Privacy Policy This policy describes the ways we collect, store, use, and protects your personal information. You accept this policy and consent to such collection, storage and use when you sign up for or use our products, services or any other features, technologies or functionalities offered by us on our website or through any other means (collectively "ZeroPay"). We may amend this policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. In addition, if the revised version includes a substantial change, we will provide you with 30 days' prior notice by posting notice of the change on the "Policy Updates" page of our website. After this 30 days notice, you will be considered as having expressly consented to all amendments to this policy.

How we collect information about you When you visit the ZeroPay website or use the ZeroPay, we collect your IP address and standard web log information, such as your browser type and the pages you accessed on our website. If you open an account, we collect the following types of information: • Contact information - your name, address, phone, email, ID and other similar information. • Financial information - the bank account numbers, digital payment account and credit card numbers that you link to your ZeroPay Payment account or give us when you use the ZeroPay. Before permitting you to use the ZeroPay, we may require you to provide additional information we can use to verify your identity or address or manage risk, such as your date of birth, national ID number, Nationality, and other identifying information. We may also obtain information about you from third parties such as credit bureaus and identity verification services. When you are using the ZeroPay, we collect information about your transactions and your other activities on our website or using the ZeroPay and we may collect information about your computer or other access device for fraud prevention purposes. Finally, we may collect additional information from or about you in other ways such as from contacts with our customer support team, results when you respond to a survey, from interactions with members of the ZeroPay corporate family, and from other companies.

How we use cookies When you access our website, we, or companies we hire to track how our website is used, may place small data files called "cookies" on your computer. We issue a "session cookie" to your computer when you log in to your account or otherwise use the ZeroPay. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we don't need to ask you for your password on each page. Once you log out or close your browser, this cookie expires and no longer has any effect. We also use longer-lasting cookies for other purposes such as to display your e-mail address on our sign-in form, so that you don't need to retype the e-mail address each time you log in to your account. We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website. Our service-providers and we also use cookies to customize our services, content and advertising; measure promotional effectiveness, and promote trust and safety. You may encounter cookies from third parties when using the ZeroPay on certain websites that we do not control (for example, if you view a webpage created by a third party or use an application developed by a third party, there may be a cookie placed by that web page or application).

How we protect and store personal information Throughout this 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 anonymised so that it does not identify a specific user. We store and process your personal information on our computers in Canada and at various customer and operations support centers around the world and we protect it by maintaining physical, electronic and procedural safeguards. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

How we use the personal information we collect Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. To that end, we use your personal information to: • provide the services and customer support you request;. • process transactions and issue notices about your transactions • resolve disputes, collect fees, and troubleshoot problems; • prevent potentially prohibited or illegal activities, and enforce our User Agreement; • customize, measure, and improve our services and the content and layout of our website; • deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; • Compare information for accuracy and verify it with third parties.

Marketing We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference by logging into your payment account going to the Manage Profile sub tab under the My Account tab and adjusting your preferences or by following the directions provided with the communication or advertisement. How we share personal information with other ZeroPay users To process your payments, we need to share 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 from verified ZeroPay users, and whether you have verified control of a bank account are provided to other ZeroPay users who you transact with through ZeroPay. In addition, this and other information may also be shared with third parties when you use these third parties to access ZeroPay. Unless you agreed to it, these third parties are not allowed to use this information for any other purpose other than to enable the ZeroPay. If you are buying goods or services and pay through ZeroPay, we may also provide the seller with your confirmed credit card billing address to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. We work with third parties, including merchants to enable them to accept or facilitate payments from or to you using ZeroPay. In doing so, a third party may share information about you with us, such as your email address, PIN or mobile phone number, when a payment is sent to you or, when you attempt to pay that merchant or through that third party. We use this information to confirm to that you are a ZeroPay customer and that ZeroPay as a form of payment can be enabled, or where a payment is sent to you to issue you notification that you have received a payment. Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you through ZeroPay or with the third parties that offer or use the ZeroPay, except with your express permission or if we are required to do so to comply with credit card association rules, a valid regulatory or law enforcement request, or, to cooperate in an ongoing law enforcement investigation, as otherwise required by law.

How we share personal information with other parties We may share your personal information with: • Members of the corporate family to provide joint content, products and services (like registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services and communications. Members of our corporate family will use this information to issue you marketing communications only if you have requested their services. • Service providers under contract who help with parts of our business operations; (fraud prevention, collection activities, marketing, 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 own benefit. • Companies that we plan to merge with or be acquired by. (Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice). • Law enforcement, government officials, or other third parties when: • we are compelled to do so by a subpoena, court order or similar legal procedure, • we need to do so to comply with law or credit card association rules • we are cooperating with an ongoing law enforcement investigation, • we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement. • Other third parties with your consent or direction to do so. Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country. ZeroPay will not sell or rent any of your personal information to third parties in the normal course of doing business and only shares your personal information with third parties as described in this policy. If you open a ZeroPay Payment account directly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a ZeroPay websites) will be shared with the owner of the third party website or application - and your information may be subject to their privacy policies.

Last Updated : 15th December 2014