Privacy Policy

Effective Date: 19th May 2026
Company: Vera Finance Ltd
Address: Waterpark Place, 20 Bay St., Toronto, ON M5J 2W3, Canada

Vera Finance Ltd. is incorporated in Ontario, Canada (OCN 1000781272) and registered with FINTRAC as a regulated reporting Money Services Business (Ref. C100000028).

1. Introduction

Vera Finance Ltd (“Vera Finance”, “we”, “us” or “our”) respects the privacy of its clients, prospective clients, website visitors, counterparties and business contacts.

This Privacy Policy explains how we collect, use, disclose, retain and protect personal information in connection with our website, onboarding processes, institutional OTC services, digital asset execution activities, fiat settlement coordination, compliance reviews, communications and related business operations.

Vera Finance is committed to handling personal information in a responsible, lawful and proportionate manner, consistent with applicable Canadian privacy requirements and the standards expected of an institutional financial services business.

2. Scope of this Policy

This Privacy Policy applies to personal information that we collect or process in connection with:

• access to and use of our website;

• enquiries submitted through our contact forms;

• institutional onboarding and client due diligence;

• OTC execution and settlement-related services;

• compliance, AML, sanctions, KYT and transaction monitoring reviews;

• communications with clients, prospective clients, service providers and counterparties;

• legal, regulatory, operational and risk management purposes.

This Policy does not apply to third-party websites, platforms or services that may be linked from our website or used independently by you. Such third parties are responsible for their own privacy practices.

3. Personal Information We May Collect

Depending on your relationship with Vera Finance, we may collect the following categories of information:

Identity and Contact Information

This may include your name, title, position, business email address, telephone number, company name, business address and other professional contact details.

Corporate and Onboarding Information

Where you or your organization seeks access to Vera Finance services, we may collect information relating to the relevant entity, directors, officers, beneficial owners, authorised representatives and controllers.

This may include corporate documents, ownership details, identification documents, proof of address, business activity information, source of funds, source of wealth, expected transaction volumes, jurisdictional exposure and supporting due diligence materials.

Transaction and Settlement Information

We may collect information relating to proposed or completed transactions, including asset type, transaction size, wallet addresses, settlement currency, banking details, transaction purpose, counterparty information and supporting documentation.

Compliance and Risk Information

We may collect or generate information for compliance purposes, including sanctions screening results, politically exposed person checks, adverse media results, KYT and wallet screening outputs, risk ratings, transaction monitoring data and internal compliance notes.

Website and Technical Information

When you visit our website, we may collect technical information such as IP address, browser type, device information, operating system, pages visited, access times, referral source and other usage data.

Communications Information

We may retain records of communications with you, including emails, messages, meeting notes, call summaries, support requests and other correspondence.

4. How We Collect Personal Information

We may collect personal information:

• directly from you or your organization;

• through our website, contact forms or onboarding forms;

• during correspondence, meetings or calls;

• from documents submitted during onboarding or compliance review;

• from blockchain analytics, KYT, KYC, AML, sanctions screening and compliance service providers;

• from banks, payment providers, liquidity providers, settlement partners or other counterparties;

• from public records, company registries, regulatory databases and other lawful sources.

We aim to collect only the information that is reasonably necessary for the purposes identified in this Policy.

5. Purposes for Which We Use Personal Information

Vera Finance may use personal information for the following purposes:

• to respond to enquiries and communicate with you;

• to assess whether we can provide services to you or your organization;

• to conduct onboarding, due diligence and risk assessment;

• to verify identity, authority, ownership and control;

• to assess source of funds, source of wealth and transaction purpose;

• to support OTC execution and settlement workflows;

• to conduct AML, sanctions, KYT, fraud prevention and transaction monitoring checks;

• to manage counterparty, operational, legal and regulatory risk;

• to comply with applicable laws, regulations, lawful requests and internal policies;

• to maintain business records and audit trails;

• to improve our website, services and operational processes;

• to protect the rights, property and security of Vera Finance, its clients, counterparties and service providers.

We do not use personal information for purposes that are materially unrelated to those for which it was collected, unless permitted by law or with appropriate consent.

6. Legal and Compliance Basis for Processing

Vera Finance may process personal information where necessary or appropriate for:

• your consent, including where you submit information to us voluntarily;

• the assessment, establishment or performance of a business relationship;

• compliance with legal, regulatory, AML, sanctions and financial crime obligations;

• the prevention of fraud, misuse, market abuse or unlawful activity;

• legitimate business, operational, security and risk management purposes;

• the establishment, exercise or defence of legal rights.

Where consent is required, we will seek to obtain meaningful consent in a manner appropriate to the sensitivity of the information and the circumstances of collection.

7. Disclosure of Personal Information

Vera Finance may disclose personal information where necessary and appropriate to:

• KYC, AML, sanctions, KYT and blockchain analytics providers;

• banks, payment institutions, settlement partners and liquidity providers;

• technology, hosting, cybersecurity and operational service providers;

• professional advisers, including legal, audit, tax and compliance advisers;

• regulators, law enforcement authorities, government agencies or courts, where required or permitted by law;

• counterparties involved in a transaction, settlement process or operational review;

• affiliates, contractors or service providers acting on our behalf.

We do not sell personal information.

Where we disclose personal information to third-party service providers, we expect such providers to process the information only for authorised purposes and to maintain appropriate safeguards.

8. International Transfers

Vera Finance may use service providers, counterparties or infrastructure located outside Canada. As a result, personal information may be transferred to, stored in or accessed from jurisdictions outside Canada.

Where personal information is transferred outside Canada, it may be subject to the laws of the jurisdiction in which it is processed, including lawful access requests by courts, regulators or government authorities.

Vera Finance takes reasonable steps to ensure that personal information transferred outside Canada remains subject to appropriate contractual, technical and organisational safeguards.

9. Data Retention

Vera Finance retains personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including legal, regulatory, compliance, audit, risk management and business recordkeeping requirements.

Retention periods may vary depending on the nature of the information, the type of relationship, applicable legal obligations and the need to maintain records relating to onboarding, transactions, compliance decisions or disputes.

When personal information is no longer required, Vera Finance will take reasonable steps to securely delete, anonymise or otherwise dispose of it.

10. Security Safeguards

Vera Finance applies administrative, technical and organisational safeguards designed to protect personal information against unauthorised access, loss, misuse, disclosure, alteration or destruction.

These safeguards may include access controls, secure storage, restricted permissions, internal policies, vendor controls, monitoring, encryption where appropriate and staff or contractor confidentiality obligations.

No method of transmission or storage is completely secure. Accordingly, while Vera Finance takes reasonable steps to protect personal information, we cannot guarantee absolute security.

11. Accuracy of Information

Vera Finance takes reasonable steps to ensure that personal information used for onboarding, compliance, transaction review and business operations is accurate, complete and up to date.

You are responsible for ensuring that information provided to us is accurate and for notifying us of any material changes, including changes to ownership, control, authorised representatives, business activity, transaction profile or contact details.

12. Your Privacy Rights

Subject to applicable law, you may have the right to:

• request access to personal information we hold about you;

• request correction of inaccurate or incomplete information;

• withdraw consent where processing is based on consent;

• request information about how your personal information has been used or disclosed;

• challenge our compliance with applicable privacy obligations;

• submit a privacy-related complaint or enquiry.

These rights may be subject to legal, regulatory, AML, security, privilege, confidentiality or recordkeeping limitations.

13. Cookies and Website Analytics

Our website may use cookies, analytics tools or similar technologies to support website functionality, improve user experience, understand website traffic and maintain security.

You may be able to control or disable cookies through your browser settings. However, disabling cookies may affect the functionality or performance of certain parts of the website.

Where required, Vera Finance will provide additional information regarding cookies through a separate Cookie Policy or cookie notice.

14. Marketing Communications

Vera Finance may use business contact information to provide updates, service information or relevant communications to clients, prospective clients and professional contacts.

You may request to stop receiving marketing communications at any time by following the unsubscribe instructions in the relevant communication or by contacting us directly.

Even where you opt out of marketing communications, we may continue to send service, compliance, legal or transactional communications where necessary.

15. Third-Party Links and Services

Our website or communications may contain links to third-party websites, platforms or service providers.

Vera Finance is not responsible for the privacy practices, content or security of third-party websites or services. You should review the relevant privacy policies before providing personal information to any third party.

16. Changes to this Privacy Policy

Vera Finance may update this Privacy Policy from time to time to reflect changes in our services, operations, legal requirements or privacy practices.

The updated version will be posted on our website with a revised effective date. Continued use of our website or services after an updated Privacy Policy is posted constitutes acknowledgement of the updated terms.

17. Contact Us

If you have any questions, requests or concerns regarding this Privacy Policy or the handling of your personal information, please contact:

Vera Finance Ltd
Waterpark Place
20 Bay St.
Toronto, ON M5J 2W3
Canada

Email: [email protected]

18. Privacy Officer

Vera Finance is responsible for personal information under its control. Privacy-related enquiries, access requests or complaints may be directed to our designated privacy contact at:

Email: [email protected]

Vera Finance will review privacy enquiries and complaints in accordance with applicable law and its internal procedures.