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PRIVACY POLICY

KOURIAR’S PRIVACY POLICY

Introduction

This Privacy Policy applies to all services offered by The Dataseed Company Canada Limited (“Kouriar”, “we”, “us”, or “our”), including our international money remittance service between Canada and Nigeria.

By accessing or using any Kouriar service, you acknowledge that you have read and understood this Privacy Policy.

1. WHO WE ARE

1.1 Company Information

The Dataseed Company Canada Ltd. is a federally incorporated Canadian company providing international money remittance services.

Kouriar enables individuals in Canada to send funds to recipients in Nigeria in Naira equivalent from the initiation currency.

  • Registered as a Money Services Business (MSB) with FINTRAC.
  • Operates in compliance with the PCMLTFA and applicable Canadian regulations.

1.2 Contact Information

3302 Carding Mill Trail

Oakville, Ontario, Canada

L6M1S1

Email: help@kouriar.com

2. SCOPE AND APPLICATION

2.1 Applicable Laws

This Privacy Policy is designed to comply with applicable Canadian and Nigerian privacy and financial regulations.

  • PIPEDA
  • Breach of Security Safeguards Regulations (Canada)
  • Nigeria Data Protection Act (NDPA 2023)
  • PCMLTFA and FINTRAC regulations
  • FCAC consumer protection guidelines

2.2 Who This Policy Applies To

  • Canadian residents using Kouriar for remittance services.
  • Recipients in Nigeria receiving remittance payments.
  • Visitors to our website and mobile applications.
  • Any individual whose personal information we process.

2.3 What Is Not Covered

  • Third-party websites or services linked on our platform.
  • Aggregated or anonymized information that cannot identify you.
  • Business contact information used professionally.

3. PERSONAL INFORMATION WE COLLECT

3.1 Identity Information

  • Full legal name
  • Date of birth
  • Government-issued identification
  • Nationality and country of residence
  • Photographs or selfies for verification

3.2 Contact Information

  • Email address
  • Mobile phone number
  • Residential address

3.3 Financial Information

  • Bank account details
  • Debit and credit card information
  • Transaction history
  • Beneficiary banking information
  • Source of funds declarations where required

We do not collect or store online banking passwords or security questions.

3.4 Compliance Information

  • PEP and HIO status assessments
  • Sanctions screening records
  • AML and FINTRAC compliance records
  • Beneficial ownership information

3.5 Technical Information

  • IP address
  • Device and browser information
  • Login and activity logs
  • Cookies and tracking technologies

4. HOW WE COLLECT INFORMATION

4.1 Directly From You

  • When creating an account
  • When completing transactions
  • When uploading verification documents
  • When contacting customer support
  • When responding to surveys or feedback forms

4.2 Automatically Through Our Platform

  • Cookies and analytics technologies
  • Server logs and activity tracking
  • Website and mobile application interactions

4.3 From Third Parties

  • Identity verification providers
  • Fraud and sanctions screening services
  • Payment partners and banks
  • Regulatory authorities where required by law

5. HOW WE USE YOUR INFORMATION

5.1 Service Purposes

  • Processing money transfers
  • Identity verification
  • Fraud prevention and AML compliance
  • Generating FINTRAC-required reports
  • Account management and recovery
  • Transaction notifications and dispute resolution

5.2 Business Purposes

  • Improving our products and services
  • Internal audits and risk management
  • Tax and legal compliance
  • Customer communications
  • Sending marketing communications with your consent

5.3 Legal Basis for Processing

We process personal information based on consent, contractual necessity, legal obligations, and legitimate business interests.

6. DISCLOSURE OF INFORMATION

6.1 Service Providers

  • Identity verification providers
  • Banking and payment partners
  • Cloud hosting providers
  • Cybersecurity and fraud prevention vendors
  • Legal and accounting professionals

6.2 Regulatory Authorities

  • FINTRAC
  • Canada Revenue Agency (CRA)
  • FCAC and other regulators
  • Courts and law enforcement agencies
  • Nigeria Data Protection Commission (NDPC)

6.3 Business Transfers

In the event of a merger, acquisition, or restructuring, personal information may be transferred as part of the transaction.

7. INTERNATIONAL DATA TRANSFERS

7.1 Canada to Nigeria Transfers

Kouriar’s services require the transfer of personal information between Canada and Nigeria.

  • We use contractual safeguards to protect transferred data.
  • Only the minimum necessary information is transferred.
  • International partners undergo due diligence reviews.

7.2 Nigerian Data Protection

Nigerian recipient data is processed in compliance with the NDPA 2023 and applicable NDPC directives.

8. DATA RETENTION

8.1 Retention Periods

  • AML and FINTRAC records: minimum 5 years
  • KYC records: 5 years after relationship ends
  • Security logs: 2 years
  • Complaint and support records: 5 years
  • Breach records: minimum 24 months

Information no longer required is securely deleted or anonymized.

9. YOUR PRIVACY RIGHTS

9.1 Rights Under PIPEDA

  • Right of access
  • Right to correction
  • Right to withdraw consent
  • Right to make a complaint

9.2 Rights Under NDPA 2023

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to object
  • Right to data portability
  • Right to restriction
  • Right against solely automated decision-making

9.3 Exercising Your Rights

To exercise your privacy rights, contact:

Email: help@kouriar.com

10. CONSENT

10.1 Obtaining Consent

We obtain consent before collecting personal information except where otherwise permitted or required by law.

10.2 Marketing Consent

Marketing communications are sent only with your express opt-in consent in compliance with CASL.

10.3 Withdrawal of Consent

You may withdraw consent for non-essential processing at any time.

11. DATA SECURITY

11.1 Security Measures

  • AES-256 encryption at rest
  • TLS encryption in transit
  • Multi-factor authentication
  • Role-based access controls
  • Security audits and penetration testing
  • Employee privacy training
  • Vendor security obligations

12. DATA BREACH NOTIFICATION

12.1 Breach Notifications

Where required by law, we will notify affected users and regulators of breaches involving a real risk of significant harm.

12.2 Breach Information

  • Description of the breach
  • Information affected
  • Actions taken by Kouriar
  • Protective steps for users

13. COOKIES AND TRACKING

13.1 Cookies We Use

  • Strictly necessary cookies
  • Analytics cookies
  • Functional cookies
  • Marketing cookies

13.2 Managing Preferences

Users may manage cookie preferences through browser settings or our Cookie Preference Centre.

14. AML & COUNTER-TERRORIST FINANCING

14.1 AML Obligations

  • Identity verification
  • Transaction monitoring
  • FINTRAC reporting
  • Sanctions screening
  • Risk assessments

15. CHILDREN’S PRIVACY

15.1 Age Restrictions

Kouriar services are not intended for individuals under 18 years of age.

16. CHANGES TO THIS POLICY

16.1 Updates

We may update this Privacy Policy periodically to reflect legal, operational, or regulatory changes.

17. GOVERNING LAW

17.1 Applicable Law

This Privacy Policy is governed by the laws of Canada and applicable Nigerian data protection legislation where relevant.

18. CONTACT US

18.1 Privacy Contact Information

Email: help@kouriar.com

Website: www.kouriar.com

Security: help@kouriar.com

18.2 External Regulators

  • Office of the Privacy Commissioner of Canada (OPC)
  • Nigeria Data Protection Commission (NDPC)
  • Financial Consumer Agency of Canada (FCAC)
  • FINTRAC