Your privacy is important to us. This statement describes the practices that NovoPayment, Inc. will follow with respect to the personal information it collects from users of developer.novopayment.com and other NovoPayment websites (and the related documentation, data, code, applications, widgets, blogs, interactive feature or other material), other hosted websites that link to this Privacy Statement, and to Twitter, LinkedIn or other social networking sites, and their respective contents, whether accessed via computer, mobile device or other technology (collectively, the “Websites”).

This Privacy Policy explains what information may be collected through the Websites, how such information may be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and activities. Please read this Privacy Policy carefully, because by using the Websites you are acknowledging that you understand and agree to the terms of this Privacy Policy. In addition, please review our Terms and Conditions of Use, which governs your use of the Websites and any content you submit to the Websites.

Scope of Privacy Policies and Procedures. In the course of business, we may come into possession of certain types of personal non-public information about natural persons who are prospective or existing clients. We may be subject to various laws enforced by the U.S. Securities and Exchange Commission, the Federal Trade Commission and certain states that govern the privacy of the Non-Public Personal Information impose restrictions on our ability to disclose such information to non-affiliated third parties and require us to provide privacy notices to natural persons. Privacy regulations may apply both to us and to our clients, including banks, brokers, mutual funds and corporations or other business entities. We seek to adhere to Payment Card Industry best practices and we will not sell or share your information with any external parties unless we have your consent.

“Personal information” is information that can be used to identify or contact you. Personal information includes your name, address, email address, and phone number, as well as information you provide us about your interests and preferences.

In some cases, we operate or host websites owned by our clients, including banks, brokers, mutual funds and corporations or other business entities (the “Business Owner” of the website). On these hosted sites, we may also collect sensitive personal information that you provide, which for some services may include your account number and Social Security number, as well as information you provide when you access your account online or conduct transactions. All personal information and sensitive personal information collected via these hosted sites is considered “Confidential Information”.

How do we collect, use, and disclose personal information? We collect personal information that you provide so that we may provide you or our clients with, or contact you about, products, services and information, to enhance your site visit or follow up with you after your visit.

If you provide personal information to us for our own use, we may use it to provide the products, services or information that you have requested and we may share it with our affiliates. We may also use your personal information for other internal business purposes, such as market research and legal compliance.

We may share any personal information, even Confidential Information, with our vendors and other third parties who perform services for us, but we forbid these companies from using your personal information for their own purposes.

Please note that we may always disclose any information as required by law, when necessary for health or safety purposes, or when needed to protect our legal rights, including to law enforcement agencies and courts in the United States and other countries where we operate in accordance with applicable laws. For example, we may disclose information about you in response to a subpoena. We may also disclose information about you in connection with the transfer of assets of our business.

Finally, if you are located outside the United States, your personal information will be maintained by us in the U.S. We may transfer your personal information to countries outside your location or the U.S. However, we assure adequate protection for your personal information in compliance with all applicable laws.

Data Collection Technologies. When you visit our website or use our mobile applications, we may collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. The technologies used on the Websites to collect information, may include, without limitation:

Cookies. When you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All

browsers are different, so visit the “help” section of your browser to learn about the privacy settings that may be available.

We collect many different types of information from cookies and other technologies. For example, we may collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to the Website and the site you visit after you leave our site.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Statement applies to the information when we associate it with your Personal Information.

Social Media Interactions. Our websites may enable you to interact with us and others via social media platforms, such as Twitter or LinkedIn. While we respect each social media platform’s privacy policies, we may collect personal information about you and your friends if you choose to use these tools.

How do we use your information? We use the information we collect about and from you for a variety of business purposes, including for example, to:

To personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested. To improve our website in order to better serve you. To allow us to better service you in responding to your customer service requests. To send periodic emails regarding products and services. To improve the Websites and for internal business purposes. How can you correct, access, and update your information? You may view and edit the personal information you have provided on any of our websites by contacting us using the link provided on such website. Our customer support department can also reasonably assist you with other requests related to information about you that may be maintained by us.

How do we protect your information? We take reasonable steps to help prevent the loss, misuse and alteration of the information under our control. For example, we have implemented physical,

logical, and administrative procedures to protect and secure the information we process and maintain. We also use encryption and firewall technologies to protect sensitive information during online transmissions.

How can you help protect your information? If you have registered on our website, we recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also remember to sign out of the registered site and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if others have access to your computer.

California Online Privacy Protection Act CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – Additional information is available at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA we agree to the following:

Users can visit our site anonymously. Once this privacy policy is created, we will add a link to it on our homepage, or as a minimum on the first significant page after entering our website. Our Privacy Policy link includes the word “Privacy”, and can be easily be found on the page specified above. Users will be notified of any privacy policy changes on our Privacy Policy Page. Users are able to change their personal information by calling us. We honor Do Not Track (“DNT”) and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place. COPPA (Children Online Privacy Protection Act) When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under 13.

Fair Information Practices. The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify the users via in site notification within 7 business days.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

Other sites. Our Websites may contain links to other sites, including those of our business partners. While we seek to link only to sites that share our high standards and respect for privacy, we are not responsible for the privacy practices employed by other sites.

Contacting us. If there are any questions regarding this privacy policy you may contact us through novopayment.com/contact

Can we change this Privacy Statement? From time to time, we may want to use personal information in ways that are not anticipated by this Privacy Statement. If we make a material change to this Statement or in how we will use your personal information, we will notify you either by posting the policy changes before they take effect. We encourage you to periodically review this Privacy Statement to learn how we are protecting your information.

Please review the “Last Update” when you visit the web site to determine if the Privacy Policy has been revised since the last time you entered the site.

 

Last update: July 23th, 2020