ReKashpay Privacy Policy

1. Introduction

In order to be able to make our services available to you in compliance with the obligations imposed by any applicable law and by rules, guidelines and directives from time to time issued by regulatory authorities, we must ask you for certain information about yourself, including identification documents, financial information (e.g., information about your identity, e-commerce sales, beneficiary account, etc.) and other information/documents as from time to time required by the applicable laws and rules, guidelines and directives. We will utilize the data provided by you in accordance with applicable provisions of governing data protection laws, which shall include, without limitation, the Personal Data (Privacy) Ordinance (Cap.486 of the laws of Hong Kong). The information obtained shall, as a matter of principle, be used by us solely for providing our services and solely to the extent necessary to render such services. The information about you which we possess shall, as a matter of principle, not be made accessible to third parties unless we are under any legal obligation to do so or under any court order with competent jurisdiction, or we must do so to render our services to you (such as rendering your personal data to our counterparts in any part of the world or the banks for processing the funds). In other cases, we will obtain your consent before we disclose any of your personal data to any third party.

2. Collection of information

(a) Collected from Official Website Visitors Like most website operators, we automatically collect data which are not personal data that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting such non-personal data is to better understand how our visitors use our official website, through cookies, web beacons, log files and other

technologies:

(1) your domain name, your browser type and operating system, web pages you view, links you click; and

(2) your IP address, the length of time you visit our official website or use our Services, your activities on our official website, and the referring URL or the webpage that led you to our official website. Please see Section 8 “Cookies” below for more information. Visitors can always refuse to supply such data, with the caveat that it may prevent them from being able to use our services.

(b) Provided by Users You may provide us data about you by filling in forms on our official website (e.g. ReKashpay Account Registration Form), or by corresponding with us (for example, by e-mail or telephone). The data you provide may include data about additional persons that are beneficial owners of our services. This includes that is

provided to us about you:

(1) upon registration for a ReKashpay Account;

(2) when you log in to your ReKashpay Account;

(3) when you submit any Settlement Orders through your ReKashpay Account;

(4) when entering a competition, promotion or survey; and

(5) when a problem is reported or a request for support is received. Visitors can always refuse to supply such personal data, but it may prevent them from being able to use our services.

3. Information we collect

We collect the personal data you provide directly to us when you apply for a ReKashpay Account, perform any transactions on the ReKashpay platform, or use other ReKashpay Services. This may include:

(a) your contact information (e.g., name, email address, phone number, billing or mailing address);

(b) bank and credit account information;

(c) IP address;

(d) identity validation (e.g., photograph, other information requested to verify your information, including copy of valid ID document or corporate documents);

(e) publicly available and/or criminal history;

(f) national or tax identification numbers;

(g) nationality;

(h) date and place of birth;

(i) details of any transactions carried out using any the services;

(j) any other information that you choose to provide to us (e.g., if you send us an email/otherwise contact us);

(k) calls/emails/other correspondence; and

(l) information through Cookies and other tracking technologies as listed above and as described in the section below entitled “Cookies”. You shall be responsible for providing accurate and up-to-date information to us or we may not be able to provide any service to you. If you are required to provide information about shareholders or beneficial owners of your business, you hereby acknowledge and confirm that you have that person’s consent to provide his/her information to us. This may include:

(a) contact information, such as name, home address, and email address;

(b) account information, such as username and password;

(c) financial information, such as bank account numbers, bank statement, and trading information;

(d) identity verification information, such as images of your government issued ID, passport, national ID card, or driving license. Depending on nationality, the information request may be different; and

(e) residence verification information, such as Utility bill details or similar information. We may collect and process Personal Data about your counterparties or third parties related to your business in providing our services. You shall be responsible to make sure that the privacy rights of any third parties, including your counterparties and other individuals related to your business, are respected, including ensuring appropriate disclosures about third party data collection and use; with respect to such data you hereby undertake with us that we are acting as your data processor, and we will process personal data in accordance with the terms of our agreement with you and act in accordance with your lawful instructions.

4. Use of personal data

We will only use your personal data to:

(a) process your transactions, including transfers into and out of any country in the World in accordance with the local laws of each such country;

(b) perform the required controls and checks in accordance with money laundering/terrorist financing and know your customer requirements under any applicable law (which shall include the Anti-Money Laundering and Counter Terrorist Financing Ordinance (Cap.615 of the laws of Hong Kong)), our internal control policies, and also the needs of any law enforcement agencies;

(c) analyze our official website usage, and improve our official website and service offerings;

(d) help us respond to your customer service requests and support needs;

(e) contact you about our services. The email address you provide may be used to communicate information and updates related to your use of our services. We may also occasionally communicate company news, updates, and related information relating to similar products and services provided by us; and

(f) administer contests, surveys or other site features as will from time to time be announced on our official website.

5. Data Retention

We will retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected as described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law, including but not limited to anti-money laundering and counter-terrorist financing laws (e.g., the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615 of the Laws of Hong Kong)). In accordance with anti-money laundering regulations, we are generally required to retain your identification documents, transaction records, and other relevant personal data for a minimum period of five years following the termination of our business relationship with you or after the completion of the relevant transaction. Upon expiry of the retention period, we will securely delete or anonymize your personal data so that it can no longer be used to identify you.

6. Disclosure of Personal Data

We only disclose your personal data (a) to legal and regulatory authorities as required by applicable law or court order with competent jurisdiction; and (b) to our employees, service providers and affiliated organizations. To this extent, we assure you that such disclosure shall be on a need-to-know basis, and an undertaking from such parties that they agree to keep such data confidential and will be subject to this Privacy Policy.

(a) Disclosure to Third Parties In processing your transactions, we may share some of your personal data (on a need-to-know basis) with our service providers. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide our services or as required by law or court order with competent jurisdiction. By using our services, you accept the contents of this Privacy Policy and agree to our disclosure of your personal data in accordance with this Privacy Policy. Our service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We strive to ensure that such third parties will be bound by terms no less protective than those described in this Privacy Policy, all applicable laws and rules, guidelines and directives from time to time issued by any regulatory authority.

(b) Disclosure to Legal Authorities We may share your personal data with law enforcement agencies and other governmental or regulatory bodies when:

(1) we are compelled by subpoena, court order, or other legal procedure; or

(2) we have a reasonable ground to believe that the disclosure is necessary to prevent physical harm or financial loss; or

(3) disclosure is necessary to report suspected illegal activity; or

(4) disclosure is necessary to investigate violations of this Privacy Policy or our Terms and Conditions.

7. Transfer and storage of data

Our services are global in nature and data may be stored and processed in any country where we have operations or where we engage service providers. That means data may be transferred and stored outside the boundary of Hong Kong. Data we collect may be transferred to and/or stored at a destination outside Hong Kong, which may have data protection rules that are different from Hong Kong, including transferring data to and from regulatory authorities, or to staff operating outside Hong Kong who process data on our behalf or for our suppliers. Staff may be engaged in the fulfilment of your request and the provision of support services. However, we will take measures to ensure that any such transfers comply with the laws of Hong Kong and that your data remains protected to the standards described in this Privacy Policy. By submitting your personal data to us, you agree to our transfer, storing or processing in accordance with this Privacy Policy. We will take steps reasonably necessary to ensure that the data is treated securely and in accordance with this Privacy Policy and the applicable laws.

8. Protection of Certain Personal Data

We take all organizational and technical measures appropriate to protect against the unauthorized access, use, alteration or destruction of your personal data. All personal data you provided to us will be stored on our secure servers. You shall be responsible for keeping your account credentials safe and secure and not sharing them with anyone. You acknowledge that transmission of information via the internet is not completely secure; any such transmission shall be at your own risk. Although no one can guarantee security of data transmitted via the internet, we strive to protect the data transmitted via the ReKashpay Account. We use industry standard security techniques to help keep the data safe including encryption when the data is in transit and at rest. The ReKashpay official website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any User Data to such third parties.

9. Cookies

Cookies are small data files that track and collect your browsing information from your web browser. Cookies will then use that information during your future visits to our official website, so that the server may immediately recognize that you have been to the official website before. Cookies will not destroy any files in your computer, but are only used to track information such as which pages users’ visit, on which pages users usually start and stop, and how frequent users visit the official website, etc. We do not use cookies to track the identity of the actual user, and cookies will only tell if a certain computer has visited our official website in the past. Cookies will not collect personal information such as names or e-mail addresses. Nevertheless, if you do not wish to have cookies in your computer, you may adjust the settings in your web browser to reject cookies. However, if you do not wish to receive Cookies, some functions may not be usable. Our official website uses cookies. If you visit our official website and your browser settings accept cookies, we consider this as acceptance of our use of cookies. We shall use cookies to collect statistics about the number of visits of users to our official website and the users’ preferences of websites and online services offered by us.You may choose to accept or reject cookies. If you reject the cookies, you may not be able to use some of the functions of our official website and accessing some online services on our official website.

10. Amendments to this Privacy Policy

This Privacy Policy may be amended from time to time as new features are added to our services or as we incorporate suggestions from our stakeholders. We may change this Privacy Policy at any time by posting a revised version of it on our official website. Such amendments shall be effective when announced on our official website. When you continue using our services, you are deemed to be bound by the revised Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your account at any time.

11. Liability

We shall in no event be liable to you in respect of any claims, losses, damages, expenses (including reasonable legal fees) arising out of or in connection with the use and/or disclosure or dissemination of the user data in accordance with this Privacy Policy and any consents that you may have otherwise provided to us.

12. Governing Law

This Privacy Policy shall be governed by and construed in accordance with Seychelles law.