company of the Valens Pay group.
1.5 In this Privacy Policy, “Company”, “Valens Pay”, “we”, “us” or “our” means, as applicable, Valens Pay Inc. and/or other affiliated entities within the Valens Pay group, depending on the service, jurisdiction, operational setup and customer relationship.
1.6 For the avoidance of doubt:
a) Valens Pay is a brand and platform and is not itself a separate legal entity;
b) services may be provided by the relevant Valens Pay group entity and/or by authorised third-party service providers; and
c) customer data may be processed by one or more entities depending on the service, jurisdiction and operational setup.
1.7 This Privacy Policy applies to:
a) the Valens Pay websites, portals and payment interfaces;
b) software, dashboards and applications provided under the Valens Pay brand;
c) onboarding, verification and account-related processes;
d) communications between you and us; and
e) personal data processed in connection with Services provided by us and/or by authorised third-party partners.
2. WHO THIS POLICY APPLIES TO
2.1 This Privacy Policy applies to:
a) website visitors;
b) applicants for accounts or services;
c) individual customers;
d) business representatives, directors, shareholders and beneficial owners;
e) counterparties and transaction participants; and
f) users interacting with onboarding, support or partner services.
2.2 The platform is not intended for individuals under 18 years of age.
3. DATA CONTROLLERS
3.1 Depending on the service and relationship, the controller of your personal data may be:
a) Valens Pay Inc.; and/or
b) Valens Pay Limited; and/or
c) another affiliated entity within the Valens Pay group.
3.2 In certain cases, authorised third-party service providers may act as independent data controllers for their own services.
3.3 The relevant controller will be identified where required in onboarding flows, account documentation, product materials or communications.
4. WHAT PERSONAL DATA WE MAY COLLECT
4.1 Identity Data
4.2 Contact Data
4.3 Account and Profile Data
4.4 Compliance and KYC/KYB Data
4.5 Financial and Transaction Data
4.6 Technical and Device Data
4.7 Usage Data
4.8 Marketing and Communications Data
4.9 Corporate Relationship Data
4.10 Other Information
(All categories remain as previously defined – unchanged)
5. HOW WE COLLECT PERSONAL DATA
5.1 We may collect personal data:
a) directly from you;
b) during onboarding and verification;
c) through platform usage;
d) via communications;
e) from cookies and similar technologies;
f) from service providers and partners;
g) from public sources and registries; and
h) from authorised representatives acting on your behalf.
6. PURPOSES FOR WHICH WE USE PERSONAL DATA
6.1 We process personal data for the following purposes:
a) provision of Services and account management;
b) onboarding, identity verification and compliance controls;
c) AML, CTF, sanctions and fraud prevention;
d) transaction processing, settlement and operational support;
e) risk management, monitoring and platform protection;
f) communication and customer support;
g) service improvement, analytics and development;
h) dispute handling, legal enforcement and compliance; and
i) marketing where permitted by law.
7. LEGAL BASIS FOR PROCESSING
7.1 Where required, we rely on:
a) contractual necessity;
b) legal obligations (including AML/CTF);
c) legitimate interests;
d) consent (where required);
e) legal claims; and
f) other lawful bases.
8. DISCLOSURE OF PERSONAL DATA
8.1 Personal data may be shared with:
a) entities within the Valens Pay group;
b) onboarding, KYC/KYB and compliance providers;
c) banks, payment institutions and financial partners;
d) card issuers, processors and wallet providers;
e) IT, hosting and analytics providers;
f) legal and compliance advisors;
g) regulators and authorities;
h) third-party providers whose services you request.
8.2 We may also disclose data:
a) to prevent fraud or crime;
b) to enforce rights or agreements;
c) to comply with legal obligations.
8.3 We do not sell personal data.
9. THIRD-PARTY SERVICES
9.1 Services accessed through the platform may be provided by third-party partners.
9.2 Where applicable:
a) your data may be shared with such providers;
b) those providers may act as independent controllers; and
c) their own terms and privacy policies may apply.
10. INTERNATIONAL TRANSFERS
10.1 Personal data may be transferred internationally.
10.2 This may occur due to:
a) global infrastructure;
b) international transactions;
c) cross-border partners;
d) compliance and support functions.
10.3 Appropriate safeguards are applied where required.
11. DATA RETENTION
11.1 Personal data is retained as long as necessary for:
a) service provision;
b) legal and regulatory compliance;
c) AML/CTF obligations;
d) dispute and audit purposes.
12. AUTOMATED DECISION-MAKING
12.1 We may use automated tools for:
a) onboarding;
b) fraud prevention;
c) risk scoring;
d) transaction monitoring.
12.2 You may request review where applicable.
13. COOKIES
13.1 We use cookies for:
a) functionality;
b) security;
c) analytics;
d) user experience.
14. SECURITY
14.1 We apply appropriate safeguards including:
a) encryption;
b) access controls;
c) monitoring;
d) vendor controls.
14.2 No system is completely secure.
15. YOUR RIGHTS
15.1 You may have rights including:
a) access;
b) correction;
c) deletion;
d) restriction;
e) objection;
f) portability;
g) withdrawal of consent.
15.2 These rights may be limited by legal obligations.
16. MARKETING
16.1 Marketing communications are sent where permitted.
16.2 You may opt out at any time.
17. COMMUNICATION RECORDINGS
17.1 Communications may be recorded for:
a) compliance;
b) security;
c) dispute handling;
d) legal purposes.
18. CHANGES TO THIS POLICY
18.1 This Privacy Policy may be updated.
18.2 Continued use may constitute acceptance.
19. CONTACT
19.1 You may contact us via:
19.2 Or at:
Valens Pay Inc.
30 N Gould St Ste R
Sheridan, WY 82801
United States
and/or
Valens Pay Limited
302-540 Lawrence Avenue
Kelowna V1Y 6L7
Canada
20. VERSION
20.1 Version date: April 2026.