PRIVACY POLICY

HELPEX PAY LTD.

Last Updated: 7 November 2026

Legal entity

Helpex Pay Ltd.

Company number

BC1594027

FINTRAC MSB registration

N300001747

Registered address

2120-580 Seaborne Avenue, Port Coquitlam, British Columbia, Canada, V3B 0M3

This Privacy Policy explains how Helpex Pay Ltd. ("Helpex", "we", "us" or "our") collects, uses, discloses, stores and protects personal information when you visit https://helpex.exchange (the "Website"), communicate with us or use our exchange-related services (the "Services").

1. WHO WE ARE AND PRIVACY RESPONSIBILITY

Helpex Pay Ltd. is a company registered in British Columbia, Canada, and registered as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under registration number N300001747, where applicable to its regulated activities. FINTRAC registration is not a banking licence, securities registration, government endorsement or guarantee.

For privacy-related questions and requests, Helpex has designated a Privacy Officer responsible for overseeing the Company's privacy practices and responding to inquiries.

Privacy Officer, Helpex Pay Ltd.

Email: help@helpex.exchange (please use the subject line “Privacy Request”)

Address: 2120-580 Seaborne Avenue, Port Coquitlam, British Columbia, Canada, V3B 0M3

Depending on the nature of the activity and the location of the individual, our handling of personal information may be governed by British Columbia's Personal Information Protection Act (BC PIPA), Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable privacy laws.

2. PERSONAL INFORMATION WE COLLECT

The information we collect depends on how you interact with Helpex, the services requested, the applicable legal requirements and the risk profile of the transaction. It may include:

• Identity and contact information: full name, date of birth, residential address, email address, telephone number, nationality and country of residence.
• Identity verification information: copies or images of identity documents, document details, photographs, selfies, liveness-check information and, where enabled by the verification process, biometric or biometric-derived information.
• Business and ownership information: company name, registration details, business address, directors, beneficial owners, representatives, ownership and control information, and authority to act for an entity.
• Financial and payment information: bank account details, payment references, source-of-funds or source-of-wealth information where required, payment status, transaction amounts, currencies and related records.
• Virtual currency and blockchain information: wallet addresses, transaction identifiers, public blockchain data, asset and network details, transaction history and risk indicators associated with blockchain activity.
• Compliance information: information relevant to identity checks, sanctions and politically exposed person screening, fraud prevention, anti-money laundering and counter-terrorist financing controls, and the assessment of unusual or potentially prohibited activity.
• Technical and usage information: IP address, device and browser information, operating system, approximate location derived from technical data, access logs, timestamps, pages viewed, referral information and cookie identifiers.
• Communications: information contained in emails, support requests, complaints, feedback and other communications with Helpex.
• Other information: information you provide to us or that is lawfully obtained from third-party sources for the purposes described in this Policy.

We do not intentionally request personal information that is not reasonably necessary for the relevant purpose. Please do not send us sensitive information unless it is requested through an appropriate channel or is necessary to resolve your request.

3. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

• directly from you when you visit the Website, create or submit an Order, complete an onboarding or verification process, make a payment, or contact us;
• automatically through the Website, server logs, cookies and similar technologies, subject to applicable law and your browser or device settings;
• from identity verification, screening, fraud prevention and compliance service providers engaged to support our Services;
• from banks, payment institutions, liquidity providers, counterparties and other service providers involved in processing or settling an Order;
• from public and lawfully accessible sources, including corporate registers, sanctions lists, regulatory publications and public blockchain networks; and
• from government, law enforcement, regulatory or other competent authorities where permitted or required by law.

4. WHY WE USE PERSONAL INFORMATION

We use personal information for purposes that are reasonable and appropriate in the circumstances, including to:

• provide, administer and support the Services and process Customer Orders;
• confirm identity, verify documents, assess eligibility and establish or maintain a business relationship;
• process payments and exchange transactions, communicate transaction status and resolve operational issues;
• meet legal and regulatory obligations, including applicable AML/CTF, sanctions, recordkeeping and reporting requirements;
• detect, prevent and investigate fraud, account misuse, financial crime, security incidents and prohibited activity;
• assess blockchain transaction exposure and relevant wallet or transaction risk;
• protect the Website, our systems, customers, employees and business operations;
• respond to inquiries, complaints, access requests and other communications;
• maintain business records, manage disputes, enforce our agreements and establish, exercise or defend legal claims;
• improve the reliability, security and performance of the Website and Services; and
• send service-related notices and, where permitted, marketing communications in accordance with applicable law.

5. LEGAL BASIS, CONSENT AND CHOICE

Where applicable privacy law requires consent, we will seek meaningful consent for the collection, use or disclosure of personal information. Depending on the sensitivity of the information and the circumstances, consent may be express or implied where permitted by law.

Some collection, use or disclosure may occur without consent where permitted or required by applicable law, including for regulatory compliance, fraud prevention, investigations, legal proceedings or disclosures to competent authorities.

You may withdraw consent where consent is the basis for a particular activity, subject to legal or contractual restrictions and reasonable notice. Withdrawal may mean that Helpex cannot provide or continue to provide some or all of the Services, complete an Order, or maintain a business relationship where the information is necessary for that purpose or required by law.

6. IDENTITY VERIFICATION AND COMPLIANCE CHECKS

Helpex may use third-party identity verification and compliance service providers to collect, verify and assess identity information and supporting documents. These providers may process identity document images, photographs, liveness information, business details and related verification results on our behalf or in accordance with their own applicable obligations.

We may also use screening and compliance service providers to assist with sanctions, politically exposed person, adverse media, fraud and other legally relevant checks. We may receive verification results, alerts, risk indicators or recommendations and use them together with other information to make decisions about onboarding, Orders or continued access to the Services.

We do not disclose our internal compliance rules, monitoring thresholds, detection logic or investigative methods in this public Policy. We may be restricted by law from explaining whether a report has been made or disclosing certain details of a compliance review.

7. BLOCKCHAIN ANALYTICS AND VIRTUAL CURRENCY TRANSACTIONS

Because the Services may involve virtual currency, Helpex may process public blockchain information, including wallet addresses, transaction hashes, transaction amounts, asset types, network data and information about the apparent source or destination of virtual currency.

We may use specialist blockchain analytics and transaction monitoring providers to assess wallet and transaction exposure, identify potential links to sanctioned persons or prohibited activity, detect suspicious patterns and support legal and regulatory compliance.

Public blockchain information may be visible to anyone and may remain permanently accessible on the relevant blockchain. Helpex cannot delete or alter information recorded on a public blockchain. We may associate public blockchain data with a Customer or Order where reasonably necessary for the purposes described in this Policy.

8. COOKIES AND SIMILAR TECHNOLOGIES

The Website may use cookies, pixels, local storage and similar technologies to enable essential functionality, maintain security, remember preferences, understand Website usage and improve performance. Where analytics or other non-essential technologies are used, they will be deployed in accordance with applicable consent requirements.

You can manage or block cookies through your browser settings. Disabling certain cookies may affect the availability or functionality of parts of the Website. If Helpex introduces analytics, advertising or other optional tracking tools, the relevant information and consent controls will be provided where required.

9. WHEN WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information, to the extent reasonably necessary and permitted by law, to the following categories of recipients:

• identity verification, KYC, screening and compliance service providers;
• blockchain analytics, virtual currency risk assessment and transaction monitoring providers;
• banks, payment processors, payment institutions, liquidity providers and counterparties involved in an Order;
• technology, hosting, cloud storage, cybersecurity, communications and customer support providers;
• professional advisers, including legal, accounting, audit and compliance advisers;
• our affiliates, where applicable and where disclosure is permitted for the purposes described in this Policy;
• government agencies, regulators, law enforcement bodies, courts and other competent authorities where disclosure is required or permitted by law; and
• a purchaser, successor or other relevant party in connection with a corporate transaction, subject to appropriate confidentiality and legal safeguards.

We do not sell personal information to third parties for money. We do not authorize service providers to use personal information for their own unrelated purposes. Where a provider processes information on our behalf, we use contractual or other appropriate measures designed to protect the information and limit its use.

10. INTERNATIONAL PROCESSING AND CROSS-BORDER TRANSFERS

Helpex and its service providers may process or store personal information in Canada and in other countries where our service providers, banks, payment partners or technical infrastructure operate. As a result, personal information may be subject to the laws of those jurisdictions and may be accessible to courts, regulators or law enforcement authorities in accordance with local law.

Where personal information is transferred to a service provider for processing, Helpex remains responsible for personal information under its control and takes reasonable contractual, organizational or other measures designed to provide an appropriate level of protection, as required by applicable law.

11. RETENTION AND DELETION

We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, to administer the Services, to resolve disputes, to enforce agreements and to meet legal, regulatory, accounting, audit, security and recordkeeping requirements.

Certain identity, transaction, payment and compliance records may need to be retained for periods prescribed by applicable AML/CTF and other laws, including after a Customer stops using the Services or requests account closure. We may also retain information where necessary to establish, exercise or defend legal claims or to preserve evidence of a transaction.

When personal information is no longer required for a legitimate purpose or legal obligation, we will take reasonable steps to securely delete it, destroy it or irreversibly de-identify it, subject to technical limitations and applicable law. Backup copies may remain for a limited period as part of routine backup and disaster recovery processes.

12. SECURITY AND PRIVACY INCIDENTS

Helpex uses reasonable administrative, technical and physical safeguards designed to protect personal information against unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Safeguards may include access controls, authentication, encryption where appropriate, staff confidentiality obligations, provider due diligence and security monitoring.

No website, electronic transmission or storage system can be guaranteed to be completely secure. Customers should use secure devices and protect their email, account credentials and payment information.

If a privacy breach occurs, Helpex will assess and respond to it in accordance with applicable law, including making required reports to regulators and notifications to affected individuals where the applicable legal threshold is met.

13. YOUR PRIVACY RIGHTS

Subject to applicable law and its exceptions, you may have the right to:

• request access to personal information about you that is in Helpex's custody or under its control;
• request information about how your personal information has been used and to whom it has been disclosed, as provided by applicable law;
• request correction of personal information that is inaccurate or incomplete;
• withdraw consent for processing activities that rely on consent, subject to legal and contractual restrictions;
• raise a concern or complaint about how Helpex handles personal information; and
• exercise any additional rights available under privacy laws that apply to you.

These rights are not absolute. We may be permitted or required to withhold information, restrict access or retain information where an exception or legal obligation applies, including in connection with investigations, legal privilege, regulatory requirements or the rights of others.

14. HOW TO MAKE A PRIVACY REQUEST OR COMPLAINT

To make a privacy request or complaint, contact our Privacy Officer at help@helpex.exchange and use the subject line “Privacy Request”. Please describe the information or issue as clearly as possible. We may need to verify your identity and ask for additional details before responding.

Helpex will review and respond to requests within the time limits required by applicable law. If we cannot provide access or make a requested correction, we will explain the reasons to the extent permitted by law and, where appropriate, record the correction request with the information.

If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner for British Columbia or the Office of the Privacy Commissioner of Canada, as applicable to your circumstances.

15. MARKETING AND SERVICE COMMUNICATIONS

We may send communications necessary to provide the Services, including Order confirmations, verification requests, security alerts, service updates and important changes to our terms or policies. These are operational communications and may continue even if you opt out of marketing.

Where we send promotional or marketing communications, we will do so in accordance with applicable law. You may unsubscribe using the mechanism included in the communication or contact us at help@helpex.exchange. Opting out of marketing will not prevent us from sending non-promotional service or legally required notices.

16. CHILDREN'S PRIVACY

The Services are not intended for individuals under eighteen (18) years of age or the applicable age of majority in their jurisdiction, whichever is higher. Helpex does not knowingly provide the Services to children. If we become aware that personal information has been collected from a person who is not eligible to use the Services, we may take steps to restrict the account and handle the information in accordance with applicable law.

17. THIRD-PARTY WEBSITES AND SERVICES

The Website or transaction process may contain links to third-party websites or services. This Policy does not govern those third parties. Their collection and use of personal information are subject to their own privacy policies and terms. Customers should review those policies before providing information directly to a third party.

18. CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time to reflect changes in our practices, Services, technology or legal requirements. The updated version will be published on the Website with a revised “Last Updated” date. Where required by law, we will provide additional notice or obtain consent for material changes.

19. CONTACT INFORMATION

For privacy questions, access or correction requests, or privacy complaints, please contact:

Privacy Officer

Helpex Pay Ltd.

Email: help@helpex.exchange (Subject: Privacy Request)

Address: 2120-580 Seaborne Avenue, Port Coquitlam, British Columbia, Canada, V3B 0M3

Website: https://helpex.exchange

END OF PRIVACY POLICY