Thank you for visiting https://www.paymight.com/. https://www.paymight.com/ is a digital asset platform operated by and proprietary to Paymight (as defined below).

This Privacy Policy (“Policy”) shall describe the information we collect from you through through https://www.paymight.com/ and/or any associated application program interface or mobile application, if any, (collectively known as “paymight.com”).

This Privacy Policy shall apply to (i) visitors to paymight.com; (ii) individuals (including consumers and merchants who are natural persons) who are users of or have their personal information provided to us (each a "User") in the course of using any services or products through and available on paymight.com (“Services”); and (iii) our business partners, vendors or any third-party provider and their personnel, officers, connected persons (“Partner”), where their personal information is provided to us in connection with the Services through paymight.com.

In this Privacy Policy, references to "you" or "your" are collectively refers to visitors to the paymight.com, a User and Partner, and references to “Paymight”, "we", "us" or "our" refer to Paymight Fintech Ltd., a Canada registered company (together with its affiliates and/or subsidiaries that are involved in providing the Services in paymight.com).

For the purposes of this Policy, you and Paymight shall be individually referred to as a "Party", and collectively as the "Parties".

By continuing to use the Services, sign up for an account with paymight,com (“Account”), visit or access paymight.com or provide us any of your information through paymight.com, you signify that you have read, understood, acknowledge and agree to this Privacy Policy. If you do not agree to this Privacy Policy, please discontinue any access and usage of paymight.com and its Services.

1. WHAT DATA DO WE COLLECT?

We collect and use personal information about you when you use our Services through paymight.com, interact with us, contact us directly with respect to any queries, or otherwise connecting with us. The personal information that we collect include shall not be limited to:

• a) your basic personal details, including your first and last name, date of birth, gender;
• b) your contact information, including address, phone number, email, or other contact information;
• c) copies or information of your identification documents;
• d) your bank account and payment information; and/or
• e) technical information, including information about the device you use to interact with us and our services (including IP address, geographical location, device type and model, screen resolution, app version, device language, device identification codes, device status information and other features/data that can be used to identify a device); and information from your visits to paymight.com (including browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/usage, page views and any search term you use, device logs in the event of a crash or error report).

2. HOW WE OBTAIN YOUR DATA

We collect your personal data in connection with the Services and paymight.com when you browse or use paymight.com, enquire about any Services, sign any contract with us (whether digital or physically), sign up to receive messages from us, sign up for an Account, or interact with us through paymight.com, e-mail, phone, SMS, or any other available communication method. We also receive your personal data from other sources, including but not limited to:

• any other third parties, including those who support the ability to make payments and conduct transactions through the relevant Services;
• our affiliates or subsidiaries;
• suppliers providing services on our behalf;
• third parties for fraud monitoring and prevention purposes, or other purposes required by law;
• from the relevant Partner; and/or
• publicly available sources.

We may combine information that we have about you from various sources, including the information you have provided to us.

3. HOW WE USE YOUR DATA

We use the information we collect to operate our business. This includes but shall not be limited to the following (collectively the “Purposes”):

• a) for the exercise of rights and performance of obligations under, and managing compliance with, our rules, policy and related documentation;
• b) to enable, build, provide, operate and test products and services, provide and operate the Services and related User services, enable transactions, facilitate the build, provision, operation and testing of products and services by others (including our affiliates and/or subsidiaries);
• c) to facilitate the provision of products by our Partners;
• d) to respond your queries, feedback, claims, disputes or otherwise provide customer support and services;
• e) for research, statistical analysis, analytics, business planning and business intelligence purposes in order to understand how users like you perceive our products and services, industry trends, usage patterns and other factors that may affect our business;
• f) to contact you in relation to our provision of Services, contact you in connection with any communication preferences or requests you have expressed, ask you for feedback about the Services or other related products and services in paymight.com, collect feedback from you and your staff about our products and services and using such feedback to improve our business and/or customize products and services; send you information about products and services, including for promotional purposes, present you with offers or promotions (including customized offers and promotions); and contact you for legal purposes;
• g) to operate marketing and advertising activities;
• h) to manage our business, including billing, invoicing, account management, reconciliation, collection, audit purposes and internal reporting;
• i) for security, authentication and risk control purposes, including to manage anti-money laundering and fraud risk, to perform creditworthiness and solvency checks, to assess, detect, investigate, prevent, remediate or report data breaches, fraud, other potentially prohibited or illegal activities and violations of our agreements and policies, industry standards, guidelines, laws and regulations, to protect the integrity and maintain the security of our services, products and platforms, to protect our rights or property and those of others and to prevent any harm or financial loss to us or others;
• j) to provide you with customised content;
• k) to make disclosures as may be required by any rules, law, regulation, subpoena, court order, other legal process or contractual or commercial requirements, including to regulatory authorities, government officials, courts, card associations or other payment schemes. Such requirements may relate to "know your customer" checks, anti-money laundering, counter-terrorist financing reporting, tax requirements or other commercial disputes;
• l) for any proposed or actual merger, acquisition, corporate reorganization, financing, sale joint venture, assignment, transfer, disposition or similar transaction, including the sale of business, assets or stock; and
• m) otherwise for everyday business purposes, to comply with law, or in other ways for which we provide specific notice at the time of collection.

4. TO WHOM DO WE SHARE DATA

We may share your personal information to better operate and manage our business, including for the Purposes. We may share your information with:

• a) your merchants that provide you with goods and services and their acquirers (if applicable), and other third parties, including those who support the ability to conduct transactions through the relevant Services

• b) third party online merchants whose services or mobile applications you elect to use;

• c) service providers elected by you;

• d) third parties where you have instructed us to share information with them;

• e) our affiliates and/or subsidiaries;

• f) any agent, contractor or third party service provider that we work with in providing the Services;

• g) if applicable, banks and other financial institutions, card associations, payment networks or others, including those involved in processing of payments and conducting transactions through the relevant Services;

• h) law enforcement agencies, insurers, government and regulatory or supervisory authorities where under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement;

• i) parties relevant to litigation proceedings and the assessment of claims or disputes, including courts;

• j) individuals and entities involved in any merger, acquisition, corporate reorganization, financing, or similar transaction with us, including in the event of the sale of all or part of our assets; and

• k) our own and others' professional advisors.

We would not share your personal information with the exception of the above for Paymight and its affiliates and/or subsidiaries (if any) ordinary course of business unless we have your expressed prior authorisation or consent.

Notwithstanding the foregoing, your prior authorized consent is not required for the sharing, transfer, or public disclosure of your personal information in the following cases:

• a) directly related to national security or defence security;

• b) directly related to public safety, public health, or vital public interest;

• c) where it is necessary to protect your or other individuals' significant legitimate rights and interests, such as life and property, but where it is difficult to obtain your consent;

• d) personal information that you disclose to the public at your own discretion;

• e) where personal information is collected from information that is lawfully and publicly disclosed;

• f) necessary to enter into and perform a contract at the request of the subject of the personal information; and/or

• g) in other case as provided for by law and regulations.

In accordance to various law and regulations, sharing or transferring personal data refers to personal data of an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access. To align with the global data protection legislations, Paymight shall put in strict measures and treat such pseudonymised data as equivalent to personal data so long as such data cannot be reidentified. The sharing, transferring or publicly disclosing of such deidentified data will not require separate notification to you and your consent. It does not include data where the identity has been removed (anonymous data).

5. HOW DO WE STORE AND PROTECT YOUR DATA

We will only retain your information for as long as is necessary for providing the Services to you and will not hold or process your information for any longer than we are legally required to.

We established a comprehensive information security management system and access control and will take reasonable and practicable security measures and technical means to store and protect your personal information in accordance with industry standards to prevent the loss, unauthorised access, public disclosure, use, modification, destruction, loss or leakage of your information consistent with applicable data protection and privacy laws and regulations. Notwithstanding the foregoing, we may retain your information for a period as required by any applicable law and regulations form time to time to ensure that any contractual disputes can be addressed. We will take all reasonably practicable steps to protect your personal information.

6. HOW DO WE PROCESS DATA ABOUT CHILDREN?

Our Services are not directed towards children under 18 years old or the legal age for giving consent hereunder pursuant to the applicable laws in your country (the “legal age”), nor does Paymight knowingly collect information from children under the legal age. If you are under the legal age, please do not use any of the Services or submit any personal information to us. As a parent or legal guardian, please do not allow such minor under your care to submit personal data to us. In the event that personal data of a minor under your care is disclosed to us, you are deemed to have accepted, consented and agreed to the processing of the minor’s personal data and to be bound by this Privacy Policy on behalf of such minor. Notwithstanding anything contrary to the foregoing, Paymight reserves the right to suspend and/or terminate any Services subscribed or accounts that are registered on paymight.com.

7. THIRD PARTY SERVICES AND SITES

We may provide links to third party websites and services (including but not limited the websites, services and mobile applications of our Partners) for your convenience and information. We do not guarantee the security of personal data and/or other information that you provide on any third party sites, including those linked from paymight.com and any third party payment channels, if any. We are at liberty to choose, engage, appoint, cooperate or participate with any third party in all kind of outsourcing, co-branding or any other relationship to offer the Services and other features in paymight.com. These services and websites may operate independently from us and have different data protection and privacy practices from us. We are not responsible for the content and privacy practices of these other websites and services and encourage you to consult the Privacy Policy of those sites. These third party sites are only for your convenience and you therefore access them at your own risk.

8. DATA TRANSFERS

Paymight has multiple offices globally and your information may be processed outside of the country where you live. Regardless of where your information is processed, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection and privacy laws and regulations.

9. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

When you use our Services or interact with us through paymight.com, you consent to our receiving, using, aggregating, and analyzing your personal information, as necessary for our business and cooperation. In accordance with applicable data protection and privacy laws and regulations, you may be entitled to:

• ask us about the processing of your personal information, including to request a copy of your personal information;

• request the correction and/or (in some cases) deletion of your personal information;

• in some cases, request the restriction of the processing of your personal information, or object to that processing;

• withdraw your consent to the processing of your personal information; and

• request receipt or transmission to another organization, in a machine-readable form, of the personal information that you have provided to us where we are using your personal information based on consent or performance of a contract; and

Where you are given the option to share your personal information with us, you can always choose not to do so. You also have the right to withdraw any consent previously given to us to share your personal information.

However, choosing not to share your personal information with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described or that you are unable to make use of the services and products offered by us. Please note that withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.

10. COOKIES

We may use "cookies", where a small data file is sent to your browser to store and track information about you when you enter paymight.com. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. While this cookie can tell us when you enter our sites and which pages you visit, it cannot read data off your hard disk.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of paymight.com.

11. CONTACT US

If you have questions or requests about the privacy of your personal information, please contact us by email via [email protected]. As required under applicable law, please note that we may take steps to ask you to provide further information to verify your identity before granting you access to information or acting on your request to exercise your rights.

12. CHANGES TO THIS PRIVACY POLICY

Privacy Policy visible on paymight.com at any time will be the most current version and shall be applicable as is where is. This Privacy Policy may be amended from time to time without notice to you. Amended Privacy Policy will be posted on this page and your use of paymight.com after such amendments have been posted shall constitute your agreement and consent to all of the relevant changes. This Privacy Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.

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