Privacy policy

Fortress Algo Inc. (DBA Wiremi)

Effective Date: March 19, 2026 · Last Updated: March 19, 2026

1. Introduction

Fortress Algo Inc., operating as Wiremi ("Wiremi," "we," "us," or "our"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use the Wiremi mobile application and related services (collectively, the "Service").

Wiremi is a FINTRAC-registered money services business and an RPAA-registered payment service provider operating under Canadian federal law.

By using the Service, you consent to the practices described in this Privacy Policy.

2. Information We Collect

2.1 Information You Provide

• Account Information: Full name, email address, phone number, date of birth, and Wiremi ID
• Identity Verification (KYC): Government-issued identification documents, address verification, and photographs as required by FINTRAC regulations
• Financial Information: Bank account details, payment method information, and transaction history
• Savings Group Information: Group membership, contribution schedules, rotation positions, and participation history
• Profile Information: Profile preferences and settings

2.2 Information Collected Automatically

• Device Information: Device type, operating system, unique device identifiers, and mobile network information
• Usage Data: Features accessed, pages viewed, actions taken, timestamps, and session duration
• Log Data: IP address, browser type, access times, and error logs
• Behavioural Data: Savings consistency, contribution patterns, circle participation, repayment history and the obligations you choose to report, used to generate your Community Credit score

2.3 Information from Third Parties

• Payment Processors: Transaction confirmation and status from payment processing partners
• Identity Verification Providers: Verification results from KYC service providers

3. How We Use Your Information

We use your personal information for the following purposes:

• Provide the Service: Process transactions, manage savings groups (ROSCAs), facilitate contributions and rotations, and maintain your account
• Build Your Community Credit: Analyze your savings behaviour, circle participation, repayments and the obligations you report to generate and maintain your Community Credit score and file
• AI-Powered Insights: Provide personalized financial insights and recommendations through our AI tools
• Identity Verification: Verify your identity as required by FINTRAC and Canadian anti-money laundering regulations
• Compliance and Legal Obligations: Meet our obligations under Canadian anti-money laundering laws, the Retail Payment Activities Act (RPAA), and other applicable laws
• Fraud Prevention: Detect, investigate, and prevent fraudulent or unauthorized activity
• Communication: Send you service-related notifications, updates, and support responses
• Improvement: Analyze usage patterns to improve the Service, fix issues, and develop new features

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 With Your Consent

• Community Credit Sharing: When you choose, through Wiremi Verify, to release your Community Credit score or file to a lender, landlord, employer or other third party. Each release is scoped to what you approve, is logged where you can see it, and expires after 30 days unless you approve it again
• Savings Groups: Your contribution history and participation status are visible to other members of your savings groups

4.2 Service Providers

We share information with third-party service providers who assist us in operating the Service, including:

• Payment processing partners
• Cloud infrastructure providers
• Identity verification services
• Error monitoring and analytics services

These providers are contractually bound to use your information only for the purposes we specify.

4.3 Legal and Regulatory Requirements

We may disclose your information when required to:

• Comply with applicable regulatory reporting obligations
• Respond to lawful requests from law enforcement or regulatory authorities
• Comply with the RPAA and Bank of Canada supervisory requirements
• File the reports the Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires of a Money Services Business with FINTRAC, including Suspicious Transaction Reports, Electronic Funds Transfer Reports for international transfers of CAD $10,000 or more, and Terrorist Property Reports. The law prohibits us from telling you that a Suspicious Transaction Report has been filed
• Screen your name against Canadian and international sanctions lists at onboarding, on every transaction and whenever those lists are updated
• Pass the sender and beneficiary details the travel rule requires (name, account number and address, date of birth or client number) to the regulated partner that carries an international transfer
• Protect the rights, safety, or property of Wiremi, our users, or the public

5. Data Retention

We retain your personal information for as long as your account is active and for the period Canadian law and our regulatory obligations require afterwards. As a Money Services Business we must keep identity verification records for five years from the date your account is closed, and transaction records and copies of any report filed with FINTRAC for five years from the date of the transaction or filing. These records cannot be deleted within that period. You may request deletion of your account and of information outside these obligations at any time.

6. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure cloud infrastructure with access controls
• Regular security audits and vulnerability assessments
• Role-based access controls for internal systems
• Monitoring and logging of system access

No method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to legal retention requirements
• Portability: Request your Community Credit data in a portable format
• Withdraw Consent: Withdraw consent for optional data processing (this will not affect the lawfulness of processing before withdrawal)
• Complaint: File a complaint with the Office of the Privacy Commissioner of Canada

To exercise any of these rights, contact us at [email protected].

8. Children's Privacy

The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will take steps to delete it.

9. International Data Transfers

Your information is primarily stored and processed in Canada. If your information is transferred outside of Canada, we ensure appropriate safeguards are in place in accordance with applicable privacy laws.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy within the app and updating the "Last Updated" date. Your continued use of the Service after changes are posted constitutes your acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Email: [email protected]

Website: https://wiremi.ca

12. Complaints

If you are not satisfied with our response to a privacy concern, you may file a complaint with:

Office of the Privacy Commissioner of Canada

Website: https://www.priv.gc.ca

Phone: 1-800-282-1376

© 2026 Fortress Algo Inc. (DBA Wiremi). All rights reserved.