Privacy Policy

Everpay's Commitment to Privacy

Everpay Corporation and its subsidiaries ("we", "us", "Everpay") are committed to maintaining the accuracy, confidentiality, and security of Personal Information. We respect rights under applicable privacy laws and only collect, use, and disclose Personal Information in accordance with those laws.

This Privacy Statement describes the Personal Information we collect, use, and disclose in the course of providing services to our merchants, partners, and other customers, including payment processing services, value-added services, or hardware and hardware support services, as well as information we collect from prospective customers, applicants, and website visitors.

1. Privacy Management Program

Everpay maintains a comprehensive privacy management program (the "Privacy Management Program") applicable to Everpay and its subsidiaries, complete with policies, practices and standards addressing information security, and the collection, use, disclosure, storage, and destruction of Personal Information held by Everpay. This Privacy Management Program includes:

• Appropriate safeguards to protect the Personal Information that Everpay collects, stores, and uses.
• Established processes for the maintenance of appropriate data management including classification, record keeping and disposal/destruction systems for Personal Information.
• Established processes to receive and respond to complaints or inquiries about our handling of Personal Information.
• Clearly established roles and responsibilities for the protection of Personal Information, and an accountability framework.
• Annual employee privacy awareness training.
• Regular assessments, audits, and revisions of our privacy practices to ensure they meet or exceed applicable legislative requirements, internal policies, industry standards and best practices.
• A process for the maintenance of a privacy incident management and reporting methodology for incidents involving the unauthorized collection, use or disclosure of Personal Information.

Our Chief Privacy Officer has been delegated the responsibility of ensuring Everpay's compliance with applicable privacy legislation. The Chief Privacy Officer oversees the Privacy Management Program and is responsible for the governance and management of matters relating to privacy and Personal Information at Everpay.

2. What Personal Information We Collect

From Existing and Prospective Merchants, Partners, and Customers

Everpay may collect the following Personal Information from existing merchants, prospective merchants, partners, and other customers, to open and manage accounts, and to provide various products and services:

• Names, roles or positions
• Financial information
• Mailing addresses, email addresses, telephone numbers
• Birth dates
• Banking information
• Recordings of calls to our support center for quality control and training purposes
• Information about complaints
• Certain other information that Everpay may collect with appropriate consent

We may obtain consent to collect personal and credit information from a credit reporting agency (including credit score). In limited circumstances, Everpay may seek consent to collect social insurance numbers to confirm identities with credit reporting agencies.

As a Service Provider

When acting as a service provider to merchants, partners, or other customers, Everpay may have access to the Personal Information of their end-users (e.g., their payment card data). In such circumstances, Everpay relies on its merchants, partners, and other customers to ensure that they have the necessary authority and consent required by applicable privacy laws to provide their end-user's Personal Information to Everpay.

From Website Visitors

Everpay also collects information from visitors to our websites. These practices are described in our Cookie Policy.

3. How We Use Personal Information

We may use Personal Information to:

• Provide, deliver and improve our products and services
• Verify identities and conduct due diligence, including complying with "know your customer" requirements under applicable laws
• Administer merchant accounts and relationships
• Process transactions and facilitate payment processing
• Detect, prevent, and respond to fraud, abuse, security incidents and other harmful activity
• Comply with legal obligations, resolve disputes, and enforce our agreements
• Communicate with you about your account, transactions, and provide customer support
• Conduct research and analytics to improve our services
• Market our products and services, subject to your right to opt-out

4. When We Share Personal Information

Everpay may share Personal Information with:

• Service providers and partners who assist us in providing products and services, subject to appropriate contractual safeguards.
• Payment card networks (e.g., Visa, Mastercard) to facilitate transaction processing and dispute resolution.
• Government and regulatory authorities when required by law, regulation, or legal process.
• Law enforcement when necessary to protect against fraud, unauthorized transactions, or other illegal activities.
• Credit reporting agencies to obtain or verify credit information.
• Financial institutions to facilitate payment processing and fund settlement.

Everpay may also disclose Personal Information in connection with a proposed or completed merger, acquisition, sale (including as part of insolvency or bankruptcy proceedings) involving all or part of Everpay, as part of a corporate reorganization, or in relation to other changes in corporate control.

5. Where We Process Personal Information

In providing services to merchants, partners, and other customers, Personal Information may be collected, stored, accessed, used or disclosed by Everpay or our service providers outside of the home province or state of the individual to which the information belongs, and in countries outside of the United States and Canada (e.g., the United Kingdom, the European Union, India, or the Philippines), for any of the purposes identified above. Everpay will continue to maintain protection of Personal Information in accordance with this Privacy Statement.

6. How We Safeguard Personal Information

Everpay has a dedicated Information Security team responsible for the implementation of physical, technical, and administrative safeguards to protect Everpay's information assets, including Personal Information. Everpay maintains policies and standards which provide direction for our information security practices, including by establishing clear roles and responsibilities for the protection of information.

Everpay's information security policies and standards align with relevant industry standards and frameworks including the Payment Card Industry (PCI) Standards, the National Institute of Standards and Technology Cyber Security Framework (NIST CSF), and other information security requirements specific to Everpay's operations.

Everpay maintains its Payment Card Industry Data Security Standard (PCI DSS) compliant Level 1 service provider status, and our compliance is reported to all major debit and credit card associations on an annual basis.

7. Device Fingerprinting & Behavioral Biometrics

To protect against fraud, unauthorized access, and financial crime, Everpay may collect and process technical and behavioral information from your device.

This includes:

• Device identifiers and browser characteristics (such as user agent, screen resolution, and system configuration)
• Network information (such as IP address and approximate location)
• Interaction data (such as mouse movements, click patterns, and typing cadence)

This information is used solely for:

• Fraud detection and prevention
• Security monitoring
• Risk assessment and compliance obligations

Everpay does not use this data for advertising or profiling unrelated to security purposes.

All such data is processed in accordance with applicable data protection laws, including GDPR where applicable.

8. Cookies, Interest-Based Advertising, and Website Data

For detailed information about our use of cookies, web beacons, and similar technologies, please refer to our Cookie Policy.

9. Privacy Choices and Rights

Marketing Communications

If you are an Everpay merchant, partner, other customer, have made an inquiry with us, have been referred to us by one of our partners, or have opted to receive marketing, promotional, and other commercial messages from Everpay, we may send you electronic messages (such as emails or text messages). If you prefer not to receive these types of electronic messages you may opt-out by clicking the "Unsubscribe" link contained in any such message.

Right to Access and Portability

If Everpay has your Personal Information, you may request to access, update, or rectify that information. You can also make a data portability request that we send your Personal Information to you or another service provider, in a structured, commonly used, and machine-readable format, if it is technically feasible. This only applies to Personal Information you have provided to us and is processed by us using automated means.

Withdrawing Consent

You have a right to withdraw consent for the collection, use, and disclosure of your Personal Information at any time, subject to legal and contractual restrictions, and on providing Everpay with reasonable notice. If you choose to withdraw your consent, Everpay may be unable to offer you some or all of our products and services.

10. Updates to This Privacy Statement

Everpay will update this Privacy Statement from time to time to reflect changes in our Personal Information practices. Any changes to our Privacy Statement are effective as of the modification date noted above, unless otherwise stated.

11. Questions, Concerns or Complaints

If you have a question, concern or complaint related to this Privacy Statement, Everpay's Personal Information processing practices, or wish to exercise applicable rights relating to Everpay's collection, use or disclosure of your Personal Information, please contact Everpay's Privacy Office at: