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PRIVACY POLICY



VERAFIN PRIVACY POLICY

Effective Date: March 1, 2022

Verafin is committed to protecting Personal Data and complying with applicable
privacy requirements in a trustworthy, transparent and responsible manner.

This Privacy Policy describes how Verafin Solutions ULC and its subsidiaries and
affiliates (collectively, “Verafin,” “we,” “our” or “us”) collects, uses and
discloses Personal Data about individuals (collectively, “users” or “you”)
receiving our products and services, exploring or maintaining a business
relationship with us (either directly or through an intermediary such as your
financial services provider, your appointed legal or other representative or
your employer) and/or using our websites or online features (each a “Site” or
collectively, our “Sites”). As used in this Privacy Policy, Personal Data means
any information relating to an identified or identifiable natural person;
Personal Data is intended to cover all information subject to personal data
processing and privacy laws applicable to our business.

The Privacy Policy also describes your rights, where applicable, and how to
exercise them. You may contact us at any time with questions related to our
Personal Data processing and privacy via email at legal@verafin.com

In some instances, we may post or provide materials that provide further
description of Personal Data processing related to certain products and
services. We may also post information about how we comply with specific
Personal Data laws or regulations like European Union or United States privacy
laws. Such materials are for informational purposes only and are not intended as
an exhaustive listing of Personal Data processing related to the product and
service. The materials should not be construed as modifying this Privacy Policy.

BRIEF OVERVIEW 

INFORMATION ABOUT HOW THIS POLICY APPLIES TO OUR GLOBAL COMPANY

As a multinational organization, different Verafin entities, products/services
and Sites may be subject to different privacy laws based on where our entity
operates, where the products/services are delivered and/or where you are
located. For example, the European Union General Data Protection Regulation
imposes certain requirements on some Verafin entities or services that are not
applicable to all of our entities or services. Where this Privacy Policy states
that a provision applies “to the extent required by applicable law,” such
provision will be applicable only to the extent that Verafin is subject to legal
requirements imposing it.

For purposes of data protection laws, except where this Privacy Policy does not
apply, as described below, the Verafin entity that will be the “controller” of
your Personal Data will be the entity that delivers the products or services you
(or the company for whom you are working or have a business relationship) are
receiving or maintains the Site that you are using. You can identify the Verafin
company that hosts a particular Site through the Site’s footer or “About” link. 

Although your data controller may be a specific Verafin entity, contact and
other customer relationship information that we collect may be held in a
customer relationship management or contact database which can be accessed by
other Verafin entities which may be located globally; further information
about international transfers of information is provided below. To the extent
required or permitted by applicable law, by visiting or using our Sites, you are
consenting to us collecting and processing information about you in accordance
with this Privacy Policy.

SITUATIONS WHERE THIS PRIVACY POLICY DOES NOT APPLY

This Privacy Policy also does not apply to Personal Data processed in connection
with delivery of services to Verafin by suppliers or contractors; such
relationships are governed solely by the Personal Data processing terms and
conditions between Verafin and the supplier/contractor. It also does not apply
to job applicants (which are covered by our separate Job Applicant Privacy
Policy) or employees, which are subject to relevant separate privacy notices.

This Privacy Policy does not apply to the extent that:

 * Verafin’s contract for delivery of products or service prescribes different
   Personal Data terms and conditions for the processing of your information;
 * Verafin is delivering products or services as a data processor in which the
   contractual terms and conditions between Verafin and the
   controller/contracting party shall govern;
 * The Site for the products or services sets forth an additional or alternative
   Privacy Policy; or
 * Applicable law imposes different processing or privacy requirements on your
   information.

INFORMATION WE COLLECT FROM YOU OR YOUR REPRESENTATIVE

We only collect information from you/your representative or about you that is
reasonably necessary for us to provide the relevant product or service, business
relationship and/or communication consistent with the nature of such product,
service, business relationship and/or communication. Based on the specific
products, services, business relationship or Sites involved as well as
requirements under applicable law, we may collect the following categories of
personal information (“Personal Data”) that you or your representative (such as
your employer, financial services provider, legal representative, company where
you are an officer, director or significant shareholder) provide to us:

 * Name:
 * Email address;
 * Social media username;
 * Telephone number;
 * Mailing address;
 * Company;
 * Title;
 * Business contact information;
 * Employment, company officer or director, or shareholder status;
 * Tax or National Identification Number;
 * Date of birth;
 * Career or professional history and educational background;
 * Financial holdings information;
 * Your recorded voice (where you are advised in advance of the recording);
 * Photograph;
 * Payment information (e.g., bank account or credit card number);
 * Username and password;
 * Passport or government issued identification information (such as for
   security purposes when visiting our facilities); and
 * Any other Personal Data you or your representative volunteers on or provides
   access to via any or our Sites and/or any Verafin community forum, social
   media offering or blog, including, but not limited to, information related to
   your use of the Sites and interests in certain products or services.

We may also automatically collect the following categories of information from
devices (e.g., mobile, computer, laptop, tablet) used to visit or use our Sites
(“Device Information”):

 * IP address;
 * Device identifier;
 * Log files;
 * Cookies;
 * Clear gifs;
 * Flash LSOs; and
 * Other information as described in our Cookies Policy.

Certain Device Information may be deemed Personal Data in accordance with
applicable law. Personal Data and Device Information are collectively referred
to as “information.”

INFORMATION THAT WE COLLECT ABOUT YOU

Based on the specific products, services, business relationship or Sites
involved (as well as requirements under applicable law), we may collect the
following categories of Personal Data on our own or from third parties about you
in accordance with applicable law:

 * Information about you available in news feeds, exchange data feeds and other
   public data sources (including the public internet);
 * Information provided by relevant regulators, government agencies and
   non-government credentialing or professional organizations;
 * Information related to your status under economic sanctions, anti-money
   laundering and similar laws or other information that may impact our ability
   to engage in business with you or a company at which you are an employee,
   officer or director or significant shareholder;
 * Information that you, your employer or other representative makes publicly
   available via your personal or company website or in social media profiles;
 * Information related to your professional activities (such as consulting to
   public retirement funds) that is contained in documents released by a
   governmental body under Freedom of Information Act, Open Government License
   or similar laws and regulations;
 * Information from event organizers for events that you have attended;
 * Information from companies providing professional contact information to
   their customers/subscribers; and
 * Other Personal Data to the extent permitted by applicable law and reasonably
   necessary for the performance of our business obligations, compliance with
   laws applicable to our business or pursuit of our legitimate business
   interests.

HOW WE USE YOUR INFORMATION

The following is an overview of Verafin’s purposes for processing Personal Data.
Often due to the nature of the product or service involved or the context in
which the Personal Data is used, it will be apparent how we intend to use the
information. Additional information about processing related to a particular
product or service may be separately posted on the relevant Site or contained in
the applicable terms and conditions.

We may use the information we collect for the purposes identified below. To the
extent required by applicable law, each purpose for the processing of Personal
Data is substantiated by one or more lawful bases for processing. Unless
otherwise identified with respect to a particular product or service, our
processing is done based of one or more of the following:

Provide you (or your employer/represented company) with our services and
products and communicate with you about your (or your employer/represented
company) accounts or use of our products, services and/or Sites

 * Perform or enter into a contract
 * Legitimate business interests
 * Comply with a legal obligation
 * Consent

Process transactions through one of our services including, but not limited to,
processing financial transactions initiated by your or your representative

 * Perform or enter into a contract
 * Comply with a legal obligation

Perform transaction and regulatory reporting requirements under applicable law

 * Perform or enter into a contract
 * Comply with a legal obligation

Monitor for security threats and fraud involving the use of our products,
services, Sites or physical facilities

 * Legitimate business interests
 * Comply with a legal obligation

Register or establish an account for you (or the company for whom you are an
employee, officer or director) as a customer

 * Perform or enter into a contract
 * Legitimate business interests
 * Comply with a legal obligation

Register you (or your employer/represented company) to receive services or
information through one or more of our Sites

 * Perform or enter into a contract
 * Consent

To the extent permitted by applicable law, identify you (or your
employer/represented company) as a prospective customer for products or services
and provide you with relevant information and/or invitations to events

 * Legitimate business interest
 * Consent

Manage our relationship with you (or your employer/represented company) as a
customer, business prospect and/or information recipient

 * Perform or enter into a contract
 * Legitimate business interest
 * Consent

To pursue or enforce our legal rights related to our business, products,
services or Sites and/or defend against claims made against us

 * Perform or enter into a contract
 * Legitimate business interest

Communicate with you (or your employer/represented company) about your account
or use of our products, services or Sites

 * Legitimate business interest
 * Consent

Create informational materials and statistical extracts for our products and
services

 * Perform or enter into a contract
 * Legitimate business interest
 * Consent

Develop, provide content for, operate, deliver, and market our services and
Sites

 * Perform or enter into a contract
 * Legitimate business interest
 * Consent

Develop and deliver marketing of our products and services and those of our
advertisers, sponsors and partners

 * Legitimate business interest
 * Consent

Improve the quality of our Sites and tailor them to your preferences

 * Legitimate business interest
 * Consent

Implement social networking features you have activated (e.g., Facebook “Like”
button and LinkedIn integration) 

 * Consent

We also use your information for compliance with our company policies and
procedures, for accounting and financial purposes, and otherwise as required or
permitted by applicable law. If you do not provide us with information as
described above, we may not be able to fulfill the applicable purpose of
collection, such as completing a contemplated transaction, responding to your
queries or providing access to our Sites to you.

With respect to situations where we process Personal Data based on our
legitimate business interest, reflecting that we are generally a
business-to-business product and service provider, we typically collect and
process limited Personal Data about corporate customer points of contact and
individuals acting in their professional capacities as part of our overall
effect to reduce the privacy impact on individuals. To the extent required by
applicable law, you have the right to object to the processing of your personal
data based on a legitimate interest as legal basis. Please see the section below
regarding your rights to find out more. Where processing is based on your
consent, you have the right to withdraw that consent at any time.

HOW WE SHARE YOUR INFORMATION

From time to time, to the extent permitted by applicable law and subject to any
contractual limitations on sharing Personal Data set forth in a relevant
contract for products and services, we may share your information with our
affiliates, subsidiaries, business partners, customers/members (such as where we
process your Personal Data in connection with your role with your employer or
financial services provider), third party service providers and authorities in
the following circumstances:

 * Verafin Business Units, Affiliates, Subsidiaries, Business Partners and
   Customers. We may share your information with our business units, affiliates,
   subsidiaries, business partners, and customers in the US and worldwide for
   purposes identified above. To the extent required or permitted by applicable
   law, by visiting or using our Sites or otherwise providing us with your
   information, you consent to this sharing of your information. Where such
   consent exists, to opt-out of such sharing, please contact us via email
   at legal@verafin.com or at the location in the Contact Us section below.
 * Service Providers. We may share your information with third parties who
   perform functions on our behalf (e.g., hosting or operating our services or
   Sites, processing credit card payments, sending email marketing
   communications, or data analysis). We do not authorize these third parties to
   use your information for purposes other than for which it has been provided,
   and do not authorize these third parties to disclose that information to
   unauthorized parties. We require these third parties to maintain appropriate
   security to protect your information from unauthorized access or processing.
 * As Required or Appropriate by Law. We may disclose your information to
   regulatory authorities (including other self-regulatory organizations),
   courts, and government agencies where we believe that doing so would be in
   accordance with or permitted or required by any applicable law, regulation or
   legal process, to defend the interests, rights, and/or property of Verafin or
   others, or to respond to emergencies.  We may also disclose your information
   as part of an information-sharing arrangement established under applicable
   law such as one developed by a government authority to combat financial
   crime.
 * Business Transfers. We may transfer your information to a third party in the
   event of any reorganization, merger, sale, joint venture, assignment,
   transfer or other disposition of all or any portion of our business, brands,
   affiliates, subsidiaries or other assets; to the extent that such a
   transaction results in you being a current or prospective customer, vendor or
   other third party point-of-contact for both the portion of the business that
   is transferred and the portion that remains with Verafin, your information
   may be both transferred to the transferee and retained by Verafin. To the
   extent permitted by applicable law, we may share information with a
   prospective buyer or transferee of the business as part of the diligence
   process provided that we require any such third party to maintain the
   confidentiality of your information and protect it with appropriate technical
   and organizational security measures.

We may share your information with other parties as directed by you or subject
to your consent. We may also share and otherwise process aggregated information
or de-identified information that does not identify you individually with other
parties. For example, from time to time, we may utilize survey information
collected from you on an aggregate, not individually identifiable, basis. We
also use this aggregated or de-identified information for our various business
purposes, including the creation and sale of other products and services to our
clients and potential clients. This aggregate or de-identified information is
not traceable to any particular client or user and will not be used by a third
party to contact you.

Except as described herein, we do not share, sell, rent or trade your
information to our service providers or business partners for their own direct
marketing purposes, unless we have explicitly given you the option to opt-in or
opt-out of such disclosures.  For certain Sites that are intended for public
use, news posting and other information distribution, the Site works on
advertising-supported basis.  On such sites, we may participate with third
parties who provide services related to the advertising appearing on such Site
or provide us information on your use of our Sites; such third parties may
operate as a “data controller” with respect to Personal Data collected by them
from your use of our site which they may use to provide tailored advertising to
you on the Site or other sites of their customers.  

MARKETING COMMUNICATIONS

We process Personal Data within the scope of our marketing and market
segmentation. With market segmentation, we mean that we categorize our customer
base based on professional affiliations and functions, alignment with our
services and products and information gathered from public sources of
information. For customers or users of our Sites, we may also use information
gathered from your use of our products, services and/or Sites for marketing
purposes to market our products and services to you, as well as to tailor
advertisements of products and services of our advertisers, sponsors and
partners to you when you are on our Sites. You always have right to request that
we stop using your personal data for direct marketing purposes.

To the extent required by applicable law, you have the right to object to the
processing of your personal data based on a legitimate interest as legal basis.
You also always have the right to withdraw your consent at any time when we need
your consent in order to process your personal data. If you withdraw your
consent, you will no longer receive information and offers that are tailored for
you. Please see the section below for more information about your rights.

If you no longer wish to receive marketing communications from us, you may
opt-out of receiving marketing-related emails by: (1) using the unsubscribe
method provided in our communications; (2) if you created an online account when
you registered to receive our emails, you may log-in to your account on the
applicable Site and make changes to your communication preferences; or (3) you
can opt out by updating your preferences in the Email Alert section of our
Sites. In particular, you have the right to object our use of your Personal Data
for direct marketing and in certain other situations (in accordance with
applicable law) by contacting us at legal@verafin.com. If you are having
difficulty unsubscribing from our email marketing communications using the above
methods, please contact us as at legal@verafin.com.

We will try to comply with your request as soon as reasonably practicable as
required by applicable law. Please note that we may need to retain certain
information for recordkeeping purposes, to complete any transactions that you
began prior to your request, or for other purposes as required or permitted by
applicable law. In addition, please note that even if you opt-out of receiving
marketing communications from one or all of our Sites, we may need to send you
service-related communications.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

To the extent required by applicable law, in our capacity as the controller of
your Personal Data, we will also provide you with the opportunity to be informed
of whether we are processing your Personal Data and at any time to access,
correct, update, oppose, delete, block, limit or object to our use of your
Personal Data. The foregoing rights will be afforded to you free of charge
(except to the extent that your requests are manifestly unfounded or excessive,
in which case, we may charge an administrative fee or refuse to meet your
request). Please note that legal obligations that apply to our business – for
example, financial regulations that apply to our EEA Regulated Business – may
prevent us from immediately deleting parts of your information. To exercise your
rights, please contact us as detailed under the Contact Us heading below.

To prevent fraudulent activity, we may require you to authenticate your identity
when you contact us. We will try to comply with your request as soon as
reasonably practicable and within timeframes required by applicable law. Please
note that in some instances, due to the nature of the information that we
receive, we may require you to provide additional information that will help us
identify which information is yours. For requests subject to the European
General Data Protection Regulation, we will respond to your request within one
month of our receipt of it. We may extend this period by two further months
taking into account the complexity of your request or the number of requests
that we have received; we will inform you of any such extension within one month
of receiving your request along with the reasons for the delay and information
about your right to file a complaint with the supervisory authority.

The following sets out a summary of your rights to the extent that your Personal
Data is processed subject to the European General Data Protection Regulation:

 * Right to access, rectification, erasure and restriction of processing. You
   have the right to request:
   * Access to your personal data. This means that you have the right to request
     information on our use of your Personal Data. You also have the right to
     request a copy of the Personal Data being processed at no cost. However, we
     may charge you a reasonable administrative fee to provide you with
     additional copies of the Personal Data. If you make your access request by
     electronic means such as email, we will provide you with the information in
     a commonly used electronic format.
   * Rectification of your personal data. We will at your request, or at our own
     initiative, rectify, anonymize, erase or complement Personal Data that you
     or we discover is inaccurate, incomplete or misleading. You also have the
     right to complete the Personal Data with additional data if relevant
     information is missing.
   * Erasure of your personal data. You have the right to request that we erase
     your Personal Data if we do no longer have an acceptable reason for
     processing the data. Given this, erasure shall be made by us if:
   * the Personal Data is no longer necessary for the purposes for which it was
     collected,
   * we use your Personal Data with your consent and you withdraw your consent,
   * you object to the processing of your Personal Data based on our legitimate
     interest and there is no overriding legitimate ground for the processing,
   * the Personal Data has not been lawfully processed,
   * we are required to erase the Personal Data due to a legal obligation, or
   * you are a child and we have collected the personal data in relation to the
     offer of information society services.

However, there might be requirements under applicable law, or other compelling
reasons, that prevents us from immediately erasing your Personal Data. In such
case, we will stop using your Personal Data for any other reasons than to comply
with the applicable law, or the relevant compelling reason.

 * Right to restrict processing: This means that we temporarily restrict the
   processing of your Personal Data. You have the right to request restriction
   of the processing when:
   * you have requested rectification of your personal data in accordance with
     this Privacy Policy, during the period of time we are verifying the
     accuracy of the data,
   * the processing is unlawful and you do not want the Personal Data to be
     erased,
   * as data controller, we no longer need the Personal Data for the purposes
     for which it was collected, but you require us to retain the information
     for the establishment, exercise or defense of legal claims, or
   * you have objected to our legitimate interest for the processing in
     accordance with this Privacy Policy, during the period of time we determine
     whether the legitimate interest overrides your privacy rights.

We will take all reasonable and possible actions to notify any recipients of
your Personal Data regarding any rectification, erasure or restrictions carried
out by us. At your request, we will also inform you with which third parties we
have shared your Personal Data.

 * Right to object to processing. You have the right to object to the processing
   of your Personal Data based on our legitimate interest. If you object to such
   processing, we will only continue with the processing if we have a compelling
   legitimate reason for the processing that outweighs your interest, rights or
   freedoms, or if continued processing is necessary for the establishment,
   exercise or defense of a legal claim.
 * Right to portability. You have the right to receive certain of your Personal
   Data in a structured, commonly used and machine-readable format and have the
   right to transmit those data to another controller. You only have this right
   when your personal data is processed by automated means and our legal basis
   for the processing is performance of a contract between you and us.
 * Right to lodge a complaint. You have the right to lodge any complaints
   regarding our processing of your personal data with the supervisory
   authority.

SECURITY OF YOUR INFORMATION

We take reasonable technical, administrative and physical security measures to
protect your information, including applying generally accepted industry
standards to protect the information submitted to us during transmission and
once we receive it. However, no method of transmission over the Internet, or
method of electronic storage is 100% secure, so we unfortunately cannot
guarantee absolute security. If you have reason to believe that your interaction
with us is no longer secure (e.g., if you feel that the security of any account
you might have with us has been compromised), please contact us immediately as
detailed under the “Contact Us” heading below.

INTERNATIONAL TRANSFERS

Some of the parties with which we may share your information, as detailed in
“How We Share Your Information”, may be located in countries that do not provide
an equivalent level of protection as your home country. Where required, Verafin
has implemented appropriate cross-border transfer solutions to provide adequate
protection for transfers of certain personal information, including, but not
limited to, the European Commission’s Standard Contractual Clauses (available
at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).
To the extent permitted by applicable law, by using our Sites, and providing us
information about you, you consent to the international transfer of information
about you to the above parties.

RETENTION OF YOUR INFORMATION

We will retain your information for the period necessary to fulfill the purposes
outlined in this Privacy Policy and as otherwise needed to comply with
applicable law and recordkeeping requirements or to address any complaints,
challenges, legal or compliance matters related to the information.

COOKIES AND SIMILAR TECHNOLOGIES

When you use our Sites, we along with our affiliates, subsidiaries and third
party service providers may use “cookies” and similar technologies (e.g., log
files, clear gifs, pixel tags and Flash LSOs) (collectively, “technology”). This
technology may involve placing small files/code on your device or browser that
serve a number of purposes, such as remembering your preferences (e.g.,
language) and generally improving your experience on our Sites. Specifically, we
may use such technology for purposes such as to:

 * Provide us with general analytics about our Sites, including demographic
   information in a non-identifiable form, in order to improve our Sites’
   performance and customize users’ experience;
 * Enable us to help you make better use of our services or Sites such as by
   suggesting how you can improve your use of different features or
   functionality or help address technical issues that you encounter in using
   our services or Sites;
 * Support security measures, such as requiring re-login into your account or
   additional authentication when using a new device to access our Sites;
 * Measure the success of our marketing campaigns and compile statistics about
   the Site’s usage and email response rates;
 * Allow you to engage in our social media offerings on our Sites (e.g.,
   Facebook “Like” button and LinkedIn integration); and
 * More effectively market our Sites and advertise other Sites that may be of
   interest to you.

USE OF SITES BY CHILDREN

None of our Sites are targeted for use by children under the age of sixteen. We
do not target any of our products or services or Site content/features for use
by children of such age.

For California Consumers

If you reside in California, we are required to provide additional information
to you about how we use and disclose your information, and you may have
additional rights with regard to how we use your information. We have included
this California-specific information below.

 * CA Personal Information. Consistent with the “Information We Collect” section
   above, we collect certain categories and specific pieces of information about
   individuals that are considered “Personal Information” in California (“CA
   Personal Information“). Specifically, we may collect the following types of
   CA Personal Information:
   * Identifiers: Name; email address; social media username; telephone number;
     mailing address; business contact information; tax or national
     identification number; date of birth; username and password; passport or
     government issued identification information (such as for security purposes
     when visiting our facilities); identifiers assigned by Verafin systems or
     systems of other self-regulatory organizations.
   * Commercial or trading-related information: products or services purchased,
     obtained or considered, other purchasing or consuming histories or
     tendencies; financial holdings information; payment information (e.g., bank
     account or credit card number); transaction history; and, transactions,
     activities or other behavior related to financial markets;
   * Internet or other electronic network activity information: computer and
     connection information; statistics on page views; traffic to and from the
     websites; device information; ad data; and other standard weblog
     information.
   * Professional or employment-related information: company; title; employment,
     company officer or director, or shareholder status; trader identification,
     client identification, employer-assigned identification or trading “short
     code”; identifiers issued by a licensing or regulatory organization;
     professional affiliations; and, career or professional history and
     educational background.
   * Legal and regulatory information: information related to your ability to
     participate in the US or other financial markets; information regarding
     your status under US or global economic sanctions, export control or other
     trade control regimes; information related to law enforcement actions,
     fraud, cybersecurity or other similar risks; and, where authorized related
     to certain Verafin services, the results of background screening including
     anti-money laundering assessments.
   * Audio or visual information: your recorded voice (where you are advised in
     advance of the recording); and photograph.
 * Sources. We may collect certain categories of CA Personal Information from
   you and other third parties as described in the “Information We
   Collect” section above. The categories of third parties from whom we may
   collect CA Personal Information include the following:
   * Third-party partners
   * Third party applications (including, blogs, chat rooms, or social
     networks);
   * Advertising networks;
   * Government agencies and other self-regulatory organizations, and
   * Other companies or organizations, such as market research firms and data
     aggregators.
 * Purposes. We collect the CA Personal Information for the business and
   commercial purposes described in the “How We Use Your Information” section
   above. As described above in the “How We Share Your Information“, we also
   share and/or disclose your CA Personal Information as follows:
   * Sharing your CA Personal Information for business purposes: we may share
     the following categories of your CA Personal Information with service
     providers, third party partners, customers, public or government
     authorities and future business partners for our business purposes:
     Identifiers; Commercial or trading-related information; Internet or other
     electronic network activity information; Professional and other
     employment-related information; Legal and regulatory information; and,
     Audio or visual information. As described above, examples of business
     purposes include performing transactions and delivering our contracted
     services, providing you requested information or services, registering and
     maintaining accounts, managing our relationship with you or your employer,
     monitoring for security threats and fraud and performing our legal and
     regulatory duties.
   * Sharing your CA Personal Information for other purposes: we may share the
     following categories of your CA Personal Information with third party
     partners and customers in a manner that constitutes a “sale” under
     California law: Identifiers; Internet or other electronic network activity
     information; Professional and other employment-related information. This
     information may be shared for the following purposes: to deliver customized
     advertising to you when using our ad-supported websites; providing data
     products and services to customers; and, performing services contracted by
     your employer or you.
 * California Consumer Rights. Subject to certain exceptions, as a California
   resident, you have the right to: (i) request access to your CA Personal
   Information; (ii) request deletion of your CA Personal Information; (iii)
   request information about the CA Personal Information about you that we have
   “sold” (as such term is defined under California law) to third parties within
   the past 12 months; and (iv) opt-out of the “sale” of your CA Personal
   Information, as detailed above.
   * Do Not Sell My Information. To opt-out of the “sale” of your CA Personal
     Information as described in this section, click on the “Do Not Sell My
     Information” link at the bottom of the screen.
   * Exercising other California consumer rights. Should you wish to request the
     exercise of your other rights as detailed above with regard to your CA
     Personal Information, we will not discriminate against you by offering you
     different pricing or products, or by providing you with a different level
     or quality of products, based solely upon this request. Please see
     the “Contact Us” section below if you have questions or would like to
     exercise such rights.

CHANGES TO THIS PRIVACY POLICY

Except to the extent limited by applicable law, we reserve the right to update
this Privacy Policy to reflect changes to our information practices by
prominently posting notice of the update on our Sites. Unless otherwise noted,
any updates will become effective 30 days after posting the updates to the
Privacy Policy, and apply to all information collected about you. If we make any
changes to this Privacy Policy that materially impact previously collected
information about you, we will, to the extent that we have your email address,
notify you by email.

CONTACT US

If you have any questions about this Privacy Policy or information we have
collected about you, please contact us by email at legal@verafin.com or by
postal mail at:

Privacy Officer
Verafin Solutions ULC

18 Hebron Way

St. John’s, NL Canada A1A 0L9



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   18 Hebron Way, St. John's, NL A1A 0L9, Canada
   1.877.368.9986
   info@verafin.com
   
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