Privacy Policy
Last updated 29 September 2026
1. Who we are
Trillioni Pay Inc. (“TrillioniPay”, “we”, “us”) is responsible for the personal information described in this policy. We are incorporated under the Canada Business Corporations Act, corporation no. 1663014-6, business no. 790495766RC0001, with our registered office at 350 Rutherford Rd S, Unit 104, Brampton, ON L6W 4N6, Canada.
We are registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business, registration no. C100000813, and with the Bank of Canada as a payment service provider under the Retail Payment Activities Act. TrillioniPay is not a bank.
We have not opened accounts yet. Today this website offers information, free tools, a waiting list, a contact form and, if you ask for them, emails. This policy describes what happens to your information when you use those.
Our Privacy Officer is responsible for how we handle personal information and answers questions and requests about it: Privacy Officer, Trillioni Pay Inc., 350 Rutherford Rd S, Unit 104, Brampton, ON L6W 4N6, Canada, relations-ca@trillionipay.com.
2. What this policy covers
This policy applies to trillionipay.com in English, French and Arabic, and to the emails we send from it. It does not apply to other websites we link to, which have their own policies. We do not publish a mobile app.
Opening an account will involve identity checks that this website does not carry out. Before we ask anyone for identity documents, we will provide the account terms and a privacy notice for onboarding. Section 11 explains what to expect.
3. What we collect
When you join the waiting list
- your email address;
- the language of the page, and the page and form you used;
- how your visit began: the campaign tags of the link you arrived from (such as utm_source), the page you started on and the site that referred you (its name only, such as linkedin.com), as explained under “Technical information” below;
- if you answer it, how you heard about us (an optional question); and
- whether you ticked the optional newsletter box (see “Email subscriptions” below).
When you use the contact form
- your name and email address;
- if you give them, your company, country, what you are interested in, your expected monthly volume and your message;
- whether you ticked the optional box asking us to email you once when onboarding opens (the account-opening notice);
- the language and page, and how your visit began, as for the waiting list;
- optionally, how you heard about us and the newsletter box.
Please do not send identity documents, bank account details or passwords through the contact form or by email. We do not need them at this stage.
Email subscriptions
If you tick the newsletter box, or the account-opening box on the contact form, we keep a record of your consent: your email address, the exact wording you agreed to, which form you used, the date and time, your language, and a coded version of your IP address (explained below). We also keep your current choices from your email preferences page and when they last changed, any unsubscribe, and what happens to the emails we send you, as section 5 describes.
Security records
To protect our forms from automated abuse, we log each form request that we accept, recognise as a repeat or turn away for exceeding our limits, with your email address, the time, the outcome and a coded version of your IP address. We turn the IP address into that code with a secret key before storing it, so our database does not hold your IP address itself.
Our tools
The IBAN checker works in your browser. To name the bank, it sends our server only the country code and the bank and branch codes, never the account number. The SWIFT tools look up the code or bank you enter. The currency converter fetches rates through our database provider, which receives your IP address as part of that request. We do not link what you type into a tool to your identity.
Technical information
As with any website, our hosting provider receives your IP address, browser and device details, the page you asked for and the time, and keeps them in logs for a short period. We use them to run and secure the site. Analytics are covered in section 6.
If you accept analytics in the cookie banner, your browser also keeps a note of how this visit began: the campaign tags of the link you arrived from, the page you were on when you accepted and the site that referred you. It is kept in session storage, which is cleared when you close the tab, and reaches us only if you submit one of our forms, so that we know which campaigns and pages bring sign-ups. If you have not accepted analytics, nothing is stored: when you submit a form, it reads the campaign tags and address of the page you are on, and the referring site, at that moment and sends them with the form. Either way it holds no identifier of its own. We filter campaign tags and page addresses for common patterns of email addresses, website names and long codes; a tag or referring site that remains may still relate to you once it is attached to your form.
Staff sign-in
The sign-in page on this website is for our staff. It is not a customer login, and there is no public sign-up.
What you must give us
To join the waiting list you must give an email address, and to use the contact form a name and an email address. Everything else is optional, including the newsletter and the account-opening notice. Without the required details we cannot handle your request.
4. Why we use it
| Purpose | Basis |
|---|---|
| Telling you when onboarding opens | Your consent, given when you join the waiting list |
| Replying to your enquiry and assessing whether we could serve your business | Your request, and our legitimate interest in answering it |
| Keeping track of sign-ups and enquiries in our customer-relationship tool | Our legitimate interest in managing our replies, within what you asked us to do |
| Sending the newsletter, FX Weekly and the welcome emails | Your express consent, given by ticking the box |
| Sending the one account-opening notice, if you ticked that box on the contact form | Your express consent, given by ticking the box |
| Keeping proof of consent, and honouring unsubscribes, bounces and complaints | Our legal obligations under Canada’s anti-spam legislation, and our legitimate interests |
| Sending fewer emails to people who do not engage with them | Our legitimate interest in not sending unwanted email |
| Protecting our forms and the site from abuse | Our legitimate interest in keeping the site secure |
| Learning how people find us (the optional “How did you hear about us?” question) | Your choice to answer |
| Knowing which campaigns and pages bring sign-ups (how your visit began) | Our legitimate interest in understanding what works. The note kept in your browser before you send a form is stored only with your analytics consent |
| Google Analytics, which loads only if you accept analytics | Your consent, given in the cookie banner |
| Handling complaints, meeting legal requirements, and establishing or defending legal claims | Our legal obligations and legitimate interests |
Where we rely on your consent, you can withdraw it at any time. Withdrawing does not affect what we did before. We do not sell personal information, we do not share it for advertising, and we do not use it to build advertising profiles.
5. Emails we send
- Confirmations. After you join the waiting list or contact us, we send one confirmation.
- Waiting list. We email you when onboarding opens. Joining the waiting list is not an application and does not reserve an account.
- Enquiries. We reply to your enquiry. If you ticked the box asking us to email you when onboarding opens, we send you that one notice, and nothing more on that basis.
- The newsletter, only if you ticked the box. Five welcome emails over your first three weeks, then an email on Wednesdays when we have new payment guides, product or launch news. FX Weekly, our note on exchange rates, may be included in it; we do not currently send FX Weekly as a separate email. If you have not clicked or replied after a number of these emails, we send it monthly instead.
Both boxes are optional. Leaving them unticked does not affect your waiting-list sign-up or our reply to your enquiry.
Our emails come from Trillioni Pay Inc., 350 Rutherford Rd S, Unit 104, Brampton, ON L6W 4N6, Canada, and replies go to relations-ca@trillionipay.com.
How to stop them. Every newsletter email, and the confirmation email if you ticked either box, has a link to a preferences page, where you can stop the newsletter, FX Weekly, the account-opening notice or everything. Most email apps also show an unsubscribe button, which stops the newsletter in one click. You can also write to us. An unsubscribe made online takes effect as soon as you submit it; we act on emailed requests without delay and in any case within 10 business days. Unsubscribing from the newsletter does not remove you from the waiting list; to leave the waiting list, email us.
What we learn from our emails. Our email provider tells us whether each email was delivered, bounced or reported as spam and, where link tracking is on, whether a link was clicked. We also note when you reply. We use this only to stop emailing an address that bounces, to treat a spam report as an unsubscribe from everything, and to send less often to people who do not engage. We do not use whether you opened an email, and we do not use any of this for advertising.
6. Cookies and similar technologies
| What | Why | How long |
|---|---|---|
| Language cookie (trillionipay-locale) | Remembers the language you chose. Set only when you switch language | 1 year |
| Cookie choice (tp-consent-v1, stored in your browser) | Remembers whether you accepted or refused analytics, so we do not ask again | Until you clear it |
| Exchange-rate cache (session storage) | Saves the converter fetching the same rate twice | Until you close the tab |
| How your visit began (tp-first-touch-v1, session storage) | Keeps the campaign tags, first page and referring site of this visit, sent to us only with a form (section 3). Set only if you accept analytics | Until you close the tab |
| Google Analytics cookies (_ga, _ga_<ID>) | Tell visits and sessions apart for statistics. Set only if you accept analytics | Up to 2 years |
| Staff session (stored in the browser) | Keeps staff signed in. Not used for visitors | Until sign-out |
We use Google Analytics 4 to understand which pages and tools are useful. Nothing from Google Analytics loads until you accept analytics in the cookie banner. Before you choose, and if you refuse, your browser does not contact Google Analytics, no analytics cookie is set and no measurement is sent, not even a cookieless one. Google’s advertising features are switched off.
If you accept, Google Analytics also records the pages you view, how you arrived, your approximate location (country and city, derived from your IP address), your device and browser, and actions such as using a tool or submitting a form. For a form, the event records the type of form, the country and the answer code to “How did you hear about us?”; it never includes your email address, name, company or message. Before page addresses are sent we remove everything after the “?” except campaign tags, and we filter campaign tags and page addresses for common patterns of email addresses, website names and long codes; for a visit that came from another site, only that site’s address is sent. Analytics does not run on the email preferences page. Google says it uses the IP address to work out location and then discards it. Google processes this data as our service provider, and its use of data from sites that use its services is described at policies.google.com/technologies/partner-sites. Google Analytics keeps event-level data for up to 14 months; aggregated reports are kept longer.
You can change your choice at any time with the “Cookie settings” link at the bottom of every page. If you withdraw your consent, Google Analytics stops at once and we delete its cookies and the note of how your visit began. You can also clear cookies and site data in your browser. Fonts are served from our own site, not from Google Fonts.
7. Who we share it with
| Recipient | What for | Where |
|---|---|---|
| Vercel | Hosting the website, which receives every request | United States company. Our server functions run in Frankfurt; Vercel may also process data in the United States and elsewhere |
| Supabase | Our database (waiting list, enquiries, consent and security records) and staff sign-in | Database in London, United Kingdom. United States company |
| Resend | Sending our emails, and telling us about deliveries, bounces, spam reports and clicks | Emails sent from Ireland; Resend stores account data and email logs in the United States |
| Attio | Our customer-relationship tool: your email, name, enquiry details and how your visit began, so our team can reply and follow up | United Kingdom company, hosted on Google Cloud in Ireland, with some service providers in the United States |
| Google (Google Analytics) | Website statistics, only if you accept analytics (section 6) | Google’s global infrastructure, including the United States |
| Namecheap (Private Email) | Hosting the mailbox at relations-ca@trillionipay.com, so it holds anything you write to us there | United States company |
| Our team mailbox | Receives the full details from each form so our staff can reply | A mailbox on the trillioni.com email domain |
| Professional advisers and auditors | Legal advice and audits, where needed | Under duties of confidentiality |
| Courts, regulators and law enforcement | Where the law requires it or a valid legal order compels it | — |
These service providers process information for us under their terms with us, including their data processing terms. If we reorganise or sell all or part of our business, the information may pass to the new owner, who must use it in line with this policy. We do not send information from our forms, subscriber lists or analytics to the AI providers we use for articles (section 13).
8. Where your information is processed
We are a Canadian company. The information collected through this website is stored in the United Kingdom and processed in the European Union, the United States and other countries where our service providers operate. You can ask us at relations-ca@trillionipay.com about the safeguards that apply to a particular international transfer. Information held outside Canada may be accessible to the courts and authorities of the country where it is held. Where EU or UK law requires us to appoint a local representative, we will publish their details here.
9. How long we keep it
Records become due for deletion at the end of the periods below. Our database removes due records automatically once a week, and we review the copies in our customer-relationship tool and our team mailbox against the same periods and delete those that are due.
- Waiting list: 12 months after onboarding opens, or 12 months after you join if you join later, unless you ask us to remove you sooner.
- Enquiries: 24 months after you send them.
- Newsletter and account-opening notice: while your consent lasts. Once all your email permissions have ended (for example when you unsubscribe from everything or report one of our emails as spam), or after we stop emailing an address that no longer accepts mail, we keep your email address and the record of your consent and how it ended for 3 years, to show that we had your consent, and then delete them. We only email addresses with a current consent, so deleting that record does not put you back on any list.
- Security records of form submissions: 90 days.
- Single-use form codes (anti-spam): 6 hours.
- Email subscriptions waiting for your confirmation: 30 days (the confirmation link works for 7 days).
- Hosting and email-delivery logs: for the short periods our providers set, from a day to a few weeks.
- Google Analytics: event-level data for up to 14 months.
We may keep information longer where the law requires it or to deal with a complaint or legal claim.
10. How we protect it
Our forms write only through our own server, which checks each request; the database tables that hold your details cannot be read or written from the browser. Access is limited to staff who need it. Our form tables store only a keyed code derived from your IP address, not the address itself, although our hosting and other providers may keep raw IP addresses in their logs (section 3). The links in our emails carry a coded token rather than your email address. Information travels encrypted between your browser and our site, and our hosting and database providers encrypt stored data. No system is perfectly secure. If a breach creates a real risk of significant harm to you, we will tell you and the Privacy Commissioner of Canada as the law requires.
11. When accounts open
As a money services business, we must verify the identity of our clients before onboarding them. When onboarding opens, applying for an account will involve information this website does not collect today, such as identity and company documents, details of directors and beneficial owners, and screening against sanctions lists. Some of it will be handled by identity-verification, banking and payment providers. We will be required to keep certain records for at least five years and to file certain reports with FINTRAC, which in some cases the law prohibits us from telling you about.
Before we collect any of that, we will provide the account terms and a privacy notice for onboarding that names the providers involved, and we will update this policy.
12. Your rights
Under Canada’s Personal Information Protection and Electronic Documents Act you can ask to see the personal information we hold about you, ask us to correct it, and withdraw your consent. If you are in Quebec, Quebec’s private-sector privacy law gives you further rights, including to receive your information in a structured, commonly used technological format.
If you are in the European Economic Area or the United Kingdom, the GDPR and the UK GDPR give you the right to access, correct, erase and port your information, to restrict or object to our use of it (including an absolute right to object to marketing), and to withdraw consent.
If you are in the United Arab Emirates or another country with a data protection law, you may have similar rights under that law. We will handle your request in line with the law that applies.
To use any of these rights, write to our Privacy Officer at relations-ca@trillionipay.com. We may ask you to confirm your identity before we act. We reply within the time the law that applies to you allows: generally 30 days under Canadian law and one month under the GDPR, which can be extended in some cases. If we need longer, we will tell you why. Some requests have limits: for example, we may keep what the law requires us to keep. If you are not satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada, to the Commission d’accès à l’information du Québec if you are in Quebec, or to the data protection authority where you live or work.
13. How our articles are written
Our articles are drafted with AI models from OpenAI and Anthropic and checked under our editorial standards before they are published. What goes into those models is public source material and our own product information. We do not send them anything from our forms, our subscriber lists or our analytics.
14. Automated decisions
We do not make decisions about you on this website by automated means that have legal or similarly significant effects. The eligibility checker only shows whether we expect to serve businesses based in a country; it does not assess you or your business.
15. Children
This website is for businesses and is not directed at anyone under 18. We do not knowingly collect information from children. If you believe a child has given us information, contact us and we will delete it.
16. Changes to this policy
We update this policy when our website, our services or the law change. The date at the top shows the latest version. If a change significantly affects how we use information we already hold about you, we will tell you by email where we have your address.
17. Contact
Privacy Officer
Trillioni Pay Inc.
350 Rutherford Rd S, Unit 104, Brampton, ON L6W 4N6, Canada
relations-ca@trillionipay.com
For complaints about our service, see our complaints process. Our terms and conditions govern the use of this website.