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PRIVACY POLICY

Versapay Corporation (“we”, “us”, or “our”) might collect and process personal
data of users of VersaPay’s website and online services. This Privacy Policy
applies to personal data we obtain from our customers and their representatives
(“Users”) through our websites when the relevant User registers to VersaPay’s
cloud-based infrastructure and software services (collectively, the “Services”).
In addition, some of our services might be subject to a separate privacy policy.
If a separate privacy policy applies to a particular service, we will post it on
the relevant website or otherwise in connection with the service in question.

Our Privacy Policy explains what data we process, how we do that and how the
data subjects, i.e. Users, may use their rights (e.g. right to object, right of
access).

This Privacy Policy may be updated if required in order to reflect the changes
in data processing practices or otherwise. The current version can be found on
our website www.versapay.com. We will not make substantial changes to this
Privacy Policy or reduce the rights of Users under this Privacy Policy without
providing a notice thereof. This policy might receive small updates, and if so,
we’ll let you know.

This Privacy Policy only covers data processing carried out by VersaPay. The
Privacy Policy does not address, and we are not responsible for, the privacy
practices of any third parties. VersaPay disclaims all responsibility for the
processing carried out by third parties, also in cases where Services include
hyperlinks to third parties’ websites. We take care of our users privacy but
cannot be responsible for the privacy practices of any third parties.

Please note that this Privacy Policy applies to processing of personal data
carried out by VersaPay as a data controller. As regards the data VersaPay’s
customers or Users insert into Services while using the Services, VersaPay
registers this personal data as a data processor and the relevant customer shall
be considered to be the data controller with regard to this personal data. We
only control personal data of our users. If a user uploads personal data onto
our services, they are the data controller and we only the data processor.

Privacy, security and online safety are important for us, and we process all
personal data with due care and in accordance with applicable laws and
regulations.

SCOPE AND CONSENT

By signing up for, accessing, or using our Services and/or website, you accept
this Privacy Policy and consent to our collection, use and disclosure of your
Personal Information as described in this Privacy Policy. This Privacy Policy
only covers data processing carried out VersaPay. The Privacy Policy does not
address, and we are not responsible for, the privacy practices of any third
parties. VersaPay disclaims all responsibility for the processing carried out by
third parties, also in cases where Services include hyperlinks to third parties’
websites.

Please note that this Privacy Policy applies to processing of personal data
carried out by VersaPay as a data processor and registers this personal data as
a data processor and the relevant customer shall be considered to be the data
controller with regard to this personal data.

Privacy, security and online safety are important for us, and we process all
personal data with due care and in accordance with applicable laws and
regulations.

PERSONAL DATA PROCESSED AND SOURCES OF DATA

We collect two types of information from the Users: (i) User Data; and (ii)
Technical Data. Although we do not normally use Technical Data to identify
individuals, sometimes individuals can be recognized from it, either alone or
when combined or linked with User Data. In such situations, Technical Data can
also be considered to be personal data under applicable laws and we will treat
the combined data as personal data.

VersaPay may collect and process for example the following User Data from Users:
(i) name and contact details; (ii) e-mail address; (iii) phone number; (iv)
invoicing and billing information; (v) other personal data Users provide
themselves.

The specific kind of User Data collected will depend on the Services used by the
User. Most of the User Data is received directly from Users at the point of
registration or otherwise at beginning of and during the customer relationship,
and the rest is based on the data they provide to VersaPay that is processed.

Technical Data we gather in connection with the use of our Services includes for
example the following data: (i) User’s IP address; (ii) browser type and
version; (iii) preferred language; (iv) geographic location using IP address or
the GPS, wireless, or Bluetooth technology on your device; (v) operating system
and computer platform; (vi) the full Uniform Resource Locator (URL) clickstream
to, through, and from our Services, including date and time; (vii) products or
services User viewed or searched for while using our Services; and (viii) areas
of our Services User has visited.

TRANSFER TO COUNTRIES OUTSIDE OF EUROPE.

We have service providers in several geographical locations and as such, we and
our service providers may transfer personal data to, or access it in,
jurisdictions outside the European Economic Area or the User’s domicile.

We will take steps to ensure that the Users’ personal data receives an adequate
level of protection in the jurisdictions in which it is processed. We provide
adequate protection for the transfers of personal data to countries outside of
the European Economic Area through a series of agreemeInformation collected when
you set up an account or perform a transaction

Versapay will collect personal information when you set up an account to use the
products and services provided by VersaPay. In addition, we also track your use
of Services, and in the course of processing a payment for you, we receive
information about you and the payment transaction from your payee and/or a
financial institution. This includes payment information that you have furnished
to the payee or you have submitted to us while using the Services.

COOKIES

We use various technologies to collect and store Technical Data and other
information when Users visit our Services, including cookies. Cookies allow us
to calculate the aggregate number of people visiting our Services and monitor
the use of the Services. This helps us to improve our Services and better serve
our Users. We may also use cookies that make the use of the Services easier, for
example by remembering usernames, passwords and preferences. We may use tracking
and analytics cookies to see how well our Services are being received by our
Users.

Users may choose to set their web browser to refuse cookies, or to alert when
cookies are being sent. This can usually be done through Internet browser’s
settings. Information about how to manage cookies can be found online.

Please note that some parts of our Services may not function properly if use of
cookies is refused.

WEB ANALYTICS SERVICES

Our Services use several web analytics services to compile Technical Data and
reports on visitor usage and to help us improve our Services.

PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA

There are several purposes for the processing of personal data by VersaPay.
Personal data is processed by VersaPay for managing the relationships with
customers, facilitating transactions and payments, and for managing, developing
and analysing our customer service. Personal data is also used to direct
marketing at special customer groups, and other business activities related to
any of these activities.

Personal data is also processed by VersaPay for the following purposes:

TO PROVIDE OUR SERVICES AND CARRY OUT OUR CONTRACTUAL OBLIGATIONS.

We process personal data in the first place to be able to offer the Services to
our customers and Users and to run, maintain and develop our business. In some
cases, personal data may be processed in order to carry out our contractual
obligations towards the User. We may use the data for example to offer essential
functionalities of the Services and to provide access to the Services. If User
contacts our customer service, we will use the provided information for
answering questions and solving possible issues.

FOR CUSTOMER COMMUNICATION.

We may process personal data for the purpose of contacting Users regarding our
Services and to inform Users of changes in our Services. Data may also be used
for research and analysis purposes in order to improve our Services.

FOR QUALITY IMPROVEMENT AND TREND ANALYSIS.

We may process information regarding the use of the Services to improve the
quality of our Services e.g. by analysing any trends in the use of our Services.
When possible, we will do this using only aggregated, non- personally
identifiable data.

LEGITIMATE GROUNDS FOR PROCESSING

We process personal data to perform our contractual obligations towards Users
and to comply with legal obligations. Furthermore, we process personal data to
pursue our legitimate interest to run, maintain and develop our business.

In some parts of the Services, Users may be requested to grant their consent for
the processing of personal data. In this event, Users may withdraw their consent
at any time.

nts with our service providers based on the Standard Contractual Clauses or
other similar arrangements.

More information regarding the transfers of personal data may be obtained by
contacting us on addresses mentioned in this Privacy Policy.

RECIPIENTS

We only share personal data within the organisation of VersaPay if and as far as
reasonably necessary to perform and develop our Services. We do not share
personal data with third parties outside of VersaPay’s organization unless one
of the following circumstances applies:

IT IS NECESSARY FOR THE PURPOSES SET OUT IN THIS PRIVACY POLICY

To the extent that third parties need access to personal data to perform the
Services, VersaPay has taken appropriate contractual and organisational measures
to ensure that personal data are processed exclusively for the purposes
specified in this Privacy Policy and in accordance with all applicable laws and
regulations.

FOR LEGAL REASONS

We may share personal data with third parties outside VersaPay’s organization if
we have a good-faith belief that access to and use of the personal data is
reasonably necessary to: (i) meet any applicable law, regulation, and/or court
order; (ii) detect, prevent, or otherwise address fraud, security or technical
issues; and/or (iii) protect the interests, properties or safety of VersaPay,
our Users or the public in accordance with the law. When possible, we will
inform Users about such transfer and processing.

TO AUTHORIZED SERVICE PROVIDERS

We may share personal data to authorized service providers who perform services
for us (including data storage, sales, marketing and customer support services).
Our agreements with our service providers include commitments that the service
providers agree to limit their use of personal data and to comply with privacy
and security standards at least as stringent as the terms of this Privacy
Policy. Please bear in mind that if you provide personal data directly to a
third party, such as through a link on our website, the processing is typically
based on their policies and standards.

FOR OTHER LEGITIMATE REASONS

If VersaPay is involved in a merger, acquisition or asset sale, we may transfer
personal data to the third party involved. However, we will continue to ensure
the confidentiality of all personal data. We will give notice to all Users
concerned when the personal data are transferred or become subject to a
different privacy policy as soon as reasonably possible.

WITH EXPLICIT CONSENT

We may share personal data with third parties outside VersaPay’s organization
for other reasons than the ones mentioned before, when we have the User’s
explicit consent to do so. The User has the right to withdraw this consent at
all times. We do not share your personal data with third-parties unless
necessary to provide you with our services or for legal reasons.

STORAGE PERIOD

VersaPay does not store personal data longer than is legally permitted and
necessary for the purposes of providing the Services or the relevant parts
thereof. The storage period depends on the nature of the information and the
purposes of processing. The maximum period may therefore vary per use.

Typically, we will store User’s personal data for as long as the User or the
relevant customer User represents is a registered subscriber or a registered
user of our Services or for as long as we have another purpose to do so and,
thereafter, for no longer than is required or permitted by law or reasonably
necessary for internal reporting and reconciliation purposes.

In general, personal data of Users are deleted within reasonable time after the
User no longer uses any part of the Services or when the User makes a request
regarding deletion of User’s personal data. We only store your personal data for
while you are using our services. The data will be deleted within reasonable
time after you’ve stopped using our services or request your personal data to be
deleted.

USER RIGHTS

RIGHT TO ACCESS.

VersaPay offers access for the Users to the personal data processed by VersaPay.
This means that Users may contact us and we will inform what personal data we
have collected and processed regarding the said User and the purposes such data
are used for.

RIGHT TO WITHDRAW CONSENT.

In case the processing is based on a consent granted by User, User may withdraw
the consent at any time. Withdrawing a consent may lead to fewer possibilities
to use our Services.

RIGHT TO CORRECT.

Users have the right to have incorrect, imprecise, incomplete, outdated, or
unnecessary personal data we have stored about the User corrected or completed.

RIGHT TO DELETION.

Users may also ask us to delete the User’s personal data from our systems. We
will comply with such request unless we have a legitimate ground to not delete
the data. We may not immediately be able to delete all residual copies from our
servers and backup systems after the active data have been deleted. Such copies
shall be deleted as soon as reasonably possible.

RIGHT TO OBJECT.

Users may object to certain use of personal data if such data are processed for
other purposes than purposes necessary for the performance of our Services to
the User or for compliance with a legal obligation.

Users may also object any further processing of personal data after prior given
consent. If User objects the further processing of personal data, this may lead
to fewer possibilities to use our Services.

In the event and at the sole discretion of VersaPay, if it is determined that
the Service can no longer be provided without customer acceptance of modified
terms, a pro-rated refund of service will be paid back to the User.

RIGHT TO RESTRICTION OF PROCESSING.

Users may request us to restrict certain processing of personal data, this may
however lead to fewer possibilities to use our Services.

RIGHT TO DATA PORTABILITY.

Users have the right to receive their personal data from us in a structured and
commonly used format and to independently transmit those data to a third party.

HOW TO USE THE RIGHTS.

The above mentioned rights may be used by sending a letter or an e-mail to us on
the addresses set out above, including the following information: the full name,
company name (if applicable), address, e-mail address and a phone number. We may
request the provision of additional information necessary to confirm the
identity of the User. We may reject requests that are unreasonably repetitive,
excessive or manifestly unfounded. As a user you have the right to access,
correct, and delete your personal data. Contact us for any requests to exercise
your rights.

DIRECT MARKETING.

Notwithstanding any consent granted beforehand for the purposes of direct
marketing, User has the right to prohibit us from using User’s personal data for
direct marketing purposes, market research and profiling by contacting us on the
addresses indicated above or by using the functionalities of the Services or the
unsubscribe possibility offered in connection with any direct marketing
messages.

You have the right to opt out of receiving electronic direct marketing
communications from us, and choosing not to receive marketing communications
from us in the future. VersaPay uses the Users’ e-mail addresses on record to
communicate of updates and important information regarding the VersaPay
infrastructure in the form of occasional newsletters. Users have the possibility
to opt out of these e-mails by unsubscribing through the e-mail itself.

You also have the right to prohibit us from using your personal data for direct
marketing purposes, market research and profiling by contacting us on the
addresses indicated above. In case your personal data are processed based on
your consent, you have the right to withdraw your consent for such processing.
You have the right to prohibit us from using your personal data for direct
marketing and unsubscribe from any e-mail campaigns.

LODGING A COMPLAINT.

In case User considers our processing of personal data to be inconsistent with
the applicable data protection laws, a complaint may be lodged with the local
supervisory authority for data protection.

INFORMATION SECURITY

We will take all reasonable and appropriate security measures to protect the
personal data we store and process from unauthorised access or unauthorised
alteration, disclosure or destruction. Measures include for example, where
appropriate, encryption, firewalls, secure facilities and access right systems.

We maintain all personal data collected through industry standard safe
mechanisms including, but not necessarily limited to encryption of password data
as well as API keys, SSL-encryption, passing of credit card information directly
to our acquiring bank(s) and encryption of any collected credit card
information.

We use administrative, organizational, technical, and physical safeguards to
protect the personal data we collect and process. Our security controls are
designed to maintain an appropriate level of data confidentiality, integrity,
and availability. We regularly test our websites, data centres, systems, and
other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely
to have negative effects to the privacy of Users, we will inform the relevant
Users and other affected parties, as well as relevant authorities when required
by applicable data protection laws, about the breach as soon as reasonably
possible.

We use appropriate security measures to keep your personal data safe. If a
breach that might affect your privacy should occur, we’ll inform the relevant
authorities and let you know.

CHANGES TO THIS PRIVACY POLICY

Versapay reserves the right to modify or amend this Privacy Policy at any time
and for any reason. If we make any changes, we will notify you by posting it on
our website and revising the “Last Updated” date at the top of this Privacy
Policy and, in some cases, provide you with additional notice (such as adding a
statement to our homepage or sending you an email notification). If there are
material changes to this Privacy Policy, we will notify you more directly by
email or means of a notice on the home page prior to the change becoming
effective. We encourage you to review our Privacy Policy periodically to stay
informed about our information practices and the ways you can help protect your
privacy. Your continued access or use of our website and Services following a
change means you consent to the collection, use and disclosure of your Personal
Information as set out in this Privacy Policy.

CONTACT US

If you have additional questions about this Privacy Policy, or wish to access
your Personal Information, please contact our customer support team at 1 (866)
999-VPAY from 6 AM to 8 PM Eastern Time, by email at support@versapay.com,
online through our website, or mail us at:

Suite 1800 – 18 King Street East
Toronto, ON M5C3C4
Canada

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