Effective Date
12-26-2025
Controller
1. Introduction
1.1 Our Commitment
At AlrealRemit, we are committed to protecting your privacy and personal information. As a Canadian-licensed Money Services Business (MSB), we handle your personal information with the highest standards of security and confidentiality, in compliance with applicable privacy laws including the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial privacy legislation.
1.2 Scope
This Privacy Policy applies to:
All personal information collected through our website, mobile applications, and services
Information collected during account registration, transactions, and customer support
Data received from third parties in connection with our services
All current and former customers of AlrealRemit
1.3 Consent
By using our services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.
2. Information We Collect
2.1 Personal Identification Information
We collect:
Full legal name
Date of birth
Contact information (email, phone, address)
Government-issued identification details
Photographs of identification documents
Signature (where required)
2.2 Financial Information
We collect:
Bank account details
Payment card information (processed securely via tokenization)
Transaction history
Source of funds information
Credit information (where applicable)
2.3 Transaction Information
We collect:
Recipient details (name, contact information, relationship to sender)
Transfer amounts and currencies
Exchange rates applied
Fees charged
Delivery methods and timelines
2.4 Technical Information
We collect:
IP addresses and device information
Browser type and version
Operating system
Usage patterns and preferences
Cookies and similar technologies data
2.5 Compliance Information
As required by Canadian regulations, we collect:
Proof of identity documentation
Proof of address verification
Source of wealth information
Politically Exposed Person (PEP) status
Sanctions screening results
3. How We Collect Information
3.1 Direct Collection
Information you provide during account registration
Details provided during transaction initiation
Documents submitted for verification
Communications with our support team
Surveys and feedback forms
3.2 Automated Collection
Through cookies and similar technologies
Via server logs and analytics tools
Through mobile application usage data
Transaction monitoring systems
3.3 Third-Party Collection
From financial institutions
From identity verification services
From credit bureaus (where permitted)
From regulatory databases
From fraud prevention services
4. Purposes of Collection
4.1 Primary Purposes
We collect and use your information to:
Provide money transfer services
Verify your identity as required by law
Process transactions securely
Comply with Canadian AML/CTF regulations
Prevent fraud and financial crimes
Communicate about your transactions
4.2 Secondary Purposes
We may use your information to:
Improve our services and user experience
Conduct research and analysis
Develop new products and features
Send service-related announcements
Personalize your experience
4.3 Legal & Regulatory Purposes
Fulfill reporting obligations to FINTRAC
Respond to legal requests and court orders
Comply with international sanctions
Maintain records as required by law
Support regulatory investigations
5. How We Use Your Information
5.1 Service Provision
Create and manage your account
Process money transfers
Verify transactions
Provide customer support
Send transaction confirmations
5.2 Compliance & Security
Conduct KYC (Know Your Customer) verification
Monitor transactions for suspicious activity
Screen against sanctions lists
Prevent money laundering and terrorist financing
Investigate potential fraud
5.3 Communication
Send important service updates
Respond to inquiries and support requests
Send regulatory disclosures
Provide marketing communications (with consent)
Share policy updates
5.4 Analytics & Improvement
Analyze service usage patterns
Improve website and app functionality
Enhance security measures
Develop new features
Conduct market research
6. Information Sharing & Disclosure
6.1 With Service Providers
We share information with:
Payment processors
Banking partners
Identity verification services
Customer support platforms
IT and security providers
Marketing agencies (with consent)
6.2 For Legal & Regulatory Reasons
We disclose information:
To FINTRAC and other regulators
To law enforcement with proper legal process
To comply with court orders
To prevent illegal activities
To protect our rights and property
6.3 With Financial Institutions
Correspondent banks for transaction processing
Receiving institutions for fund delivery
Payment networks for transaction routing
Regulatory reporting systems
6.4 Business Transfers
In the event of:
Merger or acquisition
Sale of assets
Business reorganization
Bankruptcy proceedings
6.5 With Your Consent
For additional services you request
With third parties you authorize
For marketing partnerships (with opt-in consent)
7. International Transfers
7.1 Cross-Border Data Flows
Your information may be transferred to:
Recipient countries for transaction processing
Service providers in other jurisdictions
Regulatory authorities in other countries (as required)
Cloud storage providers with global infrastructure
7.2 Safeguards
For international transfers, we ensure:
Adequate data protection agreements
Compliance with Canadian privacy laws
Appropriate security measures
Limited data sharing to necessary purposes
7.3 Recipient Countries
Data may be transferred to:
United States
Countries in Africa and Middle East (for transactions)
Cloud service provider locations
Regulatory authority locations
8. Data Security
8.1 Security Measures
We implement:
256-bit SSL encryption for data transmission
Multi-factor authentication for account access
Secure data centers with physical protections
Regular security audits and penetration testing
Employee security training and background checks
8.2 Technical Safeguards
Firewalls and intrusion detection systems
Data encryption at rest and in transit
Access controls and role-based permissions
Regular security updates and patches
Incident response and recovery plans
8.3 Organizational Safeguards
Privacy and security policies
Employee confidentiality agreements
Regular security awareness training
Third-party vendor security assessments
Privacy impact assessments
9. Data Retention
9.1 Retention Periods
We retain information:
Account information: 6 years after account closure
Transaction records: 6 years as required by FINTRAC
Identification documents: 6 years after verification
Compliance records: 6 years as required by law
Marketing consent: Until withdrawal of consent
9.2 Retention Basis
We retain data based on:
Legal and regulatory requirements
Business needs and purposes
Statute of limitations for claims
Historical analysis needs
Service improvement requirements
9.3 Secure Destruction
When retention periods expire, we:
Securely delete electronic records
Securely shred physical documents
Maintain destruction logs
Ensure complete data removal
10. Your Rights & Choices
10.1 Access & Correction
You have the right to:
Access your personal information
Request corrections to inaccurate information
Request information about our data practices
Obtain copies of your data (subject to fees)
10.2 Consent Management
You can:
Withdraw consent for marketing communications
Opt out of certain data uses (where permitted)
Request restrictions on data processing
Object to certain data processing activities
10.3 Account Management
You can:
Update your profile information
Close your account
Download transaction history
Manage communication preferences
10.4 How to Exercise Rights
Contact our Privacy Officer:
Email: privacy@alrealremit.com
Mail: Privacy Officer, AL REAL TRADE AND INVESTMENT INC., 60-6440 Centre Street NE, Calgary, Alberta T2K 0VA
Phone: +1 (403) 768-9000 (request Privacy Officer)
11. Cookies & Tracking Technologies
11.1 Types of Cookies
We use:
Essential cookies: Required for service functionality
Performance cookies: For analytics and improvement
Functionality cookies: For personalized features
Advertising cookies: For targeted marketing (with consent)
11.2 Cookie Management
You can:
Adjust browser settings to refuse cookies
Use browser settings to delete cookies
Use our cookie preference center
Note that disabling cookies may affect service functionality
11.3 Third-Party Analytics
We use:
Google Analytics (anonymized data)
Security monitoring tools
Performance tracking systems
Fraud detection services
12. Children's Privacy
12.1 Age Restrictions
Our services are not directed to:
Individuals under 18 years of age
Minors without parental consent
Children under 13 (in compliance with COPPA)
12.2 No Collection
We do not knowingly collect information from children. If we discover such collection, we will delete it immediately.
13. Third-Party Links & Services
13.1 External Websites
Our services may contain links to:
Banking partners' websites
Regulatory authority sites
Service provider portals
Educational resources
13.2 No Responsibility
We are not responsible for:
Privacy practices of third-party sites
Content on external websites
Data collection by linked services
Security of third-party platforms
14. Changes to This Policy
14.1 Update Procedure
We may update this policy to:
Reflect changes in our practices
Comply with new legal requirements
Address new technologies
Improve clarity and transparency
14.2 Notification
We will notify you of material changes by:
Email to your registered address
Notice on our website
In-app notifications (where applicable)
Providing 30 days notice when possible
14.3 Review Dates
Last updated: 12-26-2025
Next scheduled review: 12-26-2026
15. Contact Information
15.1 Privacy Officer
15.2 Complaints
If you have privacy concerns:
Contact our Privacy Officer first
If unsatisfied, contact the Office of the Privacy Commissioner of Canada
Legal recourse may be available under applicable laws
15.3 Response Time
We will respond to privacy inquiries within:
30 days for access requests
10 business days for complaints
5 business days for general inquiries
16. Definitions
16.1 Key Terms
Personal Information: Information about an identifiable individual
Consent: Voluntary agreement to collection, use, or disclosure
FINTRAC: Financial Transactions and Reports Analysis Centre of Canada
MSB: Money Services Business
PIPEDA: Personal Information Protection and Electronic Documents Act
16.2 Regulatory References
Primary Legislation: PIPEDA, PCMLTFA
Provincial Laws: Alberta Personal Information Protection Act
Regulatory Guidelines: FINTRAC guidelines and directives
Industry Standards: Financial industry privacy best practices
17. Acknowledgment
By using AlrealRemit services, you acknowledge that:
You have read and understood this Privacy Policy
You consent to our collection, use, and disclosure practices
You understand your rights regarding your personal information
You accept our security measures and safeguards
You agree to our data retention practices
This Privacy Policy supplements our Terms of Service and Refund Policy. In case of conflict, the most protective provisions for your privacy shall apply.