TERMS OF SERVICE

Last Updated: January 13, 2025

These Terms of Service (“Terms”) apply to your access to and use of the websites (  www.onbe.com ,  login.mypaymentvault.com ,  account.mypaymentvault.com ,  prepaiddigitalsolutions.com , prepaidcardstatus.com ,  www.northlane.com  and any other site which may link back to these Terms, hereinafter referred to as the"Sites"), any applications (the "App" and together with the Site, the "Platform"), any Payment Program (the "Program") and any features, content, products and other services offered by Onbe (collectively, the "Services") provided by North Lane Technologies, Inc., an Onbe Company. (“MyPaymentvault” or “we”).

Please read these terms carefully. By visiting our Platform and/or by using the Services, you agree to be bound fully and unconditionally by these Terms and Conditions of the Program Sponsor (the "Sponsor"), which is the entity that marketed and/or distributed a "Payment", including a digital token, claimable payment, card number, security code, payment code, or reward code. The Terms and Sponsor's decisions are final and binding in all matters related to the Program. We reserve the right to update, change or replace any part of these Terms, including for any business reason or as may be required to comply with applicable laws, by posting updates and/or changes here. You are encouraged to review these Terms each time you use the Services because your use of the Services after the posting of changes will constitute your acceptance of the changes.  If you do not agree to these Terms, including the mandatory arbitration provision and class action waiver in Section 13, do not access or use our Services.

If you have any questions about these Terms or our Services, please contact us at:

Address:	North Lane Technologies, Inc., an Onbe Company.
	P.O. Box 284
	Conshohocken, PA 19428
E-Mail Address:	privacy@myPaymentvault.com

Please refer to our Privacy Policy for information about how we collect, use and disclose information about you.

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1        Eligibility

You must be at least 18 years of age to access or use our Services. If you are accessing or using our Services on behalf of another person or entity, (a) you represent that you are authorized to accept these Terms on that person or entity's behalf, (b) that the person or entity agrees to be responsible to us if you or the other person or entity violates these Terms, and (c) references to "you" in these Terms will refer jointly to you and the other person or entity.

2        Timing

Timing varies by Program Sponsor. The Sponsor's computer is the official time keeping device for the Program.

All Payments are subject to verification and validation by the Sponsor before any funds can be accessed. The Sponsor is not responsible for lost, late, expired, incomplete, invalid, unintelligible or misdirected registrations and/or redemptions, or for Payments that are deactivated or non-redeemable due to fraud, suspected fraud or non-compliance with Program rules and regulations. In the event of a dispute as to any registration or redemption, the Participant's Sponsor will make the final determination.

All potential Payment recipients are subject to verification by the Sponsor, whose decisions are final and binding. A Participant will not receive a Payment or may be unable to use a Payment, even if the Program should so indicate, unless and until the Participant's eligibility has been verified. The Sponsor will not be held liable for a Participant's ineligibility or non-compliance with these Terms.

3        Payment Determination

All potential Payment recipients must comply with these Terms, and all Payments are contingent upon fulfilling all requirements. The Sponsor's decisions as to the administration and operation of the Program are final and binding in all matters related to the Program.

Payments may not be sold or transferred and are not convertible to cash. The Sponsor reserves the right to substitute a Payment or Payment product option, in whole or in part, in the event that all or any component of a Payment or Payment product option is unavailable. Payment recipients are responsible for the reporting and payment of any applicable taxes and fees associated with Payment receipt and/or use. Payments are subject to verification of eligibility. If due to printing, production, technical or other errors, more value of a specified level is claimed than intended, the intended Payment value will be determined by the Sponsor according to the Program Rules.

4         User Accounts and Account Security

You may need to register for an account to access some or all of our Services. If you register for an account, you must provide accurate account information and promptly update this information if it changes. You also must maintain the security of your account and promptly notify us if you discover or suspect that someone has accessed your account without your permission. You are responsible for all activities that occur in connection with your account and accept all risks of unauthorized access.

5        Additional Terms

Additional terms may apply to specific features, products, or services associated with our Services (“Additional Terms”), including without limitation a cardholder bank agreement that you may have with a sponsor bank and a customer program agreement that you may have with Mypaymentvault. These Terms are not intended to cover subject matter addressed in such Additional Terms, and to the extent any Additional Terms conflict with these Terms, the Additional Terms govern with respect to your access to or use of the applicable feature, product, or service.

6        Prohibited Conduct and Content

You will not violate any applicable law, contract, intellectual property or other third-party right or commit a tort, and you are solely responsible for your conduct while accessing or using our Services. You will not:

• Engage in any harassing, threatening, intimidating, predatory or stalking conduct;
• Use or attempt to use another user's account without authorization from that user and Mypaymentvault;
• Use our Services in any manner that could interfere with, disrupt, negatively affect or inhibit other users from fully enjoying our Services or that could damage, disable, overburden or impair the functioning of our Services in any manner;
• Reverse engineer any aspect of our Services (except to the extent such prohibition is not permitted under applicable law) or do anything that might discover source code or bypass or circumvent measures employed to prevent or limit access to any part of our Services;
• Attempt to circumvent any content-filtering techniques we employ or attempt to access any feature or area of our Services that you are not authorized to access;
• Develop or use any third-party applications that interact with our Services without our prior written consent, including any scripts designed to scrape or extract data from our Services;
• Bypass or ignore instructions contained in our robots.txt file that controls automated access to portions of our Services; or
• Use our Services for any illegal or unauthorized purpose, or engage in, encourage or promote any activity that violates these Terms.

7        Limited License; Copyright and Trademark

Our Services and the text, graphics, images, photographs, videos, illustrations, trademarks, trade names, service marks, logos, slogans and other content contained therein (collectively, the “MyPaymentvault Content”) are owned by or licensed to MyPaymentvault and are protected under both United States and foreign laws. Except as explicitly stated in these Terms, MyPaymentvault and our licensors reserve all rights in and to our Services and the MyPaymentvault Content. We hereby grant you a limited, nonexclusive, nontransferable, non-sublicensable, revocable license to access and use our Services and MyPaymentvault Content for your internal business purposes; however, such license is subject to these Terms and does not include any right to (a) sell, resell or commercially use our Services or MyPaymentvault Content; (b) copy, reproduce, distribute, publicly perform or publicly display MyPaymentvault Content, except as expressly permitted by us or our licensors; (c) modify the MyPaymentvault Content, remove any proprietary rights notices or markings, or otherwise make any derivative uses of our Services or MyPaymentvault Content; (d) use any data mining, robots or similar data gathering or extraction methods; and (e) use our Services or MyPaymentvault Content other than for their intended purposes. Any use of our Services or MyPaymentvault Content other than as specifically authorized herein, without our prior written permission, is strictly prohibited and will terminate the license granted herein.

8        Feedback

Any questions, comments, suggestions, ideas, original or creative materials or other information you submit about Mypaymentvault or our products or Services (collectively, “Feedback”), is non-confidential and will become the sole property of Mypaymentvault. We will own exclusive rights, including, without limitation, all intellectual property rights, in and to Feedback and will be entitled to the unrestricted use and dissemination of Feedback for any purpose, commercial or otherwise, without acknowledgment or compensation to you.

9        Copyright Complaints

We have a policy of limiting access to our Services and terminating the accounts of users who infringe the intellectual property rights of others. If you believe that anything on our Services infringes any copyright that you own or control, you may notify Onbe’s Designated Agent as follows:

Designated Agent:	Director of Compliance
Address:	North Lane Technologies, Inc., an Onbe Company.
	P.O. Box 284
	Conshohocken, PA 19428
E-Mail Address:	privacy@mypaymentvault.com

Please see 17 U.S.C. §512(c)(3) for the requirements of a proper notification. Also, please note that if you knowingly misrepresent that any activity or material on our Services is infringing, you may be liable to Onbe for certain costs and damages.

10        Indemnification

To the fullest extent permitted by applicable law, you will indemnify, defend, and hold harmless Mypaymentvault, our subsidiaries and affiliates, and each of our respective officers, directors, agents, partners and employees (individually and collectively, the “Mypaymentvault Parties”) from and against any loss, liability, claim, demand, damages, expenses or costs ("Claims") arising out of or related to (a) your access to or use of our Services;(b) your User Content or Feedback; (c) your violation of these Terms; (d) your violation, misappropriation or infringement of any rights of another (including intellectual property rights or privacy rights); or (e) your conduct in connection with our Services. You agree to promptly notify Mypaymentvault of any third party Claims, cooperate with Mypaymentvault Parties in defending such Claims and pay all fees, costs and expenses associated with defending such Claims (including, but not limited to, attorneys' fees). You also agree that North Lane will have control of the defense or settlement of any third party Claims. This indemnity is in addition to, and not in lieu of, any other indemnities set forth in a written agreement between you and Mypaymentvault or the other Mypaymentvault Parties.

11        Disclaimers

(a)We do not control, endorse or take responsibility for any User Content or third-party content available on or linked to by our Services.

(b) Your use of our Services is at your sole risk. Our Services are provided "as is" and "as available" without warranties of any kind, either express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement. In addition, Mypaymentvault does not represent or warrant that our Services are accurate, complete, reliable, current or error-free. While Mypaymentvault attempts to make your access to and use of our Services safe, we cannot and do not represent or warrant that our Services or servers are free of viruses or other harmful components. You assume the entire risk as to the quality and performance of the Services.

12   Limitation of Liability

(a) Mypaymentvault and the other Mypaymentvault Parties will not be liable to you under any theory of liability—whether based in contract, tort, negligence, strict liability, warranty, or otherwise—for any indirect, consequential, exemplary, incidental, punitive or special damages or lost profits, even if Mypaymentvault or the other Mypaymentvault Parties have been advised of the possibility of such damages.

(b) The total liability of Mypaymentvault and the other Mypaymentvault Parties, for any claim arising out of or relating to these Terms or our Services, regardless of the form of the action, is limited to the amount paid, if any, by you to access or use our Services.

(c) The limitations set forth in this section will not limit or exclude liability for the gross negligence, fraud or intentional misconduct of Mypaymentvault or the other Mypaymentvault Parties or for any other matters in which liability cannot be excluded or limited under applicable law. Additionally, some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitations or exclusions may not apply to you.

13   Release

To the fullest extent permitted by applicable law, you release Mypaymentvault and the other Mypaymentvault Parties from responsibility, liability, claims, demands, and/or damages (actual and consequential) of every kind and nature, known and unknown (including, but not limited to, claims of negligence), arising out of or related to disputes between users and the acts or omissions of third parties.You expressly waive any rights you may have under California Civil Code § 1542 as well as any other statute or common law principles that would otherwise limit the coverage of this release to include only those claims which you may know or suspect to exist in your favor at the time of agreeing to this release.

14   Dispute Resolution; Binding Arbitration

(a) Please read the following section carefully because it requires you to arbitrate certain disputes and claims with Mypaymentvault and limits the manner in which you can seek relief from us.

(b) Except for small claims disputes in which you or Mypaymentvault seek to bring an individual action in small claims court located in the county of your billing address or disputes in which you or Mypaymentvault seeks injunctive or other equitable relief for the alleged unlawful use of intellectual property, you and Mypaymentvault waive your rights to a jury trial and to have any dispute arising out of or related to these Terms or our Services resolved in court. Instead, all disputes arising out of or relating to these Terms or our Services will be resolved through confidential binding arbitration held in Manhattan, New York, New York in accordance with the Streamlined Arbitration Rules and Procedures("Rules") of the Judicial Arbitration and Mediation Services ("JAMS"), which are available on the JAMS website and hereby incorporated by reference. You either acknowledge and agree that you have read and understand the rules of JAMS or waive your opportunity to read the rules of JAMS and any claim that the rules of JAMS are unfair or should not apply for any reason.   

(c) You and Mypaymentvault agree that any dispute arising out of or related to these Terms or our Services is personal to you and Mypaymentvault and that any dispute will be resolved solely through individual arbitration and will not be brought as a class arbitration, class action or any other type of representative proceeding.

(d) You and Mypaymentvault agree that these Terms affect interstate commerce and that the enforceability of this Section 12 will be substantively and procedurally governed by the Federal Arbitration Act, 9 U.S.C. § 1, et seq. (the "FAA"), to the maximum extent permitted by applicable law.   As limited by the FAA, these Terms and the JAMS Rules, the arbitrator will have exclusive authority to make all procedural and substantive decisions regarding any dispute and to grant any remedy that would otherwise be available in court; provided, however, that the arbitrator does not have the authority to conduct a class arbitration or a representative action, which is prohibited by these Terms. The arbitrator may only conduct an individual arbitration and may not consolidate more than one individual’s claims, preside over any type of class or representative proceeding or preside over any proceeding involving more than one individual. You and Mypaymentvault agree that for any arbitration you initiate, you will pay the filing fee and Mypaymentvault will pay the remaining JAMS fees and costs.  For any arbitration initiated by Mypaymentvault, Mypaymentvault will pay all JAMS fees and costs.  You and Mypaymentvault agree that the state or federal courts of the State of New York and the United States sitting in Manhattan, New York have exclusive jurisdiction over any appeals and the enforcement of an arbitration award. 

(e) Any claim arising out of or related to these Terms or our Services must be filed within one year after such claim arose; otherwise, the claim is permanently barred, which means that you and Mypaymentvault will not have the right to assert the claim. 

15   Governing Law and Venue

These Terms and your access to and use of our Services will be governed by and construed and enforced in accordance with the laws of Delaware, without regard to conflict of law rules or principles (whether of Delaware or any other jurisdiction) that would cause the application of the laws of any other jurisdiction. Any dispute between the parties that is not subject to arbitration or cannot be heard in small claims court will be resolved in the state or federal courts of Delaware and the United States, respectively, sitting in Wilmington, DE.

16   Changes to these Terms

We may make changes to these Terms from time to time by providing notice to you. We will provide notice to you by posting the amended Terms to our Services and updating the "Last Updated" date above. We may also provide additional notice, such as by sending an email notification to the email address associated with your account or providing supplemental notice through our Services. Unless we say otherwise in our notice, the amended Terms will be effective immediately upon posting to our Services, and your continued access to and use of our Services after we provide notice will confirm your acceptance of the changes. If you do not agree to the amended Terms, you must stop accessing and using our Services.

17   Termination

We reserve the right, without notice and in our sole discretion, to terminate your right to access or use our Services. We are not responsible for any loss or harm related to your inability to access or use our Services.

18   Severability

If any provision or part of a provision of these Terms is unlawful, void or unenforceable, that provision or part of the provision is deemed severable from these Terms and does not affect the validity and enforceability of any remaining provisions.

19   Miscellaneous

In no event will Mypaymentvault or the Mypaymentvault Parties be responsible for any delay or failure to perform due to an event or circumstances outside the reasonable control of Mypaymentvault. These Terms constitute the entire agreement between you and Mypaymentvault relating to your access to and use of our Services. The failure of Mypaymentvault to exercise or enforce any right or provision of these Terms will not operate as a waiver of such right or provision. The section titles in these Terms are for convenience only and have no legal or contractual effect. Except as otherwise provided herein, these Terms are intended solely for the benefit of the parties and are not intended to confer third party beneficiary rights upon any other person or entity.

 

 

Electronic Communications Agreement

Agreement to Receive Electronic Communications

This Electronic Communications Agreement ("Disclosure") applies to all communications related to any applications (the "App" and together with the Site, the "Platform"), any Payment Program (the "Program") and any features, content, products and other services offered by Onbe (collectively, the "Services") available through account.mypaymentvault.com (the “Website”). This Disclosure supplements and is to be construed in accordance with the Terms of Access you received when you agreed to use one of Onbe’s websites ( www.onbe.com, login.mypaymentvault.com, account.mypaymentvault.com, prepaiddigitalsolutions.com, prepaidcardstatus.com, www.northlane.com and any other site which may link back to this Disclosure, hereinafter referred to as the "Sites").

"We," "us," and "our" refer to Program Manager. "Issuer" means the issuing entity. "You" and "your" refers to the person(s) to whom our Services were offered. "Communication(s)" means any customer agreement or amendments thereto; disclosure; notice; response to claims; transaction history; privacy policy; and all other information related to our Services, including but not limited to information that we are required by law to provide you in writing.

Our Services are intended for use only by person(s) who are willing and able to receive notices and communications exclusively through our Sites, or via electronic mail ("E-mail"). If you do not agree to receive the legally required notices and communications described herein in electronic and not paper form, then you may not use our Services. Similarly, if after providing consent hereunder, you withdraw it, we reserve the right to terminate your use of our Services.

1. Scope of Communications to Be Provided in Electronic Form.  When you use our Services to which this Disclosure applies, you agree that any Communications will be provided in electronic format, to the extent allowed by law, and that paper Communications will not be sent. Your consent to receive electronic Communications and transactions includes, but is not limited to:
   • All legal and regulatory disclosures and communications associated with the our Services;
   • Consumer Agreements related to our Services, Terms and Conditions, and any notices about changes in Terms and Conditions;
   • Privacy policies and notices;
   • Responses to claims filed in connection with our Services;
   • Notices regarding insufficient funds or negative balances; and
   • All other communications concerning our Services and any related transactions, products, or services.
2. Method of Providing Communications in Electronic Form. All communications that we provide in electronic form will be provided either (1) by E-mail or (2) by access to the Website.
3. How to Withdraw Consent. You may withdraw your consent to receive Communications in electronic form by calling us at 866-326-8689. At our option, we may treat your provision of an invalid e-mail address, or the subsequent malfunction of a previously valid e-mail address, as a withdrawal of your consent to receive electronic Communications. Any withdrawal of your consent to receive electronic Communications will be effective only after we have a reasonable period of time to process your withdrawal.
4. How to Update Records. It is your responsibility to provide us with true, accurate and complete e-mail address, contact, and other information related to the Disclosure and your Card, and to maintain and update promptly any changes in this information. You can update information (such as your e-mail address) through our web site or by calling us at 866-326-8689.
5. System Requirements. In order to access, view, and retain electronic Communications that we make available, you must have:
   • An Internet browser that supports 128-bit encryption, which requires Windows 2000 or later version running either Microsoft Edge or Firefox, or Mac OSX 10.2 or higher running Safari web browser. Your access to this page verifies that your browser and encryption software/device meets these requirements;
   • Sufficient electronic storage capacity on your computer’s hard drive or other data storage unit;
   • An active E-mail account with an Internet service provider and e-mail software;
   • A personal computer, tablet, or cell phone with the ability to read text-formatted email or by accessing our web site using one of the browsers specified above;
   • Adobe Reader version 9.0 or higher

We may update these requirements as necessary to preserve the ability to receive electronic Communications. If there is a substantial change in these requirements, you will be notified of the changes accordingly.

6. Requesting Paper Copies. We will not send paper copies of any Communication, however, we reserve the right, but assume no obligation, to provide a paper (instead of electronic) copy of any Communication that you have authorized us to provide electronically. You can obtain a paper copy of an electronic Communication by printing it or by requesting that we mail a paper copy. To request a paper copy, call us at 866-326-8689. We may charge you a reasonable service charge, of which we have provided you prior notice, for the delivery of paper copies of any Communication provided to you electronically pursuant to this authorization. We will not charge you to deliver a paper copy of your transaction history provided that you make no more than one request per month and the request does not exceed 24 months of transactions.
7. Communications in Writing. All Communications in either electronic or paper format from us to you will be considered “in writing.” You should print or download a copy of this Disclosure and any other Communications.
8. Federal Law. You acknowledge and agree that consent to electronic Communications is being provided in connection with a transaction affecting interstate commerce that is subject to the federal Electronic Signatures in Global and National Commerce Act (the "Act"), and that you and we both intend that the Act applies to the fullest extent possible to validate our mutual ability to conduct business by electronic means.
9. Termination/Changes. We reserve the right, at our sole discretion, to discontinue the provision of electronic Communications, or to terminate or change the terms and conditions upon which electronic Communications are provided. We will provide you with notice of any such termination or change as required by law.
10. Consent. By clicking “I agree,” By clicking a box indicating that you agree, this constitutes your electronic signature, and you give us your affirmative consent to receive electronic Communications as described herein. You further agree that your computer satisfies the hardware and software requirements specified above and that you have provided us with your current E-mail address to which we may send you electronic Communications.

 

Website Privacy Policy

PURPOSE

Our mission is to manage and modernize consumer and workforce disbursements, enabling program sponsors ("clients") to outsource their entire business to individual (B2I) payment operations – relieving them of the cost, complexity and risk that come with orchestrating these payments in-house, and delivering a customer experience that is instant, convenient and simple. In order to do this, we collect, use, and share some of your personal information.

When we do so, we process personal information solely to provide services to clients and card or payment issuers; we collect, use and disclose the data only under the instructions of the client or the card or payment issuer; and our processing of the data is subject to their instructions and privacy notices. Please read the agreement and terms and conditions provided in conjunction with your payment for further details regarding your payment issuer. For access to each payment issuer’s privacy notice, please click on each name:

• Ebixcash
• Fifth Third Bank, National Association, Member FDIC
• HDFC Bank
• Pathward, National Association, Member FDIC
• People's Trust Company
• Sunrise Banks, Member FDIC
• The Bancorp Bank N.A., Member FDIC
• Transact Payments Limited

The purpose of this Privacy Notice is to share how we do this and how to exercise your data protection rights.

Topics

• What data do we collect?
• Children
• How do we collect your data?
• How will we use your data?
• How do we store your data?
• What and with whom we share
• How to control your privacy options
• What are your rights under data privacy laws?
• What are cookies?
• How do we use cookies?
• What types of cookies do we use?
• How to manage your cookies
• Privacy policies of other websites
• Changes to our privacy policy
• How to contact us
• How to contact the appropriate authorities

This Privacy Notice describes how we manage the personal information we collect about users of our Web sites and mobile applications, as well as the personal information we collect in providing our products and services or when individuals communicate with us about our Web sites, mobile apps, products or services.

WHAT DATA DO WE COLLECT?

We may collect the following data, as applicable:

• Full name, personal or business contact information including physical mailing address, email address, telephone number, and in some instances date of birth and/or national identification number (e.g., SSN).

• Contact preferences and other business information that helps us do business with you.

• Technical information such as login information, IP address, device and operating system.

• Other data with your consent or as allowed or required by applicable law.

CHILDREN

Our Services are meant for adults and are not for children. We do not intentionally collect personal information from children under 13 without authorization from a parent or legal guardian. If you think your child under 13 has sent us data, you can contact us at privacy@mypaymentvault.com.

HOW DO WE COLLECT YOUR DATA?

You directly provide us with most of the data we collect. We collect data and process data when you:

• Use or view our website via your browser’s cookies.

• Use our products or services.

• Contact customer service.

In addition to these items, we also process personal information on behalf of our clients and card or payment issuers. When we do so, we process personal information solely to provide services to our clients and card or payment issuers. We collect, use and disclose the data only under the instructions of our client or the card or payment issuer, and our processing of the data is subject to their instructions and Privacy Notices.

HOW WILL WE USE YOUR DATA?

We process your personal information, on specific legal grounds. We do so with your consent, to fulfill the contractual requirements we have with you, comply with our legal responsibilities, or as needed to deliver our services and products and for other legitimate business interests for the purposes described in this Privacy Notice.

We collect your data so that we can operate and support our services and products only. We may use your data to:

• Send administrative material to you, such as changes to our terms, conditions, and policies.

• Provide access to our website and customer service.

• Provide technical support.

• Send you alerts that you requested.

• Identify areas where our products and services can be enhanced.

• Detect and protect against errors, fraud, or other criminal activity.

We may also use your personal information in other instances with your consent, and as required by law.

HOW DO WE STORE YOUR DATA?

We store personal information in the United States ("U.S."). If you reside outside of the U.S., you understand that we transfer personal information to the U.S. Our products and services and associated practices comply with privacy provisions as set forth by the U.S. government, including the U.S. Department of Commerce's EU Privacy Shield Framework, and GDPR as required by EU/UK. When we transfer your personal information to service providers or third parties as outlined in this Privacy Notice, we rely on contractual clauses to administer the transfer of that personal information and uphold those entities to protecting the data as described in this Privacy Notice or as required by law.

We implement security policies, processes and technical security solutions to protect personal information which includes various network safeguards, logging and alerting. In order to perform certain obligations, our authorized employees and service providers will need access to your personal information. We contractually require our service providers to protect your personal information.

We may hold personal information as long as required or relevant for the practices described in this Privacy Notice or as otherwise applicable by law. Actual hold periods differ depending on the type of services and products. The principles we use to determine the holding periods include the following:

• Personal information required to provide our services and products as described in this Privacy Notice;
• Personal information required for auditing purposes;
• Personal information required to troubleshoot problems or to assist with investigations;
• Personal information required to enforce our policies; and
• Personal information required to comply with legal requirements.

Regulations require financial institutions to obtain, verify, and record information that identifies each person for whom we open or have established an account. With respect to such records, we generally hold those records for a minimum of seven (7) years or such other time period as may be required pursuant to applicable law.

WHAT AND WITH WHOM WE SHARE

We do not share your personal information with third parties for joint marketing purposes or so they can market to you, without your prior express consent. We may share your personal information:

• With organizations and partners that help us operate our business by providing services such as website hosting, data analysis, information technology, customer service, email delivery, auditing and other similar services.
• With partners and other vendors that perform services on our behalf, such as network services support, including data processing services, customer service, call center services, information technology services, internal audit, management, or administrative purposes.
• To comply with the law or other legal responsibilities such as responding to subpoenas, including laws and other legal duties outside your country of residence.
• To answer requests from government authorities including authorities outside your country of residence.
• To protect our rights, business operations and possessions, or that of our users, employees and partners.
• To investigate, stop, or take action concerning possible or suspected illegal activities, fraud, or violations of our terms and conditions.

IDENTITY VERIFICATION & ANTI-MONEY LAUNDERING

Identity verification or an anti-money laundering check may need to be performed by a third party for the purpose of potentially supporting a relationship involving a financial transaction.

• The relevant credit reference agency is TransUnion International UK Limited.
• The search footprint retained by TransUnion International UK Limited related to the verification will indicate that either an anti-money laundering check or an identity check has been performed.
• The search footprint retained by the credit reference agency will read as having been made by Trulioo Information Services Inc.

HOW TO CONTROL YOUR PRIVACY OPTIONS

You can update your account profile online or by email. We maintain electronic records of your personal information for the purposes described in this Privacy Notice. You will be able to access and edit your personal information on the website listed on the back of the card. Otherwise, you may contact us at the email address listed at the bottom of this Privacy Notice. Your right to access, correct or delete your personal information indicated in our records is subject to applicable law including our right to retain documentation of our compliance with applicable legal requirements and technology limitations. We may take reasonable steps to confirm your identity before giving access or making modifications to your personal information.

If we receive data from other sources, we may direct you to contact those sources. Please note that we are not responsible for permitting you to review, or for updating or deleting personal information that you provide to those sources or any other third party.

WHAT ARE YOUR RIGHTS UNDER DATA PRIVACY LAWS?

When you provide us with your personal information it is only used for the purposes of providing products and services as described in this Privacy Notice. You have the option to opt-out of certain uses and disclosures of your personal information as outlined in this Privacy Notice. We may not be able to provide the full extent of our products and services if you do opt out. If you would like to opt out of these uses or disclosures of your personal information, you may contact us at the email address listed at the bottom of this Privacy Notice.

California Residents

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. Effective January 1, 2020, under the California Consumer Privacy Act (CCPA), residents of California have certain rights to access, delete, or otherwise control the use, collection, and/or disclosure of their information. California residents may also opt out of the sale of such information, if applicable; please note that we do not sell your personal information. These provisions of the CCPA do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law.

To exercise your rights as described above, please submit a request via our privacy webform.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note, consumers will not be subject to discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

EU & UK Residents

We adhere to applicable data protection laws in the EU and UK, when relevant and appropriate, including the General Data Protection Regulation (“GDPR”).

We would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

• The right to access – You have the right to request from us copies of your personal information.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete the information you believe is incomplete.
• The right to erasure - You have the right to request that we erase your personal information, under certain conditions.
• The right to restrict processing - You have the right to request that we restrict the processing of your personal information under certain conditions.
• The right to object to processing - You have the right to object to us processing your personal information, under certain conditions.
• The right to data portability - You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

We will make every effort to honor your request, however in some situations, we may not be able to act and/or may impose limitations on your request. For instance, if your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation, or infringe on applicable law.

You may exercise these rights free of charge. However, we may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please submit a request via our  privacy webform.

Canada Residents

We adhere to applicable data protection laws in Canada, when relevant and appropriate, including the Personal Information Protection and Electronics Documents Act(“PIPEDA”).

We would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

• The right to be informed - We will inform you of purposes for processing your personal information, either orally or in writing.
• The right to access - You have the right to request from us copies of your personal information. If you make a request, we have one month to respond to you.
• The right to correction - You have the right to request that we correct any personal information you believe is inaccurate.
• The right to erasure - You have the right to request that we erase your personal information.
• The right to withdraw consent – You have the right to withdraw consent at any time. However, we may retain personal information for the period in which it is necessary to fulfill the purpose for which it was collected.
• The right to lodge a complaint - You have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) if you believe we are in violation of PIPEDA.

We will make every effort to honor your request, however in some situations, we may not be able to act and/or may impose limitations on your request. For instance, if your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation, or infringe on applicable law.

You may exercise these rights free of charge. However, we may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character.

IIf you would like to exercise any of these rights, please submit a request via our privacy webform.

When Submitting a Data Subject Rights Request

Data subject rights requests may be submitted via our privacy webform. We may request additional information to verify your identity in accordance with applicable law.

WHAT ARE COOKIES?

Cookies are text files placed on your computer or device to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit www.allaboutcookies.org.

HOW DO WE USE COOKIES?

We use cookies in a range of ways to improve your experience on our website, including:

• Identify new or past users.
• Save your password if you are registered on our website.
• Enhance our website and troubleshoot issues.
• Investigate, stop, or take action concerning possible or suspected illegal activities, fraud, or violations of our terms and conditions.

WHAT TYPES OF COOKIES DO WE USE?

There are several different types of cookies our website may use, including:

• Functionality cookies - to enable certain functions of the service and to store your preferences, such as language and currency preferences and policy acknowledgments.
• Tracking and performance cookies - to understand service usage and performance.
• Essential cookies - to authenticate users and prevent fraudulent use of user accounts.

For more information, please read our Cookie Policy.

HOW TO MANAGE YOUR COOKIES

You can adjust cookies and tracking tools on our website. Your web browser may give you the ability to adjust cookies. How you do so depends on the type of cookie. Certain web browsers can be set to clear past and reject future cookies. If you block cookies on your browser, certain features of our website may not work. Additionally, if you limit or delete cookies, not all the tracking activities we have defined here will stop. The choices you make are both browser and device specific. For more information on cookies and how to manage them, visit  www.allaboutcookies.org.

PRIVACY POLICIES OF OTHER WEBSITES

Our website contains links to other websites. Our Privacy Notice applies only to our website and does not apply to the privacy practices of third-party websites. If you click on a link to another website, you should read the Privacy Notice of that website. We are not liable for these third-party practices.

CHANGES TO OUR PRIVACY POLICY

We keep our Privacy Notice under regular review and place any updates on this web page. We may inform you of any changes to our Privacy Notice as required by law. By continuing to use this website and access our services you agree to receive updates to our Privacy Notice at this website. This Privacy Notice was last updated on August 2, 2023.

HOW TO CONTACT US

If you have any questions about our Privacy Notice, the data we hold about you, or you would like to exercise one of your data protection rights, please do not hesitate to email our Privacy Officer, Thephil Russelliah Roby at privacy@mypaymentvault.com. We are committed to resolving any questions you may have.