What we collect, and why.

I. Who we are

Titan Exchange Group Inc. ("Titan", "we") is a corporate foreign-exchange and hedging desk based in Toronto, registered with FINTRAC as a money services business. This policy is written to meet the Personal Information Protection and Electronic Documents Act (PIPEDA). It applies to this website and to the personal information we handle in providing our services.

II. What we collect

• Through the forms on this site: your name, company, role, email address, phone number, the currencies you deal in, your approximate annual volume, your current bank if you tell us, and anything you write in the message field.
• When you become a client: the identification and corporate records the Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires us to obtain and keep, and the details needed to settle trades and payments.
• Automatically, when you visit: server logs kept by our hosting provider, including your IP address, browser and the pages requested, used to keep the site secure and running. We do not use advertising trackers and we do not set tracking cookies.

III. Why we collect it

To respond to your inquiry. To prepare a cost review you have asked for. To identify and onboard clients as the law requires. To execute and settle trades and payments. To keep the records the law requires. To keep this site secure. We do not sell personal information, and we do not use it for any other purpose without asking you first.

IV. Consent

By submitting a form on this site you consent to our using the information you provide to respond to you. Where we rely on your consent, you may withdraw it at any time by writing to us, subject to legal and contractual restrictions; withdrawing consent may mean we can no longer provide a service. Marketing email is sent only with your express consent, as Canada's Anti-Spam Legislation requires, and every such message carries a working unsubscribe link.

V. Who we share it with

Service providers that host this site and deliver our email process personal information on our behalf, under contract, and only to the extent needed to provide their service. Some operate outside Canada, including in the United States, where their systems are subject to local law. We disclose personal information to regulators and law enforcement when the law requires it, including reports to FINTRAC.

• Hosting: Vercel Inc. [confirm at launch]
• Transactional email: Resend Inc. [confirm at launch]
• Bot protection on the forms, when enabled: Cloudflare, Inc. (Turnstile), which receives connection and browser signals to tell people from automated traffic. [confirm at launch]

VI. How long we keep it

Inquiries that do not become client relationships are kept for up to twenty-four months and then deleted. Client identification and transaction records are kept for at least five years after the end of the relationship or the date of the transaction, as the Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires.

VII. How it is protected

Personal information is encrypted in transit, access is limited to the people who need it, and providers are chosen for their security practices. No method is perfect. If a breach creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as the law requires.

VIII. Your rights

You may ask what personal information we hold about you, ask us to correct it, and withdraw consent as described above. Write to the Privacy Officer at the email address below; we respond within thirty days. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada.

IX. Cookies

This site works without cookies, with one exception: when you use the language toggle, a cookie named lang remembers your choice so the right language opens on your next visit. It holds nothing else, expires after a year, and is not used for tracking or advertising. If we add analytics in future, it will be a service that does not use cookies or identify individual visitors, and this policy will say so.

X. Contact

Privacy Officer: [name to be confirmed]
Titan Exchange Group Inc.
Toronto, Ontario
steven@titanfx.ca

XI. Changes

We may update this policy. The date at the top is the date of the current version. Material changes will be noted here.

XII. Language

This policy is published in English and French. [Which version prevails in case of discrepancy: to be confirmed with counsel.]