Buckzy – United States of America

Effective March 2022

Introduction

Your privacy and keeping Your personal information secure are extremely important to us. At Buckzy Payments Inc., we are committed to protecting and respecting Your privacy and handling Your information in an open and transparent manner.

This Privacy Policy (“Policy”) explains among other things: what we do with Your personal information; what we do to keep it secure; with whom we share Your information; Your rights in relation to the personal information we hold about You; and who You can contact for more information. In this Policy, references to “You” and “Your” are references to users of our website, a customer and a consumer.

We will amend or update this Policy regularly to reflect changes in our practices with respect to the processing of personal information, or changes in applicable law. We encourage You to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.

If You don’t want to read all the details. Here are the highlights that You may really wish to know:

• Where appropriate we share Your personal information within Buckzy Payments Inc., our affiliates, partners and other companies. Upon request or where we are legally obliged, we may share Your information with public agencies.
• We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers). In providing this information You confirm to us that You have their permission to do so.
• We use third parties to process Your personal information on our behalf to perform our services for You, and due to the international nature of our business some of them are based outside the United States of America.
• You have several rights over Your personal information, and the manner in which You can exercise those rights are contained in this Policy.
• We will send You direct Marketing if You have agreed to receive it. We do this to encourage You to use our services and send You offers or promotions that may interest You. You can ask us to stop sending You marketing information at any time. Either by sending us an email at privacy@buckzy.net or by selecting the unsubscribe button at the bottom of any email communication You may receive from us.
• We may use Your personal information to display online advertisements and Marketing relating to our services on our website or online media channels only if You have selected to accept all cookies.

Definitions

To help clarify our meaning, we have used certain capitalised terms in this Policy. These terms and their meaning are:

“Cookie” means a small text file which includes a unique identifier that is sent by a web server to the browser on Your computer, or any other internet-enabled device when You visit an on-line site.

“Data Protection Legislation” means the Gramm-Leach-Bliley Act of 1999, the CAN-SPAM Act of 2003, and such applicable legislation as may exist in Your State or Territory of residence.

“Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research and events. This list is not exhaustive.

“Services” means Buckzy service and such other services or products that we may introduce from time to time.

Who are we?

Buckzy Payments, Inc. (“Buckzy”, “We”, “Us”, “Our”), a State of Delaware corporation, is committed to protecting and respecting Your privacy, handling Your information in an open and transparent manner, and keeping Your information secure.

The personal information we collect about You

We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Data Protection Legislation and as set out in this Policy.

The personal information we collect and use may include, among other things:

• Your name, company name and title;
• Your contact information such as Your email address, postal address and telephone number or any telephone number used to call us;
• Your demographic information such as age, education, and interests;
• evidence of Your identity, (for example passport information, social security number; and driver’s license);
• unique identifiers such as Your username and password;
• Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
• Your payment details and other financial data (for example, Your bank or payment method provider’s name) and salary details; and
• Information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers), where You provide us with such information. In providing this information You confirm to us that You have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.

How we collect Your personal information

• Information You give to us when You use our services. If You use our services You will need to provide certain information including Your name and address and debit card number, as well as the name and other details of the recipients of the money transfers that You instruct us to carry out. This information must be complete and accurate, and if not we may have to take additional steps to complete the transaction.
• Other information You give to us. This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when You communicate with us by phone, e-mail or otherwise. It includes, for example, information You provide when You register on the website for us to contact You, when You inquire about any of our Services, when You sign up to receive notifications, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address.
• From other members of Buckzy Payments Inc., We may collect information about You from our affiliates in Canada, the U.K., and other subsidiaries or affiliates globally.
• Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram, You might give us permission to access information from those accounts or services.
• Other Sources. We may receive information about You from other sources, including publicly available resources, e.g. newspapers, internet sites, registries, or public records, and combine this data with information we already have about You. This helps us to update, expand and analyse our records and provide services that may be of interest to You.

How we use Your personal information

Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.

We use Your information for the following specific purposes:

• to carry out our obligations arising from any contracts entered into between You and us or from applicable law such as anti-money laundering laws, and to provide You with the Services in accordance with our Terms and Conditions and with this Policy;
• to register You with an account;
• to fulfil Your Transaction / (Request;
• to send You confirmations or other notifications;
• to notify You about temporary or permanent changes to our services or other service-related messages;
• to assist You where online applications are not completed;
• to prevent fraud, money laundering, and any other illegal activity;
• to ensure that content from our site is presented in the most effective manner for You and for Your computer;
• to promote our business;
• to send You Marketing communications, as applicable, provided that You have given us Your contact details and that You do not decide to opt out from this type of communications, in accordance with Data Protection Legislation.
• to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
• as part of our efforts to keep our site, and our services safe and secure;
• Analytics, web traffic analysis, to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
• to make suggestions and recommendations to You and other users of our site about services that may interest You or them;
• to train, monitor and assess the effectiveness of the manner in which we provide the Services to You;
• to consider and investigate any concerns or complaints You may have; and
• to display personal testimonials of satisfied consumers on our website in addition to other endorsements, where You have agreed with a third-party review site that we may do so. If You wish to update or delete Your testimonial, contact us at privacy@buckzy.net.

Buckzy Payments Inc., will not sell, rent or otherwise disclose Your information to third party marketers or others unaffiliated with Buckzy or other partners for the purpose of advertising, promoting or selling other services to You. However, where and to the extent permitted by law, Buckzy may work with third parties to analyze the information that we gather from You when You visit our website, our LinkedIn page, Facebook page, and our online advertisements, whether or not You use the Buckzy service. For further information see the Who we might share Your personal information with section of this Privacy Policy.

Direct Marketing

We may use the contact details You provided to send You marketing communications by email, telephone, or other communication formats about similar products or services where permitted by applicable law (unless You have opted out).

In other cases, we may ask for Your consent to send You marketing communications about products or services offered by Buckzy, its affiliates, and other partners.

Opting Out of Direct Marketing

You can opt out of receiving Buckzy marketing communications by modifying Your email subscriptions by clicking on the unsubscribe link or following the opt-out message included in the communication.

Alternatively, simply send an email to privacy@buckzy.net and the email address that You wish to be removed within the email.

Please note that if You request we stop sending You Marketing messages or You unsubscribe, we may continue to send You service and administrative communications such as transfer updates and other important information on Your transaction.

Who we might share Your personal information with

Your personal information is very important to us. However, there are circumstances where it is necessary for us to share Your information for legitimate business purposes (including operating our site, and providing services to You), in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose Your personal information to:

Links to Other Sites

Our sites may contain links to other websites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once You link to another website from our site You are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before You submit any data to these websites.

International transfer of Your personal information

Due to the international nature of our business, we may need to transfer Your personal information to other Buckzy entities, to other third parties as noted in the “Who we might share Your information with” section of this policy, and recipients, in connection with the purposes set out in this Policy. For this reason, we may transfer Your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which You are located. Buckzy will take reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.

Buckzy may transfer the personal information of customers or consumers covered by this policy on servers or databases outside of the European Economic Area (EEA) only for the purpose of executing an international payment. Some of these countries may not have the equivalent level of protection under their data protection laws as in the EEA

How we keep Your personal information secure

We have implemented appropriate administrative, technical and organisational security measures designed to protect Your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal information, we cannot guarantee or warrant the security of Your data transmitted to our site; and any transmission is at Your own risk. Please note that You are responsible for maintaining the security of Your credentials used to access any Buckzy service or account, and You must report suspected unauthorized activity to us. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.
We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.

Protecting Your own information

It is important to keep Your password secure to prevent fraudulent use of Your account. Do not disclose Your password to anyone else and especially anyone who requests it from You by telephone or email. Buckzy will never ask You to provide Your password or personal information via email. Please be aware of the following:

• Change Your password regularly and avoid using the same password on other websites to prevent hackers from access to Your account;
• Avoid simple passwords that can easily be guessed;
• Be aware that public WiFi networks are risky and hackers may capture Your online transactions and personal information. Only connect to a network You can trust;
• If You use a shared computer, make sure You log out immediately after You have finished using the website; and
• Beware of ‘phishing’ where criminals may attempt to steal Your information by sending You bogus emails.

How long will we keep Your personal information

We take every reasonable step to ensure that Your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, we will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

The period for which we will retain information about You will vary depending on the type of information and the purposes for which we will use it. Generally, unless applicable law or our legal and regulatory obligations require a longer retention period, we will keep our records for at least five years after You have terminated Your relationship with us.

Your Rights

Subject to applicable law, You may have a number of rights regarding our processing of Your relevant personal information, including:

• the right not to provide Your personal information to us (however, please note that we may be unable to provide You with the full benefit of our site, or our services, if You do not provide us with Your personal information);
• the right to request access to Your personal information, together with information regarding the nature, Processing and disclosure of that personal information;
• the right to request for the correction of any inaccuracies in Your personal information;
• the right to request for the erasure of Your personal information. This is also known as the right to be forgotten. We will keep a note of Your name if You ask for Your personal information to be erased;
• the right that we restrict our use of Your personal information;
• where we use Your personal information on the basis of Your consent, You have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of Your personal information in reliance upon any other available legal basis); and
• the right to lodge complaints with a Data Protection Authority regarding the use of Your personal information by us or on our behalf.

We may require proof of Your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute; therefore exemptions or limitations may apply. For example, we can refuse to provide information if fulfilling Your request would reveal the personal information about another person, or if You request that we delete information which we are required to retain by law, have compelling legitimate interests to keep, or need access to fulfil our legal obligations.

You can contact us at privacy@buckzy.net if You want to enforce any of these rights. We will comply with our legal obligations as regards Your rights as a data subject.

Any request for access to Your personal information must be in writing and we will endeavour to respond within a reasonable period and in any event within one month (three months for complex or numerous requests), in compliance with Data Protection Legislation. We reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to You and we will inform You about Your rights.

Contact us

Questions, comments and requests regarding Your personal information and our Policy are welcome and should be sent to privacy@buckzy.net.

You may also use these contact details if You wish to make a complaint to us relating to Your privacy.

If You have any concerns about our use of Your information, You can make a complaint to the Attorney General of Your State or Territory of residence, or to our regulator in Your State or Territory of residence.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Consumers residing in California have some additional rights with respect to their personal information under the California Consumer Privacy Act “CCPA”. If You are a California resident this notice applies to You and supplements the main privacy policy.

The purpose of this Notice at Collection is to provide You with timely notice, at or before the point of collection, about the categories of personal information that may be collected from You and the purposes for which the personal information may be used. The Categories of Personal Information are listed below.

Please note that Personal Information does not include:

• Publicly available information from government records;
• De-identified or aggregated consumer information;

Categories of Personal Information Collected

In the preceding 12 months, we have collected the categories of personal information listed below. For more details about the data points we collect, please see the “The personal information we collect about You” section in our main privacy policy.

• Identifiers – For example, name, company name, title, postal address, email address, unique personal identifier, Internet Protocol addresses, social security number, driver’s licence number, passport number or other similar identifiers.
• Personal information categories from Cal. Civ. Code § 1798.80(e) – For example: a name, social security number, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, or other financial information.
• Commercial Information – For example, records of Your transactions, or other money transfer or remittance histories.
• Internet or other similar network activity – For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
• Data – For example, inferences drawn from personal information to create a profile about a consumer reflecting the consumer’s preferences and characteristics.

Categories of Third Parties

In the 12 months prior to the effective date of the Privacy Statement, Buckzy may have shared Your Personal Information with the following Categories of Third Parties listed below. For more details on our data sharing, please see the “Who we might share Your personal information with” section in our main privacy policy:

• Government entities: government entities including law enforcement agencies;
• Professional services organizations: professional services organizations, such as law firms and independent auditors;
• Advertising and social networks: advertising and social networks (who may combine Your personal information with their own records, and records available from other sources for their own marketing purposes);
• Internet service providers;
• Payment processors and payout partners;
• Help desk service providers;
• Financial, accounting and Legal services providers;
• Data analytics providers and other aggregators;
• Operating systems and platforms; and
• Our affiliates, or subsidiaries of Buckzy.

Business or Commercial purposes for using Your personal information

All the categories of personal information we collect about You (as detailed above) are used for the following purposes below. For more details on our use of Your personal information, please see the “How we use Your personal information” section in our main privacy policy:

• Providing our services (money transfers, account servicing and maintenance, customer services, advertising and marketing, analytics and communication about our services).
• For our operational purposes, and the operational purposes of our service providers and integration partners.
• Improving our existing services and developing new services.
• Prevention, detection, protection and prosecution of security incidents, illicit or fraud related activity.
• Bug prevention, error reporting, and activities to maintain the quality or safety of our services.
• Auditing consumer interactions on our site.
• Short term use such as customizing the content of our website.
• Our legitimate interests in promoting our business.
• To send You marketing information about products and services from Buckzy and its affiliates.
• Any other use that we will inform You about.

Sale of Your personal information

Under the CCPA, some sharing of personal information (like Your name, email address, etc.) may be considered a “sale”. We don’t sell Your personal information for money, although we may allow certain third parties to use that information for purposes that may not directly benefit Buckzy.

Your Rights

Subject to exceptions, You may have a number of rights regarding our processing of Your personal information, including:

• • The right not to provide Your personal information to us (however, please note that we may be unable to provide You with the full benefit of our site, or our services, if You do not provide us with Your personal information);
  • The right to request access to Your personal information. You have the right to request that we disclose the categories of personal information that we collect or use. You may also request the specific information that we have collected about You. However, we may withhold some information where the risk to You, Your personal information, a third party, or our business is too great to disclose the information;
  • The right to request for the correction of any inaccuracies in Your personal information;
  • The right that we restrict our use of Your personal information;
  • The right to request for the deletion of Your personal information. We will delete Your personal information on receipt of a Verifiable Consumer Request. You should also be aware that this right is qualified and not absolute. Therefore we may refuse to delete Your personal information if we need it for one or more of the following purposes:
  • Contract
    • To complete the transaction for which we collected Your personal information;
    • To provide a product or service which You have either requested, or You would reasonably expect in the context of our relationship with You; and
    • To carry out a contract with the consumer.
  • Security:
    • To detect security incidents;
    • To protect against malicious, deceptive, fraudulent, or illegal activity; and
    • To prosecute people responsible for such activities;
• Debugging in order to detect and repair errors that affect intended functionality;
• To comply with California’s Electronic Communications Privacy Act;
• Research: To engage in public or peer-reviewed scientific, historical, or statistical research, that:
• • Is in the public interest;
  • Would be seriously impaired or impossible to carry out without retaining the personal information; and
  • Has been consented to by the consumer;
• Internal purposes: To use it for a purpose that is:
• • Internal to Buckzy; and
  • In-line with the reasonable expectations of the consumer, in the context of their relationship with our business;
• To comply with a legal obligation;
• For the establishment, exercise or defence of legal claims;
• Other purposes: To use it for any other purpose that is:
• • Lawful; and
  • Internal to Buckzy.

How to exercise Your rights of access and deletion

To exercise Your rights, please submit a verifiable consumer request to us by sending an email to privacy@buckzy.net. Only You, or a person registered with the California Secretary of State that You authorise to act on Your behalf, may make a verifiable consumer request related to Your personal information.
You may make a verifiable consumer request for access, deletion and 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.

If You have an account with us, logging into Your account and sending us a request through the account will serve to verify Your identity and request, although we may request additional information if we believe Your account has been compromised.

For security reasons (and notwithstanding any of the above), 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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will deal with Your request within 45 days. If reasonably necessary, we can extend this period by an additional 45 days. We shall notify You if we extend this period.

Right of non-discrimination

You have the right not to receive discriminatory treatment from Buckzy Payments Inc., for exercising Your CCPA privacy rights. Please note: this right is a “passive right” and so You cannot exercise it.

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 result in 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. However, we do not currently provide any financial incentives.

If You feel that You have received discriminatory treatment as the result of exercising Your CCPA rights, You may contact us at privacy@buckzy.net. You can contact us about our privacy policy and practices at privacy@buckzy.net.

U.S. Consumer Privacy Notice

WHAT DOES BUCKZY PAYMENTS, INC. DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal informaon. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal informaon. Please read this noce carefully to understand what we do.

What?

The types of personal informaon we collect and share depend on the product or service you have with us. This informaon can include:

• Contact informaon such as postal address, telephone number
• Demographic informaon such as age, educaon
• Unique idenfiers such as username, email address

How?

All financial companies need to share customers’ personal informaon to run their everyday business. In the secon below, we list the reasons financial companies can share their customers’ personal informaon; the reasons Buckzy Payments, Inc. chooses to share; and whether you can limit this sharing.

WHAT WE DO

How does Buckzy Payments, Inc. protect my personal information?
To protect your personal informaon from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Buckzy Payments, Inc. collect my personal information? We collect your personal informaon, for example, when you

• open an account or give us your contact informaon
• tell us who receives the money or tell us where to send the money
• make a payment request. We also collect your personal informaon from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

• sharing for affiliates’ everyday business purposes—informaon about your creditworthiness
• affiliates from using informaon to market to you

State laws and individual companies may give you addional right to limit sharing.

DEFINITIONS

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Our affiliates include companies with a Buckzy Payments name; financial companies such as Buckzy Payments Limited and Buckzy Payments Private Limited.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Buckzy Payments, Inc. does not share with nonaffiliates so they can market to you

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Our joint markeng partners can include banks

Other Important Information

For California residents:

We will not share informaon we collect about you with nonaffiliated third pares, except as permied by law, including, for example, with your consent or to service your account. We will limit sharing with our affiliates to the extent required by California law. See our Privacy Policy for further

informaon about the rights provided to California Residents with respect to personal data we may collect about them.

Questions?

Email privacy@buckzy.net.