EFFECTIVE DATE

December 11, 2023

OUR COMMITMENT TO PRIVACY

VankPay, a Vank LLC service, knows that you care about how your personal information is used and disclosed. We take your privacy seriously. Our primary goal is to provide you with exceptional service.

We understand that you may have questions or concerns regarding your personal information and how it will be used. To make this Privacy Policy easy to find, we make it available on the home page of VankPay’s website at VankPay.com (the “Website”) and through our mobile applications. You may also email us at privacy@VankPay.com with any privacy-related questions you have.

APPLICABILITY OF PRIVACY POLICY

This Privacy Policy applies to all information we collect through our Services from current and former VankPay users. “Services” means any products, services, content, features, technologies, or functions, and all related websites, applications, and services offered to you by Vank, LLC. in connection with a VankPay account. When you are no longer our customer, we continue to disclose your information as described in this Statement. This Statement only applies to the Services and does not apply to the practices of any other VankPay service.

VankPay is always improving. As the Services evolve, we may occasionally update this Privacy Policy to reflect changes to our business, Services, or applicable laws. If the revised version requires notice by applicable law, we will provide you with 30 days prior notice by posting notice of the change on the “Privacy Policy” page of our website and mobile apps, the revised Privacy Policy will be effective as of the published effective date.

Throughout this Privacy Policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific person.

THE INFORMATION WE COLLECT

When you visit the website or use one of our mobile applications or other Services, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service. If you open a VankPay account, we will collect the following information from you:

• Account Information: text-enabled cellular/wireless telephone number, machine or mobile device ID, and other similar information.

• Identification Information: your name, street address, email address, date of birth, and Social Security number (“SSN”) (or other government-issued verification numbers).

• Device information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention, and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.

• Geolocation Information: information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to disclose your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available on your device.

• Social Web Information: with your consent, we may also collect information from social networks, such as your Facebook Connect credentials and email account information. If you authorize Facebook Connect, the plug-in allows us access to your email address, Facebook friends list, and public profile (including profile picture). Social and e-mail contact information helps you connect to friends and contacts for invitation and payment transmission purposes (as well as helping us improve the Services and fight fraud).

• Financial Information: bank account online login information, bank account and routing numbers, and credit cards linked to your VankPay account. VankPay does not disclose financial information with third-party social networking services such as those listed in the prior bullet.

• Biometric Information: when you consent to the user experience, we collect face scans to authenticate your account and manage fraud and risk.

• Audio, electronic, visual, or similar information: Call recordings when you talk to customer service or sales.

• Professional or employment information – including business information, contact emails, phone numbers, and taxpayer ID numbers.

• Information you provide when you contact us – your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account status, repayment history, and information about others if you choose to share it with us.

We may also collect the above data from other third parties, including service providers, internet service providers, partners and merchants, credit reporting agencies, government entities, data brokers, data analytics providers, advertising networks, card networks, and financial institutions.

We are committed to providing a safe, secure, and all-around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address, or other information to comply with the law or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention, and similar services.

When you are using the Services, we collect information about your account transactions, and we may collect Geolocation Information and/or information about your computer your operating systems, or other access device for fraud prevention and other similar purposes.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team, store results when you respond to a survey, or when you use VankPay or another VankPay service.

INFORMATION FROM CHILDREN

The Services are not directed to children under the age of 18. If we obtain actual knowledge that we have collected personal information from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.

HOW WE USE COOKIES

When you visit or use our Services or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”). We use Cookies to recognize you as a customer; customize Services, other content, and advertising, measure the effectiveness of promotions, perform a wide range of analytics, mitigate risk, and prevent potential fraud, and promote trust and safety across our Services.

Certain Services are only available using Cookies, so if you choose to disable or decline Cookies, your use of certain Services may be limited or not possible.

Do Not Track: Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

Please review our Statement on Cookies and Tracking Technologies to learn more about how we use Cookies.

HOW WE PROTECT AND STORE PERSONAL INFORMATION

We store and process your personal information using third-party servers located in data centers in the United States. This information is protected by physical, electronic, and procedural safeguards in compliance with applicable US federal and state laws and regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure the security of our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered, or destroyed by a breach of our administrative, managerial, and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal information as well, including never sharing your VankPay password with anyone.

If VankPay learns of a systems security breach, we may attempt to notify you electronically so you can take appropriate protective steps. By using the Services, you agree that VankPay may communicate with you electronically. VankPay may post a notice on the website or mobile applications if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at privacy@VankPay.com.

HOW LONG DO WE STORE YOUR PERSONAL INFORMATION

We retain your Personal Information for as long as needed or permitted in the context of the purpose for which it was collected and consistent with applicable law.

The criteria used to determine our retention period are as follows:

• Personal Information used for the ongoing relationship between you and VankPay is stored for the duration of the relationship plus a period of 10 years, unless we need to keep it longer, such as:

• • a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under Anti-Money Laundering obligations

• • litigation, investigations, audit, and compliance practices, or to protect against legal claims.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Our primary business purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun, and customized experience. We may use your personal information to:

• provide the Services and customer support you request;

• process transactions and match payments, and send notices about your transactions or your network activity;

• resolve disputes, collect fees, and troubleshoot problems.

• prevent potentially fraudulent, prohibited, or illegal activities, and enforce our User Agreement using our risk and fraud tools which may include the use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information, and Geolocation Information.

• create an account connection between your VankPay account and a third-party account or platform;

• customize, personalize, measure, and improve our services and the content and layout of our website, including showing you location-based promotions and business profiles;

• send you updates about new products and services that we are offering to customers;

• compare information for accuracy and verify it with third parties;

• perform other duties as required by law;

• if you elect to disclose your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-based options, functionality, offers, advertising, search results, or other location-based content; and

• if you have a business profile, you can choose to use your address to offer location-based promotions to VankPay users near you.

HOW DO WE DISCLOSE PERSONAL INFORMATION WITHIN THE VANKPAY NETWORK

To process payments on VankPay, we need to disclose some of your personal information with the person or company that you are paying or is paying you. Your contact information, date of sign-up, the number of payments you have received, and other verification metrics like social graph activity may be provided to users or companies when you transact with, on, or through VankPay.

We work with vendors to enable them to accept payments from you using VankPay. In doing so, a vendor may disclose information about you with us, such as your mobile phone number or VankPay username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a VankPay customer and that the vendor should enable VankPay as a form of payment for your purchase.

Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you through VankPay, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.

HOW WE DISCLOSE PERSONAL INFORMATION WITH OTHER PARTIES

VankPay does not disclose your personal information to third parties for their promotional or marketing purposes.

Some personal information is public and may be seen by anyone on the internet, whether or not they have a VankPay account. Public information may also be seen, accessed, reshared, or downloaded through VankPay APIs or third-party services that integrate with our products.

• Public information for personal profiles includes your VankPay username, profile photo, first and last name, month, and year of VankPay account creation, and public transactions in which you’ve been involved.

• Public information for business includes VankPay username, profile and background photos, business description, and QR code.

• Public information for business may be indexed by and searchable on search engines.

In addition to any public information, we may disclose your personal information with:

• Our parent company, Vank, LLC., and affiliates and subsidiaries it controls, but only for purposes allowed by this document.

• Companies that Vank, LLC. plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this Privacy Policy concerning your personal information. If your personal information could be used contrary to this Statement, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.

• Law enforcement, government officials, or other third parties if VankPay is compelled to do so by a subpoena, court order, or similar legal procedure; when it is necessary to do so to comply with law; or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the VankPay User Agreement, or as otherwise required by law.

• Third-party service providers who assist us in providing Services to you or who provide fraud detection or similar services on our or any vendor’s behalf.

• Businesses when you subscribe to their business profile. We will share your name with a business when you subscribe to their profile.

• Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their benefit.
• Partners and merchants, their service providers, and others involved in a transaction, for example, when you use the Services to initiate online purchases, or return goods, we may disclose information about you and your VankPay account with the other parties (or their service providers) involved in processing your transactions. Please note that personal information shared with partners and merchants (or their service providers) involved in a transaction is subject to the partners’ and merchants’ privacy policies and procedures.

• For our businesses and their beneficial owners, we report personal information to databases maintained by the card networks under the card scheme rules to fulfill listing and reporting obligations.

• Other users if you have a business profile. You may choose to display certain information about your business profile on the VankPay network, such as your street address, phone number, email, social media accounts, and website. You can control how this information is displayed in your business profile settings. We will also disclose certain information about your business profile to other users, such as how long ago your business profile was created, the total number of subscribers, and the total number of transactions. We may also use your address, transaction activity, and engagement activity on VankPay to rank your business relative to other businesses in your area.

• Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.

• • For this Privacy Policy, an “account connection” with such a third party is a connection you authorize or enable between your VankPay account and a non-VankPay account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, VankPay, and the third party will exchange your personal information and other information directly. Examples of account connections include, without limitation: linking your VankPay account to a social media account or social messaging service; connecting your VankPay account to a third-party data aggregation or financial services company, if you provide such company with your VankPay account log-in credentials; or using your VankPay account to make payments to a merchant or allowing a merchant to charge your VankPay account.

• • If you connect your VankPay account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third party about you and your use of the third party’s service. For example, if you connect your VankPay account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third party via an account connection in a manner consistent with this Privacy Policy.

• • Information that we disclose with a third party based on an account connection will be used and disclosed by the third party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal information as part of the account connection. For example, personal information that VankPay discloses with a third-party account or platform such as a social media account may in turn be disclosed to certain other parties, including the public, depending on the account or platform’s privacy practices.

• • If you choose to use Siri or iMessage to send payments via VankPay, when available, or to otherwise use the Services, such use is subject to Apple’s terms and conditions for the use of iMessage and/or Siri, as applicable, and the terms of the VankPay User Agreement. By using Siri or iMessage, you authorize us to disclose some of your VankPay account data (including your friends list, list of persons you have transacted with most recently and most frequently, transaction instructions, and transaction notes) with Apple to allow it to facilitate transaction requests made through Siri or iMessage on iOS. Data disclosed with Apple will be used under Apple’s then-current user agreements and privacy policies. You can grant or revoke Apple’s access to VankPay on iOS at any time under the “Siri” or “iMessage” settings on your iPhone.

VankPay does not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under the control of VankPay and is subject to the terms of use and privacy policies of such third parties.

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You can review and update your personal information in your account settings at any time by logging in to your account.

LINKS TO OTHER SERVICES OR SITES

The Services may contain links to (or allow you to link to) other third-party services or websites. VankPay does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the Privacy Policy of any third-party service or website that collects personally identifiable information.

HOW TO CONTACT US

If you have questions or concerns regarding this Privacy Policy or any feedback about your privacy and the Services that you would like us to consider, please email us at privacy@VankPay.com.