Kappa Pay Inc. and its affiliates (“Kappa Pay,” “we,” “us,” or “our”) respect your privacy. This Privacy Policy describes the processing of Personal Information (defined below) that is provided, collected, or shared on the sites, applications, social media pages, or other platforms that link to this Privacy Policy (collectively, the “Service”). It also describes your choices about the collection, sharing, and use of your Personal Information.

We may collect a range of “Personal Information:”

• “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you and/or your business.

Important information about procedures for opening a new account:

• “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you and/or your business.

What this means for you:

• When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

The types of “Personal Information” we collect may include:

• Contact Information - If you submit an inquiry, register for an account, or provide information on our Service, we may collect your contact information. This may include your name, address, date of birth, email address, phone number, and other information that will allow us to identify you, such as a driver’s license.
• Financial Information - If you use our Service to make or receive payments, we will collect your financial information, including your name, social security number, ID card number, and account information.
• Location Data - While navigating our Service your mobile device or browser may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your phone and browser.
• Usage Information - When you use our Service, our servers may automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Service), domain names associated with your Internet service provider, information on your interaction with the Service, and other such information.
• Communication Information - We may collect audio, electronic, or visual information, which includes screen sharing views; any data in any files uploaded, emailed or otherwise provided by customers; the contents of your communications with us, whether via email, social media, telephone, or otherwise; and inferences we may make from other Personal Information we collect.

We may collect your Personal Information directly from you:

• For example, if you register for an account on the Service, or request or purchase products, services, or information from us.

We may also collect Personal Information from third parties:

• For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.

Through online tracking technologies:

• We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Service. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Service, to enhance your experience through personalization, and to help us better understand the features of the Service that you and other users are most interested in.
• Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Service may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.
• Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Service and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy policy of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, visit https://allaboutdnt.com.

Through analytics:

• We use analytics services, including Google Analytics, to assist us with analyzing our website traffic through cookies and similar technologies. For more information on Google Analytics’ processing of your Personal Information, see https://policies.google.com/technologies/partner-sites?hl=en-US. You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

To the extent permitted by applicable law, we may use Personal Information to:

• Operate the Service and provide support to our business functions;
• Fulfill customer requests, such as to create an account or complete customer purchases;
• Protect against criminal activity, claims, and other liabilities;
• Send you information about our company, products, services, and promotions;
• Respond to reviews, comments, or other feedback provided to us;
• Support and personalize the Service and our advertising efforts;
• Protect the security and integrity of the Service;
• Provide customer support;
• The extent required for benchmarking, data analysis, audits, developing new products, enhancing the Service, facilitating product, software and applications development, improving the Service, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
• Meet our contractual requirements;
• Comply with applicable legal or regulatory requirements and our policies;
• Respond to inquiries related to employment opportunities;
• Market, advertise, and provide the Service; and
• The extent necessary for any other lawful purpose for which the Personal Information is collected.

We may share the Personal Information identified in Section 1 of this Privacy Policy in the following circumstances:

For legal obligation or safety reasons:

• When we have a good faith belief that access, use, preservation, or disclosure of Personal Information is reasonably necessary to a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, b) enforce or investigate a potential violation of the Terms & Conditions, c) detect, prevent, or otherwise respond to fraud, security, or technical concerns, d) support auditing and compliance functions, or e) protect the rights, property, or safety of Kappa Pay, its users, or the public against harm.

In the case of a merger or sale:

• If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.

To service providers:

• When we hire a service provider to help operate the Service or our business, we may give access to Personal Information as necessary to perform the service for Kappa Pay. This may include service providers that operate our Service, send our communications, or run our promotions.

To business partners:

• We may share Personal Information with our trusted business partners. For example, we may share your Personal Information with a company when we co-sponsor a promotion or service. These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.

To third parties for marketing purposes:

• We may share your Personal Information with third parties for their marketing purposes. This may include third parties whose services we believe you may be interested in, or who are interested in providing you with services.

For residents of Nevada, USA:

• We are providing you this notice under state law. You may be placed on our internal Do Not Call List by following the directions in Section 8 of this Privacy Policy. Nevada law requires we provide the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101 USA; phone number: +1 (702) 486-3132; email: aginfo@ag.nv.gov; Kappa Pay Inc., 75 State Street, 1st Floor, Boston, MA 02109 USA; phone number: +1 (833) 922-8222; email: legal@kappapay.com.

For residents of California, New Mexico, North Dakota, and Oregon, USA:

• We will not share information we collect about you with nonaffiliates, unless the law allows. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit sharing among our companies to the extent required by law. If you are a resident of California, please see the information below in Section 13 (California Residents) for more information regarding your rights.

For residents of Vermont, USA:

• We will not disclose information about your creditworthiness to our affiliates and will not disclose your Personal Information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. For additional information concerning our privacy policies, call us at +1 (833) 922-8222.

This Service is hosted in the United States. If you are visiting this Service from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected, or processed in the United States, where our data center and servers are located and operated.

We do not knowingly collect or solicit any Personal Information from children under the age of 18. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at legal@kappapay.com or contact us using the information listed in Section 14.

We are not responsible for the practices employed by any websites or services linked to or from the Service, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy policy.

We are not responsible for the practices employed by any websites or services linked to or from the Service, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy policy.

When we use the term “Personal Information” in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 14.

Categories of Personal Information collected, used, and shared:

In accordance with California law, we may have collected and shared the following categories of Personal Information within the past 12 months:

Identifiers:

• A real name, Internet Protocol address, email address, and online identifiers.
• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)):
  E.g., a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
• Internet or other similar network activity:
  Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
• Geolocation data:
  Physical location or movements.
• Protected classification characteristics under California or federal law:
  Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
• Professional or employment-related information:
  Current or past job history or performance evaluations.

We share each of these categories of Personal Information with our service providers to the extent necessary for them to facilitate our business purposes. We also share this Personal Information for the purposes set forth in Section 4 above.

Your California privacy rights:

• If you are a resident of California, you may have the following rights:

If you would like to exercise your rights listed above, send (or have your authorized agent send) an email to legal@kappapay.com or call us toll-free at +1 (833) 922-8222.

Note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes (e.g., tax accounting). You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.

The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at +1 (916) 210-6276.

Note that we may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with an updated Privacy Policy if material changes are made. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Service.

If you have any questions about our practices or this Privacy Policy, please contact us at +1 (833) 922-8222 or hello@kappapay.com.