BlackGallo
Legal

Privacy Policy

BlackGallo · Operated by Cryptopayze Solutions Ltd. · Last updated: March 2026

This Privacy Policy describes our practices regarding the collection, use, and disclosure of your information when you interact with our services. It is essential to read this Privacy Policy alongside any other privacy notices we may provide when collecting or processing your personal information. This ensures you fully understand how and why we use this data.

This policy covers all services provided by Cryptopayze Solutions Ltd., operating as BlackGallo ("we," "our," or "BlackGallo"), a British Columbia corporation registered under number BC1543997 and registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business (MSB) providing services of foreign exchange dealing, money transferring, dealing in virtual currencies, and payment service provider, under FINTRAC registration number C10001312.

For users in Canada, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA). This includes obtaining consent for data collection and ensuring data is protected and used appropriately.

BlackGallo is established in Canada and offers its Services from Canada. The Services are directed to businesses (legal entities) and are not specifically directed to individuals acting in a personal capacity or to individuals outside Canada, including in the European Union or European Economic Area. If you access or use the Services from outside Canada, you do so on your own initiative and are responsible for compliance with applicable local laws.

Privacy Officer / Data Protection Contact

For privacy-related inquiries, requests, or complaints, contact our Privacy Officer at: support@blackgallo.net

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.

1. Definitions

  • Personal Information: Any information relating to an identified or identifiable individual, including individuals acting as directors, officers, beneficial owners, authorized representatives, or agents of a business client.
  • Processing: Any operation performed on personal information, such as collection, storage, use, or disclosure.
  • Account: The business account granted to clients as set out in our Terms and Conditions.
  • Platform: The BlackGallo website, API, and associated interfaces through which we provide our Services.
  • Transaction: Any exchange of fiat currency for crypto-assets or crypto-assets for fiat currency, or any transfer of digital assets, conducted through our Services or through integrated third-party services.
  • Client: A business (legal entity) that has been registered and approved to use BlackGallo's Services.
  • Third-Party Service Provider: A crypto-licensed partner, such as Fipto (fipto.com), through which certain additional digital asset services may be made available to Clients.

2. Consent

We use your information only with your consent or as permitted by law. We obtain your consent to collect, use, disclose, and store personal information when you or your authorized representatives:

  • Create an Account on behalf of a business entity.
  • Use our Services.
  • Submit information for identity verification and know-your-business procedures.
  • Communicate or interact with us.

By using our Services, you give your affirmative consent to the practices outlined in this Privacy Policy. This includes complying with all related terms and conditions as well as applicable laws and regulations. Your consent remains valid throughout your relationship with BlackGallo. If you disagree with any part of the Privacy Policy, we advise you not to use our Services. Some processing is required by law or necessary to provide the Services and cannot be withdrawn while your Account remains active.

3. Purposes and Authority for Processing

We collect, use, disclose, and retain personal information with your knowledge and consent, except where permitted or required by law.

We process personal information as necessary to: (a) provide and secure the Services; (b) verify identity and conduct know-your-business (KYB), know-your-customer (KYC), and beneficial ownership verification, and prevent fraud; (c) comply with legal and regulatory obligations, including anti-money laundering and counter-terrorist financing requirements and reporting to FINTRAC; and (d) enforce our Terms and protect the integrity of our Platform.

4. Data We Collect

4.1 Business Client Information

We collect the following categories of information during onboarding and throughout the business relationship:

Corporate Entity Information:

  • Full legal name, trading name(s), and incorporation number
  • Date and country of incorporation
  • Registered office address and business address (if different)
  • Company phone number and email address
  • Nature of business, expected activity, and geographic scope
  • Registration and licensing documentation (where applicable)
  • Financial statements or management accounts
  • List of directors and corporate structure documentation

Information on Directors, Beneficial Owners, and Authorized Persons:

  • Full legal name
  • Date of birth
  • Nationality
  • Residential address
  • Contact details (email, phone number)
  • Government-issued identification documents (passport, ID card) and selfies (and, where applicable, biometric comparison or liveness checks)
  • Nature and description of beneficial ownership
  • Source of funds and source of wealth information
  • Occupation and role within the entity
  • Tax identification number (TIN), where required by applicable law

IP address and device information: Automatically collected for account security and fraud prevention. This information may be shared with identity verification services.

Regulatory transfer information: Where required by law, we may collect and disclose certain originator and beneficiary information in connection with virtual currency transfers to other financial institutions, money services businesses, or virtual asset service providers in order to comply with anti-money laundering obligations.

4.2 Identity Verification Services

We may use third-party identity verification services to assist in verifying the identity of directors, beneficial owners, and authorized persons and to prevent fraud. These services may receive names, addresses, dates of birth, phone numbers, identification documents, and related information. Data shared with these providers is subject to their respective privacy policies and data retention schedules. These providers may process information outside Canada and may disclose information where required by applicable law.

4.3 Payment Service Providers and Banks

When sending money to BlackGallo, your bank or payment service provider collects your information. Some data, such as the entity name and bank account information, may be transmitted by your bank to our banking partners or payment processors as part of the information included in the payment notification. For withdrawals, we share the beneficiary payment information with our processing partners or banks, which may include the name, bank account, and address of the beneficiary, as required to process bank transactions.

4.4 Transaction Data

  • Transaction logs: Collected and stored for compliance, accounting, and client information.
  • Crypto-asset addresses: Collected for transaction purposes and fraud prevention. Not shared with third parties unless as part of a law enforcement or judicial request or a fraud investigation.
  • Crypto-asset transaction IDs: Collected and stored for compliance, client information, and fraud prevention. Not shared with third parties unless as part of a law enforcement or judicial request or a fraud investigation.

4.5 Third-Party Digital Asset Services

Where Clients access additional digital asset services (such as internal wallet, storage, or transfer services) through our integrated third-party partners (e.g., Fipto), Clients will be clearly informed and required to accept the third-party provider's terms and conditions and privacy policy. Personal and corporate information necessary to onboard with such third-party providers may be shared with them for the purpose of compliance and service delivery. Data handling by third-party providers is governed by their own privacy policies.

4.6 Communications with BlackGallo

When you communicate with BlackGallo via our platform, email, or other channels, we may collect your name, email, phone number, and the content of your communication. This helps us provide better service, handle your requests, and comply with legal obligations.

5. Data Protection, Storage, and Retention

Data Protection: We are committed to keeping your information safe. We employ technological and administrative safeguards, including encryption of data in transit and at rest, secure infrastructure, and strict access controls. However, no service can be completely secure. If you have concerns about a data breach, please contact us immediately.

Data Retention: We retain personal information as necessary, subject to applicable laws and regulations. In accordance with our record-keeping obligations under FINTRAC regulations, we will retain Accounts and Personal Information for at least a period of five (5) years after the last transaction or account closure. We may retain certain information for longer periods where required to comply with legal or regulatory obligations, respond to lawful requests, resolve disputes, enforce our agreements, or prevent fraud.

Post-Retention Data Management: Data is securely deleted or de-identified after the retention period. Deletion permanently erases data, while de-identification prevents identifying individuals.

International Data Transfers: Personal information may be processed or stored outside of Canada by our service providers (for example, cloud hosting, identity verification, analytics, or security providers). When information is located outside Canada, it may be subject to the laws of the jurisdiction where it is stored and may be accessible to courts, law enforcement, or regulatory authorities in that jurisdiction. We do not represent that the Services comply with the data protection laws of jurisdictions outside Canada.

Children's Privacy: Our services are not intended for individuals under 18. We do not knowingly collect data from minors. If a minor provides data without consent, we will remove it and terminate the associated Account.

6. Your Rights to Your Data

Under PIPEDA, you have the following rights regarding your personal information:

  • Accessing and Correcting Your Data: You have the right to access your personal information and obtain a copy. If information is inaccurate, you can request changes. Requests must provide enough detail for us to identify the information.
  • Withdrawing Consent: You may withdraw consent for our data processing under certain conditions. Withdrawing consent may impact our ability to provide the Services and may result in suspension or termination of your Account where processing is required by law or necessary to comply with regulatory obligations.
  • Unsubscribing from Promotional Emails: You can unsubscribe from promotional emails by clicking the "Unsubscribe" link in the email or contacting us.

How to Exercise Your Rights: To exercise your rights, contact us by email at support@blackgallo.net. BlackGallo will action your request only where this is not inconsistent with its Terms and Conditions, legal, and regulatory obligations. In certain circumstances, applicable anti-money laundering laws may restrict what we can disclose to you, including situations where disclosure could interfere with regulatory reporting or investigations.

7. IP Addresses

We may collect information about your computer, including where available your IP address, operating system, and browser type, for system administration, security, and fraud prevention purposes. This is statistical data about our users' browsing actions and patterns and does not by itself identify any individual.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our Platform. Cookies are small data files stored on your device.

Types of Cookies We Use:

  • Essential Cookies: Necessary for the operation of our website.
  • Performance Cookies: Collect information about how you use our website to help us improve it.
  • Functional Cookies: Remember your preferences and personalise your experience.

Managing Cookies: You can manage your cookie preferences through your browser settings. Disabling cookies may affect the functionality of our Services.

We may use third-party service providers to assist us in understanding the use of our Platform. Our service providers may place cookies on the hard drive of your computer and receive information that helps us understand how visitors navigate our site. Our service providers are contractually restricted from using information they receive from our Platform other than to assist us.

By continuing to use our Platform, you consent to our use of cookies as described above. For more information, please see our Cookie Policy.

9. Disclosure of Personal Information

We use your Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law.

You acknowledge that by using our Services and your acceptance of the BlackGallo Terms and Conditions, you will be providing us with Personal Information. You consent to us disclosing that information where we are required by law, to third parties for electronic identification purposes as outlined above, to integrated third-party digital asset service providers where you have elected to use such services, and to FINTRAC or other regulatory authorities as required. In certain circumstances, we may be legally prohibited from notifying you that such a disclosure has occurred or from providing further details.

Non-personally identifiable visitor information may be provided to other parties for analytics purposes. We do not sell your personal information to third parties.

Any third party that receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for BlackGallo, unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective than the obligations we undertake to you under this Privacy Policy.

10. Third-Party Links

Occasionally, at our discretion, we may include or offer third-party products or services on our website, including integrated digital asset services provided by third-party partners. These third-party sites have separate and independent privacy policies. We encourage you to review the privacy policies of each site that you visit or service that you use. We do not control those third-party sites and you agree that we are in no way responsible or liable for any of those third-party sites, including their content, policies, products, services, or actions.

11. Security

We have implemented security measures to ensure the confidentiality of your Personal Information and to protect it from loss, misuse, alteration, or destruction. These security measures include: password-protected directories and databases to safeguard your information, SSL/TLS technology to ensure that your information is fully encrypted and sent across the Internet securely, and other measures to protect our systems from vulnerabilities.

Only authorised personnel of BlackGallo have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

12. Updates to Our Privacy Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated via our website. Changes are effective as of the date indicated in the Privacy Policy. Our policies, content, information, and features may be revised, modified, updated, and/or supplemented from time to time. Where changes are material, we will make reasonable efforts to provide notice through our website or other appropriate means.

13. Contact Information

If you have any questions about this Privacy Policy, please contact us at:

Cryptopayze Solutions Ltd. (operating as BlackGallo)

Canada

Email: support@blackgallo.net

Website: www.blackgallo.net / www.blackgallo.tech