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Radilink Privacy Policy

Effective Date: July 22, 2026 Last Updated: July 22, 2026

1. Introduction & Scope

RADILINK PAYMENTS INC. ("Radilink," "we," "us," or "our") is a corporation incorporated under the laws of the Province of British Columbia, Canada (British Columbia Incorporation Number BC1580776), registered with FINTRAC as a Money Services Business (MSB Registration Number N300000928), with its registered office at 6th Floor, Suite 1, 777 Hornby St, Vancouver, BC V6Z 1S4, Canada.

Radilink provides cross-border business payment services, including fiat-to-fiat electronic funds transfers, virtual currency and stablecoin conversion and exchange, and segregated virtual IBAN provisioning, exclusively to business clients (each, a "Business Client"). Radilink does not offer its payment services to individuals acting in a personal or consumer capacity.

This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with:

  • our website at radilink.io and any related web or mobile applications (collectively, the "Platform");
  • our onboarding, know-your-customer ("KYC"), and know-your-business ("KYB") processes; and
  • the payment and virtual currency services we provide to Business Clients (collectively, the "Services").

Because our Services are provided to businesses, most of the personal information we handle relates to individuals connected with a Business Client — such as beneficial owners, directors, authorized signatories, and representatives — rather than to the Business Client itself (which, as a corporate entity, is not a natural person). Throughout this Policy, "you" refers to any individual whose personal information we collect, including such representatives and to visitors of our Platform.

This Policy is intended to comply with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable substantially similar provincial privacy legislation, as well as our obligations as a money services business ("MSB") under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA").

2. Our Role as a Money Services Business

Radilink is registered as a money services business with the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC"), Canada's financial intelligence unit and anti-money laundering/anti-terrorist financing regulator, and operates as a reporting entity under the PCMLTFA.

As a regulated MSB, Radilink is legally required to collect, verify, retain, and, in certain circumstances, report personal and transactional information to FINTRAC and other competent authorities. These obligations include client identification and verification (KYC/KYB), beneficial ownership identification, sanctions and politically exposed person ("PEP") screening, ongoing transaction monitoring, and record-keeping. This Policy describes how we meet these legal obligations in addition to delivering our Services. Where PIPEDA and our AML/ATF obligations under the PCMLTFA intersect, our compliance obligations take precedence, as permitted under PIPEDA.

3. What Personal Information We Collect

3.1 Information You or Your Business Provide to Us

When a Business Client is onboarded or uses our Services, we collect personal information about the Business Client's beneficial owners (individuals holding, directly or indirectly, 25% or more of the entity), directors, authorized signatories, and representatives, including:

  • full name, date of birth, nationality, and government-issued identification documents (e.g., passport, driver's licence);
  • residential and business contact information (address, email, telephone number);
  • position/title and authority to act on behalf of the Business Client;
  • source-of-funds and source-of-wealth information;
  • corporate registry extracts, ownership structure, and beneficial ownership declarations for the Business Client; and
  • account login credentials and platform authentication information.

3.2 Transaction Information

In connection with processing electronic funds transfers and virtual currency transactions, we collect:

  • beneficiary and payer/payee name, account number, IBAN, SWIFT/BIC, and sort code details;
  • payment amount, currency, and stated purpose of the transaction;
  • for electronic funds transfers of CAD $1,000 or more, "Travel Rule" information about the payer and payee, as required under FINTRAC's rules; and
  • virtual currency wallet addresses and blockchain transaction data (for BTC, ETH, USDT, and USDC transactions).

3.3 Information We Collect Automatically

When you visit our Platform, we automatically collect technical information such as your IP address, browser and device type, operating system, pages viewed, and access times, generally through cookies and similar tracking technologies (see Section 11).

3.4 Information We Collect From Third Parties

We obtain personal information from:

  • identity verification and KYC service providers (currently Sumsub), who verify identity documents and perform sanctions, PEP, and adverse media screening;
  • blockchain analytics providers (currently Crystal Blockchain), who assess the risk profile of virtual currency addresses and transactions;
  • our banking-as-a-service and virtual IBAN partner (currently OpenPayd);
  • public corporate registries and databases, for the purpose of verifying beneficial ownership and corporate standing; and
  • publicly available sanctions, watchlist, and PEP databases.

4. How We Use Your Personal Information

We use personal information to:

  • establish and verify the identity of Business Clients and their associated individuals (KYC/KYB);
  • assess and manage risk, including sanctions, PEP, and adverse media screening, and ongoing transaction monitoring;
  • process electronic funds transfers and virtual currency conversions and exchanges you or your Business Client instruct us to carry out;
  • provision and administer segregated virtual IBANs;
  • detect, investigate, and prevent fraud, money laundering, terrorist financing, and other financial crime;
  • comply with our legal and regulatory obligations under the PCMLTFA and to FINTRAC, the Bank of Canada, and other applicable authorities;
  • communicate with you about your account, transactions, and our Services, including through your dedicated account manager;
  • maintain, secure, and improve our Platform; and
  • respond to inquiries and enforce our agreements with Business Clients.

5. Legal Basis and Consent

We collect, use, and disclose personal information only with your knowledge and consent, except where otherwise permitted or required by law. Consent may be express (for example, when you or your Business Client sign our Business Payment Services Agreement) or implied by the context of our relationship.

Certain collection, use, and disclosure of personal information is required by law — in particular, our KYC/KYB, screening, monitoring, and reporting obligations under the PCMLTFA. In these cases, we are required to collect and use this information as a condition of providing the Services, and consent cannot be withdrawn for these specific purposes while our legal obligations remain in force.

6. How We Share and Disclose Information

We disclose personal information to:

  • Service providers and partners who perform functions on our behalf, including Sumsub (identity verification and screening), Crystal Blockchain (virtual currency risk analytics), OpenPayd (virtual IBAN and banking services), and correspondent and beneficiary banks and payment rails necessary to execute your transactions (e.g., SWIFT, SEPA, Faster Payments/CHAPS);
  • Regulators and government authorities, including FINTRAC, the Bank of Canada, the Canada Revenue Agency, and other domestic or foreign regulators, where required or permitted by law;
  • Law enforcement, in response to a valid legal request or where necessary to protect the rights, property, or safety of Radilink, our clients, or others;
  • Professional advisors, such as our auditors, lawyers, and compliance consultants, on a confidential basis; and
  • A successor entity, in connection with a merger, acquisition, financing, or sale of all or part of our business, subject to appropriate confidentiality protections.

We do not sell personal information to third parties.

7. International/Cross-Border Data Transfers

Some of our service providers operate outside Canada, and personal information may be collected, processed, or stored in other jurisdictions, including where our service providers or correspondent banking partners are located. When personal information is transferred outside Canada, it may become subject to the laws of the jurisdiction in which it is held, including lawful requirements to disclose personal information to government authorities in that jurisdiction. We take contractual and organizational steps to require that our service providers protect personal information to a standard consistent with this Policy and applicable Canadian law.

8. How We Protect Your Information

We maintain administrative, technical, and physical safeguards designed to protect personal information against loss, theft, and unauthorized access, use, disclosure, alteration, or destruction, appropriate to the sensitivity of the information. These include restricting access to personal information to personnel and service providers who require it to perform their functions, encrypting sensitive data in transit, and requiring secure authentication for access to our Platform.

No method of transmission or storage is completely secure. If you have reason to believe your interaction with us or the Platform is no longer secure, or you become aware of any unauthorized access to your account, please contact us immediately using the information in Section 14.

9. Data Retention

We retain personal information, transaction records, and KYC/KYB documentation for a minimum of five (5) years from the date the relevant business relationship ends or the transaction is completed, as required under the PCMLTFA and its regulations. We may retain certain information for longer where necessary to comply with other legal, regulatory, tax, or accounting requirements, to resolve disputes, or to enforce our agreements. When personal information is no longer required for these purposes, we destroy, erase, or anonymize it.

10. Your Privacy Rights

Subject to certain exceptions under applicable law (including where information is required to be retained for our AML/ATF obligations), you have the right to:

  • access the personal information we hold about you;
  • request correction of inaccurate or incomplete personal information;
  • withdraw consent to our collection, use, or disclosure of your personal information, where consent is the basis for such processing and subject to legal or contractual restrictions; and
  • ask questions about our privacy practices or lodge a complaint.

To exercise any of these rights, contact our Privacy Officer using the information in Section 14. We will respond to your request within the timelines required by applicable law.

11. Cookies and Tracking Technologies

Our Platform uses cookies and similar technologies to operate securely, remember your preferences, and understand how the Platform is used. You can control or disable cookies through your browser settings; however, doing so may affect the functionality of the Platform, including your ability to log in and use the Services.

12. Children's Privacy

Our Services are intended for business use by adults acting on behalf of a Business Client. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete it.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, Services, or legal obligations. We will post the revised Policy on our Platform with an updated "Last Updated" date. If changes are material, we will provide additional notice as appropriate, such as by email to your Business Client's registered contact.

14. How to Contact Us

If you have questions, requests, or concerns about this Policy or our handling of your personal information, please contact our Privacy Officer:

Email: privacy@radilink.io Mail: RADILINK PAYMENTS INC., 6th Floor, Suite 1, 777 Hornby St, Vancouver, BC V6Z 1S4, Canada

15. How to Complain

If you are not satisfied with our response to a privacy concern, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada 30 Victoria Street, Gatineau, Quebec K1A 1H3 Toll-free: 1-800-282-1376 Website: www.priv.gc.ca