Privacy Notice

1. Introduction & Commitment to Privacy

Palmtree Financials Inc. (“TokPay,” “Company,” “we,” “us,” or “our”) is committed to maintaining the confidentiality, security, and integrity of corporate and personal information entrusted to us by institutional clients, partners, and visitors.

This Privacy Notice describes how we collect, process, store, and protect information collected through the TokPay web platform, interfaces, APIs, and communication channels.

2. Information We Collect

As an institutional B2B financial technology platform, we collect information necessary to fulfill regulatory compliance, establish corporate clearing accounts, and execute requested settlements:

• Corporate Entity Data: Certificate of incorporation, articles of association, registered business address, tax identification numbers, and operating licenses.
• Beneficial Ownership & Representative Information: Names, work email addresses, job titles, and government-issued identification of authorized signatories and Ultimate Beneficial Owners (UBOs) owning 25% or more equity.
• Financial & Transactional Data: Virtual account routing details, beneficiary bank account information (BSB, SWIFT, IBAN), transaction amounts, and counterparty payment references.
• Cryptographic Identifiers: Public blockchain wallet addresses provided by clients for automated digital asset settlement routing. We never request or store private keys.
• Technical Usage Data: IP addresses, browser specifications, operating system details, and session timestamps collected to detect fraudulent activities and enforce API rate limits.

3. How We Use Collected Information

We utilize collected information strictly for operational and compliance purposes, including:

• Performing statutory Know-Your-Business (KYB), Anti-Money Laundering (AML), and sanctions checks.
• Transmitting account opening and clearance instructions to our regulated partner banking institutions.
• Routing automated settlement notifications, invoices, and confirmation statements.
• Investigating suspicious activity and protecting platform security.
• Communicating updates regarding account onboarding, product features, and service notifications.

4. Information Sharing & Third Parties

We do not sell, rent, or monetize your corporate or personal data. Information is shared solely on a need-to-know basis with:

• Regulated Banking & Financial Partners: Licensed banking institutions and domestic clearing networks that issue dedicated accounts and execute fiat wire settlements.
• Compliance & Identity Verification Providers: Third-party screening databases used to verify entity registration and cross-check against global sanctions lists (e.g., OFAC, UN, EU).
• Transactional Infrastructure Providers: Secure enterprise email dispatch gateways (such as Resend) used to deliver transactional confirmations and service notices.
• Legal & Regulatory Authorities: Where mandated by enforceable court orders, subpoenas, or applicable domestic financial regulations.

5. Data Retention & Security Standards

We employ institutional-grade administrative, technical, and physical safeguards:

• All data in transit is encrypted using modern TLS (Transport Layer Security) cryptographic protocols.
• Sensitive corporate documentation is stored in encrypted, access-restricted cloud vaults.
• In accordance with global anti-money laundering regulations, certain transactional and KYB verification records are retained for a minimum statutory period (typically 5 to 7 years) following account termination.

6. Your Privacy Rights

Subject to applicable statutory record-keeping requirements, corporate representatives and individuals whose personal information is processed by TokPay may request:

• Confirmation of whether personal information is being processed.
• Access to and copies of information held by the Company.
• Correction of inaccurate, outdated, or incomplete records.
• Opt-out from marketing communications at any time.

7. Privacy Inquiries & Data Protection Contact

To exercise your rights or submit questions regarding our privacy practices: