Last updated on September 10, 2026
1. Introduction
This Privacy Policy (hereinafter – “Policy”) describes how Varixon Inc., a company incorporated under the laws of Alberta, Canada, with its registered address at 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada and Corporate Access Number 2028407035 (hereinafter – “Company”, “We”, “Our” or “Us”), collects, uses, discloses, stores, protects and otherwise processes Personal Information in connection with the Company’s website (hereinafter – “Website”) and the provision of its over-the-counter virtual currency exchange services (hereinafter – “OTC Services”).
The Policy applies to Personal Information collected through the Website, in connection with the OTC Services, and through other communications or interactions with the Company.
Use of the Website, use or request of the OTC Services, or other interaction with the Company constitutes acknowledgement that this Policy has been made available and should be reviewed before Personal Information is provided.
This Policy should be read together with the Company’s Terms of Use, Cookie Policy, and any other applicable legal notices or policies made available on the Website.
2. Scope
This Policy applies to the collection, use, disclosure, retention and protection of Personal Information by the Company.
For the purposes of this Policy, “Personal Information” means information about an identifiable individual, as understood under applicable Canadian federal and provincial privacy legislation.
The Company processes Personal Information in accordance with applicable Canadian privacy laws, including, where applicable, the Personal Information Protection Act (Alberta) (hereinafter – “PIPA”) and the Personal Information Protection and Electronic Documents Act (hereinafter – “PIPEDA”).
3. Accountability
The Company is responsible for Personal Information under its control or in its custody and has designated an individual responsible for overseeing the Company’s compliance with applicable privacy requirements.
Reasonable steps are taken to ensure that Personal Information is accurate, complete and up to date as necessary for the purposes for which it is used.
The Company maintains policies and procedures designed to protect Personal Information, address privacy-related inquiries and complaints, and ensure that personnel and other individuals acting on behalf of the Company are informed of their privacy responsibilities.
Where Personal Information is transferred to a third-party for processing, the Company remains responsible for such Personal Information and takes appropriate contractual or other measures to require the third-party to provide a level of protection comparable to that required by applicable privacy legislation.
4. Information We Collect
The Company collects Personal Information that is necessary to provide the OTC Services, meet legal and regulatory requirements, and prevent fraud, financial crime and other misuse. The categories of Personal Information We may collect are set out below.
4.1 Personal Information
- name, date of birth, address, occupation or nature of principal business, and government-issued identification;
- email address, telephone number and other contact details;
- information concerning legal entities, including registration details, directors, officers, beneficial owners and authorised representatives, where applicable;
- bank account and payment information, source of funds and source of wealth information, where required;
- nature of business, intended use of the OTC Services and other information relevant to the business relationship;
- information required for client identification and verification, sanctions and politically exposed persons / heads of international organisations screening, transaction monitoring and other compliance purposes; and
- information contained in correspondence, inquiries, support requests and other communications with the Company.
4.2 Transaction Information
- transaction type, date, time, amount and status;
- funds and virtual currencies involved in the transaction;
- payment and receipt methods;
- exchange rates and applicable fees;
- account information and transaction reference numbers;
- wallet addresses and other transaction identifiers, including sending and receiving addresses and transaction hashes; and
- bank account details and payment references relating to fiat settlements.
4.3 Technical Information
The Company may automatically collect technical information necessary to operate and secure the Website, including IP address, browser and device information, access logs and information collected through strictly necessary cookies and similar technologies, as further described in the Cookie Policy.
4.4 Information from Third Parties
The Company may receive Personal Information from third-party verification, screening, compliance, blockchain analytics, payment, liquidity, infrastructure and communication service providers, where necessary for identity verification, anti-money laundering and anti-terrorist financing (hereinafter – “AML/ATF”), and sanctions screening, fraud prevention, transaction execution, security, record-keeping, dispute handling or compliance with applicable laws.
The Company limits the collection of Personal Information to that which is necessary for the purposes identified in this Policy. Personal Information is collected by fair and lawful means.
5. Purposes of Collection and Use
The Company identifies the purposes for which Personal Information is collected at or before the time of collection. The purposes for which Personal Information is collected should be clear and readily explainable. The Company collects and uses Personal Information for the following purposes:
- to provide and administer the OTC Services, process, execute and settle transactions, manage client relationships and facilitate settlements;
- to identify and verify individuals and entities, conduct conduct Know Your Customer (hereinafter – “KYC”) and Know Your Business (hereinafter – “KYB”) procedures procedures, verify authority, ownership and control, sanctions and politically exposed persons / heads of international organisations screening, and perform ongoing due diligence;
- to monitor transactions and activities for suspicious, unusual or potentially unlawful activity and to prevent financial crime;
- to assess eligibility to use the OTC Services and apply applicable jurisdictional, sanctions, regulatory and risk-based restrictions;
- to assess source of funds, source of wealth, business activity and transaction purpose, where required;
- to detect, prevent and investigate fraud, unauthorised access and other security or cybersecurity incidents;
- to communicate regarding the OTC Services, transactions, account-related matters, policy updates and inquiries;
- to create and maintain records required under applicable laws and regulations;
- to manage complaints, disputes, investigations and legal claims;
- to comply with applicable legal and regulatory requirements, respond to lawful requests from competent authorities, and establish, exercise or defend legal claims; and
- to maintain, analyse and improve the Website, OTC Services and related systems, where permitted by applicable law.
6. Consent
The knowledge and consent of the individual are required for the collection, use or disclosure of Personal Information. In certain circumstances, Personal Information may be collected, used or disclosed without the knowledge and consent of the individual where permitted or required by applicable law.
The form of consent may vary depending on the circumstances and the sensitivity of the Personal Information. Where required by applicable law, express consent will be obtained.
An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The Company will inform the individual of the implications of such withdrawal, which may limit or prevent the provision of the OTC Services.
7. Disclosure of Personal Information
The Company may disclose Personal Information to third parties where necessary to provide the OTC Services or comply with applicable law, including:
- KYC/KYB, identity verification, sanctions, politically exposed persons, heads of international organisations, adverse media, fraud prevention and risk-screening providers;
- blockchain analytics, Know Your Transaction (hereinafter – “KYT”) and transaction monitoring providers;
- payment, banking, settlement, exchange, liquidity and other operational counterparties;
- hosting, cloud, IT, cybersecurity, maintenance and infrastructure providers;
- professional advisers, including legal counsel, auditors, tax advisers and compliance consultants;
- affiliates or group companies, where applicable and necessary for internal administration, compliance, risk management or service support; and
- regulators, law enforcement agencies, courts and other public authorities where required or permitted by law.
8. Cross-Border Processing and Service Providers
Personal Information may be transferred to, accessed, processed or stored by service providers located outside Canada. In such circumstances, Personal Information may be subject to the laws of the jurisdiction in which the relevant service provider operates and may be accessible to courts, law enforcement, regulators or other authorities in that jurisdiction where required by law.
The Company takes reasonable contractual, technical and organisational measures appropriate to the nature of the processing and remains responsible for Personal Information under its control as required by applicable privacy law.
Individuals may obtain information about the Company’s policies and practices relating to service providers located outside Canada, including information regarding the countries or jurisdictions in which such service providers may process Personal Information and the purposes for which they are authorised to process it, by contacting the person responsible for the Company’s privacy compliance using the contact details set out in Section 16.
9. Safeguards and Information Security
The Company applies technical, organisational, and physical safeguards to protect Personal Information against unauthorised access, loss, misuse, alteration, or disclosure. These security measures include:
- restricting access to authorised persons on a need-to-know basis;
- maintaining appropriate security measures and monitoring access;
- requiring third-party service providers to maintain appropriate safeguards;
- maintaining confidentiality and privacy practices; and
- securely deleting or anonymising information when no longer required.
While the Company takes reasonable and appropriate measures to protect Personal Information, no method of transmission over the Internet or electronic storage system is completely secure. Individuals are responsible for taking appropriate preventive measures, in particular for ensuring the security of their own devices, protecting their login details and avoiding the transmission of confidential information via unsecured channels.
10. Children and Minors
The OTC Services are not intended for children or individuals who are unable to provide meaningful consent. If the Company becomes aware that Personal Information has been collected without the required consent, it will take reasonable steps to address the situation in accordance with applicable law.
11. Rights
Subject to applicable law, individuals hold the following rights:
- the right of access to Personal Information held by the Company and information about its use and disclosure;
- the right to correction of Personal Information that is inaccurate or incomplete;
- the right to withdraw consent to the collection, use, or disclosure of Personal Information;
- the right to raise a privacy-related inquiry or complaint with the Company and, where applicable, submit a complaint to the Office of the Information and Privacy Commissioner of Alberta or the Office of the Privacy Commissioner of Canada;
- the right to raise a privacy-related inquiry or complaint with the Company regarding the handling of Personal Information, and, if the matter is not resolved, submit a complaint to the Office of the Privacy Commissioner of Canada.
Requests for access, correction, or withdrawal of consent must be made in writing using the contact details provided in this Policy.
The Company will assist individuals in preparing an access request where assistance is required and will respond to an access request within thirty (30) days, subject to any applicable extension or limitation permitted by law.
An access request is generally provided at minimal or no cost. If an exceptional fee applies, the Company will inform the individual of the approximate cost prior to processing, and proceed only upon confirmation.
The Company may require sufficient information to verify the identity of the individual making the request. Where access is refused, the Company will provide the reasons for the refusal and information about available recourse, as required by applicable law.
12. Breach Notification and Incident Management
The Company maintains procedures to identify, assess and respond to incidents involving Personal Information.
Where a breach involving Personal Information gives rise to a notification or reporting obligation under applicable privacy law, the Company will notify the competent privacy authority and affected individuals as required by law. This may include notification to the Office of the Information and Privacy Commissioner of Alberta or the Office of the Privacy Commissioner of Canada, as applicable.
Records of security breaches involving Personal Information will be maintained as required by law, and reasonable steps will be taken to reduce the risk of harm and prevent recurrence.
13. Third-party Links and Integrations
The Website or OTC Services may contain links to or integrations with third-party websites, applications, platforms, or tools, including payment processors, verification partners, liquidity providers, and infrastructure services.
These third parties operate independently and are governed by their own privacy policies, terms of service, and security standards. The Company is not responsible for the privacy practices, content, or security measures of such external parties. Individuals are encouraged to review the privacy policies and relevant legal terms of any third-party services they access or use through links or integrations provided by the Company.
14. Retention
The Company retains Personal Information only for as long as necessary to fulfill the purposes for which it was collected or to comply with applicable statutory requirements.
- identification, KYC/KYB, beneficial ownership, transaction, AML/ATF, reporting and other compliance records are retained for the statutory retention periods applicable to the relevant category of record, which may generally include periods of at least five (5) years under applicable Canadian AML/ATF requirements;
- technical, security, and Website logs are retained as long as needed for fraud prevention and system integrity;
- correspondence, inquiries, and support records are kept for the duration of the business relationship and a reasonable period thereafter;
- legal and dispute files are retained for the duration of the applicable statutory limitation periods.
When retention periods expire, Personal Information is securely destroyed, erased, or anonymized.
15. Changes to this Policy
The Company reserves the right to modify or update this Policy at any time to reflect operational, legal, or regulatory changes.
When updates occur, We will publish the revised Policy on the Website and update the “Last updated” date. Where changes are material, we will provide appropriate notice via email, the Website, or the OTC Services interface, and obtain Your express consent where required by applicable law.
16. Contact Us
Inquiries, access or correction requests, and questions concerning the handling of Personal Information should be addressed to:
- Company name: Varixon Inc.
- Registered address: 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada
- Email: varixon.financial@gmail.com