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Privacy Policy
Information We Collect
Personal Identification
We collect your full legal name, date of birth, government-issued ID numbers, and residential address as required by FINTRAC regulations and Canadian AML/CTF legislation.
Contact Information
Email address, phone number, and mailing address are collected to facilitate your account, transaction notifications, and regulatory correspondence.
Financial Information
Bank account details, transaction history, transfer amounts, and source of funds declarations are retained for compliance and service delivery purposes.
Device & Usage Data
IP address, browser type, device identifiers, and interaction logs help us secure your account and improve our platform experience.
How We Use Your Data
Service Delivery
Your data powers the core remittance service — processing transfers, verifying recipients, and confirming delivery to destinations across Africa and the Middle East.
Regulatory Compliance
As a FINTRAC-registered MSB, we are legally obligated to perform KYC verification, monitor transactions for suspicious activity, and maintain records for up to 7 years.
Security & Fraud Prevention
We analyze transaction patterns and device data to detect and prevent unauthorized access, money laundering, and fraudulent transfers.
Communications
Transaction confirmations, security alerts, and service updates are sent to your registered contact details. Marketing communications require your explicit consent.
Data Sharing & Disclosure
Partner Institutions
To complete your transfer, we share necessary recipient and transaction data with our banking partners, correspondent agents, and mobile wallet providers in destination countries.
Regulatory Authorities
We may disclose information to FINTRAC, CRA, law enforcement, or other regulatory bodies when required by Canadian law or court order.
Service Providers
Vetted third-party processors (payment gateways, KYC verification services, cloud infrastructure) access only the minimum data required to perform their functions.
No Sale of Data
We do not sell, rent, or trade your personal information to advertisers, data brokers, or any third party for commercial purposes. Your data is not a product.
Your Rights & Controls
Access & Portability
You may request a complete copy of all personal data we hold about you at any time. We will provide this in a machine-readable format within 30 days of your verified request.
Correction & Deletion
You have the right to correct inaccurate data and request deletion of your account. Note that regulatory retention obligations may require us to retain certain records.
Opt-Out Rights
You may opt out of marketing communications at any time via your account settings or by contacting support. Transactional and compliance communications cannot be disabled.
Complaint Rights
If you believe your privacy rights have been violated, you may lodge a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.
Security Measures
Encryption
All data in transit is protected by TLS 1.3 encryption. Sensitive data at rest is encrypted using AES-256. Database access is strictly controlled and audited.
Access Controls
Employee access to customer data follows the principle of least privilege. Multi-factor authentication is mandatory for all internal systems accessing personal information.
Incident Response
In the event of a data breach affecting your rights, we will notify you and the Privacy Commissioner within 72 hours, as required under PIPEDA.
Data Retention
Retention Periods
Transaction records and KYC documentation are retained for a minimum of 7 years following the last transaction, as mandated by FINTRAC and PCMLTFA.
Account Closure
Upon account closure, we delete non-mandatory personal data within 90 days. Regulatory records are retained for the legally required period before secure deletion.
Automated Deletion
Systems are in place to automatically flag and delete data that has exceeded its required retention period, subject to any active legal holds or investigations.
Cookies & Tracking
Essential Cookies
Session authentication, CSRF protection, and user preference cookies are strictly necessary for the platform to function. These cannot be disabled.
Analytics Cookies
We use privacy-respecting analytics to understand how our platform is used. These cookies are anonymized and do not track you across other websites.
Managing Cookies
You can control non-essential cookies through your browser settings or our cookie preference centre, accessible from the footer of every page.
Questions about this policy?
Contact our Privacy Officer at privacy@sudanicash.com or write to AL REAL TRADE AND INVESTMENT INC., Toronto, Ontario, Canada.
This policy is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. SudaniCash is a service of AL REAL TRADE AND INVESTMENT INC., a Money Services Business registered with FINTRAC under registration number C10000108.
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