Privacy Policy

As used herein, "HappyCoins" refers to the company Digital Currency Services B.V., including without limitation thereby, its owners, directors, investors, employees or other related parties. Digital Currency Services B.V. is a company with limited liability, incorporated under the laws of the Netherlands. Depending upon context, "HappyCoins" may also refer to the services, products, Site, content or other materials (collectively, "Materials") provided by HappyCoins.

HappyCoins and its affiliates (hereinafter, "HappyCoins", "we", "us" or "our") are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms of Use) governs our collection, processing and use of your Personal Information. We define "Personal Information" as information that identifies you personally, e.g. your name, address, e-mail address, trades, banking details, etc.

The purpose of this Privacy Policy is to inform you of:

• The kinds of Personal Information which we may collect about you and how it may be used;
• Our use of information regarding IP Addresses and our use of cookies;
• Any disclosure of Personal Information to third parties;
• Your ability to correct, update and delete your Personal Information;
• The security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control; and
• Retention of Personal Information.

GATHERING AND USE OF PERSONAL INFORMATION

We may collect your Personal Information if you use the Site, open an Account to use the Platform or perform any Transactions on the Platform. The types of Personal Information that we collect may include (but is not limited to):

• Your name;
• Your photographic identification, including a high quality image of your government issued ID; passport, and national ID card; Tax Id number
• Your address;
• Your e-mail address;
• Your banking details including account numbers;
• Your date of birth;
• Your transactions; and
• Your utility bill or bank statement confirming your residential address.

We may use your Personal Information for the following purposes:

• To personalize your experience (your information helps us to better respond to your individual needs);
• To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you);
• To analyse use of our Site;
• To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs;
• To undertake a verification of your identity in accordance with our AML and Identity Verification Policy;
• To process transactions. Your information, whether public or private, will not be sold, exchanged, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested by the customer;
• To send periodic emails. The email address you provide for order processing, may be used to send you information and updates pertaining to your order or request, in addition to receiving occasional company news, updates, promotions, related product or service information, etc.;
• To administer a contest, promotion, survey or other site feature.

We will process your Personal Information only for the purpose(s) for which it has been provided to us.

IP ADDRESSES

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

COOKIES

The HappyCoins site uses cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties.

We use third party service providers to assist us in better understanding the use of our Site. Our service providers may place cookies on the hard drive of your computer and receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service providers analyse this information and provide us with aggregate reports. The information and analysis provided by our service providers can be used to assist us in better understanding our visitors' interests in our Site and how to better serve those interests. The information collected by our service providers may be linked to and combined with information that we collect about you while you are using the Platform. Our service providers are contractually restricted from using information they receive from our Site other than to assist us.

By using our Site you are agreeing that we may use cookies for the purposes set out above.

DISCLOSURE OF PERSONAL INFORMATION

We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law.

You acknowledge that by using our Services and your acceptance of the HappyCoins Terms of Use that you will be providing us with Personal Information. You consent to us disclosing that information where we are required by law to third parties for electronic identification purposes as outlined above.

Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Any third party that receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for HappyCoins, unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

THIRD PARTY LINKS

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

We do not control those third party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites.

CORRECTION / UPDATING / DELETION OF PERSONAL INFORMATION

You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at: Contact.

HappyCoins will action your request only where this is not inconsistent with its Terms of Use, legal and regulatory obligations. Upon your written request, we will provide you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. Such request will be accepted once per calendar quarter per Account Holder.

SECURITY

We have implemented security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction.

We implement a variety of security measures to maintain the safety of your personal information when you submit a request, place an order or access your personal information. These security measures include: password protected directories and databases to safeguard your information, SSL (Secure Sockets Layered) technology to ensure that your information is fully encrypted and sent across the Internet securely and other measures to protect our servers from hackers and other vulnerabilities.

Only authorized personnel of HappyCoins have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

RETENTION OF PERSONAL INFORMATION

We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory obligations. In accordance with our record keeping obligations we will retain Accounts and Personal Information for, at least a period of five years after they are closed by Users.

CHANGES

Our Site policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of HappyCoins. If we change this Privacy Policy, we will take steps to notify users by a notice on our Site and will post the amended Privacy Policy on the Site.

DEFINITIONS

Private Information: information which personally identifies you and is collected and used by HappyCoins as set out in this Privacy Policy and/or as otherwise permitted by law.

Account: which is granted to Members as set out in our Terms of Use.

Platform: hardware and software technologies which are used by HappyCoins to provide Service as set out in our Terms of Use.

Transaction: means (i) the agreement between the Buyer and the Seller to exchange Crypto-currency through the Service for currencies at a commonly agreed rate ("Crypto-currency Purchase Transaction"), (ii) the conversion of currencies into Crypto-currency deposited by Members on their account ("Conversion Transaction"), (iii) the transfer of Crypto-currency among Members ("Crypto-currency Transfer Transaction"), (iv) the transfer of currencies among Members ("Currency Transfer Transaction"), (v) the Custody of Crypto-currency and (vi) the purchase of ancillary products ("Purchase Transactions"). HappyCoins may not offer all of these types of transactions at this time or in all places.

HappyCoins

Operated by HAPPY CONNECT SERVICES CA INC.

Last updated: March 2026

Introduction to Our Privacy Policy

This Privacy Policy describes our practices regarding the collection, use, and disclosure of your information when you interact with our services. It is essential to read this Privacy Policy alongside any other privacy notices we may provide when collecting or processing your personal information. This ensures you fully understand how and why we use this data.

This policy covers all services provided by HAPPY CONNECT SERVICES CA INC., operating as HappyCoins (“we,” “our,” or “HappyCoins”), a British Columbia corporation located at 5577 153A Street, Suite 207, Surrey, BC, V3S 5K7, registered under the number BC1505322 and registered with FINTRAC as a Money Service Business (MSB) dealing in virtual currencies. For users in Canada, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA). This includes obtaining consent for data collection and ensuring data is protected and used appropriately.

HappyCoins is established in Canada and offers its Services from Canada. The Services are not specifically directed to individuals outside Canada, including in the European Union or European Economic Area. If you access or use the Services from outside Canada, you do so on your own initiative and are responsible for compliance with applicable local laws.

Privacy Officer / Data Protection Contact

For privacy-related inquiries, requests, or complaints, contact our Privacy Officer at: support@happycoins.com.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.

1. Definitions

• Personal Information: Any information relating to an identified or identifiable individual.
• Processing: Any operation performed on personal information, such as collection, storage, use, or disclosure.
• Account: The account granted to users as set out in our Terms and Conditions.
• Platform: The HappyCoins website, API, and associated interfaces through which we provide our Services.
• Transaction: Any exchange of fiat currency for crypto-assets or crypto-assets for fiat currency conducted through our Services.

2. Consent

We use your information only with your consent or as permitted by law. We obtain your consent to collect, use, disclose, and store your personal information when you:

• Create an Account.
• Use our Services.
• Request to verify your identity.
• Communicate or interact with us.

By using our Services, you give your affirmative consent to the practices outlined in this Privacy Policy. This includes complying with all related terms and conditions as well as applicable laws and regulations. Your consent remains valid throughout your relationship with HappyCoins. If you disagree with any part of the Privacy Policy, we advise you not to use our Services.

3. Purposes and Authority for Processing

We collect, use, disclose, and retain personal information with your knowledge and consent, except where permitted or required by law.

We process personal information as necessary to:

(a) provide and secure the Services;

(b) verify identity and prevent fraud;

(c) comply with legal and regulatory obligations, including anti-money laundering and counter-terrorist financing requirements and reporting to FINTRAC; and

(d) enforce our Terms and protect the integrity of our Platform.

4. Information We Collect

4.1 Data We Collect

Here is a detailed breakdown of the types of information we collect during your interaction with our Services, why we collect it, and when we may share it with third parties:

• Email address: We collect email addresses to allow users to log in to the HappyCoins application, confirm transactions, contact users, and send updates. Your email address may be shared with identity verification services and payment service providers.
• First and last name: We collect your full name to comply with KYC/AML regulations, verify identity, prevent fraud, and facilitate transactions. Your name may be shared with identity verification services and payment service providers.
• Phone number: We collect your phone number for KYC/AML compliance, fraud prevention, and as an additional contact method. Your phone number may be shared with identity verification services.
• Residential address: We collect your address for KYC/AML compliance and residency verification. Your address may be shared with identity verification services and payment service providers.
• Date of birth: We collect your date of birth for KYC/AML compliance. Your date of birth may be shared with identity verification services.
• Occupation and source of funds: We collect your occupation and source of funds information for KYC/AML compliance. This information is generally not shared with third parties.
• IP address and device information: Automatically collected for account security and fraud prevention. This information may be shared with identity verification services.
• Identification documents and selfies: Collected for KYC/AML compliance and fraud prevention. This information may be shared with identity verification services. These services may share information extracted from identity documents with third parties for database queries and data validation.
• Tax identification number (TIN): Where required by applicable law, we may collect your TIN for regulatory compliance and reporting purposes.
• Regulatory transfer information: Where required by law, we may collect and disclose certain originator and beneficiary information in connection with virtual currency transfers to other financial institutions, money services businesses, or virtual asset service providers in order to comply with anti-money laundering obligations.

4.2 Identity Verification Services

We may use third-party identity verification services to assist in verifying your identity and preventing fraud. These services may receive your name, address, date of birth, phone number, identification documents, and related information. Data shared with these providers is subject to their respective privacy policies and data retention schedules.

4.3 Payment Service Providers and Banks

When sending money to HappyCoins, your bank or payment service provider collects your information. Some of your data, such as your name and bank account information, may be transmitted by your bank to our banking partners or payment processors as part of the information included in the payment notification. For withdrawals, we share the beneficiary payment information with our processing partners or banks, which may include the name, bank account, and address of the beneficiary, as required to process bank transactions.

4.4 Transaction Data

• Transaction logs: Collected and stored for compliance, accounting, and user information.
• Crypto-asset addresses: Collected for transaction purposes and fraud prevention. Not shared with third parties unless as part of a law enforcement or judicial request or a fraud investigation.
• Crypto-asset transaction IDs: Collected and stored for compliance, user information, and fraud prevention. Not shared with third parties unless as part of a law enforcement or judicial request or a fraud investigation.

4.5 Communications with HappyCoins

When you communicate with HappyCoins via our platform, email, or other channels, we may collect your name, email, phone number, and the content of your communication. This helps us provide better service, handle your requests, and comply with legal obligations.

5. Data Protection, Storage, and Retention

Data Protection: We are committed to keeping your information safe. We employ technological and administrative safeguards, including encryption of data in transit and at rest, secure infrastructure, and strict access controls. However, no service can be completely secure. If you have concerns about a data breach, please contact us immediately.

Data Retention: We retain your personal information as necessary, subject to applicable laws and regulations. In accordance with our record-keeping obligations under FINTRAC regulations, we will retain Accounts and Personal Information for at least a period of five (5) years after the last transaction or account closure. We may retain certain information for longer periods where required to comply with legal or regulatory obligations, respond to lawful requests, resolve disputes, enforce our agreements, or prevent fraud.

Post-Retention Data Management: Data is securely deleted or de-identified after the retention period. Deletion permanently erases data, while de-identification prevents identifying individuals.

International Data Transfers: If your personal data is transferred outside of Canada, we ensure it is protected by appropriate safeguards, including contractual protections that provide a comparable level of data protection.

Children’s Privacy: Our services are not intended for individuals under 18. We do not knowingly collect data from minors. If a minor provides data without consent, we will remove it and terminate the associated Account.

6. Your Rights to Your Data

Under PIPEDA, you have the following rights regarding your personal data:

• Accessing and Correcting Your Data: You have the right to access your personal data and obtain a copy. If information is inaccurate, you can request changes. Requests must provide enough detail for us to identify the information.
• Withdrawing Consent: You may withdraw consent for our data processing under certain conditions. Withdrawing consent may impact our ability to provide the Services and may result in suspension or termination of your Account where processing is required by law or necessary to comply with regulatory obligations.
• Unsubscribing from Promotional Emails: You can unsubscribe from promotional emails by clicking the “Unsubscribe” link in the email or contacting us.

How to Exercise Your Rights: To exercise your rights, contact us by email at support@happycoins.com. HappyCoins will action your request only where this is not inconsistent with its Terms and Conditions, legal, and regulatory obligations. In certain circumstances, applicable anti-money laundering laws may restrict what we can disclose to you, including situations where disclosure could interfere with regulatory reporting or investigations.

7. IP Addresses

We may collect information about your computer, including where available your IP address, operating system, and browser type, for system administration, security, and fraud prevention purposes. This is statistical data about our users’ browsing actions and patterns and does not by itself identify any individual.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our Platform. Cookies are small data files stored on your device.

Types of Cookies We Use:

• Essential Cookies: Necessary for the operation of our website.
• Performance Cookies: Collect information about how you use our website to help us improve it.
• Functional Cookies: Remember your preferences and personalise your experience.

Managing Cookies: You can manage your cookie preferences through your browser settings. Disabling cookies may affect the functionality of our Services.

We may use third-party service providers to assist us in understanding the use of our Platform. Our service providers may place cookies on the hard drive of your computer and receive information that helps us understand how visitors navigate our site. Our service providers are contractually restricted from using information they receive from our Platform other than to assist us.

By using our Platform you are agreeing that we may use cookies for the purposes set out above.

9. Disclosure of Personal Information

We use your Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law.

You acknowledge that by using our Services and your acceptance of the HappyCoins Terms and Conditions, you will be providing us with Personal Information. You consent to us disclosing that information where we are required by law, to third parties for electronic identification purposes as outlined above, and to FINTRAC or other regulatory authorities as required. In certain circumstances, we may be legally prohibited from notifying you that such a disclosure has occurred or from providing further details.

Non-personally identifiable visitor information may be provided to other parties for analytics purposes. We do not sell your personal information to third parties.

Any third party that receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for HappyCoins, unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective than the obligations we undertake to you under this Privacy Policy.

10. Third-Party Links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We encourage you to review the privacy policies of each site that you visit. We do not control those third-party sites and you agree that we are in no way responsible or liable for any of those third-party sites, including their content, policies, products, services, or actions.

11. Security

We have implemented security measures to ensure the confidentiality of your Personal Information and to protect it from loss, misuse, alteration, or destruction. These security measures include: password-protected directories and databases to safeguard your information, SSL/TLS technology to ensure that your information is fully encrypted and sent across the Internet securely, and other measures to protect our systems from vulnerabilities.

Only authorised personnel of HappyCoins have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

12. Updates to Our Privacy Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated via our website. Changes are effective as of the date indicated in the Privacy Policy. Our policies, content, information, and features may be revised, modified, updated, and/or supplemented from time to time. Where changes are material, we will make reasonable efforts to provide notice through our website or other appropriate means.

13. Contact Information

If you have any questions about this Privacy Policy, please contact us at:

HAPPY CONNECT SERVICES CA INC. (operating as HappyCoins)
5577 153A Street, Suite 207
Surrey, BC, V3S 5K7
Canada

Email: contact@happycoins.ca

Website: www.happycoins.ca