Terms of Use

These Terms of Use (the “Terms”) govern your access to and use of the website fintwinpay.com (the “Website”) operated by FIN TWIN TECHNOLOGIES INC., operating as FINTWIN PAY (“FINTWIN Pay”, “the Company”, “we”, “us” or “our”). By accessing the Website you agree to these Terms. If you do not agree, please do not use the Website.

1. Who We Are

FIN TWIN TECHNOLOGIES INC. is a corporation incorporated under the laws of the Province of Ontario, Canada (Ontario Corporation Number 1001472662). We are registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business (registration number N300000029) and with the Bank of Canada as a payment service provider under the Retail Payment Activities Act.

Registered office: 1025 King Street East, Unit 107-1587, Cambridge, Ontario, N3H 3P5, Canada.
Head office: 380 Wellington Street, Tower B, 6th Floor, Office 636, London, Ontario, N6A 5B5, Canada.
Email: [email protected]

2. Scope of These Terms

These Terms apply to the use of the Website and to the information published on it. They do not constitute an offer of financial services.

Our payment, foreign exchange and virtual currency services (the “Services”) are provided through our client portal at my.fintwinpay.com and are governed by the service terms, fee schedule and risk disclosures made available in the client portal (together, the “Client Agreement”). You must accept the Client Agreement before your account is activated. In the event of any conflict between these Terms and the Client Agreement in relation to the Services, the Client Agreement prevails.

Our Privacy Policy and Complaint Handling Procedure form part of these Terms.

3. Geographic Availability and Eligibility

FINTWIN Pay provides cross-border payment and exchange services from Canada. We do not facilitate domestic payments within Canada.

Our Services are available to clients in any jurisdiction where we may lawfully provide them, subject to the Client Agreement, our eligibility requirements and our internal risk policy. We do not provide Services to individuals, entities or jurisdictions that are subject to comprehensive sanctions under Canadian law or under other sanctions applicable to us, and we do not accept clients whose activities fall outside our risk appetite. We may decline, restrict or terminate access to the Services on the basis of our risk policy at our discretion and without giving reasons. We also do not facilitate any transaction prohibited by sanctions applicable to us or to that transaction. Our risk policy may change without prior notice.

We do not market, promote or direct our Services to persons established or situated in the European Union, the European Economic Area or the United Kingdom, whether directly or through introducers, affiliates or any other person acting on our behalf. We are not authorised as a crypto-asset service provider in the EU. A person in those jurisdictions may use our Services only where the Services are requested at that person’s own exclusive initiative and can lawfully be provided. We verify these conditions before activating Services, including how the client learned of FINTWIN Pay and whether any introduction or prior contact took place. Registering an account, completing identity verification or accepting these Terms or the Client Agreement does not by itself establish that these conditions are met.

Where Services are provided on this basis, they are limited to the service actually requested by the client and the relationship relating to that service. This does not entitle the client to our full range of products and does not permit unsolicited promotion of additional services.

Requests from persons in the United Kingdom are subject to a separate assessment of applicable UK requirements, including financial promotion restrictions. A client-initiated request does not by itself establish eligibility.

Eligibility also depends on whether we may lawfully provide the requested Service in your jurisdiction. Successful identity verification or account registration does not, by itself, establish eligibility. Each party remains responsible for complying with the laws applicable to it.

4. Regulatory Status and Important Notices

Our registrations with FINTRAC and the Bank of Canada do not constitute regulatory endorsement of the Company or its Services and do not authorise us to provide services in any other jurisdiction.
FINTWIN Pay is not a bank and is not a member of the Canada Deposit Insurance Corporation. A FINTWIN account is an online service profile, not a bank deposit account.
Crypto-assets are not legal tender in Canada and their legal treatment varies by jurisdiction. Crypto-assets may lose all their value, and blockchain transfers may be irreversible.
Information on the Website is provided for general information only and does not constitute financial, legal, tax or investment advice.

5. Account Registration

Creating an account in the client portal is subject to identity and business verification, jurisdictional eligibility under Section 3 and approval of the requested Services. We may ask how you learned of FINTWIN Pay and about any introduction or prior contact. You must provide accurate and complete information and keep it up to date. Your account is activated only after our review and your acceptance of the Client Agreement.

6. Use of the Website

You agree to use the Website only for lawful purposes and in accordance with these Terms. You must not:

use the Website in any way that breaches applicable law or regulation, or to facilitate money laundering, terrorist financing, fraud or sanctions evasion;
interfere with the operation or security of the Website, or attempt to gain unauthorised access to any part of it;
use automated tools to copy, scrape or extract content from the Website;
use virtual private networks, proxies or other tools to mask your location in order to circumvent geographic or eligibility restrictions.

7. Intellectual Property

The Website and its content, including text, graphics, logos and software, are owned by or licensed to the Company and are protected by copyright and trademark law. “FINTWIN PAY”, “FIN TWIN PAY” and the FINTWIN logo are trade names and marks of the Company. You may not reproduce, distribute or create derivative works from the Website content without our prior written consent, except as permitted by law.

8. Third-Party Links and Providers

The Website may contain links to third-party websites and references to third-party service providers. We are not responsible for the content, availability or practices of any third party. Third-party providers involved in the delivery of our Services are described in our Privacy Policy and in the Client Agreement.

9. Privacy

We collect, use and disclose personal information in accordance with our Privacy Policy and the Personal Information Protection and Electronic Documents Act (PIPEDA).

10. Disclaimer and Limitation of Liability

The Website is provided “as is” and “as available”. To the extent permitted by applicable law, we make no warranty that the Website will be uninterrupted, error-free or free of harmful components, and we accept no liability for any loss arising from your use of, or inability to use, the Website or from reliance on information published on it. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law. Liability in relation to the Services is governed by the Client Agreement.

11. Changes to These Terms

We may update these Terms from time to time. The current version of these Terms is the version published on the Website. Changes to the Client Agreement are communicated in accordance with the Client Agreement.

12. Governing Law and Jurisdiction

These Terms are governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein. This does not exclude mandatory laws or regulatory requirements that apply to either party. Subject to any mandatory rules on jurisdiction that cannot lawfully be excluded, the courts of the Province of Ontario have exclusive jurisdiction over any dispute arising out of or relating to these Terms or the Website.

13. Complaints and Contact

If you have a complaint, please follow our Complaint Handling Procedure. For any other question about these Terms, contact us at [email protected].