Terms and Conditions

1. Regulatory status

CobbyPay is registered in Canada with the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) as a Money Services Business, registration no. M23204811 (MSB registration effective 8 June 2023, valid to 18 February 2028). CobbyPay is also registered with the Bank of Canada as a payment service provider (“PSP”) under the Retail Payment Activities Act (“RPAA”). CobbyPay’s Bank of Canada PSP registration took effect on 7 April 2026. Registration with FINTRAC or the Bank of Canada does not make CobbyPay a bank and does not constitute a government guarantee or endorsement of CobbyPay or its services.

CobbyPay is not a bank. Funds made available through CobbyPay are not bank deposits with CobbyPay and are not represented by CobbyPay as being protected by the Canada Deposit Insurance Corporation or any other deposit guarantee scheme.

2. Services

Subject to eligibility, jurisdiction, compliance approval, product availability and third-party infrastructure, CobbyPay may provide or facilitate payment accounts or payment functionality, domestic and international electronic funds transfers, collection and payout services, foreign exchange, merchant or business payment services, payment initiation or transmission, cards through authorized partners, and services relating to virtual currency or stablecoins where legally permitted.

A service may be provided directly by CobbyPay or through banks, payment institutions, electronic money institutions, card issuers, payment processors, correspondent institutions, liquidity providers, custodians, blockchain infrastructure providers or other duly authorized third parties. Product descriptions on the website do not guarantee availability to every Client or jurisdiction.

3. Eligibility and authority

• You must have legal capacity to enter into a binding agreement and satisfy CobbyPay’s onboarding and risk requirements.
• If acting for a legal entity, you represent that you are duly authorized to bind it and give instructions on its behalf.
• You must provide complete, accurate and current information and promptly notify CobbyPay of material changes.
• CobbyPay may decline onboarding or restrict products based on jurisdiction, risk appetite, regulatory obligations or third-party availability.

4. Identification, AML/ATF, sanctions and compliance

CobbyPay is subject to Canadian anti-money laundering and anti-terrorist financing requirements, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and related regulations. You must provide information and documents reasonably requested for KYC/KYB, beneficial ownership, source of funds, source of wealth, purpose of transactions, sanctions screening, fraud prevention, tax or regulatory compliance.

CobbyPay may delay, reject, hold, restrict, return, reverse where operationally possible, or refuse a transaction; request additional information; suspend an account; or terminate a relationship where required or permitted by law, regulation, sanctions, court or regulatory direction, or CobbyPay’s risk controls. Applicable law may prohibit CobbyPay from explaining certain compliance actions or reports.

5. Payment instructions and authorization

Instructions submitted using authenticated credentials, approved users, API credentials, authorized email channels or other agreed authentication methods may be treated as authorized. You are responsible for checking beneficiary names, account identifiers, IBANs, routing details, wallet addresses, blockchain networks, currencies, amounts and references before submission.

Submission or acknowledgement of an instruction does not mean that the transaction is final or irrevocably accepted. Processing may depend on cut-off times, settlement systems, compliance review, liquidity, third-party availability and network conditions.

6. End-user funds and safeguarding

Where CobbyPay holds end-user funds within the scope of the RPAA, CobbyPay maintains safeguarding arrangements and a safeguarding-of-funds framework intended to meet applicable RPAA and Retail Payment Activities Regulations requirements, including reliable access to safeguarded funds and protection of end-user funds in the event of CobbyPay’s insolvency, as applicable to the relevant service and arrangement.

Safeguarding is not the same as deposit insurance. The precise flow and safeguarding treatment of funds may depend on the product, currency, payment rail and third-party provider. Additional information is set out in CobbyPay’s Safeguarding of End-User Funds Disclosure.

7. Foreign exchange

Displayed or quoted foreign-exchange rates may be indicative until confirmed. CobbyPay may apply a spread, margin or fee. Once an FX transaction is executed it may be irreversible, and cancellation may be subject to CobbyPay’s consent, market movement and third-party costs.

8. Virtual currency and stablecoins

Digital assets and stablecoins may involve volatility, de-pegging, liquidity, technology, smart-contract, cybersecurity, blockchain, regulatory and counterparty risks. Blockchain transfers may be irreversible. You are responsible for the accuracy and compatibility of wallet addresses and networks. CobbyPay does not provide investment, tax or legal advice.

9. Fees and third-party charges

Applicable fees, spreads, margins, network costs and third-party charges may be disclosed in a fee schedule, transaction quote, platform notice, invoice or separate agreement. You authorize CobbyPay to debit amounts properly due from balances or settlement amounts where permitted by the applicable service agreement. Fees are non-refundable except where required by law or expressly agreed.

10. Security and unauthorized activity

You must protect credentials, devices, passwords, API keys and authentication factors and promptly notify CobbyPay of suspected compromise, fraud or unauthorized activity. CobbyPay may apply security holds, enhanced authentication, transaction limits or other controls to protect Clients and payment systems.

11. Restricted activities

You must comply with CobbyPay’s Acceptable Use and Prohibited Activities Policy. CobbyPay may refuse or terminate activity involving unlawful conduct, fraud, sanctions evasion, money laundering, terrorist financing, prohibited jurisdictions, unlicensed financial services, ransomware, darknet activity, mixers or other activity outside CobbyPay’s risk appetite.

12. Suspension, closure and termination

CobbyPay may suspend, restrict or terminate Services where required or permitted by law, where a Client breaches these Terms, where information is not provided, where security or fraud concerns arise, where a third-party relationship becomes unavailable, or where continued service would create unacceptable legal, regulatory, operational, financial or reputational risk.

You may request account closure, subject to pending transactions, investigations, legal holds, outstanding obligations, record-retention requirements and lawful restrictions. Any remaining funds will be dealt with in accordance with applicable law and the relevant service arrangements.

13. Records, privacy and communications

CobbyPay may collect, use, disclose, transfer and retain information in accordance with its Privacy Policy and applicable law. Electronic notices may be delivered through the website, platform, registered email address or other agreed electronic channel.

14. Service availability and third parties

Services are provided on an “as available” basis. CobbyPay does not guarantee uninterrupted access or a particular settlement time unless expressly agreed. To the extent permitted by law, CobbyPay is not responsible for failures caused by payment networks, banks, correspondents, card schemes, blockchain networks, telecommunications, force majeure or other third parties outside its reasonable control.

15. Liability

To the maximum extent permitted by applicable law, CobbyPay will not be liable for indirect, incidental, special, exemplary, punitive or consequential loss, including loss of profits, business, opportunity or goodwill. Nothing in these Terms excludes or limits liability, rights or remedies that cannot lawfully be excluded or limited, including any mandatory rights under applicable payment, privacy or consumer protection law.

16. Complaints

Complaints may be submitted to support@cobbypay.com. CobbyPay will acknowledge, investigate and respond to complaints under its Complaints Handling Policy and applicable legal and regulatory requirements. Privacy complaints may also be directed to info@cobbypay.com.

17. Amendments

CobbyPay may amend these Terms to reflect changes in law, regulation, products, risk controls, third-party infrastructure or business practices. Material changes will be communicated by reasonable means where required. The effective date of the current version will be displayed on the website.

18. Governing law

These Terms are governed by the applicable laws of Canada and the province or territory specified in the Client’s applicable service agreement or, where none is specified, the province or territory in which CobbyPay’s relevant Canadian establishment is located, subject to mandatory laws that apply to the Client. Nothing in this clause overrides a mandatory statutory forum or remedy.

19. General

If any provision is invalid or unenforceable, the remaining provisions continue in effect. A failure to enforce a provision is not a waiver. You may not assign your rights without CobbyPay’s prior written consent. CobbyPay may assign or transfer rights or obligations where permitted by law, including as part of a corporate reorganization or transfer of business.

20. Contact

General enquiries: info@cobbypay.com
Complaints and support: support@cobbypay.com

Registered office
1907 Baseline Road, Unit 104
Ottawa, Ontario K2C 0C7, Canada