## Privacy Policy and Data Governance Version 5.0 – Last Updated: April 29, 2026
Commitment to Privacy:
Vartunexia ("the Platform", "we", "us") prioritizes the security of our users' personal and analytical data.
Our operations are strictly aligned with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec’s Law 25 (formerly Bill 64).
Our primary administrative office is located at Suite 2100, 1000 De La Gauchetière Street West, Montreal, QC H3B 4W5, Canada.
Categories of Data Collected:
Personal Identifiers: Includes full legal name, date of birth, and government-issued identification for mandatory KYC verification.
Financial & AI Telemetry: Information regarding the source of funds, digital asset transaction history, and risk profiles generated by our neural engines.
Digital Footprint: IP addresses, hardware identifiers, browser specifications, and geographical metadata captured during platform interaction.
Legal Basis for Data Processing:
Contractual Obligation: Data is processed to fulfill our commitment to providing access to the AI-driven analytical suite.
Regulatory Compliance: Adherence to federal anti-money laundering (AML) laws and FINTRAC reporting requirements.
Legitimate Interests: Proactive threat detection, cybersecurity hardening, and the optimization of our predictive models.
Explicit Consent: All non-essential data collection, such as marketing telemetry and specialized analytics, is based on a clear user opt-in.
Security Architecture and Residency:
Encryption Protocols: All sensitive records are secured via AES-256 encryption at rest and TLS 1.3 for data in transit.
Data Sovereignty: While utilizing redundant cloud nodes for low-latency performance, all personal data is governed by Canadian and Quebecois data protection standards.
Internal Governance: Access to private datasets is restricted to authorized compliance officers through strict multi-factor authentication (MFA).
Rights of the Data Subject:
Inquiry and Access: You have the right to request a complete copy of the personal information held by the platform.
Rectification: Users can demand the immediate correction of inaccurate or incomplete datasets.
Right to Deletion: The right to request account erasure, subject to mandatory 7-year regulatory retention periods for financial activity.
Data Portability: Requesting the transfer of data to another service provider in a machine-readable format.
Privacy Liaison:
For all matters related to data protection, contact our Privacy Officer at: [email protected].
You retain the right to lodge a formal complaint with the Commission d'accès à l'information du Québec or the Office of the Privacy Commissioner of Canada.