NODA FINTECH INC.
NodaPay is a brand operated by NODA FINTECH INC.
1. Introduction
NODA FINTECH INC., operating the NodaPay brand (hereinafter referred to as the “Company”, “we”, “us” or “our”) is committed to providing reliable, transparent and secure payment services and ensuring that all customer complaints are addressed fairly, consistently and in a timely manner.
The Company maintains a structured complaints handling process designed to protect customers’ interests, facilitate the effective resolution of disputes and identify potential deficiencies in its payment services.
2. Purpose and Scope
The purpose of this Policy is to establish a transparent and accessible procedure for receiving, reviewing, investigating and resolving complaints relating to the Company’s products, services and retail payment activities.
This Policy applies to complaints submitted by existing and former customers, end users and other persons directly affected by the Company’s payment services.
Complaints may concern:
- Delayed, unsuccessful or incorrectly executed payment transactions;
- Unauthorized or disputed transactions;
- Inaccurate transaction information;
- Fees, commissions or exchange rates;
- Restrictions or delays affecting access to customer funds;
- Technical failures or interruptions of payment services;
- Customer service or communication issues;
- Privacy, confidentiality or security concerns;
- Other matters relating to the Company’s services.
Complaints indicating operational risks or incidents shall be assessed with reference to Section 17 of the RPAA and Section 5 of the RPAR.
3. Regulatory Framework
The Company conducts its activities in accordance with applicable Canadian laws and regulatory requirements, including, where applicable:
- Retail Payment Activities Act (RPAA);
- Retail Payment Activities Regulations (RPAR);
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA);
- Personal Information Protection and Electronic Documents Act (PIPEDA);
- FINTRAC Compliance Program Requirements.
Where a complaint identifies a potential operational incident, security breach or issue affecting the safeguarding of end-user funds, the Company shall assess the matter in accordance with applicable regulatory obligations and internal risk management procedures.
The Company shall comply with all applicable regulatory notification and reporting requirements.
4. Submission of Complaints
Customers may submit complaints free of charge through the following channels:
Email: info@nodapay.ai
Website: https://nodapay.ai
Postal Address: 300-1095 McKenzie Avenue, Victoria, British Columbia, V8P 2L5, Canada
Customers are encouraged to provide:
- Full name and contact information;
- Transaction reference number, where applicable;
- Description of the complaint;
- Date of the relevant transaction or event;
- Supporting documents or other relevant evidence;
- Expected resolution, where appropriate.
The Company may request additional information where reasonably necessary to investigate the complaint.
The absence of some information shall not automatically prevent the Company from registering and assessing a complaint.
For complaints relating to the handling of personal information, the Company shall apply the procedures established under PIPEDA, Schedule 1, Principle 4.10 (Challenging Compliance).
5. Acknowledgement of Complaints
Upon receipt of a complaint, the Company shall register it in its internal complaints register and assign a reference number.
The Company aims to acknowledge receipt of a complaint within five (5) business days.
The acknowledgement shall, where appropriate, include:
- Confirmation that the complaint has been received;
- A complaint reference number;
- Information about the review process;
- An indicative timeframe for providing a response;
- Contact information for further communication.
Complaints shall be handled confidentially and without unnecessary delays.
The acknowledgement timeframe is an internal Company service standard and is not a statutory deadline under the RPAA.
6. Complaint Investigation and Resolution
All complaints shall be reviewed objectively and fairly by authorized Company personnel.
The Company shall:
- Assess the nature and circumstances of the complaint.
- Review relevant transaction records, communications and supporting documentation.
- Investigate any potential operational failures, errors or deficiencies.
- Consult relevant internal departments or third-party service providers where necessary.
- Determine appropriate corrective measures or remedies.
- Communicate the outcome to the complainant.
The Company aims to provide a final response within fifteen (15) business days from receipt of the complaint.
Where additional investigation is required, the Company shall inform the complainant of the reason for the delay and provide an updated expected response date.
The Company shall make reasonable efforts to resolve all complaints promptly.
Where an investigation identifies potential operational risks or incidents, the Company shall assess these matters in accordance with RPAA, Section 17 and RPAR, Section 5.
The fifteen-business-day timeframe is an internal service commitment, not a statutory deadline imposed by the RPAA.
7. Complaint Resolution
Following the investigation, the Company shall provide a clear response explaining the outcome of the complaint.
Depending on the circumstances, the resolution may include:
- Clarification or explanation of the relevant transaction or service;
- Correction of an identified error;
- Reprocessing of an unsuccessful transaction;
- Refund or reimbursement, where applicable;
- Correction of incorrectly applied fees;
- Implementation of measures to prevent recurrence;
- Rejection of the complaint with an explanation of the reasons.
Any refund, reimbursement or compensation shall be assessed in accordance with applicable law, contractual terms and the circumstances of the case.
The Company shall not guarantee reimbursement where there is no legal or contractual entitlement to such reimbursement.
8. Escalation of Complaints
If a complainant is dissatisfied with the initial resolution, they may request a further review.
Escalated complaints shall be referred to the Company’s designated senior management representative or Compliance Officer, as appropriate.
The review shall be performed by a person who was not directly responsible for the initial decision, where reasonably practicable.
The Company shall communicate the outcome of the escalation to the complainant.
Customers may also raise concerns with an applicable external authority or dispute resolution body where such recourse is available under relevant legislation.
The Bank of Canada supervises compliance with the RPAA but does not act as a general customer dispute resolution or compensation body.
Where an escalated complaint identifies a potential operational risk or incident, the matter shall be assessed in accordance with the Company’s operational risk management and incident response framework, established pursuant to RPAA, Section 17.
9. Operational Incidents and End-User Funds
Where a complaint indicates a potential operational incident affecting the Company’s retail payment activities, the matter shall be assessed under its Operational Risk Management and Incident Response Framework.
Such matters may include:
- Payment service disruptions;
- Unauthorized access to payment systems;
- Security or confidentiality breaches;
- Material transaction processing failures;
- Incidents affecting the availability or integrity of payment services;
- Events restricting end users’ access to funds held by the Company.
9.1 Incident Notification
Where an incident has a material impact on end users, other payment service providers or relevant clearing houses, the Company shall comply with the notification obligations established under RPAA, Section 18 - Requirement to Notify.
The Company shall notify the Bank of Canada and materially affected parties without delay, in accordance with the applicable statutory requirements.
The form, manner and content of the notifications shall comply with RPAR, Sections 11 and 12.
Where contact information is unavailable for every materially affected person or entity, the required incident notice shall also be posted on the Company’s website in accordance with RPAR Section 12.
9.2 Safeguarding of End-User Funds
Where the Company holds end-user funds within the meaning of the RPAA, complaints concerning access to or protection of those funds shall be assessed under its Safeguarding-of-Funds Framework in accordance with RPAA, Section 20 - Safeguarding of Funds and RPAR, Section 15 - Safeguarding-of-Funds Framework.
The Company shall investigate relevant complaints to identify potential deficiencies in safeguarding arrangements and take appropriate corrective action.
10. Confidentiality and Data Protection
The Company shall protect personal and confidential information obtained during the complaints handling process.
Personal information shall be collected, used, retained and disclosed in accordance with applicable privacy and data protection legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA).
Access to complaint records shall be restricted to authorized personnel who require such information for the performance of their duties.
Personal information shall not be disclosed to unauthorized third parties except where permitted or required by law.
11. Record Keeping
The Company shall maintain an internal register of complaints to support effective monitoring, accountability and regulatory compliance.
The register may include:
- Date of complaint receipt;
- Customer identification or reference information;
- Complaint category and description;
- Relevant transaction details;
- Investigation actions and findings;
- Responsible employee or department;
- Date and content of the response;
- Resolution and corrective actions;
- Escalation history, where applicable.
Complaint records shall be retained in accordance with the Company’s record retention procedures and applicable statutory requirements.
Where records are required to demonstrate compliance with the RPAA and RPAR, the Company shall apply the retention requirements prescribed by RPAR, Section 40 - Record Keeping and Retention.
Such records must generally be retained until five years after the date on which they cease to demonstrate the Company’s current compliance with the applicable requirements, subject to relevant statutory exceptions.
The Company shall also implement appropriate protective measures for regulatory records in accordance with RPAR, Section 41.
This does not mean that every ordinary customer complaint is automatically subject to the RPAA statutory retention requirement.
12. Monitoring and Continuous Improvement
The Company shall periodically review complaints to identify recurring issues, operational deficiencies and potential risks affecting customers or payment services.
Where systemic issues are identified, appropriate corrective actions shall be implemented.
Relevant findings may be considered as part of the Company’s operational risk assessments, internal controls and compliance monitoring activities.
Where complaints reveal operational risks or weaknesses in the risk management and incident response framework, the Company shall assess whether updates are necessary under RPAR, Section 5.
13. Policy Review
This Policy shall be reviewed at least annually and whenever material changes occur in the Company’s business activities, regulatory requirements or complaints handling procedures.
Any amendments shall be approved by the Company’s designated management representative.
The Company shall ensure that the current version of this Policy is available to customers through its official website.
The annual review of this Complaints Handling Policy is an internal Company standard.
Separately, the mandatory review of the Operational Risk Management and Incident Response Framework is governed by RPAR, Section 8 - Review.
14. Contact Information
For questions, concerns or complaints relating to the Company’s payment services, please contact:
NODA FINTECH INC.
NodaPay is a brand operated by NODA FINTECH INC.
Incorporation number: BC1532562
Business number: 709331623 BC0001
FINTRAC MSB registration number: C100000891
Email: info@nodapay.ai
Website: https://nodapay.ai
Registered Address: 300-1095 McKenzie Avenue, Victoria, British Columbia, V8P 2L5, Canada
The Company is committed to reviewing complaints fairly, professionally and promptly and continuously improving the quality and reliability of its services.