Legal

Privacy Policy

Version 4 — 7 October 2026

IMPORTANT INFORMATION

This document is the privacy notice statement (“Privacy Policy”) of Capi Money Inc., the US holding company of a group of companies (the “Capi Money Group” or “Group”), which provide business-to-business financial services (“Capi Services”) through the website: www.capimoney.com (“Capi Website”).

In this Privacy Policy, “Capi Money,” “Capi,” “we,” “us,” or “our” refers to the Capi Money Group member responsible for your Personal Data. “You,” or “your” means any visitor to the Capi Website or any representative of a customer of Capi Money. “Personal Data” means any information which identifies you as an individual, such as your name, address, email, age and IP address.

This Privacy Policy sets out how we collect, store, use, share, and process Personal Data when you use Capi Services or the Capi Website and any Capi mobile sites, applications, or features. The Privacy Policy also describes the rights you have over your Personal Data. It is a global Privacy Policy, which means it applies to all Capi Money customer representatives and website users and their Personal Data in the jurisdictions presently serviced by Capi.

1. About Us

1.1. The Group member responsible for your Personal Data will depend on the country in which you receive Capi Services, access the Capi account created by a customer (“Capi Account”) as an authorised user of that account, or access the Capi Website. You will be notified when setting up an account with Capi which Group entity you have a relationship with when using Capi Services. Unless you originally signed up for a Capi Account from Canada or the United States, the UK entity will be the controller of your Personal Data.

Canada — Capi Money Canada Ltd

Incorporated Ontario, registration number 1000566594
Registered address Unit 807, 130 Spadina Avenue, Toronto, Ontario, M5V 2L4, Canada
Registered Money Services Business (MSB) in Canada with Financial Transactions and Reports Analysis Centre (FINTRAC), registration number M23576825
Data protection authority: Office of the Privacy Commissioner of Canada (OPC). For more detail, see www.priv.gc.ca/en/.

UK — Capi Money UK Ltd

Incorporated England and Wales, registration number 15031811.
Registered address 128 City Road, London, EC1V 2NX, UK
Authorised by the Financial Conduct Authority as an Electronic Money Institution under the Electronic Money Regulations 2011, firm reference number 1034536.
Data protection authority: Information Commissioner’s Office (ICO). For more detail, see www.ico.org.uk.

USA — Capi Money Inc.

Incorporated Delaware, registration number 7262022.
Registered address 1209 Orange Street, Wilmington, DE 19801, USA
Not presently providing Capi Services in the USA.
Data protection authority: Federal Trade Commission (FTC). For more detail, see www.ftc.gov.

Côte d’Ivoire — CPMY CIV SAS

Incorporated in Côte d’Ivoire, registration number RCCM CI-ABJ-03-2024-B17-00123
Registered address Abidjan 2 Plateaux - Cocody
Registered as an intermédiaire en opérations de banque (IOB)
Data protection authority: Autorité de régulation des télécommunications/TIC de Côte d’Ivoire (ARTCI). For more detail, see www.artci.ci.

1.2. In this Privacy Policy, we mention data protection laws. However, the specific law that applies to you will be the law applicable to the Capi Money Group member that delivers Capi Services to you.

2. Principles

2.1. We are dedicated to handling all Personal Data in a manner that is lawful, fair, and transparent.

2.2. We gather only the Personal Data that is relevant to and essential for our business operations.

2.3. Personal Data is utilized for enhancing customer service, developing new offerings, and improving our current products and services.

2.4. When sharing information with third parties, we include the necessary stipulations (including, where relevant, contractual terms) to protect the transferred Personal Data, complying with relevant laws.

2.5. Occasionally, we may have to reveal your Personal Data to government or judicial organizations, or to our regulators, as mandated by law.

2.6. We endeavor to keep your Personal Data accurate and current by taking reasonable steps in verifying and updating our records.

2.7. We secure the Personal Data within our custody or control by implementing suitable security measures, preventing any unauthorized access, collection, usage, disclosure, copying, alteration, or elimination of this information.

3. Types of Personal Data collected

3.1. We collect and process Personal Data that you provide to us directly or we may obtain from third parties or public sources. This section outlines the ways we collect and process that information.

3.2. We may collect and process the following types of Personal Data when you visit the Capi Website, use or access a Capi Account, use Capi Services to complete transactions, or contact and interact with us:

User information. Information about you, including personal identifiers (e.g., name, date of birth, citizenship, and more), contact details (e.g., address, email, or phone number), and for customer representatives, details about their relationship to the organization (e.g., roles, titles, and authorization at the organization).
Government-issued identification. Information from national ID cards, driver’s licenses, passports, visas, tax IDs, etc.
Communication history. Information about discussions, correspondence, or other interactions with us.
Digital footprint. Information related to your online activity and devices, like IP addresses, geolocation, device characteristics and settings, browser and operating system, web browsing history, social network data, and specifics about how and when you interact with our website, including cookie data.

3.3. Personal Data that we collect and process from other sources include:

Information from payment service providers. Information from our partners in countries covered by our remittance services, such as names associated with phone numbers.
Information from social media and public records. Information about users from publicly available social media accounts and records to conduct enhanced due diligence as part of anti-money laundering and sanctions compliance.

3.4. When providing Capi Services, we may in limited circumstances collect, handle, and store sensitive Personal Data, such as driver license identification, for legal compliance reasons (like anti-money laundering checks). Some jurisdictions categorize different types of information as sensitive. For example, for the purposes of UK data protection laws, we may collect and process the following types of sensitive Personal Data about you: biometric data, and information that may reveal political opinions and associations. All such sensitive Personal Data shall be appropriately protected under applicable data protection laws.

3.5. Given the nature of our foreign exchange and payment services, we may handle the Personal Data of individuals other than those of our customers’ organizations. For example, we may retain information about the beneficiaries of the payments made by our customers, including their authorized officers and representatives.

4. Age Requirement

4.1. Capi Money provides business-to-business financial services, which are not designed for, or directed to, anyone under the age of 18. By using Capi Services, the user represents that they are at least 18 years of age or older.

4.2 We do not knowingly collect Personal Data of minors. If we become aware of anyone using Capi Services, who may be under 18, we will take all reasonable steps to ensure their data is deleted and not processed any further and inform the user of the steps taken.

4.3. If you become aware of any data we may have collected from someone under 18 years of age, please contact Capi Customer Service.

5. Legal basis for using Personal Data

5.1. Under data protection legislation, we must have a valid legal reason for using your Personal Data.

5.2. We rely on the following legal bases to process your Personal Data:

Legal obligations. We may process your Personal Data where it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Legitimate interests. We may process your Personal Data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Consent. We may process your Personal Data where you have given us your permission (i.e., consent) to do so.

6. Purposes for which we collect your Personal Data

6.1. We process your user information for the purpose of facilitating access to a customer’s Capi Account, providing Capi Services, maintaining account and service integrity, and managing our relationship with our customers or potential customers.

6.2. We may use your user information, government-issued identification, and communication history to meet our legal obligations and to enforce our rights, including with respect to confirming your identity, complying with applicable law, establishing or responding to legal claims, and actioning data rights requests.

6.3. We may use your user information, government-issued identification and communication history to protect you and others against fraud and other illegal activity or to cooperate with law enforcement investigations. Your information helps us increase the safety of online payments, while reducing the risk of fraud, money laundering and other harmful activity. We will process this Personal Data in order to comply with our legal obligations, but also where we have a legitimate interest (e.g. to prevent fraud or to protect our business, where this is not a legal requirement).

6.4. We may also process your user information, government-issued identification, communication history, marketing and communications information and digital footprint where this is necessary for our legitimate interests, including:

Informing you of updates to Capi Services.
Managing and refining our operations and services, including troubleshooting, analysis, and research.
Responding to your inquiries and solving any potential issues you might have.
Offering you relevant products and services if you are an authorised representative of a Capi customer.
Enhancing software, services, or related products for your benefit.
Adhering to internal data disclosure or usage requirements within the Capi Money Group, including compliance programs related to sanctions, anti-money laundering, or the prevention of other illegal activities.
To use data analytics to improve the Capi Website, our products and services, marketing, customer relationships and experiences.
To ensure that the content and advertising delivered to you on the Capi Website is relevant.
Allowing certain third parties to present you with products or services that may be of interest.

6.5. You may be unable to create a Capi Account or access Capi Services as a representative on behalf of a customer if you do not provide Personal Data required by us.

7. Sharing Personal Data

7.1. In the course of providing Capi Services, we may share your Personal Data with third parties, including:

Our Group. We share Personal Data with members of the Capi Money Group to provide Capi Services, maintain account and service integrity, and support our business operations.
Service Providers. We will share your Personal Data with service providers we rely upon to provide Capi Services. This includes agents, contractors, and third-party service providers, who provide administrative, IT and system administration, technical, payment, identity verification, analytics or other services in connection with our business.
Payment institutions and beneficiaries. We also share Personal Data with the payment institution you use to make any foreign exchange or payment transactions and the beneficiaries of any payments you make through our payment service providers. When making a payment, the beneficiary may receive information about you along with your payment, such as your name and bank account number.
Legal authorities. We may share your Personal Data with government authorities, law enforcement, or courts to comply with legal requirements, where disclosure is necessary as a matter of applicable law or to exercise, establish, or defend our legal rights or those of our affiliates and service providers.
Professional advisors. We may share your Personal Data with our professional advisors, such as lawyers, accountants, and auditors.

7.2. In the event of any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company (or in negotiations to do so), we may share or transfer your Personal Data to that company or its representatives or advisors.

7.3. In all cases, we will ensure our agreements with third parties include requirements that they act in accordance with data protection legislation concerning your Personal Data.

8. International data transfers

8.1. As Capi Services are international in nature, we may have to transfer your Personal Data outside the country in which we collected your Personal Data to perform services, like processing payments and providing customer support.

8.2. Personal Data collected by us may be transferred, stored, and processed in other countries, including the United States. These countries’ data protection laws may differ from those in your location. For example, if you are based in the United Kingdom, other countries may not have as comprehensive data protection laws in place.

8.3. We will implement appropriate safeguards for these transfers and ensure adequate data protection measures are in place. For example:

If another country does not have equivalent data protection standards as your location, we will ensure agreements are in place with strict data protection safeguards before Personal Data is transferred (i.e., relying on the UK International Data Transfer Agreement or Addendum to the European Commission standard contractual clauses (“SCCs”), approved by the UK Information Commissioner’s Office). You can find the UK International Data Transfer Agreement here and the UK Addendum to the EU SCCs here.
Where data protection law otherwise permits us to transfer your Personal Data outside the country in which it was collected (e.g., where we can rely on transfer derogations under UK GDPR, such as where we have obtained your explicit consent, or where the transfer is necessary for us to perform a contract with you).

You can also contact us (using the details provided at Clause 20 below) if you would like to know more about how we transfer your personal data overseas.

9. Marketing

9.1. We may use your contact information to send you marketing updates about Capi Services, including via email, telephone, text, or other communication channel. This may include news, promotions, contests, and company or service updates.

9.2. You have the right to request that we do not process your Personal Data for marketing purposes. You may exercise this right at any time by clicking an unsubscribe link in emails sent from us or by contacting Capi Customer Service.

9.3. If you decide to stop receiving marketing communications, we will cease sending you such communications as soon as reasonably practicable and within a month of receiving your unsubscribe request. You can change your preferences anytime.

9.4. You will then be removed from the marketing lists. However, we may still communicate with you in certain circumstances. For example, we may still send you service-related messages that are necessary for the administration and use the Capi Account, to respond to customer service requests, or for other non-marketing purposes.

10. Cookies

10.1. We use cookies and other tracking technologies on the Capi Website and in emails we send you to help us:

Recall your details on the Capi Website;
Monitor your interaction with the Capi Website and Capi Services;
Personalize your online experience;
Assess the effectiveness of our services and communications; and
Improve Capi Services overall.

10.2. Most internet browsers are set to accept cookies by default. If you prefer, you may choose to set your browser to remove or reject cookies, but this may affect certain features or services. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy: http://www.capimoney.com/cookies.

11. Retention of Personal Data

11.1. If you are a customer representative, we will retain your Personal Data in line with our Customer Document Retention Policy for the length of any agreement with the customer to use Capi Services, or for five (5) years, whichever is longer. We may also retain your Personal Data as long as required by local laws (such as tax, accounting, or other legal requirements) and best practices or guidelines (as recommended by relevant authorities).

11.2. As a regulated financial institution, we are required to store some of your Personal Data beyond the termination of any agreement between us. In such circumstances, your information will be accessed only if essential and deleted when no longer required by any relevant law.

11.3. We will delete Personal Data requiring deletion either manually or automatically. If deletion is not possible, we shall anonymize it.

11.4. When deciding how long to keep your Personal Data, we think about how much and what kind of Personal Data we have, how sensitive it is, the risk of unauthorised use or disclosure, why we are

using your Personal Data, and if there is another way to achieve these purposes, as well as what legal and regulatory retention obligations we are subject to.

12. Amending your information

12.1. If you would like to review or change the information on the user profile of the Capi Account held by a customer, or to delete your profile, you can do so at any time by logging into the Capi Account and following the instructions therein. If you have any trouble accessing your Capi Account, you can contact Capi Customer service at support@capimoney.com.

12.2. Based on the laws applicable to you, you may have the right to request access to the Personal Data we collect from you, change that information, or delete it. For more information, refer to Clauses 15-18 of this Privacy Policy.

12.3. Upon a request to delete your profile, we will deactivate or delete (i) your profile on the Capi Account and (ii) information on our active databases. However, we may retain some information pursuant to our Privacy Policy to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

13. Automated decision-making

13.1. We may use automated decision-making (i.e. automated processes in which there is no human involvement) when you apply on behalf of a potential customer to open a Capi Account and when providing you with Capi Services, including for identity verification and fraud prevention. This processing may potentially lead to decisions being made in relation to you or the organization that you represent, including application rejection, transaction blocking, or account closure.

13.2. Automated decision-making in this context may include Know Your Customer (KYC) checks, including for example whether an individual is a match for applicable government sanctions lists.

13.3. If you are affected by such decision-making, you will be notified. You may also choose to appeal, which ensures manual review of any decision made using automated decision-making processes. If you believe you have been impacted by an automated process or wish to know more, please contact Capi Customer Service at support@capimoney.com.

14. Security of Personal Data

14.1. We implement appropriate and reasonable security measures, including physical, electronic, and procedural safeguards, to protect your Personal Data from unauthorized access. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be 100% guaranteed.

14.2. Although we will do our best to protect your information, transmission of personal information to and from us is at your own risk. Always be cautious and use good judgment when using digital technologies and making online payments.

15. Data protection rights

15.1. In some regions, like the United Kingdom, Canada, and some US states, you may have rights under data protection laws that gives you greater access to and control over your Personal Data.

15.2. Further information on data protection rights that might apply to you if you are in Canada, the United Kingdom, and certain US states are found in Clauses 16-18, respectively. You acknowledge that the rights summarized in these sections are illustrative and may not be exhaustive of your rights under applicable law.

16. Canada

16.1. In Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) governs how your Personal Data can be collected, used, and disclosed.

16.2. If you are based in Canada, you may have applicable rights including:

Right to be informed. This means knowing what Personal Data is collected about you, how it is used, and for what purpose. We rely on this Privacy Policy for the purpose of explaining this information.
Right to access data. This means being informed of the existence and use of your Personal Data as well as receiving a copy of the Personal Data held about you.
Right to rectification. This refers to having any incomplete or inaccurate information held about you corrected. We rely in part on the Capi Website, where you can update certain details we hold about you.
Right to objection. This means objecting to us processing your Personal Data where our legal basis for processing is consent.
Right to not be subject to automated decision-making. Subject to exceptions, this involves the right not to be subjected to decisions based solely on automated processing, including profiling that produces legal effects concerning you.

16.3. To request action on any of these rights in Canada, contact Capi Customer Service. Please note we may have to validate your identity before accessing your information.

17. United Kingdom

17.1. In the United Kingdom, data protection laws governing the use of your Personal Data include: the UK General Data Protection Regulation (UK GDPR), the UK Data Protection Act 2018 and the UK Privacy and Electronics Communication Regulations 2003.

17.2. If you are based in the United Kingdom, you may have the following rights:

Right to be informed. This means knowing what Personal Data we collect about you, how we use it, for what purpose and legal basis, who we share it with and how long we keep it. We rely on this Privacy Policy for the purpose of explaining this information.
Right to access data. This means receiving a copy of the Personal Data we hold about you.
Right to rectification. This refers to having any incomplete or inaccurate information held about you corrected. We rely in part on the Capi Website, where you can update certain details we hold about you.
Right to erasure. This means requesting us to delete your Personal Data if it is no longer necessary for the purpose for which it was collected or needed by us to meet our legal obligations.
Right to restrict processing. This involves requesting us to stop using your Personal Data.
Right to withdraw consent. This means you can withdraw your consent where we are relying on your consent to process your Personal Data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Right to objection. This means objecting to us processing your Personal Data. You have the right to object to the processing of your Personal Data if it is for marketing purposes. If we use your Personal Data on the basis of legitimate interests, and you object to such use, we will assess whether your rights outweigh our legitimate interests.
Right to portability. This means transferring Personal Data to you or another company, in a structured, commonly used and machine-readable format.
Right to challenge automated decision-making. This means that you can challenge and request a review of decisions based solely using automated decision-making, including profiling, which produces legal effects concerning you or similarly affects you.

16.3. If you would like to exercise any of these rights in the United Kingdom, contact Capi Customer Service. Please note we may have to validate your identity before accessing your information and responding to your request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

16.4 There may be circumstances where we cannot, or are entitled not to, respond to your request to exercise your rights above (e.g. where data protection law exempts us from compliance with your request). We will inform you of this, where relevant, at the time you make your request.

18. United States

18.1. In the United States, if you are a resident of one of the following states, local legislation governs the use of information that can be used to directly identify or linked to an individual consumer or household (“Personal Information”) as follows:

California: California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA)
Colorado: Colorado Privacy Act (CPA)
Connecticut: Senate Bill 6 for an Act Concerning Personal Data Privacy and Online Monitoring (CTDPA)
Utah: Senate Bill 227 for the Consumer Privacy Act (UCPA)
Virginia: Consumer Data Protection Act (CDPA)

18.2. If you live in any of the states outlined in Clause 18.1, you may have applicable rights including:

Right to be informed. This requires us to inform you about how we use your Personal Information. We rely on this Privacy Policy for the purpose of explaining this information.
Right to access. This means knowing if we are processing your Personal Information and receiving a copy of it if so. Under this right, you may also ask about the categories of Personal Information we hold about you, the sources from where it is collected, our purpose in collecting or sharing it, and the types of third parties we share it with.
Right to rectification. This means correcting inaccuracies in the Personal Information held about you considering its nature and our purpose of processing it.
Right to erasure. This means requesting us to delete your Personal Information if it is no longer necessary for the purpose for which it was collected or needed by us to meet our legal obligations or for a legitimate interest.
Right to data portability. This means transferring Personal Data to you or another company.
Right to opt-out. This involves opting out of the processing of your Personal Information for purposes of targeted advertising or the sale of Personal Information, except as permitted or required by law.
Right to “Do Not Sell My Personal Information.” This involves a right to opt out of the sale of your Personal Information. We do not sell Personal Information. We also do not knowingly sell or share Personal Information of anyone under sixteen (16) years of age.
Right to not be subject to automated decision-making. Subject to exceptions, this involves the right to opt out of your Personal Information being used for the purpose of profiling to reach solely automated decisions.

18.3. Additional data protection rights in California:

You have the right to request us to limit our use of the sensitive Personal Information to what is necessary for the reasonable performance of our services.
You also have the right to not be discriminated against because you exercise any of your other data protection rights.

18.4. Additional data protection rights in Virginia:

You have the right to appeal any decision by us not to grant your request to exercise a data protection right.

18.5. To request action on any data protection right you may have in some US states, contact Capi Customer Service. Please note we may have to validate your identity before accessing your information.

19. California Resident Privacy Notice

19.1. For individuals residing in California from whom we collect Personal Information as a business under the CCPA, the following table outlines the categories of Personal Information we may have collected, disclosed commercially, sold, or “shared” (for behavioral advertising purposes) in the past twelve (12) months.

A. Identifiers (e.g., name, email, telephone, IP address) — Collected: Yes; Disclosed: Yes; Sold/shared: Yes
B. Categories of Personal Information in the California Customer Records statute (e.g., name or phone) — Collected: Yes; Disclosed: Yes; Sold/shared: Yes
C. Protected classification characteristics under California or federal law (e.g., sex, gender identity) — Collected: No; Disclosed: N/A; Sold/shared: N/A
D. Commercial information (e.g., purchasing history or tendencies) — Collected: No; Disclosed: N/A; Sold/shared: N/A
E. Biometric information (e.g., fingerprints, voiceprints) — Collected: No; Disclosed: N/A; Sold/shared: N/A
F. Internet or other similar network activity (e.g., browsing history, search history, online behavior, interest data, and interactions with websites) — Collected: Yes; Disclosed: Yes; Sold/shared: No
G. Geolocation data (e.g., device location) — Collected: Yes; Disclosed: Yes; Sold/shared: No
H. Sensory information (e.g., audio, electronic, visual, thermal, olfactory or similar information) — Collected: No; Disclosed: N/A; Sold/shared: N/A
I. Professional or employment-related information (e.g., job title, company) — Collected: Yes; Disclosed: Yes; Sold/shared: No
J. Non-public education information (e.g., student records) — Collected: No; Disclosed: N/A; Sold/shared: N/A
K. Inferences drawn from personal information (e.g., consumer profile) — Collected: No; Disclosed: N/A; Sold/shared: N/A
L. Sensitive Personal Information (Identifiers) (e.g., financial account numbers, passwords, or login credentials) — Collected: Yes; Disclosed: Yes; Sold/shared: No
M. Sensitive Personal Information (Precise Geolocation) (e.g., specific physical location data) — Collected: No; Disclosed: N/A; Sold/shared: N/A
N. Sensitive Personal Information (Group Membership) (e.g., racial or religious groups) — Collected: No; Disclosed: N/A; Sold/shared: N/A
O. Sensitive Personal Information (Contents of Communications) — Collected: No; Disclosed: N/A; Sold/shared: N/A
P. Sensitive Personal Information (Genetic Data) — Collected: No; Disclosed: N/A; Sold/shared: N/A
Q. Sensitive Personal Information (Identifying Biometric Information) — Collected: No; Disclosed: N/A; Sold/shared: N/A
R. Sensitive Personal Information (Health Information) — Collected: No; Disclosed: N/A; Sold/shared: N/A
S. Sensitive Personal Information (Sex Life or Orientation) — Collected: No; Disclosed: N/A; Sold/shared: N/A

20. Capi Customer Service

20.1. You can contact Capi Customer Service at support@capimoney.com.

21. Concerns or complaints

21.1. If you have concerns or complaints regarding this Privacy Policy, you can contact us directly at Capi Customer Service, as set out in Clause 20.

21.2. If you are dissatisfied with our handling of your Personal Data or a related request, you can file a complaint as set out below:

Canada: You can contact the Office of the Privacy Commissioner at https://www.priv.gc.ca/en/.
UK: You can contact the UK Information Commissioner’s Office at https://ico.org.uk.
USA: You can file a complaint with your State or Territory’s Attorney General or the local regulator in a jurisdiction in which we operate.

21.3 We would appreciate the opportunity to resolve your complaint, so we would request that you please contact us in the first instance (i.e., before approaching one of the supervisory authorities listed above).

22. Updates to Privacy Policy

22.1. We may change this Privacy Policy from time to time to reflect changes in the law, best practice standards, the way we handle your Personal Data, or the nature of Capi Services.

22.2. Any change will be effected by posting a revised version of the Privacy Policy to the Capi Website. We encourage you to check the website occasionally to stay up to date.