Draft for legal review. Not yet in effect.

Privacy Policy

Effective date · Last updated date

The short version

1. Who we are

Jaara is a money transfer service operated by ModeSwift Financial Inc. (“we”, “us”), a company registered in province, Canada, at business address. We are responsible for the personal information described in this policy. Our Privacy Officer is name, who you can reach at [email protected].

This policy covers the Jaara app and website. It follows Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

2. What we collect

When you create an account

When you verify your identity

When you add money and send transfers

From your device

We don’t use advertising trackers or sell data, and we don’t collect your contacts, location or photos beyond the ID and selfie you take for verification.

3. Why we use it

We ask for your consent when you sign up and verify your identity. Some uses are required by law, and we can’t provide the service without them.

4. Who we share it with

We share only what each company needs to do its job for us, under contracts that require them to protect it.

WhoWhat forWhere
SupabaseHosting our database and sign-inCanada
DiditChecking your ID and selfieconfirm (European Union)
FincraReceiving your Interac e-Transfers and paying your recipientsconfirm (Nigeria, United Kingdom and other countries it operates in)
Your recipient’s bankConfirming the account name and receiving the paymentThe recipient’s country
GoogleSign-in with Google, and address suggestions while you typeUnited States and other countries
TwilioTexting you codes, and checking that a phone number is a Canadian mobile numberUnited States
ExpoDelivering push notificationsUnited States
email providerSending emails such as codes, security notices and statementsconfirm

We also disclose information to FINTRAC, law enforcement or other authorities when Canadian law requires it. We may not be allowed to tell you when we do.

If our business is sold or merged, your information may pass to the new owner, who must keep protecting it as this policy describes.

5. Information outside Canada

Some of the companies above store or process information outside Canada, and sending money abroad means sharing your recipient’s details with banks in their country. Information outside Canada is subject to the laws of that country, and authorities there may be able to access it.

6. How long we keep it

When we no longer need information, we delete it or make it anonymous.

7. Closing your account

You can close your account in the app under Account → Close my account. If your account has no identity check or transactions, we delete everything. Otherwise we delete your sign-in, linked emails, saved recipients and notifications straight away, and keep the records the law requires for the period above.

8. Your rights

Email our Privacy Officer at [email protected]. We reply within 30 days. If you’re not satisfied, you can complain to the Office of the Privacy Commissioner of Canada.

9. How we protect it

Your information is encrypted in transit and stored with providers that encrypt it at rest. Access is limited to staff who need it, and every back-office decision is logged. The app locks itself when you leave it and can require Face ID or a fingerprint. Every transfer needs your PIN, and a phone you haven’t confirmed sees only part of your details. After your PIN is reset or your email or phone number changes, sending waits 24 hours and we let you know, so you can freeze your account if it wasn’t you. No system is perfectly secure: if a breach creates a real risk of significant harm, we’ll notify you and the Privacy Commissioner as the law requires.

10. Children

Jaara is for adults only. We don’t knowingly collect information from anyone under the age of majority in their province.

11. Changes

If we make important changes to this policy, we’ll tell you in the app or by email before they take effect.

12. Contact

ModeSwift Financial Inc. · business address · [email protected]