1. What Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of information that relates to or could reasonably be associated with an individual ("Personal Information") that we gather when you are accessing or using our Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage nor does it apply to Personal Information relating to our merchants’ customers’ that we process in the course of providing our billing and subscription management services. Such information is processed pursuant to our agreements with our merchants.

We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for our Services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any Personal Information to us or on the Services. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@requre.com

We gather various types of Personal Information from our users, as explained more fully below. We may use this Personal Information to personalise and improve our services, to contact users, to fulfil your requests for certain products and services, to analyse how users utilise the Services, and as otherwise set forth in this Privacy Policy. We may share certain types of Personal Information with third parties, as described below. However, we do not rent or sell your information.

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2. What Information Does Company Collect?

Information You Provide to Us

1. We receive and store any information you knowingly provide to us. For example, we collect Personal Information, including but not limited to, your name, title, company, email address, phone number, address, location and browser information. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features. We may anonymize your Personal Information so that you cannot be individually identified, and provide that information to our partners.
2. If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Services. Also, we may receive a confirmation when you open a message from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive marketing communications from us, please indicate your preference by using the unsubscribe mechanism provided by the communication. Please note, however, that you will continue to receive legal notices and other important account information after you unsubscribe from our marketing list.

Information Collected Automatically

1. Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser including your IP address, "cookie" information, and the page you requested. "Cookies" are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device's acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.
2. When we collect usage information (such as the numbers and frequency of visitors to the Website), we typically use this data in aggregate form, and not in a manner that would identify you personally, unless we are investigating an issue related to your use. For example, this aggregate data tells us how often users use parts of the Services, so that we can make the Services appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal experience. We never disclose aggregate information to a partner in a manner that would identify you personally.

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3. Will Company Share Any of the Personal Information It Receives?

We neither rent nor sell your Personal Information in personally identifiable form to anyone. However, we do share your Personal Information with third parties as described in Section 2 and in this Section:

Affiliated Businesses and Third Party Websites We Do Not Control

1. In certain situations, businesses or third party websites we are affiliated with may market or advertise products or services to you through the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such promotional activities because they will be identified in the related marketing and advertising materials, and we will share your Personal Information with that affiliated business only to the extent that it is related to such promotional activities. For example, we may partner with an affiliated business to produce a white paper. The affiliated business will be identified in the white paper, and if you elect to download the white paper through the Service we will share the information you provide in connection with downloading the white paper with the affiliated business that helped us prepare the white paper. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business' or websites' policies.

Agents

1. We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

Business Transfers

1. We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

Protection of Company and Others

1. We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

With Your Consent

1. Except as set forth above, you will be notified when your Personal Information may be shared with third parties in personally identifiable form, and will be able to prevent the sharing of this information.

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4. Is Personal Information About Me Secure?

We endeavour to protect the privacy of your Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

The Services may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site's privacy policy.

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5. What Personal Information Can I Access?

Our Services give you access to a broad range of information (including Personal Information) about your account and your interactions with the Service for the purpose of viewing and, in certain cases, updating or deleting that information. The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at privacy@requre.com

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6. What Choices Do I Have?

You can always opt not to disclose information to use, but keep in mind some information may be needed to register with us or to take advantage of some of our special features.

You may request deletion of your information by emailing us at privacy@requre.com. Please note that some information may remain in our records, for example in our archives, after your request of deletion of such information. We may use any aggregated data derived from or incorporate your Personal Information after you update or delete it, but not in a manner that would identify you personally.

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7. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you a message. You are bound by any changes to the Privacy Policy when you use the Services after such changes have been first posted.

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8. General Data Protection Regulation (GDPR)

European Users

If you are in the European Union ("EU"), Lichtenstein, Norway, or Iceland ( collectively the "EEA"), or in the United Kingdom ("UK"), you may have additional rights under the EU General Data Protection Regulation (the "GDPR") and applicable data protection law in the UK with respect to your Personal Data, as outlined below.

As used in this section, "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with your data such as collection, use, storage and disclosure.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@requre.com

Who Is the Data Controller?

Company is the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of Services to customers, in which case we are the processor of Personal Data. If you are an end user or employee of one of our customers and would no longer like to be contacted by one of our customers that use our Services or you would like to access, correct, request deletion or exercise other rights with respect to your data, please contact the customer that you interact with directly.

What Personal Data Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

• First and last name
• Company name, VAT number
• Email address
• Mailing address
• Telephone number
• Username
• Account Code (can include email addresses)
• Credit card and credit card CVV
• Transaction and Billing Data

Information we receive from third party sources: Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following:

Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect or Twitter OAuth), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.

Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:

• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information
• Transaction information (e.g. transaction amount, date and time such transaction occurred)
• Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
• Location information (e.g. IP address, zip code)
• Log data (e.g. access times, hardware and software information)

How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalise our Services. For example, we use Personal Data to:

• Create and manage user profiles
• Communicate with you about the Services
• Process orders
• Contact you about Service announcements, updates or offers
• Provide support and assistance for the Services
• Personalise website content and communications based on your preferences
• Respond to user inquiries
• Fulfil user requests
• Comply with our legal or contractual obligations
• Resolve disputes
• Protect against or deter fraudulent, illegal or harmful actions
• Enforce our Terms of Service

We process your Personal Data with your consent, to enable us to perform our contract with you and for the purposes of our "legitimate interests" or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data to perform our obligations under our Terms of Service with you, which enables us to provide you with the Services. If you do not provide us with Personal Data that we need to perform our contract with you, you will not be able to use some or all portions of the Services that require such data.
• First and last name
• Email address
• Mailing address
• Credit card and credit card CVV
• Transaction and Billing Data
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
• First and last name
• Email address
• Mailing address
• IP Address
• Examples of these legitimate interests include:
• Operation and improvement of our business, products and services – for example, we analyze the way you interact with the Website (such as the links you click on and the pages you visit) in order to improve the design and layout of the Website
• Marketing of our products and services
• Provision of customer support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions

We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

• Payment processors
• Fraud prevention service providers
• Ad networks
• Analytics service providers
• Marketing service providers
• Staff augmentation and contract personnel
• Hosting service providers
• Co-location service providers
• Telecommunications service providers

We also share Personal Data when necessary to complete a transaction initiated or authorised by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

• Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorised by you through the Services)
• Social media services (if you interact with them through your use of the Services)
• Third party business partners who you access through the Services
• Other authorized parties

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).

We also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services

Furthermore, if we choose to buy or sell assets, Personal Data is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, Personal Data would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy

How Long Do We Retain Your Personal Data? We retain Personal Data about you for as long as reasonably necessary for the purposes described in this Privacy Policy or while we have a legitimate business need to do so in accordance with legal and additional compliance requirements. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Afterwards, we retain some information in a depersonalised or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organisational measures based on the type of Personal Data and applicable processing activity. For example, we use encryption and tokenisation to keep your Personal data secure.

What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@requre.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is manifestly unfounded or excessive, if it jeopardises the rights of others, or if it is not required by law. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. 2
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilise some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Company's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

What If You Have Questions Regarding Your Personal Data? If you have any questions about this section or our data practices generally, please contact us using the following information:

Name:
REQURE Compliance Team

Email address for contact:
privacy@requre.com