Privacy Policy

This Privacy Policy explains how BELEM Blockchain Technology Co., Ltd. (o/a BELEM Blockchain) ("BELEM", "we", "us") collects, uses, discloses, and protects your personal information when you use the BELEM platform (belem-services.com). We are committed to handling your data lawfully, fairly, and transparently in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the EU and UK General Data Protection Regulation (GDPR).

BELEM is accountable for personal information under its control and has implemented policies and procedures designed to comply with applicable privacy legislation, including PIPEDA. We apply the core PIPEDA principles of accountability, limiting collection to what is necessary, limiting use and disclosure to identified purposes, maintaining the accuracy of personal information, applying appropriate safeguards, and being open about our information-handling practices.

1. Data controller and Privacy Officer

• Controller: BELEM Blockchain Technology Co., Ltd. (o/a BELEM Blockchain).
• Ontario Corporation Number: 1000260680 · FINTRAC MSB: M23331281.
• Address: 439 University Avenue, 5th Floor, Toronto, Ontario, Canada, M5G 1Y8.
• Privacy Officer: [Privacy Officer Name] — privacy@belem-services.com.

Our designated Privacy Officer is responsible for BELEM's compliance with this Policy and applicable privacy laws. You may contact the Privacy Officer directly with any question, request, or concern about how we handle your personal information.

2. Personal data we collect

• Identity data — name, date of birth, nationality, government-ID details, photo and liveness video, occupation.
• Contact data — email, phone number, residential address.
• Financial data — IBAN/account numbers, source-of-funds documentation, wallet addresses, transaction history.
• Technical data — IP address, device and browser information, and session logs, used strictly for security and fraud prevention.
• Communications — correspondence with our support and compliance teams.

3. Consent

By creating an account, submitting information, or using our services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy, except where consent is not required or permitted to be withheld by law (for example, certain anti-money-laundering, sanctions, and legal-obligation purposes). You may withdraw consent for optional processing, such as marketing, at any time, subject to legal and contractual restrictions.

4. How and why we use your data (legal bases)

• Legal obligation — KYC, AML/CTF, sanctions screening, Travel Rule, tax reporting, and record-keeping under the PCMLTFA and equivalent laws.
• Performance of contract — operating your account and processing deposits, exchanges, and withdrawals.
• Legitimate interests — fraud prevention, platform security, and service improvement, balanced against your rights.
• Consent — optional marketing communications and non-essential cookies, which you may withdraw at any time.

As part of our regulatory compliance obligations, personal information may be processed through automated sanctions screening, politically exposed person (PEP) screening, adverse-media screening, transaction monitoring, and blockchain-analytics tools. These checks help us detect and prevent financial crime; where an automated result requires action, it is reviewed by our compliance personnel.

5. Who we share data with

• FINTRAC, regulators, and law enforcement, where legally required.
• KYC, sanctions, and blockchain-analytics providers (identity verification and chain analytics).
• Correspondent banks and Travel-Rule counterparties, limited to the data necessary to settle your transaction.
• Infrastructure providers acting as processors under written contract (cloud hosting, email delivery, customer-support tooling).

We do not sell or rent your personal data, and we do not use it for advertising profiling.

6. Law enforcement and lawful requests

BELEM may disclose personal information in response to lawful requests from courts, regulators, law enforcement agencies, or other governmental authorities where legally required. We assess each request for validity and scope, and disclose only the information we are legally obligated to provide.

7. International transfers and data residency

Personal information may be stored and processed in Canada, the United States, the European Union, and other jurisdictions where our service providers operate. Where personal information is transferred outside Canada or the EEA, we rely on Standard Contractual Clauses, adequacy decisions, or equivalent safeguards to ensure an adequate level of protection. Information processed in another country may be subject to that country's laws, including lawful access by its authorities.

8. Data retention

We retain identity and transaction records for a minimum of five years after the end of our relationship, as required by the PCMLTFA and equivalent AML laws. Certain records collected for anti-money-laundering (AML) and anti-terrorist-financing (ATF) purposes may be retained for periods required under the PCMLTFA and FINTRAC guidance, even after account closure. Security logs are kept for 12 months. Marketing preferences are kept until you withdraw consent. After the applicable period, data is securely deleted or anonymised.

9. Security and breach reporting

Data is encrypted in transit (TLS 1.2+) and at rest. Access to identity documents is restricted to compliance personnel on a need-to-know basis, logged in tamper-evident audit trails, and protected by multi-factor authentication. We maintain incident-response procedures and keep records of all security incidents involving personal information. We report material breaches to affected individuals and to regulators (such as the Office of the Privacy Commissioner of Canada) where required by applicable privacy laws.

10. Your rights

Subject to legal limits (notably AML record-keeping), you have the right to access, rectify, port, restrict, or object to the processing of your data, to withdraw consent, and to request erasure once retention periods lapse. To exercise these rights, email privacy@belem-services.com — we respond within 30 days.

11. Complaints

If you are unhappy with how we handle your data, you may lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) or, in the EEA/UK, with your local Data Protection Authority. We ask that you contact our Privacy Officer first so we can try to resolve the matter.

12. Cookies and website tracking

We use strictly necessary cookies to maintain your session and security. Optional analytics cookies are only set with your explicit consent and can be withdrawn at any time.

In addition to cookies, we may collect information through server and web logs (including IP address, browser type, pages visited, and timestamps), analytics tools, and fraud-detection and device-recognition technologies. We use this information to keep the Platform secure, detect and prevent fraud, and improve our services. Where required by law, non-essential tracking is used only with your consent.

13. Children

The Platform is not directed at, and may not be used by, persons under 18. We do not knowingly collect data from minors.

14. Updates

We may update this Policy. Material changes will be announced by email or by a banner on the Platform at least 15 days before they take effect.

15. Contact

Privacy Officer: [Privacy Officer Name] — privacy@belem-services.com
BELEM Blockchain Technology Co., Ltd., 439 University Avenue, 5th Floor, Toronto, Ontario, Canada, M5G 1Y8.