JustiFi

Privacy Policy

We provide a flexible, plug-and-play fintech infrastructure to help accelerate the potential of our customers’ platforms. We offer a variety of white-label tools, applications, software and services (collectively, the “Platform”) to our business customers, who utilize the Platform as part of providing their own services and products to end users.

This Privacy Policy describes how JustiFi Technologies, Inc. (“JustiFi”, “we”, “us”, “our”) we collect, use and disclose information about individuals acting on behalf of an existing or potential business customer of our Platform (e.g., company founders, beneficial owners of merchants that we directly offer products or services to, account administers or authorized users) and individuals who visit our website (https://justifi.tech) or otherwise communicate or directly do business with us (for example, when you send us an email) (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services (including individuals acting on behalf of existing or potential customers), and an “end user” means an individual consumer that does business with, or otherwise interacts with, one of our business customers (e.g., if an individual buys a product from a merchant that uses our Platform for payment processing), but does not directly do business with us or use or access our Services.

Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access or download any of the Services.

01. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time, in which case we will update the “Last Revised” date. If we make material changes to the way we use information we collect, we will use commercially reasonable efforts to notify you and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy, please do not use or access any of the Services.

02. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy covers our collection of information about users of the Services, including individuals who access and use the Platform on behalf of a business customer. This Privacy Policy also describes our collection and processing of information that business customers collect on our behalf and share with us, including information collected about their own business customers or merchants. However, this Privacy Policy does not apply to nor does it describe our business customers’ own collection, use, disclosure or security of information about end users of their platforms, and we recommend that you review the terms and policies, including any privacy policy, for those platforms for information about their practices. If you have questions about the use of information by our business customers, please reach out to the relevant customer directly. Please note that the Services, and our Platform, are designed for users in the United States only and are not intended for users located outside the United States.

03. OUR COLLECTION AND USE OF INFORMATION

When you use or access the Services, we may collect certain categories of information about you from a variety of sources. Some features of the Services may require you to enter information about yourself. You may decide not to provide this information, but doing so may prevent you from using or accessing these features.

Information that you directly submit through our Services may include:

• Basic contact and identification details, such as your name, email address, company name, role and address, other information about your business, mailing address and phone number. We collect this information to create and maintain your account, consider your application for Services, communicate with you (including to tell you about products that may be of interest to you), provide you with products and services, respond to your queries and support transactions you may request.

• Account information, such as your username, password, security questions that you select and the answers you provide. We collect this information to create, maintain and secure your account with us, so you can more readily initiate transactions or to provide information to partners in order for such partners to provide or support the Services. If you choose to register an account, you are responsible for keeping your account credentials safe. Do not share your access details with anyone else.

• Identification information, such as your date of birth, tax ID (such as Social Security number or Employer Identification number) and other financial information about your business. We collect this information to create and maintain your account, consider your application for Services, and to provide you with products and services.

• Payment and transaction information, such as your bank account, credit or debit card information and billing address, and information about payments and transactions that we process. We collect this information to process payments and to provide you with products or services requested.

• Information relating to your visit to our website or use our Services, including information that you submit when interacting with our Service’s features and webforms and information collected via cookies and tracking technologies (“Tracking Technologies”), as described further below.

• Any other information you choose to include in communications with us.

We may also collect certain information about your interaction with the Services (“Usage Data”) through Tracking Technologies, which we use to tailor features and content to you, provide you with offers or promotions, run analytics, and better understand user interactions with the Services:

• Device information, such as unique device identifier, IP address, device type, browser type, operating system, and precise location (if you choose to provide it).

• Online activity data, such as date and time stamps and log data.

• Other information, regarding your interaction with the Services, such as clickstream data and ad impressions.

We may also obtain information about you from outside sources, including from:

• Public databases and ID verification partners. We may obtain information about you from public databases and ID verification partners to verify your identity and information you may provide us.

• Third party sources and credit reporting agencies. We may obtain information about you from third party sources. Such information may include credit report information, identity verification information, fraud detection information, collection information, and information about any person or corporation with whom you have had, currently have, or may have a financial relationship.

• Data append services, data brokers and joint marketing partners. We may receive personal information from these sources so that we can better understand which of our Services may be of interest to you.

• External bank account information providers. When you use certain Services, we may collect from you, e.g., usernames, passwords, account numbers, and other account information for third-party websites and Internet banking services. This information is used to obtain your account, transaction, and other banking information from the relevant financial institution on your behalf.

• Lenders, financial institutions and brokers. When you connect your financial accounts or leverage the Platform to offer financial products or services to end users, we obtain information about you from your lender, financial institution, or broker.

• Our business customers. We may receive information directly from our business customers, including information about their own customers or merchants who may want to use our Services. We may enter into agreements with these other customers or merchants, who then become our own customer.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information on third-party services and platforms, see the section below, Third Party Websites and Links. In addition to the usage described above, we may use all of the information described above in the following ways:

• Improving and Developing our Services. We use analytics to help us analyze your use of our Services and diagnose technical issues. We use personal information to provide you with and improve our Services, connect you with financial partners who provide products and services, for internal research and development, to develop new services and product offerings, and support our efforts to make our Services more relevant and more useful to you.

• Communications. We will use the contact information we have about you to perform the Services, which may include sending codes via SMS to authenticate you. We may communicate with you using the contact information we have about you (e.g. using email, phone, text message or videoconference) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and include you on our marketing information campaigns.

• Social Media and Promotions. We may use information you submit to administer the offer, program or promotion. We will also use information you make available on social media to market to you unless we are not permitted to do so.

• Fraud Prevention and Security. We collect and use information to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection, and to otherwise seek to secure our Services and transactions against unauthorized access, use, modification or misappropriation of information or funds. We may collect information from you, and about you or your end users, from financial parties and third parties. We may also use technology to assess the fraud risk associated with an attempted transaction by a user with a partner.

• Compliance with Legal Obligations. We use information to help us and our partners meet contractual and legal obligations, including those related to anti-money laundering, Know-Your-Customer (“KYC”) laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas and other legal obligations. We may also use information to enforce any applicable terms of service, and to protect the Services, our rights, and the rights of our users or others.

If you are a California resident, we collect and in the past 12 months have collected the following categories of personal information (including sensitive information, denoted by ): identifiers, personal information listed in the California Customer Records statute, commercial information, Internet and similar network activity information, geolocation information, account access credentials for your JustiFi account, Social security, driver’s license, state ID card or passport number*. We only use and disclose sensitive personal information for the purposes specified in the CCPA or otherwise in line with your consent.

04. HOW JUSTIFI SHARES YOUR INFORMATION

We may share your information with third parties, including with:

• Vendors or other service providers who help us provide the Services, including for identity verification, KYC, cloud storage, security, customer relationship management, marketing communications, web analytics and payment processing. Service providers also include payment processors, payment networks, external bank account information providers, credit reporting and scoring agencies, providers of identity services, risk investigation and mitigation service providers, hosting, technology and communication providers, security and fraud prevention consultants, risk investigation and mitigation service providers and customer service vendors.

• Credit bureaus, collection agencies and ID verification partners. Depending on circumstances, we may share your personal information with credit bureaus and collection agencies, as permitted by law.

• Lenders, financial institutions, brokers and other banking partners, including card networks, payment processing or Buy Now Pay Later partners, and other partners that support or enable us to provide products and services.

• Other. We may also share your information with our customers or, as relevant, their own business or merchant customers, to comply with applicable law or any obligations thereunder, in connection with an asset sale, merger, bankruptcy, or other business transaction, to comply with applicable terms of service, to ensure the safety of JustiFi and/or its users, within our corporate group, with professional advisors such as auditors, law firms, and accounting firms, or when you request or direct us to share information.

We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.

05. COOKIES AND OTHER TRACKING TECHNOLOGIES

As described above, we collect Usage Data through Tracking Technologies, including Google Analytics. Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly. To opt out of tracking by Google Analytics, click here.

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

06. SOCIAL FEATURES

Features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access JustiFi’s pages on third-party platforms (such as LinkedIn or X (formerly Twitter)), and from there “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your data. If you use Social Features, information you post or make accessible may be displayed publicly by the third-party service. Both JustiFi and the third-party may have access to information about you and your use of both the Services and the third-party service. For more information on third-party services and platforms, see the section below, Third Party Websites and Links.

07. THIRD PARTY WEBSITES AND LINKS

We may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or X (formerly Twitter)) may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

08. CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information from children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

09. PRIVACY RIGHTS

Depending on where you live and applicable law, you may have the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to Know. You have a right to request the following information about our collection, use and disclosure of your personal information: categories of personal information we have collected, disclosed for a business purpose; categories of sources from which we collected personal information; the business or commercial purposes for collecting personal information; categories of third parties to whom the personal information was disclosed for a business purpose; and specific pieces of personal information we have collected.

• Right to Delete. You have a right to request that we delete personal information we maintain about you.

• Right to Correct. You have a right to request that we correct inaccurate personal information we maintain about you.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

10. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, or to request to exercise a right outlined above, please email us at info@justifi.tech or contact us at 550 Vandalia St, Suite 105, St. Paul MN, 55044.