REAL TIME PAYMENTS LLC

PRIVACY POLICY

Effective Date: September 8, 2023

Introduction.

Privacy Policy.We are committed to safeguarding the privacy of our website visitors and respecting their right to data privacy. As such, this Privacy Policy (“Privacy Policy”) applies to information we collect or use on our websites, including https://paymentcenter.qpay123.com, https://extaoa.qpay123.com or any related Web Pages (Collectively referred to as the “Website”) and any products, features, services, memberships, applications, widgets, or any portion thereof (collectively, the “Services”), owned or controlled by Real Time Payments LLC, or its affiliated companies, which are entities that control, are controlled by or are under common control with us (“Affiliates”) (collectively, the “Company” or “we” or “our” or “us”).

Changes to Privacy Policy. Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and at our sole discretion. We encourage visitors to frequently check this page for any changes to the Privacy Policy. Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of the changes. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you and for periodically visiting this privacy policy to check for any changes.

Terms of Service. This Privacy Policy and our Terms of Service, which are located at https://paymentcenter.qpay123.com and https://extaoa.qpay123.com (the “Terms of Service”), which is incorporated herein by reference, are an agreement (collectively, this “Agreement”) between you (“You” or “your” or “you”), a user of the Services, and us. By using our Website or any of our Services, you acknowledge and agree to this Privacy Policy, and consent to our use of cookies in accordance with the terms of this Privacy Policy. You also acknowledge and agree that the Terms of Service is an agreement between You and us, and you may become subject to other terms and conditions as a result of using our Services.

Third-Party Links. The Services may contain third-party links to other websites or services, which we do not control or own. Please be aware that we are not responsible for the content or privacy practices of such other third-party websites or services, and your use of such websites or services may be subject to other or different terms and conditions. We encourage our users to be aware when they leave the Services and to read the privacy statements of any other site that collects personal information. When you use the Services or its content, certain third parties may use automatic information collection technologies to collect information about you or your device.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Information We Collect.

We may collect, store and use the following kinds of personal information:

(a) information about your computer and about your visits to and use of the Services including your Internet Protocol (IP) address, geographical location, browser type and version, devise characteristics, operating system, language preferences, referral source, and information on action taken on the Website, such as your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, length of visit, page views, website navigation paths and other technology on the devices you use to access this website;

(b) information that you provide to us when registering with the Services including, but not limited to, your email address;

(c) information that you provide to us when using the Services, or that is generated in the course of the use of those services including the timing, frequency and pattern of service use;

(d) information relating to any purchases you make of our goods and/or services or any other transactions that you enter into through the Services including your name, address, telephone number, email address, fax number, bank account number, bank routing number, and credit card details;

(e) content that you submit to or through the Services or via links to social media networks, forums, instant messaging, chat, blogs, message boards, chat rooms or similar functionality, including audio recordings, software code, videos, photos, images, text, information (including, without limitation, personal information), user comments, and any other content (collectively, “Content”)

(f) information contained in or relating to any communication with us or our third-party service providers for customer support or other communications, including, without limitation, records and copies of correspondence and responses to surveys for research purposes;

(g) information from and about the devices you use to access the Services, including attributes such as the operating system, hardware version, device settings, file and software names, types, battery and signal strength, device identifiers, device locations, specific geographic locations (such as GPS, Bluetooth, Wi-Fi signals), connection information such as the name of your mobile operator or ISP, browser type, language, time zone, mobile phone number and IP address.

(h) in connection with your visit or use of the Services, we may automatically collect information about our users, such as the numbers and frequency of users and their characteristics and information about similar groups of users, certain age groups or users that live in a particular geographical area. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and beacons;

(i) when you access or use the Services, or any portion thereof, we may collect physical location information that is sufficiently precise to allow us to locate a specific person or device (“ Location Information ”). We only collect Location Information with your permission (e.g., such as when you agree to provide it to us after you initially access or use the Services). We may use Location Information to provide you with content and services that are relevant to a particular location, such as advertising, search results, and directions;

(j) the Services may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information;

(k) information that you provide to us when additional verification by bank or compliance authority is needed according to governmental rules, anti-money laundering (AML) or “know-your-customer” (KYC) policies, including, but not limited to, master agent name, company legal name, company DBA name, business type, phone number, country, state, business address, city, zip code, FEIN, email, bank name, bank routing number, bank account number, driver’s license number, and social security number; and

(l) any other personal information that you choose to send to us.

We may collect, store and use information obtained by automated means through the Services such as, cookies, web beacons, web server logs, JavaScript and similar technologies, including technologies designed to obtain information regarding your use of the Services:

(a) “Cookies” are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in the Services are visited and by how many people. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website The “Help” portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We recommend that you leave the cookies activated because cookies allow you to use many features of the Services. For more information, please refer to Section 5 of the Privacy Policy.

(b) “Web Beacons,” also known as Internet tags, pixel tags, single-pixel GIFS or clear GIFs, link web pages to web servers and their cookies. Web Beacons can be embedded in web pages, videos, or emails, to collect certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the content, the IP address of your computer, and the Uniform Resource Locator (URL) of the web page from which the content was viewed. We may use this information to reduce or eliminate messages sent to a user.

(c)“Web Server Logs,” including browser types, Internet service providers (ISPs), referring/exit pages, platform types, date/time stamps, number of clicks, and IP addresses. An IP address is a number that is automatically assigned to your computer whenever you access the Internet, which web servers use to identify where to send the information your computer requests. We may use IP addresses for a number of purposes, such as system administration, to report aggregate information to our business partners, or to audit the use of our Services.

(d) “Local Shared Objects,” sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit.

(e) “Ad IDs” and Other In-App Tracking Methods . There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app.

In using some features of the Services, you may also be able to submit information about other people. Before you disclose to us the personal information of another person, you must obtain that person’s consent, and you hereby represent that you have obtained such consent from such person, to both the disclosure and the processing of that personal information in accordance with this Privacy Policy.

How We Use Your Information.

Personal information submitted to us through our website will be used for the purposes specified in this Privacy Policy or on the relevant pages of the Services.

We may use your personal information to:

(a) To provide, operate, maintain, improve, and promote the Services, and any other information, products or services that you request from us;

(b) To enable you to access and use the Services, including uploading, downloading, collaborating and sharing content, photos, images, videos and information, with other users or third parties;

(c) To process, verify, and complete transactions, and send you related information, including purchase confirmations and invoices, to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, collection and enforcement, and to build a user database;

(d) To send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; sending you technical notices, updates, security alerts, and support and administrative messages sending statements, invoices and payment reminders to you, and collecting payments from you; and, when we have location information, we use it to tailor our Services for you and others;

(e) To send promotional communications, such as providing you with information about services, features, newsletters, offers, promotions, contests, events and sending updates;

(f) To monitor and analyze trends, usage, and activities in connection with the Services and for marketing, advertising, administrative, analytical, research, optimization, and other purposes. For example, we may use statistical analyses of usage data in order to measure interest in the various areas of the Services, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes;

(h) To investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;

(i) To personalize the Service’s content, features or advertisements;

(j) To deal with inquires and complaints made by or about you relating to the Services;

(k) To verify compliance with the terms and conditions governing the use of the Services;

(l) To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies; and

(m) To conduct a periodic review of your background causing a consumer and commercial report to be generated.

If you submit personal information, including Content, for publication on the Services, we will publish and otherwise use that information in accordance with the license you grant to us, and by submitting such information to us, you hereby grant us a worldwide, revocable, sublicensable and royalty-free license to use such personal information for our business purposes. You shall be solely responsible for your own Content and the consequences of submitting and publishing your Content on the Services. You further agree that you will not submit to the Services any Content or other material that is contrary to this Privacy Policy or contrary to applicable local, national, and international laws and regulations.

Disclosing Personal Information.

Service Providers. We engage service providers to perform functions and provide services to us. We may share your private personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

Authorized Personnel. Our employees, agents, consultants, contractors, or other authorized personnel, including those of our contractors, service providers, subsidiaries and affiliates, may have access to user information as necessary in the normal course of our business.

Business Transfers. In some cases, we may choose to buy or sell assets, or have engaged in discussions with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Services users is among the assets transferred. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if the Services, the Company, or substantially all of its assets, were acquired, liquidated, or dissolved, personal information would be one of the assets that is transferred.

Government, Law Enforcement or Third Parties. We may disclose any information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of the Company and its affiliates, personnel, users, third parties, or others. We reserve the right to disclose a user’s Personal Information if we believe, in good faith, that the user is in violation of the Terms of Service, even without a subpoena, warrant or other court order.

Your Rights.

We will provide you with an opportunity to exercise certain controls and choices regarding our collection, use and sharing of your information through Opt-out options.

In accordance with local law, your controls and choices may include:

a) You may correct, update and delete your account information, as described below;

b) You may change your choices for subscriptions and newsletters;

c) You may choose whether or not to receive offers from us;

d) You may choose whether you received targeted advertising from us or our partners.

Opt-out. We have created the following mechanisms to provide you with control over certain uses and disclosures of your information:

● Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website . If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

● Location Information. You can choose whether or not to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Services may then be inaccessible or not function properly.

● Promotion by the Company. If you do not wish to have your email address or contact information used by the Company to promote our own or third parties' products or services, you can opt-out by following the unsubscribe instructions provided in the e-mail you receive or contacting us directly at RTPCompliance@rt2.com . If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

● Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by following the unsubscribe instructions provided in the e-mail you receive or contacting us directly at RTPCompliance@rt2.com .

● Targeted Advertising.If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by following the unsubscribe instructions provided in the e-mail you receive or contacting us directly at RTPCompliance@rt2.com . You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by providing us notice at RTPCompliance@rt2.com .

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (the “NAI”) by visiting http://www.networkadvertising.org/index.asp .

Accessing and Correcting Your Information.

If you have an account, you can help ensure that your contact information and preferences are accurate, complete, and up to date by logging into your account or by emailing us at RTPCompliance@rt2.com . For other personal information we hold, we will provide you with access for any purpose including requesting that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to his/her personal information records. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. If you delete your Content from the Services, copies of your Content may remain viewable in cached and archived pages, or might have been copied or stored by other Services users. Proper access and use of information provided on the Services, including Content, is governed by our Terms of Service, available at https://paymentcenter.qpay123.com and https://extaoa.qpay123.com.

Notice to California Residents.If you are a California resident, you may have certain additional rights.

California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. To make any such requests, please email us at RTPCompliance@rt2.com or write us at 100 SE 2 ^nd Street, Ste 2000, Miami, FL 33131.

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take action to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

Retaining personal information

This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

Personal information that we process for any purpose or purposes may be maintained.

Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:

(a) to the extent that we are required to do so by law;

(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Security of Personal Information

We will take reasonable administrative, technical, organizational and physical precautions to safeguard against the loss, misuse or alteration of your personal information. These safeguards vary based on the sensitivity of the information that we collect and store. For example, when processing sensitive personal data (such as data about ethnic or racial origin, political opinions/union membership, data concerning health, sex life or sexual orientation, genetic data, or biometric data) or data that reveals sensitive personal data, especially when using data profiling extra safeguards will be added.

We will store all the personal information you provide on our secure password- and firewall-protected servers.

We will notify consumers and regulatory authorities in case of breach without undue delay.

You acknowledge that the transmission of information over the internet is inherently insecure, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy.

You acknowledge that the safety and security of your information also depends on you. You are responsible for keeping the password you use for accessing the Services confidential; we will not ask you for your password (except when you log in to our Services).

Users from Other Jurisdictions

The Service is controlled and operated by us from the United States. If you choose to use the Services or provide information to us, please note that we may transfer your information, including personal information, in and to the United States and process it there.

We do not represent or warrant that the Services, or any portion thereof, are appropriate, lawful, or available for use in any particular jurisdiction. Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: The United States of America.

Those who choose to access the Services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations, and are subject to United States export controls in connection with your use of the Services and are responsible for any violations of such controls, including, without limitation, any United States embargoes or other federal rules and regulations restricting exports.

We may limit the availability of the Services, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion.

Personal information that you publish on the Services or submit for publication on our Website may be available, via the Internet, around the world. We cannot prevent the use or misuse of such information by others.

You expressly agree to the transfers of personal information described in this Section.

Notice to Users in The European Union .

If you are a user in the European Union, you should know that we are the controller of your personal information. Here is some additional information we would like to bring to your attention:

Bases for using your information: Your country only allows us to use your personal information when certain conditions apply. These conditions are called “legal bases” and we typically rely on one of four:

(a) Contract:We might use your information because you’ve entered into an agreement with us.

(b) Legitimate interest:We might use your information because we have—or a third party has—a legitimate interest in doing so. For example, we need to use your information to provide and improve our services, including protecting your account, delivering your news, providing customer support, and helping you find content we think you’ll like. An important point to understand about legitimate interest is that our interests don’t outweigh your right to privacy, so we only rely on legitimate interest when we think the way we are using your data doesn’t significantly impact your privacy or would be expected by you, or there is a compelling reason to do so.

(c) Consent: In some cases, we’ll ask for consent to use your information for specific purposes. If we do, we’ll make sure you can revoke your consent in our services or through your device permissions. Even if we’re not relying on consent to use your information, we may ask you for permission to access data like contacts and location.

(d) Legal obligation:We may be required to use your personal information to comply with the law.

Your rights in regard to your personal information.

(a) You have the right to object to our use of your information. If you don’t agree with us processing certain types of your personal information, you can contact us to make such request.

(b) You have the right to in some circumstances, including if the accuracy of the personal data is contested by the data subject for a certain period of time, to request a restriction on processing means in which we will be entitled to continue to store that data, but cannot process it any further.

(c) You have a right, in some circumstances, to receive your personal data that you provide to us in a structure commonly used and in a machine-readable format.

We may collect your personal information from, transfer it to, and store and process it in the United States and other countries outside of where you live. Whenever we share information of European Union users outside the European Union, we make sure an adequate transfer mechanism is in place, including data processing agreements based on the European Union/EEA Standard Contractual Clauses.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

By using our Services, you consent to us transferring information about you to these countries.

Privacy Notice for California Residents

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in our Privacy Policy. Where noted herein, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some of its requirements.

Information We Collect

Our Website or we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:

o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, our Website or we have collected the following categories of personal information from our consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	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.	YES
C. 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).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Our Website and we obtain the categories of personal information listed above from the following categories of sources:

· Directly from you. For example, from forms you complete or products and services you purchase.

· Indirectly from you. For example, from observing your actions on our Website, including insofar as provided to us through your actions on other provider’s websites or social media sites, such as Google and Facebook.

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

· To provide, support, personalize, and develop our Website, products, and services.

To create, maintain, customize, and secure your account with us.

· To process your requests, purchases, transactions, and payments and prevent transactional fraud.

· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

· To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

· For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

· As described to you when collecting your personal information or as otherwise set forth in the CCPA.

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users/consumers is among the assets transferred.

Other purposes.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, Company has not sold personal information to the categories of third parties indicated in the chart below.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
A: Identifiers.	Data provided to 3 ^rd party for KYC, Due Diligence, ID Verification and screening.	None
B: California Customer Records personal information categories.	Data provided to 3 ^rd party for KYC, Due Diligence, ID Verification and screening	None
C: Protected classification characteristics under California or federal law.	Data provided to 3 ^rd party for KYC, Due Diligence, ID Verification and screening	None
D: Commercial information.	None	None
E: Biometric information.	None	None
F: Internet or other similar network activity.	None	None
G: Geolocation data.	None	None
H: Sensory data.	None	None
I: Professional or employment-related information.	None	None
J: Non-public education information.	None	None
K: Inferences drawn from other personal information.	None	None

Reselling Personal Information

The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request ( see Exercising Access, Data Portability, and Deletion Rights , below), we will disclose to you:

The categories of personal information we collected about you.

· The categories of sources for the personal information we collected about you.

· Our business or commercial purpose for collecting or selling that personal information.

· The categories of third parties with whom we share that personal information.

· The specific pieces of personal information we collected about you (also called a data portability request).

· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o sales, identifying the personal information categories that each category of recipient purchased; and

o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights, below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either emailing us at RTPCompliance@rt2.com or write us at 100 SE 2 ^nd Street, Ste 2000, Miami, FL 33131.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please send us a duly notarized declaration or other written verification, such as a power of attorney, over which we retain discretion whether or not to accept.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights , below.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at RTPCompliance@rt2.com.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.

· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you a different level or quality of goods or services.

· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can resultin different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us at: RTPCompliance@rt2.com .

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting us at: RTPCompliance@rt2.com .

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to RTPCompliance@rt2.com or write us at 100 SE 2 ^nd Street, Ste 2000, Miami, FL 33131.

List of Our Affiliates and Related Properties.

Below is a representative list of some of our affiliated properties and related properties that currently may have access to personal information collected from Users on our Services as set forth in this Privacy Policy. We may update this list from time-to-time, so please check back periodically to keep up-to-date.

Affiliates:None.

Related Properties:None.

Changes to Our Privacy Notice.

We reserve the right to amend our Privacy Policy at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes .

Our Contact Information.

If you have any questions, feedback or to report a violation regarding the Privacy Policy, or the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at by email RTPCompliance@rt2.com or you may send a letter to 100 SE 2 ^nd Street, Ste 2000, Miami, FL 33131.

If you need to access this Privacy Policy in an alternative format due to having a disability, please contact RTPCompliance@rt2.com and 1-866-236-7733.

This Privacy Policy was last updated on September 8, 2023.