1st July 2021,

1.0 GENERAL INFORMATION

This privacy policy explains the way we collect, use, manage, disclose and protect your information, including any non-public personal information.

This policy applies to information we collect when you use our website and mobile application (collectively, "Services'') or otherwise interact with us as described below. This privacy policy may be changed from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepage of our website or mobile application or by sending you an email notification).

We encourage you to review the privacy policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy. This privacy policy applies to the Services provided by Pesapeer Incorporated (“we” or “us”) and applies to consumer users (individually referred to as "you") of our websites, applications, and other online services to which this Privacy Policy is posted. This Privacy Policy is part of our Terms of Use. If you do not agree with every provision of this Privacy Policy and our Terms of Use, you may not access or use our Services.

We are committed to the protection of your privacy while you use our website, products, services, and applications. You may browse parts of this Website without providing any information about yourself and without accepting cookies. In that case, it’s unlikely we’ll possess and process any information relating to you.

2.0 APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a "Device").

3.0 MODIFICATIONS AND REVISIONS

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. If we do so, however, we will notify you and obtain your consent to the change in processing. Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision or amendment.

4.0 PERSONAL DATA WE RECEIVE FROM YOU

When you visit our Services, we may collect the following personal information from or about you:

4.1 Contact Information: Your full legal name, telephone number, location, postal address, e-mail address, date of birth, means of identification, occupation, personal description and photograph. From time to time, Pesapeer may require you and/or your Beneficiary to provide us with additional information and/or documentation to confirm your identity and your eligibility to use the Pesapeer service.

4.2 Account/Registration Information: Username and password, reminder questions and answers, account numbers, and communication preferences such as which newsletters you would like to receive (when you provide that information to us).

4.3 Payment Information: Credit card or bank account number, expiration date, and card verification number (when you provide that information to us). Information about your Beneficiary, which may include sensitive personal information such as your Beneficiary's name, address, mobile phone number and/or bank account information.

4.4 Online Identifiers: IP address, advertising ID, unique device ID, and other information about your device, and internal and third-party IDs that have been assigned to you.

4.5 Location Information: Information about your precise location that we collect from your device (collected in limited circumstances) or information about your general location derived from your IP address.

4.6 Internet Activity Information: Information about your use of our Services, your interactions with the emails we send to you, and your activities on other websites you visit, including the web pages, content, and advertisements you view and links you click on, and whether you open, forward, or click the links in emails we send to you; your browsing history; and social media you use, including the “shares” and “likes” you make on a social media platform that is connected to the Services.

4.7 Inferences about Your Interests, Preferences, and Other Behavioral Data: Hobbies and interests (like the frequency with which you access the App, the time you spend there, the way you move through the site, your transfer history, and details regarding the amount of money you transfer and your Beneficiaries).

Depending on how you use our website, products, services, and applications, you will be subject to different types of Personal Data collected and different manners of collection:

4.8 Registered users

You, as a user of our website, products, services, and applications, may be asked to register to use our website, products, services, and applications in a legal manner. During the process of your registration, we will collect some of the following Personal Data from you through your voluntary disclosure. Personal Data may be asked for concerning:

interacting with our representatives in any way;
receiving notifications by text message or email about marketing;
receiving general emails from us.

By undergoing the registration process, you consent to us collecting your Personal Data, including the Personal Data described in this clause, as well as storing, using or disclosing your Personal Data under this Privacy Policy.

Passive Data Collection shall apply to all visitors of our use our website, products, services, and applications.

4.9 Related Entities

We may share your Personal Data, including Personal Data that identifies you personally, with any of our parent companies, subsidiary companies, affiliates or other trusted related entities.

However, we only share your Personal Data with a trusted related entity if that entity agrees to our privacy standards as set out in this Privacy Policy and to treat your Personal Data in the same manner that we do.

4.10 Email Marketing

You may be asked to provide certain Personal Data, such as your name and email address, to receive email marketing communications. This information will only be obtained through your voluntary disclosure and you will be asked to affirmatively opt-in to email marketing communications.

4.11 User Experience

From time to time, we may request information from you to assist us in improving our website, products, services, and applications, such as demographic information or your particular preferences.

5.0 PERSONAL DATA WE RECEIVE AUTOMATICALLY

5.1 Cookies

We may collect information from you through automatic tracking systems (such as information about your browsing preferences) as well as through information that you volunteer to us (such as information that you provide during a registration process or at other times while using our website, products, services, and applications as described above).

For example, we use cookies to make your browsing experience easier and more intuitive: cookies are small strings of text used to store some information that may concern the user, his or her preferences or the device they are using to access the internet (such as a computer, tablet, or mobile phone). Cookies are mainly used to adapt the operation of the site to your expectations, offering a more personalized browsing experience and memorizing the choices you made previously.

A cookie consists of a reduced set of data transferred to your browser from a web server and it can only be read by the server that made the transfer. This is not executable code and does not transmit viruses.

Cookies do not record or store any Personal Data. If you want, you can prevent the use of cookies, but then you may not be able to use our website, products, services, and applications as we intend. To proceed without changing the options related to cookies, simply continue to use our website, products, services, and applications.

5.2 Technical cookies

Technical cookies, which can also sometimes be called HTML cookies, are used for navigation and to facilitate your access to and use of the site. They are necessary for the transmission of communications on the network or to supply services requested by you. The use of technical cookies allows the safe and efficient use of the site.

You can manage or request the general deactivation or cancelation of cookies through your browser. If you do this though, please be advised this action might slow down or prevent access to some parts of the site.

Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit our website, products, services, and applications. These are also considered technical cookies when they operate as described.

Temporary session cookies are deleted automatically at the end of the browsing session - these are mostly used to identify you and ensure that you don't have to log in each time - whereas permanent cookies remain active longer than just one particular session.

5.3 Third-party cookies

We may also utilize third-party cookies, which are cookies sent by a third-party to your computer. Permanent cookies are often third-party cookies. The majority of third-party cookies consist of tracking cookies used to identify online behavior, understand interests and then customize advertising for users.

Third-party analytical cookies may also be installed. They are sent from the domains of the aforementioned third parties external to the site. Third-party analytical cookies are used to detect information on user behavior on our website, products, services, and applications. This takes place anonymously, to monitor the performance and improve the usability of the site. Third-party profiling cookies are used to create profiles relating to users, to propose advertising in line with the choices expressed by the users themselves.

5.4 Profiling cookies

We may also use profiling cookies, which are those that create profiles related to the user and are used to send advertising to the user's browser.

When these types of cookies are used, we will receive your explicit consent.

To learn more about cookies, you may wish to visit: www.allaboutcookies.org or www.google.com/policies/technologies/cookies/.

5.5 Support in configuring your browser

You can manage cookies through the settings of your browser on your device. However, deleting cookies from your browser may remove the preferences you have set for using our website, products, services, and applications.

5.6 Log Data

Like all websites and mobile applications, our website, products, services, and applications also make use of log files that store automatic information collected during user visits.

The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner to verify the correct functioning of the site, and for security reasons. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, under applicable laws, to block attempts at the damage to our website, products, services, and applications or damage to other users, or in the case of harmful activities or crime. Such data are never used for the identification or profiling of the user, but only for the protection of our website, products, services, and applications and our users.

6.0 THIRD PARTIES

We may utilize third-party service providers ("Third-Party Service Providers"), from time to time or all the time, to help us with our website, products, services, and applications and to help serve you.

We may use Third-Party Service Providers to assist with information storage (such as cloud storage).

We may provide some of your Personal Data to Third-Party Service Providers to help us track usage data, such as referral websites, dates and times of page requests, etc. We use this information to understand patterns of usage of and to improve our website, products, services, and applications. We may use Third-Party Service Providers to host our website, products, services, and applications. In this instance, the Third-Party Service Provider will have access to your Personal Data. We may allow third parties to advertise on our website, products, services, and applications. These third parties may use cookies in connection with their advertisements (see the "Cookies" clause in this Privacy Policy).

Pesapeer may verify and confirm all of the information that you provide to us (or that we otherwise collect from your accessing the Pesapeer App) with third parties, including the financial institution where you have your Payment Account, and the telecommunications company or financial institution through which your money is sent to your Beneficiary. Pesapeer may also verify such information with identity verification services, electronic databases, social media companies and credit reporting agencies. Pesapeer may share your information with the banks, telecommunications providers and other financial services firms who facilitate payment to your Beneficiary.

Some of our Third-Party Service Providers may be located outside of the Province of Ontario, Canada, and may not be subject to Canadian privacy laws. We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our privacy standards as set out in this Privacy Policy. Your Personal Data will not be sold or otherwise transferred to other third parties without your approval.

Notwithstanding the other provisions of this Privacy Policy, we may provide your Personal Data to a third party or third parties to protect the rights, property or safety, of us, our customers or third parties, or as otherwise required by law. We will not knowingly share your Personal Data with any third parties other than under this Privacy Policy. If your Personal Data might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we not share that information.

In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain services that we rely on third-party providers for.

7.0 COMMUNICATIONS

We will get your express opt-in consent before we share your personal data with any company outside PESAPEER INCORPORATED for marketing purposes. If you opt-in to receive marketing from manufacturers, we recommend that you read their privacy policy to see how they will use your data and how to alter your marketing preferences with them should you wish to in the future.

8.0 TRANSFERS AND DISCLOSURES

In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including without limitation, Personal Information that you provide and other information concerning your relationship with us.

We may transfer your Personal Data to third parties under confidentiality obligations when required for the performance of any service in relation to the Services we offer on our Site.

In any event, where we allow other parties to use Personal Data we hold about you, those parties are bound by strict contractual provisions with us and only have access to personal data needed to perform their functions and may not use it for other purposes. Further, they must process the personal data in accordance with this Privacy Policy.

9.0 STORAGE OF PERSONAL DATA

We use secure physical and digital systems to store your Personal Data when appropriate. We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction.

Please note, however, that no system involving the transmission of information via the internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.

Personal Data is stored throughout your relationship with us. We delete your Personal Data upon request for cancelation of your account or other general requests for the deletion of data.

In the event of a breach of your Personal Data, you will be notified in a reasonable time frame, but in no event later than two weeks, and we will follow all applicable laws regarding such breach.

10.0 USE OF PERSONAL DATA

We primarily use your Personal Data to help us provide a better experience for you on our website, products, services, and applications and to provide you the services and/or information you may have requested, such as the use of our website, products, services, and applications. Pesapeer may maintain and use all of the information and documentation that you provide, as well as information that we derive from your use of the service, and the information that we obtain about you from third parties to enable Pesapeer comply with laws and regulations, including those intended to prevent fraud, money laundering, and other abuses of the financial system.

Information that does not identify you personally, but that may assist in providing us broad overviews of our customer base, will be used for market research or marketing efforts. Such information may include but is not limited to, interests based on your cookies.

Personal Data that may be considered identifying may be used for the following:

Improving your personal user experience.
Communicating with you about your user account with us.
Marketing and advertising to you, including via email.
Contacting you as necessary to confirm or complete a transaction, and to allow our agents, partners and service providers to fulfill their obligations in providing the Pesapeer service to you.
Providing customer service to you.
Advising you about updates to our website, products, services, and applications or related Items.
We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance. Before doing that, we will always tell you of our intentions and of the specific purpose in making the recording.
Understand trends in how the visitors to our Services interact with the ads, content, and features on our Services (e.g., your behavior on our Services may be included in a general report about whether people prefer video content over written content on our Services).

11.0 DISCLOSURE OF PERSONAL DATA

Although our policy is to maintain the privacy of your Personal Data, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, at our sole and exclusive discretion. Such cases may include, but are not limited to:

affiliates, business partners, joint marketers, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
advertisers and advertising networks solely to select and serve relevant advertisements to you and others;
to third party service providers that connect to your bank account(s) with bank account login credentials provided by you in order for us to perform Services and confirm availability of funds;
analytics and search engine providers that assist us in the improvement and optimization of our site;
to your friends associated with your social media account, to other users of the Services and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account. By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy;
if you open or access your Pesapeer Account directly on a third party website or via a third party application, with the provider of the third party website or application;
to explore and/or undertake a corporate transaction, including any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Customer Agreement and other applicable agreements; or to protect the rights, property, or safety of Pesapeer, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
to assist us in conducting or co-operating in investigations of fraud or other illegal activity, or to respond to requests from public and government authorities (including those outside your country of residence), upon demonstration of lawful authority;
to prevent and detect fraud or crime;
in response to a subpoena, warrant, court order, as required by law;
to allow us to pursue available remedies or limit the damages that we may sustain;
to develop customer relationships, services and systems.
If we suspect any fraudulent activity on our website, products, services, and applications or if we have noticed any activity which may violate our terms or other applicable rules.

12.0 YOUR RIGHT TO REQUEST

You have the right to:

12.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

12.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Please note that this may amount to a termination of your right to use the Site.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact privacy@pesapeer.com.

12.8 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

These rights can all be exercised by contacting us at privacy@pesapeer.com

13.0 OPTING OUT

From time to time, we may send you informational or marketing communications related to our website, products, services, and applications such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email address support@pesapeer.com. You may also click the opt-out link which will be provided at the bottom of all such communications.

Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our website, products, services, and applications or your account with us.

By providing any Personal Data to us, or by using our website, products, services, and applications in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.

14.0 ACCEPTANCE OF RISK

By continuing to use our website, products, services, and applications in any manner, you manifest your continuing assent to this Privacy Policy. You further acknowledge, agree and accept that no transmission of information or data via the internet is always completely secure, no matter what steps are taken. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. You acknowledge, agree and accept that we do not guarantee or warrant the security of any information that you provide to us, and that you transmit such information at your own risk. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

15.0 CONTACT INFORMATION

If you have any questions about this Privacy Policy or the way we collect information from you, or if you would like to launch a complaint about anything related to this Privacy Policy, you may contact us at the following email address support@pesapeer.com.