Stefa Pay Inc. - Terms of Use

Version 1.1 · Effective date: 6 October 2026 · Last updated: 6 October 2026

This page contains: terms and conditions for using this Site and the data provided on it; terms for using the Site User Panel; conditions for gathering, storing and using a Site User's data; and other legal information.

I. Basic terms and definitions

"Site" means Stefa Pay Inc.'s entire website under its domain name s-pay.io, including the public website, associated subdomains, mobile applications, portals, dashboards, the Site User Panel and related online services, in each case only where applicable.
"Company" or "Stefa" means Stefa Pay Inc., a company incorporated in the Province of Ontario, Canada (Ontario Corporation Number 1001533856), registered as a money services business with FINTRAC under number N300001170.
"Site User" or "User" means any individual or entity browsing this Site, or registered on the Site and using its Site User Panel.
"Terms of Use" means these terms of use and other general terms established herein.
"Site User Panel" means a panel with statistical data, financial reports, transactions, account balances and other information accessible to registered Site Users.
"Services" means the financial services offered by the Company, including cross-border B2B payments, multi-currency accounts, foreign exchange dealing, electronic funds transfers, virtual-currency (stablecoin) settlement and other related services, in each case subject to the Company's regulatory authorisations. Account and IBAN services are provided through regulated banking and payment partners.
"PCMLTFA" means the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) and its regulations.
"PIPEDA" means the Personal Information Protection and Electronic Documents Act (Canada).
"CASL" means Canada's Anti-Spam Legislation.

II. General agreement information

These Website Terms govern use of the public website only. Transaction instructions, fees, settlement, foreign exchange, transaction holds, liability, reserved rights, banking-partner dependencies, complaints handling and payment execution are governed by the terms agreed with the client for the relevant Services and by applicable law, not by these Website Terms.

Purpose. The purpose of these Terms is to maintain a clear relationship between Stefa Pay Inc. and its Site Users and to state the terms for using the Site and the Services, covering general conditions, financial obligations, regulatory compliance, privacy and other matters.

The Services. All financial and payment-processing services are provided subject to these Terms and applicable Canadian law including the PCMLTFA. The Services include, without limitation, cross-border B2B payments, multi-currency accounts, foreign exchange transactions, electronic funds transfers (EFTs) and virtual-currency (stablecoin) settlement. The Company is registered with FINTRAC as a money services business (including dealing in virtual currency) and operates within the regulatory framework established by Canadian federal and Ontario provincial law. The Company is also registered with the Bank of Canada as a payment service provider under the Retail Payment Activities Act (RPAA), registered since 9 September 2026.

Stefa Pay is not a bank. Registration with FINTRAC and the Bank of Canada does not constitute endorsement, guarantee or prudential supervision of our services, and client balances are not insured by CDIC.

The Services are provided to legal entities and to individuals above 18 years of age (or the legal age required in the User's jurisdiction). The Services are designed for business use.

Communications. The Services may include service announcements, administrative messages, transaction confirmations and regulatory notices. These messages are essential to the Services and continue regardless.

III. Eligibility

The Services are available to: legal entities incorporated or registered in jurisdictions where the Company offers its Services and which satisfy the Company's customer due diligence requirements; and individuals 18 or older with contractual capacity. In each case, persons must not be located in, resident in or operating from jurisdictions restricted under the Company's country-risk framework, and must not appear on, or be controlled by persons appearing on, applicable sanctions lists (including the OSFI Consolidated List, Canadian Ministerial Directives and partner-jurisdiction sanctions regimes).

Stefa reserves the right to restrict or decline unsupported or prohibited jurisdictions, parties, activities and transaction types, as determined by its internal risk standards, which are dynamic. Use of the Services by ineligible persons is prohibited and may result in immediate termination of access, measures required or permitted by law (including restricting, declining, delaying, returning, suspending or freezing transactions or property where legally required), and notification to applicable Canadian authorities.

IV. Rights of the Site User

The Site User has the right: to contact Site support with questions, claims or recommendations; to have sensitive information protected by reasonable administrative, technical and physical safeguards (no organisation can guarantee absolute protection) and not distributed to third parties except where required by Canadian law (including PCMLTFA reporting), essential to provide the Services, or permitted under the Privacy Notice; to view detailed and timely transaction information, statistics and balances through the Site User Panel; to receive timely notice of fraudulent or harmful activity and to combine efforts with the Company to stop it; to exercise all PIPEDA rights (access, correction, and to challenge the Company's compliance).

V. Obligations of the Site User

The Site User undertakes: to observe these Terms and the Company's safety rules fully; to acknowledge that internet transmission confidentiality cannot be absolutely guaranteed outside the Company's controlled facilities; to provide reliable, current and accurate information, including all information required for the Company's customer due diligence under the PCMLTFA; to safeguard login credentials and report suspected compromise immediately; to ensure entered data corresponds to reality and complies with law; to help ensure the Site's functionality and safety; to keep their device free of malicious software; to report changes in personal information, beneficial ownership, control or business activity within 30 days; not to use the Services for any illegal activity (including money laundering, terrorist financing, sanctions evasion or fraud); to observe the Company's policies including its AML/ATF Policy; and to cooperate with all customer due diligence, source-of-funds and beneficial-ownership enquiries as a condition of continued access.

VI. Compliance obligations - KYC, AML and sanctions

The Company is a regulated reporting entity under the PCMLTFA and operates an AML/ATF compliance programme. By using the Services, the Site User acknowledges and agrees:

that the Company must identify and verify all customers, identify beneficial owners of legal-entity customers, ascertain the purpose and intended nature of the relationship, and conduct ongoing monitoring;
that the Company will request, and the User will provide, all information reasonably required to satisfy regulatory obligations (identification documents, beneficial-ownership declarations, source-of-funds and source-of-wealth documentation, business-activity descriptions and counterparty information);
that the Company conducts ongoing screening of customers, beneficial owners, directors, authorised signatories and counterparties against sanctions lists, PEP databases, internal watchlists and adverse media;
that the Company must file Suspicious Transaction Reports, Electronic Funds Transfer Reports, Terrorist Property Reports, large virtual currency transaction reports and other reports with FINTRAC where thresholds are met;
that the Company is prohibited under the PCMLTFA from disclosing that a suspicion has been formed, an investigation is underway or a report has been filed (the "no-tipping-off" prohibition), and may accordingly decline to explain certain operational decisions;
that the Company may, on Compliance Officer authorisation and in compliance with law, freeze property, block transactions, refuse activity or terminate the relationship where required by sanctions law, terrorist-property obligations or the Company's risk appetite;
that the User will cooperate with periodic reviews and event-driven re-verification; and
that the User will notify the Company within 30 days of any material change in beneficial ownership, control, business activity, jurisdiction or other information previously provided.

The User acknowledges that the Company's compliance obligations are independent of, and may take precedence over, the User's commercial preferences, and that complete explanations for compliance-driven decisions may not always be possible due to legal restrictions.

VII. Rights of the Company

The Company has the right to: make changes to the Site, its components and the Company's policies; ask the User to follow the Site's rules and safety requirements; take actions necessary for the Site's safety and functionality; perform maintenance with reasonable notice where practicable; monitor account activity for compliance with these Terms and law; request additional information or documentation at any time for due diligence, monitoring or sanctions purposes; block, suspend, restrict or close an account for violation of the Company's policies or law, or where required by regulatory or banking-partner obligations; and refuse to establish or continue a relationship on grounds permitted by law, including financial-crime risk, sanctions exposure or inconsistency with the Company's risk appetite.

VIII. Obligations of the Company

By agreeing to these Terms, the Site User agrees to the transfer of the User's (and, where applicable, the User's clients') personal data to the Company. The User represents that it has a lawful basis and authority to provide personal information of other individuals and has given required notices or obtained required consents. The Company is a personal-data processing manager under PIPEDA.

The Company may process personal data of Site Users and their clients to provide the Services, including under concluded contracts, to record customer accounts, to offer and maintain its Services, to protect the Company's legal interests, and to satisfy obligations under the PCMLTFA, PIPEDA and sanctions legislation. The Company may obtain personal data from third parties (identity-verification providers, screening databases) and disclose it to service providers, banking partners, correspondent institutions, regulators, FINTRAC and law-enforcement authorities only where required, permitted or reasonably necessary for the purposes described in the Privacy Notice or applicable law.

The Company shall: ensure the safety and functionality of the Site, subject to the limitations below; provide the User with reliable information about their account; maintain reasonable administrative, technical and physical safeguards to protect the User's data; and comply with applicable Canadian law, including the PCMLTFA, PIPEDA, CASL and sanctions legislation.

IX. Responsibilities and limitations of the Company

To the maximum extent permitted by applicable law: the Company is not responsible for damage arising from Site usage, inability to use, or the results of such usage; for indirect or consequential damage, lost profits or missed benefits; for losses resulting from unlawful actions of third parties; for losses resulting from malware, incorrect data entry or the User's breach of these Terms; for full functionality under force majeure; for external references placed on the Site; for malfunctions caused by reasons beyond the Company's control; or for delays, suspensions or refusals of transactions arising from regulatory compliance, sanctions screening, transaction monitoring or banking-partner requirements.

X. Copyright and trademarks

Unless stated otherwise or owned by a third party, Stefa Pay Inc. owns all intellectual property rights in the Site content. Content may be viewed, copied, printed and published only in compliance with these Terms and with the Company's written agreement, without altering conditions, trademarks or copyright notices, and only for informative purposes. All brand names, trademarks, logos and similar elements are the Company's intellectual property (or used lawfully where owned by third parties). Unauthorised downloading, publishing, copying or altering of this information may lead to legal action. The User shall not transfer or make the Services available to any third party, or provide any derived service, without the Company's prior written permission.

XI. Privacy and personal data (PIPEDA)

Stefa Pay Inc. protects the privacy of Site Users' personal information in accordance with PIPEDA and applicable provincial privacy law. Collection, use, disclosure, retention and security are governed by the Company's Privacy Notice, available on the Site. In summary: the Company collects only information necessary to provide the Services and comply with regulatory obligations; uses and discloses it only for those purposes or as permitted or required by law; applies reasonable safeguards; retains it for legally required periods (including PCMLTFA record-keeping) and then securely destroys it; honours access, correction and consent-withdrawal rights (subject to legal and contractual limits); applies contractual safeguards where information is processed outside Canada; and, in the event of a breach involving real risk of significant harm, notifies affected individuals and the Office of the Privacy Commissioner of Canada. For privacy enquiries, contact [email protected] or the Site support channel.

XII. Anti-spam (CASL)

The Company complies with CASL. By registering, the User consents to receive service-related communications (service announcements, administrative messages, transaction confirmations and regulatory notices) that are essential to the Services.

XIII. Prohibited uses

The Site User shall not, and shall not permit any third party to: use the Services for any unlawful purpose (money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, tax evasion or other prohibited activity); transmit or store unlawful material; attempt unauthorised access to the Site or related systems; introduce malicious code; disrupt the operation of the Site or Services; circumvent the Company's due diligence, sanctions or monitoring controls; facilitate transactions involving prohibited jurisdictions, sanctioned persons or restricted activities; use automated systems without written authorisation; or impersonate any person or misrepresent any affiliation. Violation may result in immediate termination, freezing of property and notification to applicable Canadian authorities including FINTRAC and the RCMP.

XIV. Account suspension, restriction and termination

Provisions governing pending transactions, return of funds, post-termination access and record retention are set out in the terms agreed with the client for the relevant Services. The Company may, at its discretion and in accordance with law, suspend, restrict or terminate access where: the User has violated these Terms; provided false or incomplete information; failed to provide required compliance information; engaged in activity inconsistent with the declared purpose or the Company's risk appetite; is identified as a sanctioned person or connected to a sanctioned jurisdiction; is a listed terrorist entity or holds property on its behalf; where required by law, court order or regulatory direction; where banking partners cannot support the relationship; or where continuation would be inconsistent with the Company's regulatory obligations. Decisions are communicated consistent with the Company's no-tipping-off obligations, and complete reasons may not always be available.

XV. Applicable law and dispute resolution

Use of this Site is governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein. All disputes concerning this Site or these Terms shall be settled by the courts of the Province of Ontario, which have exclusive jurisdiction. The Site User waives any objection to venue on the grounds of inconvenient forum. The Company may seek injunctive or equitable relief in any jurisdiction where the User or its assets are located. The United Nations Convention on Contracts for the International Sale of Goods does not apply.

XVI. General provisions

Severability. If any provision is held invalid, the remaining provisions continue in full force. Entire agreement. These Terms, together with the Privacy Notice and any documents incorporated by reference, constitute the entire agreement regarding use of the Site. Amendments. The Company may amend these Terms at any time; material amendments will be communicated through the Site User Panel or by email, and continued use constitutes acceptance. No waiver. Failure to enforce any provision is not a waiver. Assignment. The User may not assign its rights without the Company's consent; the Company may assign to any affiliate or successor. Force majeure. The Company is not liable for failure or delay resulting from causes beyond its reasonable control.

XVII. Legal address and contact

Stefa Pay Inc. · 1110 Finch Avenue West, Unit 220, North York, Ontario, M3J 2T2, Canada · FINTRAC MSB Registration Number N300001170 · Ontario Corporation Number 1001533856

For questions and support: [email protected] · Phone: +1 450 485 9061 · Support: [email protected] · Privacy: [email protected] · Compliance: [email protected]. The Company endeavours to respond within reasonable timeframes during business hours, Monday to Friday, excluding Canadian statutory holidays.

By accessing or using this Site, the Site User acknowledges having read, understood and agreed to be bound by these Terms of Use.