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Privacy Policy

Effective date: 10.08.2026

This Privacy Policy (“Policy”) explains how Evendough Holdings Ltd. (“Evendough,” “we,” “us” or “our”) collects, uses, discloses and protects personal information in connection with Algoz OTC and its related services.

1. Application and Scope 

Evendough Holdings Ltd. is a corporation incorporated under the laws of Canada and a Money Services Business (MSB) registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), registration number M21246144.

This Policy is intended to comply with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, substantially similar provincial privacy legislation. PIPEDA may also apply to personal information involved in international and interprovincial commercial activities. 

2. Information We Collect

We may collect personal information necessary to provide our services, establish and maintain business relationships, and meet legal and regulatory obligations, including:

  • Name, contact details, date of birth, nationality and address; 

  • Government-issued identification and verification documents; 

  • Corporate, beneficial ownership, tax identification and KYC/KYB information; 

  • Banking and payment information, including IBAN and SWIFT/BIC details; 

  • Transaction history, exchange rates applied, settlement information and digital asset wallet addresses; 

  • Source-of-funds and source-of-wealth information where required; 

  • Communications and information relating to our business relationship; and 

  • Technical information such as IP address, device information, browser type, login activity, geolocation, and platform usage. 

We may collect information directly from you, automatically through your use of our website or platform, or from third parties where permitted or required by law.

3. Purposes for Collection and Use

We may collect, use and disclose personal information for legitimate business and regulatory purposes to:

  • Provide and administer OTC trading, execution, onboarding and settlement services; 

  • Verify identity and assess client eligibility; 

  • Comply with applicable AML/ATF, sanctions and other legal and regulatory requirements; 

  • Detect and prevent fraud, financial crime and unauthorized activity; 

  • Process transactions and work with banks, payment providers, custodians and technology providers; 

  • Communicate with clients and provide support; 

  • Maintain, secure and improve our website and services; and 

  • Comply with legal, regulatory, court or law-enforcement requirements. 

We will not use personal information for unrelated purposes without consent where consent is required by applicable law.

4. Consent

Where required by applicable law, we will obtain appropriate consent for the collection, use or disclosure of personal information.

Personal information may also be collected, used or disclosed without consent where permitted or required by law, including for regulatory, legal, fraud-prevention or reporting purposes.

Where applicable, you may withdraw consent, subject to legal, regulatory or contractual requirements. Withdrawal of consent may affect our ability to provide certain services. 

5. Disclosure of Personal Information

We may disclose personal information to:

  • Banks, payment providers and other financial institutions; 

  • Digital asset custodians and settlement providers; 

  • Technology, compliance, verification and other service providers; 

  • Professional advisers and insurers; 

  • Regulatory, law-enforcement and government authorities where required or permitted by law; and 

  • A successor entity in connection with a merger, acquisition, restructuring or similar corporate transaction. 

Where we engage third parties to process personal information on our behalf, we take appropriate contractual or other measures to protect that information.

We do not sell or rent personal information.

6. Data Retention 

We retain personal information only for as long as reasonably necessary to fulfil the purposes described in this Policy, provide our services, resolve disputes, enforce agreements and comply with applicable legal and regulatory requirements.

Certain records must be retained for at least five years under applicable FINTRAC requirements, with the applicable retention period depending on the type of record. 

When personal information is no longer required, we will securely delete, destroy or anonymize it in accordance with applicable requirements.

7. Safeguards

We maintain appropriate physical, technical and organizational safeguards designed to protect personal information against unauthorized access, disclosure, loss, misuse or alteration.

The safeguards applied are appropriate to the nature and sensitivity of the information. However, no method of transmission or storage can be guaranteed to be completely secure.

8. Cookies and Analytics

We may use cookies and similar technologies to:

  • Maintain secure sessions and support website functionality; 

  • Prevent fraud and unauthorized activity; 

  • Understand website usage and improve performance; and 

  • Improve our services and user experience. 

You may manage cookies through your browser or available cookie controls. Disabling certain cookies may affect website functionality.

9. Cross-Border Processing

Personal information may be processed or stored in jurisdictions outside Canada where necessary to provide our services or through our service providers.

Where personal information is processed outside Canada, we take appropriate contractual or other measures designed to provide an appropriate level of protection under applicable privacy laws. Personal information processed outside Canada may also be subject to the laws and lawful access requirements of the jurisdiction in which it is processed. 

10. Your Privacy Rights

Subject to applicable law, you may request access to personal information we hold about you and request correction of inaccurate or incomplete information.

You may also request deletion of personal information where permitted by law. Such requests may be limited by legal, regulatory or contractual obligations, including applicable FINTRAC record-retention requirements. 

Requests may be subject to identity verification.

11. Privacy Complaints and Contact

For privacy questions, access or correction requests, or complaints, please contact:

 

Privacy Officer
Evendough Holdings Ltd.
Email: compliance@evendough.com

​

We will investigate and respond to privacy complaints in accordance with applicable law.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada:

​

30 Victoria Street
Gatineau, Quebec K1A 1H3
1-800-282-1376
Office of the Privacy Commissioner of Canada

12. Marketing Communications

Where we send commercial electronic messages, we will comply with applicable requirements, including Canada's Anti-Spam Legislation (CASL), where applicable.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes to our services, practices or applicable legal requirements.

The updated Policy will be posted on our website with the revised effective date. Where required by law, we will provide additional notice or obtain consent.

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