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VERSAPAY WEBSITE PRIVACY NOTICE

Effective Date: March 23, 2023

This Privacy Notice describes how Versapay (“our,” “we”) collects, uses, and
shares personal information via our website, our platform, and other online
services (collectively, our “Services”). The Services includes the provision of
software-as-a-service (SaaS) and other tools enabling our business customers to
process payments (our “Clients”). Our Services include our products
Collaborative AR, Cash Application, ERP Payments, and Payments Processing.
Collaborative AR permits our Clients to automate accounts receivable in the
cloud. Our Cash Application automates Client payment processing. Our ERP
Payments integrates into our Clients’ accounting and enterprise resource
planning (ERP) systems to automate payment processing. Payments Processing
allows us to onboard our Clients and process their transactions.

We collect information you choose to give us and other information that may be
automatically collected from your use of our Services, including from your
device. We use that information to operate our business, and for a variety of
other purposes set forth below. Below, we also describe choices we offer with
respect to your data.

This Privacy Notice does not apply to third parties or their services. This
Privacy Notice does not apply to information that cannot be identified to any
individual, household, or their devices, such as de-identified or anonymized
data. This Privacy Notice does not apply if you are a consumer of one of our
business customers (such as a Merchant) to the extent we use the information
such business customers provide to us only to provide services to such business
customer. We are not responsible for how individual Clients choose to use our
platform; you should refer to them to understand their data use and/or privacy
practices or to exercise rights you may have with respect to them.

Information We Collect

How We Use Information We Collect

How We Secure Information

How We Share Information

What Choices Do I Have?

Updates to Our Privacy Notice

Contact Information

Information We Collect

To provide our Services, we collect data by which you may be personally
identified. We may also collect information about the devices and equipment you
use to access our Services, including usage data.

We collect your personal information from a variety of sources, including:

 * Directly from you when you provide it to us.
 * Automatically as you utilize the Services.
 * From third parties, including analytics providers.

Information directly from you. The information we collect on or through our
Service from individuals may include information that you provide directly to us
or to the Client involved in your transaction, including your first and last
name, billing address, credit card details, bank account information and
transaction ID. We also collect information provided at the time you fill out
forms on our Service, implement our Service, sign up for emails and newsletters,
or communicate with us.

If you are a Client(or applying to be a Client) of ours, we may collect
information that you provide to us including your first and last name, Social
Security Number, bank account information, business identification number, tax
withholding allowances and tax filing status, information about your previous
payment processing activities with us or third party payment services providers,
information about your current intended payment processing activities, and other
information about your suitability to be a Client on our network. In evaluating
Clients, we may also conduct background or credit checks on key individuals
(such as owners).

Information we collect through automatic data collection technologies. We may
collect data regarding your use of our Services through cookies, web beacons,
and other automatically collected information. This data may include your IP
address, date and time you access our Services and the pages and content you
access during your visit, websites that you link to or from, emails from us that
you open, and the links you click on within those emails. We may also collect
information from your mobile device or your computer about how you interact with
our Services, including IP address, operating system, and browser type. This
information helps us address customer support issues, provide you with a
personalized experience, prevent fraudulent use of our services, and manage the
Services we provide you, including gathering aggregated data about engagement.
Cookies are small identifiers sent from a web server that are stored on your
device for the purpose of identifying your browser or storing information or
settings in your browser. Cookies may also be used to personalize your visit by
storing your preferences or displaying content based upon what you have viewed
through our Services and other websites. Web beacons or pixel tags connect web
pages to web servers and their cookies. We and others may use these and similar
technologies on our services and other websites.

Other parties may collect personally identifiable information about your online
activities over time and across third-party websites when you use our website or
other Services. We do not respond to “do not track” signals or other mechanisms
that provide consumers the ability to exercise choice regarding the collection
of personally identifiable information about an individual consumer’s online
activities over time and across third-party websites or online services.

Information we collect from third party sources. We may collect additional
information from third-parties. These third parties may provide us information
both in connection with our [website or other Services] and through tools they
use to collect information about you when you use [our website or other
Services]. The information they collect may be associated with your personal
information or they may collect information about your online activities over
time. They and we may use this information to provide you with interest-based
advertising or other targeted content, and for other purposes (such as to better
understand our Services’ audience).

How We Use Information We Collect

We may use data we collect for a variety of purposes, including the following
(which includes activity on behalf of our business clients):

 * To provide our Services to our business customers, including processing
   payments for our Clients.
 * To assess suitability to be a Merchant, including whether applicants meet our
   anti-money laundering, “know your customer,” background checking and other
   compliance requirements. In addition, we use the data we collect from Clients
   to fulfill obligations and to track, report on and display transaction
   history.
 * To maintain, analyze, customize, measure, and improve our Services, which
   includes generating internal reports about the use of our Services.
 * To send transactional communications, including requests for information,
   responses to requests for information, and other Service updates.
 * To provide customer support.
 * To communicate with our customers, including about products updates and
   offerings that we think they may be interested in.
 * For account management, finance, dispute resolution, and reporting purposes.
 * To monitor and enforce our legal terms or similar terms.
 * For internal business reasons, including internal audits or investigations,
   company research, insurance purposes.
 * To comply with law and satisfy our regulatory compliance obligations.
 * To detect and prevent fraud and other prohibited, illicit or illegal
   activity, and to protect you, others, and ourselves.
 * For other purposes permitted by law or to which you consent.

Please note that we may combine the information we gather about you in
identifiable form, including information from third parties. We may use this
information, for example, to improve and personalize our Services, content, and
advertising.

How We Secure Information

We are committed to maintaining measures to protect the security of your
information. Of course, despite these measures, no network or system is ever
entirely secure and we cannot guarantee the security of networks and systems
that we operate or that are operated on our behalf. Note that our Services may
interact with other payment processors, payment gateways, and third party
systems at the direction of our Client or other business customers. We are not
responsible for the security of these third party systems.

How We Share Information

If you are a Merchant, we may share information you provide with service
providers and third parties, including those businesses, banks, and/or
independent service organizations involved in processing payment transactions .
If you are a Client or a key individual owner or employee of such a merchant, we
may share your identification information with our identity verification
vendors, and for background and other suitability checks. .

Our service providers may also include IT, advertising, or communications
providers who help us operate our Services. Please note that some of these
vendors, including our analytics providers, may store your personal information
subject to their own privacy policies and practices not subject to the terms of
this Privacy Notice.

We may also share information relating to identified or identifiable
individuals:

 * With our professional advisors who provide legal, compliance, accounting,
   banking, or consulting services.

 * To comply with our legal obligations or to protect the interests, property,
   or legal rights of you, ourselves, or third parties.

 * With law enforcement, officials, or other third parties when we are compelled
   to do so by a subpoena, court order, or similar law enforcement request, or
   when 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 this Privacy Notice or
   other applicable terms.

 * With companies or other entities in connection with, or during the
   negotiation of, any merger, sale of company stock or assets, financing,
   acquisition, divestiture, or dissolution of all or a portion of our business.

 * For other legal purposes, such as to enforce our legal terms, or to exercise
   or defend legal claims.

 * With your direction or consent.

What Choices Do I Have?

Update personal information. If you are a Client of ours that has an online
account with us, you can log in to your account to access or correct your
information. If you are a consumer, please contact the Client associated with
your transaction.

Marketing communications. You may receive marketing information from Versapay.
You may opt out of receiving marketing emails, by following the unsubscribe link
in each email. Please note that you may continue to receive non-marketing emails
from us after you opt-out.

Cookies. You have a number of choices regarding certain cookies. Most web
browsers automatically accept cookies, but you may modify your browser’s setting
to notify you of cookie placement or decline cookies. If you choose to decline
cookies, certain features of our website may not function properly as a result.

Updates to Our Privacy Notice

We may update this Privacy Notice from time to time in order to provide
clarification or notice of changes to our practices. If we make changes, we will
revise the Effective Date at the top of this Privacy Notice. Changes to this
Privacy Notice will be effective once they are posted unless otherwise
indicated.

Contact Information

If you have any questions or concern about this privacy notice or the privacy
practices at Versapay, please contact us via our privacy portal.


Versapay

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Solupay Consulting, LLC, d/b/a Versapay, is a registered Independent Sales
Organization of Wells Fargo Bank, N.A., Concord, CA, Fifth Third Bank, N.A. 38
Fountain Square Plaza, Cincinnati, OH 45263, and Elavon, Inc. Georgia, a wholly
owned subsidiary of U.S. Bancorp, Minneapolis, MN. Versapay is a registered
Agent of Esquire Bank NA, Jericho, NY.

©2024 Versapay. All Rights Reserved

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