These terms apply to every Dakoshi client. Where we have signed a separate written agreement with you, that agreement prevails over these terms to the extent the two conflict.
1. Scope and who is responsible
DAKOSHI SOLUTIONS INC., operating as Dakoshi Digital Finance, with its registered office at 10 King Street East, Suite 600, Toronto, Ontario M5C 1C3, Canada, is responsible for the personal information described here. This policy covers our website, our client portal and the services we provide.
We handle personal information under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and the anti-money-laundering legislation that applies to us as a registered Money Services Business.
2. What we collect
Identity and contact information:
- name, date of birth, nationality and country of tax residence;
- residential address, email address and phone number;
- tax identification number;
- government-issued identity documents and proof of address, including the images you upload.
For business clients, additionally:
- company name, registration number, date of incorporation, industry and website;
- operating address and registered address;
- the purpose of the account, expected activity and source of funds;
- the identity information listed above for every beneficial owner holding 25% or more, and for directors and representatives.
Transaction and account information:
- balances, instructions, amounts, currencies, corridors and counterparties;
- recipient details you give us, including their bank or wallet information;
- the documents we generate for you, such as certificates and receipts.
Technical information:
- IP address, browser and device information, and the date and time you accept our terms — which we keep as evidence of that acceptance;
- security and access logs.
When you give us information about another person — a beneficial owner, a director, a recipient — you confirm you are entitled to give it to us and that they have been told how it will be used.
3. Why we use it
- To verify who you are and decide whether we can open or keep your account.
- To provide the services: process instructions, convert and move funds, produce your documents.
- To meet our legal obligations, including identity verification, record keeping, monitoring and reporting.
- To detect and prevent fraud, sanctions breaches and money laundering.
- To keep the platform secure and to investigate incidents.
- To communicate with you about your account and about problems with a transaction.
- To improve the service, using aggregated information that does not identify you.
Most of this we do because the law requires it or because it is necessary to provide a service you asked for. Where we rely on your consent, you can withdraw it — see section 9.
4. What the law requires of us
As a FINTRAC-registered Money Services Business, we are required to verify your identity, keep records of transactions and of the documents that supported your verification, monitor activity, and report certain transactions to FINTRAC.
These obligations override your preferences: we cannot delete records the law requires us to keep, we cannot open an account without verifying identity, and where we report a transaction the law may prohibit us from telling you.
5. Who we share it with
We do not sell personal information and we do not share it for advertising. We share it only as described here.
To open and operate your account we send HIFI the identity, business and beneficial-owner information described in section 2, together with the documents you upload. HIFI carries out its own verification and screening, and it decides independently whether to accept you. It in turn shares what is necessary with the banking institutions that hold and move the funds.
We also share personal information with:
- cloud infrastructure and hosting providers that run the platform;
- email and communication providers, so we can write to you;
- professional advisers — auditors, lawyers, accountants — bound by confidentiality;
- regulators, law enforcement and courts, where the law requires or permits it;
- a buyer or successor, if our business is transferred, subject to this policy.
6. Where your information is processed
We require our providers by contract to protect personal information to a standard comparable to the one we apply, but a contract cannot displace a foreign authority's lawful access. We state this so that you know it before you give us your information, not afterwards.
7. How long we keep it
We keep identity records, transaction records and the supporting documents for at least five years after your account is closed or after the transaction, as Canadian anti-money-laundering legislation requires. Some records are kept longer where another law, an audit or a legal claim requires it.
When we no longer need information and no obligation requires us to keep it, we delete it or render it anonymous.
8. How we protect it
We encrypt information in transit and at rest, restrict internal access to the people whose work requires it, log administrative actions, and review our controls. Identity documents you upload are passed to the verification provider and are not stored on our own servers.
No system is perfectly secure. If a breach creates a real risk of significant harm to you, we will notify you and the Privacy Commissioner of Canada as the law requires.
9. Your rights
Under PIPEDA you may ask us to:
- tell you what personal information we hold about you and how we have used and shared it;
- give you a copy of it;
- correct it where it is inaccurate or incomplete;
- withdraw a consent you gave us.
We will respond within thirty days. There are limits: we cannot give you information that would reveal another person's personal information, that is subject to legal privilege, or that relates to a suspicious transaction report — the law prohibits us from disclosing that one. Withdrawing consent for information we need in order to verify you or to meet a legal obligation means we can no longer operate your account.
If you are not satisfied with our answer, you may complain to the Office of the Privacy Commissioner of Canada.
11. Children
Our services are for adults and for businesses. We do not knowingly collect personal information from anyone under 18. If we learn that we have, we delete it, subject to any record-keeping obligation.
12. Changes to this policy
We may update this policy. The updated version is published on this page with a new effective date, and where a change is material we will notify you.
13. Contact
To exercise a right, ask a question, or make a complaint, write to our Privacy Officer:
DAKOSHI SOLUTIONS INC.10 King Street East, Suite 600Toronto, Ontario M5C 1C3Canada