HoneyBadger Enterprises Ltd.
Last Updated: October 16, 2026
HoneyBadger Enterprises Ltd. ("HoneyBadger," "we," "us" or "our") operates cryptocurrency automated teller machines ("crypto ATMs"), online digital asset sales and over-the-counter ("OTC") trading services in Canada. This Privacy Policy explains how we collect, use, disclose and protect your personal information when you use our services, visit our websites or contact us.
We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy laws, including British Columbia's Personal Information Protection Act.
1. Our Regulatory Obligations
HoneyBadger is registered with the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC") as a Money Services Business ("MSB"). Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA"), we must verify our customers' identities, keep records, monitor transactions and report certain transactions to FINTRAC. These are our anti-money laundering ("AML") and know-your-customer ("KYC") obligations. If you do not provide information required by law, we cannot complete your transaction.
2. Information We Collect
- Identity and contact information: name, date of birth, address, email, phone number, occupation, government-issued photo ID and a selfie or liveness check to confirm it matches you
- Compliance information: the purpose of your transaction, whether you are acting for a third party, politically exposed person ("PEP") status, sanctions screening results, and source of funds and source of wealth, only when required for enhanced due diligence. For business clients, we also collect corporate and beneficial ownership information.
- Transaction information: transaction type, amount, date and time, digital asset type, fees, payment method and crypto ATM location
- Wallet information: wallet addresses, blockchain transaction hashes and blockchain analytics risk data
- ATM images: our crypto ATMs may capture images or video of users at the time of a transaction
- Communications: emails, messages and call recordings (we will tell you if a call is recorded)
- Technical information: device and browser type, Internet Protocol ("IP") address, approximate location, device identifiers and cookie data
We may also receive information from identity verification providers, blockchain analytics and sanctions screening providers, payment processors, law enforcement and public sources.
3. How We Use Your Information
- To process your transactions and provide customer support
- To verify your identity and meet our legal obligations, including record-keeping and reporting to FINTRAC and the Canada Revenue Agency ("CRA")
- To detect and prevent fraud, scams, money laundering and other illegal activity
- To protect the security of our crypto ATMs, websites and systems
- To improve our services
- To send marketing communications, only with your consent
We use automated tools to help verify identity and assess transaction risk. Significant decisions, such as refusing a transaction or closing an account, are reviewed by our compliance team.
4. Consent
We collect, use and disclose personal information with your consent, except where the law permits or requires otherwise. You may withdraw your consent at any time, but not for information we are legally required to collect or keep. Withdrawing consent may mean we can no longer serve you.
5. Fraud and Scam Protection
To protect customers from scams, we may ask about the purpose of a transaction, contact you to confirm it, or delay or refuse transactions that appear fraudulent. We will never ask for your private keys, seed phrase or passwords. If you suspect a scam, contact us immediately at help@badgercoin.com.
6. Sharing Your Information
We do not sell your personal information. We share it only as needed with:
- Regulators and authorities, such as FINTRAC and the CRA, as required by law, and law enforcement in response to a court order, subpoena or other lawful request
- Service providers that help us operate, including identity verification providers, blockchain analytics providers such as Chainalysis, payment processors, financial institutions, crypto ATM and cloud service providers, and professional advisors
- Other virtual asset service providers, where required for virtual currency transfers
- Parties to a business transaction, such as a merger or sale, subject to confidentiality obligations
Our service providers are contractually required to protect your information. Some are located outside Canada, including in the United States, and your information may be subject to the laws of those countries. Please note that the law prohibits us from telling you whether we have filed certain reports with FINTRAC.
7. How Long We Keep Your Information
We keep personal information only as long as needed for the purposes described in this policy or as required by law. As an MSB, we must keep identity verification and transaction records for at least five years. When information is no longer needed, we securely destroy or anonymize it.
8. How We Protect Your Information
We protect personal information with administrative, technical and physical safeguards appropriate to its sensitivity, including encryption, restricted access and multi-factor authentication for internal systems. No method of transmission or storage is completely secure, and you are responsible for safeguarding your own wallet, private keys, seed phrases, devices and account credentials. If a breach creates a real risk of significant harm to you, we will notify you and report it as required by law.
9. Cookies
Our websites use cookies for essential functions, security and fraud prevention, analytics (such as Google Analytics) and, with your consent, marketing. You can manage cookies through our cookie banner (where available) or your browser settings.
10. Marketing Communications
We send marketing messages in accordance with Canada's Anti-Spam Legislation ("CASL"). You can unsubscribe at any time. We will still send you service messages, such as transaction confirmations and security alerts.
11. Your Rights
You may request access to the personal information we hold about you, ask us to correct it, or withdraw your consent, subject to legal limits. Send requests to help@badgercoin.com. We will verify your identity and respond within 30 days. In some cases, the law permits or requires us to refuse access, such as for information related to reports made to FINTRAC or ongoing investigations.
12. Blockchain Transactions Are Public
Transactions on public blockchains are permanent and visible to anyone. We cannot change or delete information recorded on a blockchain.
13. Minors
Our services are not intended for anyone under the age of majority in their province or territory and we do not knowingly collect their personal information.
14. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version will be posted on our website with a new effective date. We will provide additional notice of material changes where appropriate.
15. Contact Us
Questions or requests about this Privacy Policy can be directed to our Privacy Officer:
HoneyBadger Enterprises Ltd.
Email: help@badgercoin.com