We reserve the right to change this Privacy Policy at any time by posting a revised version and changing the "Effective Date" above. The amended version will go into effect on the "Effective Date" specified. We will provide you fair advance notice of substantial changes in how we use your information, which may include notification on the PayAveta app or website, or by email. If you do not agree with these changes, you have the option to terminate your account at any time. If you continue to use our Services, you agree to any changes to this Privacy Policy.

PayAveta's E-Sign Consent is accepted by you. By publishing it on our website, sending you push notifications through the Services, or emailing the email address specified in your Account, we may give you the disclosures and notices demanded by law as well as additional information regarding your Account (see below). The same meaning and consequences apply to electronic disclosures and notices as they would have if we had sent them to you in physical form. Such disclosures and notifications shall be deemed to have been sent to you when posted on our website or when pushed or emailed to you, whichever occurs first, within twenty-four (24) hours. Contact the PayAveta App Support if you want to stop receiving electronic messages. You might need to cancel your Account if we can't accommodate your request.

We need to collect information about you in order to provide you with the Services or assistance you have requested. We gather (and/or have collected) the types of personal information listed below during the 12-month period before the effective date of this Privacy Notice. You can also opt to voluntarily provide us with information.

Information You Provide to Access our Services

We collect information you provide when you apply or sign up for a PayAveta App account, go through our identity or account verification process, authenticate into your account, communicate with us, answer our surveys, participate in contests or promotions offered by us or our partners, or otherwise use our Services.

We collect the following categories of information about you when you use our Services, including:

• Identification information includes your name, email address, zip or postal code, phone number, username, signature, and authentication credentials (for example, the information you use to log in to your PayAveta account), as well as your Internet Protocol ("IP") address.

• Additional Identification Information for Users , such as: your full mailing address; your date of birth; government-issued identification, such as your TRN/Tax ID/Social Security number, passport, or driver's license; and a photograph, facial scan, and biometrics extracted from such image if you choose to share such information in order to send and receive larger payment amounts or purchase Crypto Currency.

• Financial Information, such as: Bank account(such as name of bank, SWIFT code, branch name and branch address, account number, account name, type of account, and currency) and payment card numbers you add to your PayAveta account, as well as your Paya Card number if you have one.

Our third-party payment gateway service providers and processors may store or otherwise process your Bank Card Details in accordance with their privacy practices, and we may share some of your Bank Card Details with them. In addition, our third-party PCI compliant data security providers may store or otherwise process your Bank Card number and CVV number in accordance with their privacy practices.

• Transaction Data includes details about payment transfers to and from you such as a description of the transaction, the transaction amount, transaction currency, names of the Sender and Recipient, transaction date and time, devices and payment methods used to complete the transactions and any photo or GIF attached to the transaction.

• Usage Data includes information about how you use our Platform, products and Services and how you use your devices to access our Platform, including the pages you visit and searches you make.

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

• Other Personal Data includes:

a - any other data uploaded onto our Platform by you or shared with other Users of our Platform by you via our Platform;

b - communications with us via social media platforms, email, electronic messages and other electronic and non-electronic communications;

c - third-party partner information related to how you use our third-party partners, such as your reviews of our partners or other service providers;

d - your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices' address book contacts, and other social media such as Facebook, Instagram and Twitter.

Information You Provide to Enhance Your Experience

You can choose to provide us with additional information to improve your user experience when using our Services:

• Contacts Information You can choose to allow us to access and upload your phone contacts information to help you find the people to whom you want to send money, to assist you in inviting your friends to the PayAveta App, for account and identity verification and fraud prevention purposes, to reduce the risk of sending payments to the wrong person, or to provide other personalized services. You can change your settings at any moment to cease sharing your phone contacts with us, but we will always need a recipient's username, phone number, or email address to transfer money to them as you wish.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, model of your mobile phones and computers and their device identification number, operating system, hardware version, device settings and other technology identification on the devices used to access our Platform, file and software names and types, time zone setting, device locations such as through GPS, Bluetooth or Wi-Fi signals, browser plug-in types and versions, connection information such as the name of your mobile operator or ISP, or language setting.

Information We Collect From Your Use of our Services

We collect information about you and the devices you use to access the Services, such as your computer, mobile phone, or tablet. The information that we collect includes:

• Geolocation Information The location of your device, including your IP address, device language, and location of your network provider. This may include precise geolocation information. For more information and to learn how to disable collection of precise geolocation information from your mobile device

• Other Information You Provide We collect information that you voluntarily provide to us, including your photograph, if you choose to upload a picture to the Services; survey responses; participation in contests, or other prospective marketing forms or devices; suggestions for improvements; referrals; or any other actions you perform on the Services.

SOURCES OF INFORMATION WE COLLECT ABOUT YOU

We gather (and/or have collected) information about you from the following sources during the 12-month period before the effective date of this Privacy Policy: • You directly, when you submit information to us or allow us to access information
• Your devices and how you interact with our Services
• Our group companies or affiliates
• Other sources, including:

• Identity Verification. Information from third-party verification services (e.g., identity verification agencies and companies which provide third party analytics (see “Third-Party Analytics” below)), and publicly available sources. In some circumstances, where lawful, this information can include your government-issued identification number.

• Credit, Compliance, and Fraud. Information about you from third parties for any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

We may collect, use, and share information about you (or have collected, used, or shared information about you during the 12-month period before the effective date of this Privacy Policy) for the following reasons:

Providing, Improving, and Developing our Services

• Determining whether the Services are available in your country;
• Processing or recording payment transactions or money transfers;
• Providing you with the PayAveta product and features you choose to use;
• Displaying your historical transaction information;
• Connecting you with people you already know;
• Providing, maintaining and improving our Services;
• Developing new products and services;
• Delivering the information and support you request through the use of our Services;
• Improving, personalizing and facilitating your use of our Services, content and applications;
• Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services, including
• promotions or discounts offered by us or our partners; and
• Otherwise providing you with the products and features you choose to use.

Communicating with You About our Services

• Sending you surveys and getting your feedback about our Services; and
• Sending you information we think you may find useful or which you have requested from us about our products and services.

Protecting our Services and Maintaining a Trusted Environment

• Conducting investigations, complying with and enforcing any applicable laws, regulations, legal requirements, and industry standards, and responding to lawful requests for information from the government or to valid legal process;
• Contacting you to resolve disputes, collect fees and help you with our Services;
• Debugging to identify and fix errors that impair how our Services function;
• Making sure you follow our Terms of Use or other applicable agreements or policies;
• Investigating, detecting, preventing, recovering from, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf;
• Protecting your, our, or our other customers’ rights or property, or the security or integrity of our Services;
• Verifying or maintaining the quality and safety of our Services; and
• Verifying your identity (e.g., through government-issued identification numbers).

Advertising and Marketing

• Marketing our Services to you; and
• Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners.

If we send you marketing emails, each email will have instructions on how you can “opt out” of getting future marketing from us.

Other Uses

• For any other reason we may tell you about from time to time, with your consent.

We may share the information described in the “Information We Collect About You” section with the following categories of service providers and third parties:

With Other Users of our Services

• With other users of our Services. For example, we may share information with the person(s) with whom you transact when you make or accept a payment or money transfer using our Services. This helps them know they’re getting money from you (or that you requested a payment from them). We may also make certain information available to other PayAveta customers to help them know they’re making a payment to the right person, such as when you joined PayAveta and whether you appear in their contacts, and the number of people in their contacts who have also transacted with you. We may also make certain information available to person(s) with whom you choose to communicate using our Services to help them know they are communicating with the right person, such as your name, username, and prior transaction history and transaction amount with such person. If you choose, we may also allow you to share additional information about you and your use of our Services with other PayAveta customers.

With our Affiliates and Group Companies

• For the reasons stated above, with our group companies and corporate affiliations. We may share your information internally, for example, to provide you with enhanced services from the PayAveta App and other PayAveta company products you use, to understand how you interact with PayAveta company products to help make our Services better for you and everyone, and to help us build Services tailored to your preferences.

With our Service Providers

• With service providers who help us provide, maintain, and improve our Services (for example, vendors who assist us with fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, credit bureaus, crypto exchanges, carrying brokers, and other entities in connection with your payment, money transfer process, investing activity, or otherwise to help us provide the Services;

With Advertising Partners

• With advertising partners who help us run our advertising campaigns, analyze our site, run contests, special offers, or other events or activities, and track metrics on our behalf or in connection with our Services.

Business Transfers and Corporate Changes

• To a subsequent owner, co-owner, or operator of one or more of the Services; or
• If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all of our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

Safety and Compliance with Law

• If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with our Terms of Use or other applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

With Others with Your Consent

• With your consent. For example:
• At your direction or as described at the time you agree to share;
• When you authorize a third party application or website to access your information

Aggregated and Anonymized Information

• We also may share (within our group of companies or affiliates, or with service providers or other third parties) aggregated and/or anonymized information that does not specifically identify you or any individual user of our Services.

We collect certain information when you engage with our online services or read emails we send you using automatic technologies such as cookies, web server logs, web beacons, and other technologies. A "cookie" is a text file that websites send to the computer or other internet-connected device of a visitor in order to uniquely identify the visitor's browser or to save information or settings in the browser. A "web beacon," also known as an internet tag, pixel tag, or clear GIF, is a little visual image that may appear on our websites or in emails.

We use these automated technologies to collect your device information, internet activity information, and inferences as described above. These technologies help us to:

• Remember your information so you do not have to re-enter it;
• Track and understand how you use and interact with our online services and emails;
• Tailor our online services to your preferences;
• Measure how useful and effective our services and communications are to you; and
• Otherwise manage and enhance our products and services.

We set some of these automated technologies ourselves, but others are set by third parties who deliver services on our behalf. For example, we may use other companies’ web analytics services (described in the “Third-Party Analytics Services” section), which use automated technologies to help us evaluate how customers use our websites.

Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device. You can learn more about cookies and how to manage your preferences by visiting www.allaboutcookies.org.

We may use third-party analytics service providers to help us with our online services, such as Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons, and web server logs to help us analyze how you use our online services. We may disclose your site-use information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services.

We keep your information as long as is necessary for the purposes identified in this Privacy Notice, including to provide you the Services, to comply with applicable law and legal obligations, and to defend our legal rights, property and users. Even after you deactivate your account, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with certain criteria, such as applicable law, applicable statute of limitations, or as we believe is reasonably necessary to comply with applicable laws, regulations, legal processes, or governmental requests, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Use or other applicable agreements or policies, or to take any other actions consistent with applicable law.

Personal Information

You can access, change, or correct information that you have provided by logging into your PayAveta account at any time or by making a request to us using the contact details below. We will need to verify your identity before granting access or otherwise changing or correcting your information.

Deactivating Your Account

If you wish to deactivate your account or if you would like to have your account closed permanently, please contact us at PayAveta Support.

Location Information

We may need access to location information, including precise geolocation information obtained from your device, in order to perform certain Services. Certain Services will not work correctly and you will be unable to use them if you do not consent to the collecting of this information. You may disable our collecting of location data at any moment by changing the settings on your mobile device. Some of our mobile applications will no longer work if you do so. You may also stop our gathering of location information through mobile application by removing the PayAveta mobile applications from your device using the regular uninstall method.

Do Not Track

Certain web browsers allow you to instruct your browser to respond to Do Not Track (“DNT”) signals to website you visit, informing those sites that you do not want your online activities to be tracked. At this time, our websites are not designed to respond to DNT signals or similar mechanisms from browsers.

Promotional Communications

You can opt out of receiving in-app push notifications containing promotional messages from us by following the instructions on screen or by following the instructions in those messages. If you decide to opt out, we may still send you non-promotional communications in-app, or via email and text, such as transaction receipts and messages about your account, or our processing of your information in accordance with the provision of our Services.

HOW WE SECURE INFORMATION

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers.

We may, and we may use third-party service providers to, process and store your information in the United States, Canada, Japan, the United Kingdom, the European Union, and other countries. Authorized employees, representatives, and agents will have access to your information for the purposes described in this Privacy Policy.

Please contact our privacy team with any questions or concerns regarding this Privacy Policy at PayAveta Limited by logging into your PayAveta account and visiting PayAveta Privacy Support

If you have any questions or concerns regarding our privacy policy, or if you believe our privacy notice or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our privacy team listed above. We will respond to let you know when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution. If you remain dissatisfied, you can also make a formal complaint to the applicable privacy regulator in your jurisdiction.