Last Updated: 4th February 2026

DEFINITIONS AND INTERPRETATION

• In this Safeguarding and Client Funds Handling Policy (the “Policy”), unless the context otherwise requires:
  • “Client Funds” means monetary funds received, held, or processed by Flowapay on behalf of its business customers in connection with the Services.
  • “Flowapay”, “we”, “us”, or “our” means FLOWA PAY INC., as defined in Clause 2.1.
  • “MSB” means Money Services Business.
  • “Services” means the payment processing, foreign exchange, virtual currency, and related services provided by Flowapay on a business-to-business basis
  • “Segregated Account” means a bank or financial institution account held in Flowapay’s name and designated for the holding of Client Funds separate from Flowapay’s own operational funds.
• Headings are for convenience only and shall not affect interpretation.
  
  

2. REGULATORY STATUS
   • Flowapay is a company incorporated under the laws of British Columbia, Canada (Incorporation No. BC1521911).
   • Flowapay is registered as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under MSB Registration Number C100000902 and is subject to applicable Canadian anti-money laundering and counter-terrorist financing legislation.
   • This Policy describes Flowapay’s internal arrangements and controls for the handling of Client Funds and does not constitute a guarantee or insurance of funds.
     
     
3. SCOPE OF APPLICATION
   • 1 This Policy applies to all Client Funds received, held, processed, or settled by Flowapay in connection with the Services.
   • Flowapay provides Services exclusively on a business-to-business basis, including to licensed online gaming and digital commerce operators.
   • This Policy forms part of Flowapay’s broader compliance, risk management, and operational control framework and is supplemented by contractual arrangements with business customers.
   • Flowapay does not receive, hold, or process funds on behalf of consumers or the general public.
     
     
4. NATURE OF CLIENT FUNDS
   • Client Funds are funds received by Flowapay for the purpose of processing payment transactions, settlements, or related services on behalf of business customers.
   • Client Funds do not constitute deposits and are not treated as Flowapay’s own property.
   • Flowapay does not use Client Funds for its own operational expenses, investments, lending activities, or proprietary purposes.
   • Flowapay does not store, process, or transmit cardholder data. All card payment data is handled by PCI DSS Level 1 certified third‑party payment platforms.
     
     
5. SEGREGATION OF CLIENT FUNDS
   • Flowapay maintains Segregated Accounts for the purpose of holding Client Funds.
   • Client Funds are held separately from Flowapay’s own corporate or operational funds and are recorded distinctly in Flowapay’s internal accounting records.
   • Segregated Accounts are held in Flowapay’s name and designated for the exclusive purpose of holding Client Funds.
   • Flowapay does not intentionally commingle Client Funds with its own funds.
   • Segregation of Client Funds is an operational control measure and does not constitute regulatory safeguarding as defined under EU or UK electronic money or payment services legislation.
     
     
6. RECONCILIATION AND CONTROLS
   • Flowapay maintains internal accounting and reconciliation procedures designed to:
     • track Client Funds received and disbursed
     • identify discrepancies or irregularities;
     • support accurate settlement and reporting.
   • Reconciliations are performed on a regular basis in accordance with Flowapay’s internal control framework.Access to Segregated Accounts is restricted
     
     
7. USE AND MOVEMENT OF CLIENT FUNDS
   • Client Funds may be moved only for the purposes of:
     • executing payment transactions as instructed by business customers;
     • settling funds to merchants or designated counterparties;
     • processing refunds or chargebacks in accordance with contractual terms;
     • complying with legal or regulatory obligations.
   • Flowapay may temporarily hold Client Funds where required for operational processing, reconciliation, or regulatory compliance.
     
     
8. INSOLVENCY AND LIMITATIONS
   • Client Funds are held in Segregated Accounts to reduce the risk of misuse and to support orderly administration in the event of Flowapay’s insolvency.
   • This Policy does not constitute a guarantee that Client Funds will be protected against all losses in the event of insolvency.
   • Client Funds are not insured, are not covered by any deposit protection scheme, and are not safeguarded under an EU electronic money or payment institution regime.
     
     
9. REGULATORY AND LEGAL DISCLOSURES
   • Flowapay handles Client Funds in accordance with applicable Canadian MSB requirements and contractual obligations with business customers.
   • Flowapay may disclose information relating to Client Funds to banks, financial institutions, regulators, or law enforcement authorities where required by applicable law or regulation.
     
     

10. RESPONSIBILITIES OF BUSINESS CUSTOMERS
    • Business customers remain responsible for compliance with applicable gaming, consumer protection, and payment regulations in the jurisdictions in which they operate.
    • Flowapay does not assume responsibility for the underlying legality of a business customer’s activities or for end-user obligations beyond the scope of the Services.
      
      
11. POLICY REVIEW AND AMENDMENTS
    • Flowapay may amend this Policy from time to time to reflect changes in law, regulation, operational practices, or risk management requirements.
    • The current version of this Policy shall be made available on Flowapay’s website and shall apply from the date of publication.
      
      
12. CONTACT DETAILS
    • For questions relating to this Policy, please contact:
      • Email: compliance@flowapay.io
      • Postal Address: FLOWA PAY INC., 997 Seymour St., Suite 250 – #1605, Vancouver, BC V6B 3M1, Canada