FuturePay Privacy Policy

This Privacy Policy (“Privacy Policy” or “this Policy”) applies to all services provided to you by Futurepay Global Limited (“FuturePay”, “we”). This Privacy Policy is issued by FuturePay Global Limited (“FuturePay”, “we” or “us”). FuturePay is the data user responsible for the personal-data processing described in this Policy. FuturePay’s contact address is set out in Section 12 of this Policy.This Policy is formulated to clearly explain to you how we collect, hold, use, store, disclose and transfer your personal data, safeguard all privacy rights conferred upon you under the Cap. 486 Personal Data (Privacy) Ordinance (the “Ordinance”), as well as fulfil statutory compliance obligations in respect of anti-money laundering, counter-terrorist financing and any cross-border payment regulatory requirements.

FuturePay understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our partners and the users of Futurepay Global Limited websites and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.We use bold text to highlight terms and personal information within this Policy that are of significant relevance to your rights and interests to draw your attention. Before accepting this Policy, please read it carefully and ensure you fully understand it. If you have any questions, you can contact us using the contact methods stated in this Policy.

1. Policy Statement

1.1This Policy provides you with notice regarding how and why your personal data is collected; how your personal data is used; to whom your personal data may be transferred; how to access, review, and modify your personal data; as well as our policies concerning direct marketing and the use of cookies, among other matters.

1.2The terms "data", "personal data", "data user", "processing", "disclosure", and other terms defined in the Ordinance as used in this Policy shall carry the meanings given to them under the Ordinance.

1.3By accessing or using our service, you shall be deemed to have fully understood and agreed to the contents set forth in this Policy. You may choose not to provide the data we request; however, if you do not do so, FuturePay may be unable to provide you with information and services or respond to your enquiries. This does not constitute consent for any activity for which separate consent is required by applicable law, including direct marketing or providing personal data to another person for use in direct marketing.

1.4This Policy applies generally across the FuturePay and our affiliated companies include companies with a Futurepay name. However, individuals in certain jurisdictions or categories may have additional or different privacy rights, or may be protected by additional or different requirements for the processing of personal data. Those special requirements will be explained in the applicable schedules to this Policy.

2. Personal Data Collected by FuturePay and Purposes of Collection

Account Registration

When you register for a FuturePay account, you are required to provide your name and email address, and set a password to create your FuturePay account. FuturePay will verify the validity of your information and confirm your identity by sending an email verification code.

Account Login

When you log in to your FuturePay account, you need to provide your email address to FuturePay. FuturePay will verify your identity by requesting you to enter your preset login password.

Modification of Account Information

You may independently modify your account password, full name and email address. To respond to your request for changes to account information, FuturePay will prompt you to enter an email verification code to authenticate your identity.

Identity Verification

To confirm your identity, establish your account and fulfil statutory AML/CTF obligations, including enhanced due diligence (EDD/KYB), adverse media screening, ongoing risk monitoring and other verification procedures, FuturePay will collect the following information:

a.Where you use FuturePay’s services as an individual merchant, FuturePay will collect your personal identity and tax information: your date of birth, nationality, identity document, document photo, valid identification number, residential address and postal code;

b.When you use FuturePay’s services as a corporate merchant, FuturePay will collect information relating to your contact persons, shareholders (including UBOs) and directors: date of birth, nationality, identity document, residential address and postal code of such contact persons, corporate shareholders and directors;

c.To complete real-name account opening verification, liveness detection for impersonation prevention, secondary authentication for high-risk operations and other verification processes, FuturePay may also collect your facial scan data, liveness detection data and other image and biometric information, to the extent permitted by applicable law, upon completion of required notices and obtaining necessary consents;

d.FuturePay will also verify the information you provide to FuturePay through fraud prevention agencies, companies registry records and governmental or private databases;

e.FuturePay may also collect your information from sources such as media reports, online registers and public websites;

Transaction Processing

a.To execute your payment instructions and settle funds, FuturePay will collect your financial information, including bank account name and account number, local account identifiers such as IBAN/CLABE, name and country/region of the issuing bank, SWIFT/BIC and local clearing codes, account currency, card number (or its tokenized identifier), card expiry date and cardholder name, mobile phone number and email address registered with the bank, e-wallet or virtual account identifiers, necessary transaction history and account statements.

b.When you conduct transactions using FuturePay’s services, FuturePay will collect your transaction information, including payer/payee details (name, address, country/region and account information), transaction amount, original currency and settlement currency, applicable exchange rates and fees, transaction time and transaction reference number, payment method and transaction channel, remittance purpose and payment remarks, supporting documents required to verify transaction background (such as invoices, contracts, customs declarations and logistics documents) together with the personal data contained therein, records relating to refunds and chargeback disputes, payee name verification results, IP address and device information at the time of transaction initiation, as well as approximate geolocation inferred therefrom.

c.Where required for risk and compliance reviews, FuturePay may request you to provide additional transaction-related information on a case-by-case basis.

Account Risk Control

To safeguard the security of your account and to fulfil statutory anti-fraud and anti-telecom and cyber fraud obligations, FuturePay will collect the following information:

a.FuturePay will collect your device and network technical data, including your access IP address, access time, device type, operating system and version, browser type, version and tamper detection, whether the proxy, VPN, bot, incognito mode, virtual machine is used, whether the device is jailbroken/rooted, time zone settings, geolocation and other data;

b.If you authorize location sharing, FuturePay may also collect precise geolocation information of your device;

c.When FuturePay identifies security risks or transaction risks associated with your account.

Operational Optimization

To ensure you can use all the services of the website and platform and to conduct coordinated management of internal platform operations, including for troubleshooting, data analysis, product testing, statistical and survey purposes, FuturePay will collect the following personal data:

a.FuturePay will collect your website and App interaction behaviour data, including your page views and clickstream, records of products viewed or searched, and feature usage;

b.FuturePay may also obtain your personal data from information supplied by ad networks and analytics service providers. Such providers may provide FuturePay with your information, including your traffic source, ad click attribution data and campaign identifiers;

c.FuturePay uses tools such as Cookies, pixel tags and local storage identifiers on FuturePay’s websites and applications to maintain user login status and analyse user behaviour, advertising preferences and other data.

Service Notifications

FuturePay may send you service notifications via your reserved email address. You can unsubscribe from receiving FuturePay service notifications by following the instructions contained in the email. However, once you opt out, you will no longer receive service-related information such as service progress updates from FuturePay, and you shall bear all adverse consequences arising from non-delivery on your own.

Customer Support

When you contact FuturePay’s customer service to obtain support services, you will also need to provide your FuturePay account data to verify your identity. Futuremore, to ensure service quality, protect the rights and interests of platform users, prevent fraud, and verify the accuracy of information you provide during customer service interactions, FuturePay will record calls between you and FuturePay customer service (both incoming and outgoing). Your chat records via online customer service, including email correspondence, online chat transcripts and complaint ticket contents, will also be collected.

Direct Marketing

subject to the notification and consent requirements in Section 4 and applicable law, to provide you with information about FuturePay’s goods or services;

User Rights Protection

FuturePay may from time to time collect information you provide when submitting feedback, suggestions or reports to FuturePay.

Miscellaneous

FuturePay may use your personal data in order to comply with all applicable laws and regulatory requirements, or for any matters directly connected with or arising from the above.

3. Manners of Sharing Personal Data by FuturePay

3.1Sharing Personal Data with FuturePay’s Affiliated Companies

To facilitate the provision of services to you and carry out routine technical maintenance and operations, we may share your personal data with FuturePay’s affiliated companies to the extent necessary for business purposes. FuturePay shall implement robust security protection mechanisms to safeguard the safety of your personal particulars, and only authorise personnel with genuine access requirements for contract performance and daily business operations to retrieve such data.

3.2Sharing Personal Data with FuturePay’s Business Partners

To perform our service commitments and execute the terms of cooperation agreements, we may synchronise part of your customer particulars (including corporate basic information, bank account details, transaction records, etc.) with our business counterparts such as banks, payment clearing institutions and assorted financial service providers, for the purpose of delivering cross-border payment services to you.

FuturePay also engages a wide range of service providers to jointly render services covering technical infrastructure maintenance, data processing, risk control management, identity verification, anti-money laundering checks and other scenarios. Accordingly, to ensure complete service delivery, we need to entrust selected vendors and third-party collaborators to process certain categories of your personal data, including identity documents, transaction orders, payment histories, device information and the like. The specific recipients shall be determined based on the service type you select and applicable business scenarios. Your consent to such sharing is a prerequisite for us to supply the corresponding services to you.The specific recipients shall be determined based on the service type you select and applicable business scenarios. FuturePay will require service providers processing data on its behalf to adopt appropriate data-protection and security measures; where applicable law requires your consent, we will obtain the required consent before the relevant processing.

3.3Sharing Personal Data with KYC/AML Service Providers and Other Financial Institutions.

To comply with AML/KYC obligations, due diligence, compliance and risk‑control requirements, FuturePay engages qualified third‑party identity verification service providers (“Service Providers”) to deliver identity verification and risk‑screening services. We may furnish your identity document materials, imagery and contact information (including personal identifiers such as email addresses) to such Service Providers for the aforesaid purposes.

Services provided by Service Providers include a “reusable identity verification” function, under which verification results you have completed may be reused across institutions so as to spare you from repeated document submissions. You hereby expressly consent that, via the Service Providers’ systems, FuturePay may: (i) transmit your verification materials to another institution with which you intend to conduct business; or (ii) receive your verification materials held by another institution where you have previously completed verification. To enable such function, you consent that Service Providers may search verification records processed on behalf of FuturePay using personal identifiers such as your email address, for the purpose of locating and cross‑referencing your information. Such searches shall be conducted solely for identity verification, anti‑money laundering and compliance risk‑control purposes.

The foregoing arrangement is voluntary. Your refusal to grant such consent shall not affect your access to FuturePay’s products and services; you will only be required to submit verification documents yourself pursuant to standard procedures. You may withdraw your consent at any time via email, and such withdrawal shall take effect prospectively only in respect of subsequent transfers.

Your personal data may be transferred to and processed in jurisdictions outside Hong Kong, including the European Economic Area, the UK and the US. FuturePay has entered into written data‑processing agreements with Service Providers, requiring them and their sub‑processors to implement data‑protection and security measures in compliance with applicable laws.

3.4Disclosure of Personal Data to Regulatory Authorities and Law Enforcement Bodies

Regulatory authorities vested with statutory inspection and supervisory powers may demand access to your data pursuant to their statutory functions and duties; we shall submit your personal particulars to such regulators in accordance with their requirements. Meanwhile, FuturePay may also disclose your personal data externally to fulfil statutory legal obligations, or protect the legitimate rights, interests and property security of FuturePay itself, other organisations and natural persons (for instance, furnishing documents upon requests issued by courts and law enforcement agencies).

3.5Information Disclosure for Rights Protection and Investigation of Unlawful Conduct

FuturePay may, at its reasonable discretion, disclose your personal data where it deems necessary to investigate and suppress illegal activities and fraudulent acts, hold you liable for breaches of Terms of Service and any Policy and impose corresponding sanctions; or retrieve evidence and resolve commercial disputes in litigation or arbitration proceedings involving FuturePay.

3.6Sharing Personal Data with Advertisers and Media Partners

FuturePay may use aggregated and pseudonymised or anonymised data for commercial operations, such as optimising advertising placement strategies and boosting marketing campaign performance. FuturePay shall not share raw identifiable personal data directly with partners unless we have obtained your explicit authorisation. We will only supply aggregated statistical datasets incapable of pinpointing any specific individual, including audience segmentation data for advertising campaigns and advertising conversion performance metrics.

3.7Sharing Personal Data with Website Analytics and Search Engine Service Providers

FuturePay commissions such service providers to analyse user browsing behaviour on our website, with a view to continuously optimising website functions and enhancing your user experience.

3.8Sharing Personal Data with Prospective Acquirers and Investors

In the event of material corporate transactions including the acquisition, takeover or transfer of all or part of our assets, we will duly notify you via email, in-platform messages and other channels of any changes to the ownership and usage rules governing your personal data, as well as all privacy rights you are entitled to in respect of your personal particulars.

3.9Sharing Authorised by You

In certain circumstances, FuturePay may share your personal data with other third parties provided we have obtained your explicit prior consent.

4. Direct Marketing

4.1Subject to applicable law and after giving the required notice and obtaining the required consent, FuturePay may use your name and contact details for direct marketing purposes. Such activities include sending you promotional emails and conducting direct marketing of FuturePay’s products, services or activities.

4.2FuturePay shall only use your personal data for direct marketing, or provide it to a third party for use in direct marketing, after obtaining the prior consent required by applicable law. You reserve the right to withdraw any consent previously granted to FuturePay for using your personal data for direct marketing and disclosing such data to third parties. Following your withdrawal of consent, FuturePay shall cease such use or provision for direct marketing purposes.

4.3If you have previously given consent and wish to withdraw it, or no longer wish to receive promotional communications from FuturePay in any format, you may contact FuturePay via the contact details specified elsewhere in this Policy.

5. Cookies

Cookies are small text files containing limited information that are stored on devices such as your computers, smartphones and tablets when you visit our websites. FuturePay employs tools including cookies, pixel tags and local storage identifiers on our websites and applications to maintain user login status, analyze user behavior, advertising preferences and other data. FuturePay may share such data with analytics and advertising service providers. You may still browse our websites if you configure your web browser to reject cookies. However, if you disable all cookies (including necessary cookies), most website functions will malfunction, and you may be unable to log in and access our services. For detailed information about cookies, please refer to the Cookie Policy.

6. Retention of Personal Data by FuturePay

6.1Your personal data shall be stored on servers operated by third parties located within Singapore. FuturePay will retain your personal data only for the period necessary to fulfil the purposes set out in this Policy, comply with our legal and contractual obligations, and adhere to prevailing industry practices. Upon the expiry of the retention period applicable to a specific category of data, FuturePay shall delete, archive, anonymise or destroy such data in accordance with our internal policies and prescribed procedures.

6.2In accordance with anti-money laundering, counter-terrorist financing and record-keeping laws and regulatory requirements applicable to FuturePay, we are required to retain certain personal data and transaction records from the date on which our business relationship with you terminates or the completion date of a one-off service rendered to you. Such records will generally be kept for five (5) years. Where you personally or the relevant transactions are subject to judicial investigations or litigation proceedings concerning anti-money laundering, counter-terrorist financing or other anomalous transactions, and such investigations or proceedings remain unresolved upon the expiry of the five-year retention period, the relevant personal data shall be retained until all such investigations and litigation matters are fully concluded.

7. Measures Adopted by FuturePay to Safeguard Your Personal Data

7.1FuturePay shall strictly comply with the Ordinance and applicable laws and regulations, respect and protect your personal privacy. Except as provided in this Privacy Policy, the Terms of Service or other FuturePay policies, or as required by the Ordinance and other applicable laws and regulations, FuturePay will not arbitrarily collect, hold, use, disclose or share your personal identity data without your authorisation.

7.2Transmission Security. To protect your data, FuturePay applies end-to-end encryption to personal data obtained through all channels, including:

a.All FuturePay file-upload channels use TLS encryption and file-integrity checks to prevent files from being tampered with;

b.All network communications between you and the FuturePay system use TLS 1.2 or higher encryption protocols, ensuring that data is not intercepted, tampered with or forged in transit;

c.In addition to TLS, sensitive fields (such as bank card numbers and identity document numbers) are protected with RSA/AES envelope encryption to provide end-to-end encryption protection;

d.Data transfers between FuturePay and external verification agencies or partner banks use dedicated lines or encrypted API channels, to ensure the security of inter-institutional data transfers;

e.Biometric data is transmitted to verification service providers using end-to-end encryption. Intermediate nodes cannot decrypt it, and no third-party caching or transit nodes are used during transmission.

7.3Storage Security Measures

7.3.1FuturePay classifies and manages personal information in accordance with ISO 27001/27701 standards and implements a tiered encrypted-storage strategy:

a.Documents such as proof of source of funds are encrypted at file level using AES-256 and stored in a secure document management system;

b.Sensitive information such as your basic account information, identity documents, shareholders’ and directors’ information, and transaction records is encrypted at database-field level using AES-256. Identity documents and document-image information are separately encrypted and stored in a secure storage area, while tax information is physically/logically segregated from general business data;

c.For your biometric data, only irreversible feature vectors are stored; no original facial photographs or videos are retained. Such data is stored in a separate encrypted database and is physically/logically segregated from general business data;

d.FuturePay stores primary account numbers (PANs) for your debit and credit cards through tokenisation or encryption, and only displays the last four digits of card numbers on pages. Following each transaction, information such as CVV/CVC card security codes is destroyed immediately and is not stored. All encryption keys are managed by hardware security modules (HSMs) and are rotated regularly.

7.3.2With respect to all types of transaction records generated on the FuturePay platform, FuturePay uses hash-chain verification and comprehensive audit-log controls to prevent transaction data tampering and ensure that business operations are fully traceable. FuturePay has deployed a real-time off-site disaster-recovery architecture and achieved a data-synchronisation standard of RPO≈0, to ensure the integrity, security and recoverability of stored data.

7.3.3For your personal data, FuturePay has established a comprehensive access-log control mechanism, under which access records are retained and periodically reviewed, and anomalous access activities are promptly recorded.

7.4Access Control and Permission Management

7.4.1FuturePay strictly follows the principle of role-based least-privilege access control (RBAC). Only FuturePay employees who need to know your personal data for business purposes, and third-party service providers processing data on FuturePay’s behalf, may access such data; unauthorised roles have no access or can only view masked versions. For staff accounts, FuturePay implements multi-factor authentication (MFA) and privileged access management (PAM), together with fixed session time-out controls that automatically sign users out when idle time-outs are reached, to mitigate risks of improper use of privileged accounts. In respect of production transaction data, only the relevant payment-gateway system services may access it; manual enquiries require approval and masking. No person may directly view biometric data, which is compared automatically by the system only;

7.4.2FuturePay conducts strict background and qualification checks on employees upon onboarding. All FuturePay employees authorised to access your personal data are required to comply with this Policy and have signed confidentiality agreements; their permissions are revoked immediately upon departure. FuturePay also provides regular employee training to strengthen awareness of privacy compliance;

7.5FuturePay regularly reviews its security measures and, where applicable, undergoes independent audits or assessments, including at least one penetration test annually and re-assessments of data security audits and personal information protection impact assessments (PIAs). FuturePay deploys a web application firewall (WAF) and ensures that it meets compliance requirements such as PCI DSS. Any statements relating to PCI DSS or other security certifications are subject to FuturePay’s then-current valid and verifiable certification or audit documents.

7.6Data Masking and Display Security. When sensitive personal information such as mobile phone numbers, email addresses, identity document numbers and bank card numbers is displayed on the FuturePay platform, FuturePay masks the middle characters of the relevant fields. In non-essential scenarios, payee account numbers and identity document numbers are displayed in truncated form. Dynamic watermarks are applied to sensitive-document viewing pages to mitigate risks of data leakage caused by screenshots or screen captures. Advertising attribution data does not contain users’ real identities and uses only advertising IDs or device pseudonyms.

7.7Physical Environment and Endpoint Security. FuturePay implements tiered access control for data centres and core office areas to prevent unauthorised physical access. FuturePay applies disk encryption to devices and removable media, operates a mobile device management (MDM) framework, and prohibits employees from using personal devices to access work systems, data or networks. Confidential paper records are filed and managed in dedicated cabinets; obsolete materials are centrally shredded and destroyed. FuturePay has established data loss prevention (DLP) measures for real-time monitoring and risk interception of activities such as copying, external transmission, transfer and screen capture of sensitive data.

7.8Where FuturePay processes personal data as a data processor and a data breach occurs, FuturePay will notify the user immediately upon becoming aware of the incident and in any event no later than 72 hours thereafter. Within the scope of FuturePay’s reasonable control, FuturePay will assist customers in fulfilling their obligations relating to the breach, including, without limitation, taking commercially reasonable measures to mitigate its impact and making notifications to the Office of the Privacy Commissioner for Personal Data or other relevant law-enforcement authorities;

7.9You should be aware that no transmission or storage of information can be absolutely secure. FuturePay has made every effort to protect your personal data, but we cannot guarantee 100% security of all data; any data breach not caused by FuturePay’s wilful misconduct or gross negligence is at your own risk. You should therefore keep your login account and password securely concealed and safeguarded and must not, in any form, allow any other person to borrow or take over your account. If you discover a risk that your password has been compromised, you should promptly contact FuturePay through the methods published on the FuturePay website or by calling customer service, so that we can freeze account operation privileges in a timely manner and reduce the risk of others misusing your account for unlawful activities. Only after you submit valid identity documents and relevant supporting materials and FuturePay verifies them without discrepancy may your password be reset and normal account access be restored.

8. Cross-border Transfer and Processing of Personal Data

8.1Given the nature of the cross-border payment services provided by FuturePay, you acknowledge and consent that your personal data may be transferred to third-party service providers located outside Hong Kong. FuturePay undertakes to adopt all reasonable and necessary measures to ensure that any personal data collected, held, stored, used or otherwise processed in jurisdictions outside Hong Kong shall be protected to a standard no less stringent than that stipulated under this Policy and the Ordinance.

8.2When transferring personal data to other countries or regions, FuturePay shall implement all reasonable and necessary steps to comply with applicable laws governing cross-border data transfers. In particular, where the data protection legislation of the receiving jurisdiction affords a lower level of protection than that applicable in your place of residence, FuturePay will take all reasonable and necessary precautions to guarantee the proper handling of your personal data in compliance with this Policy, including but not limited to entering into standard contractual clauses for data transfers with data recipients; transferring data to countries, regions or recipients deemed to provide an adequate level of personal data protection under applicable laws; and adopting other lawful viable transfer mechanisms.

9. Your Rights in Respect of Your Personal Data

9.1Pursuant to the Ordinance, you are entitled to the following rights concerning your personal data:

a.To confirm whether FuturePay holds any of your personal data and obtain access to such data. You may request a copy of the personal data file maintained by FuturePay that relates to you. For compliance with statutory requirements, FuturePay shall exclude certain information upon disclosure, including personal data that can be used to identify third parties, as well as personal data associated with the prevention or detection of criminal offences;FuturePay may refuse, delay or limit provision of certain information to the extent permitted or required by applicable law, including personal data that may identify third parties and personal data relating to the prevention or detection of crime;

b.To require FuturePay to rectify any inaccurate personal data held about you. You may ask us to amend incorrect or outdated information pertaining to yourself. Nevertheless, FuturePay reserves the right to verify the accuracy of any updated information you submit;

c.To withdraw your prior consent granted to FuturePay for the use or disclosure of your personal data for direct marketing purposes;

d.To enquire about FuturePay’s policies and practices regarding personal data.

9.2You may exercise all the aforesaid rights by contacting FuturePay via the contact details specified in this Policy at any time. Under the Ordinance, FuturePay reserves the right to charge a reasonable fee which is directly necessary for processing your personal data access requests.

10. Amendments to this Policy

FuturePay may revise this Policy at any time and shall notify you of such revisions via email or other regular communication channels previously notified to you in advance.

11. Contact Details

Should you have any enquiries, comments or suggestions regarding this Policy, you may contact FuturePay via the channels set out below:

Futurepay Global Limited

Contact Address: Suite 8, Room 1206A, 12/F, Tower 2, Cheung Sha Wan Plaza, 833 Cheung Sha Wan Road, Cheung Sha Wan, Kowloon, Hong Kong

Email Address (Data Protection Officer): [email protected]

12. Language

This Policy is drawn up in English. If there is any discrepancy between the English version and any other language versions of this Privacy Policy, the English version shall prevail in all respects.

Schedule 1 — U.S. Consumer Financial Privacy Notice

1.Federal law gives consumers the right to limit some but not all sharing, and also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. This Schedule forms part of this Privacy Policy and applies only where you are a U.S. consumer who obtains or has obtained a financial product or service from FuturePay primarily for personal, family or household purposes (a “Covered U.S. Consumer Service”). This Schedule does not apply to information about companies or to products or services obtained for business, commercial or agricultural purposes. In the event of any inconsistency between this Schedule and the main body of this Policy, this Schedule controls with respect to a Covered U.S. Consumer Service.

2.This Schedule applies only where you enter into an agreement for a Covered U.S. Consumer Service with Futurepay Global Limited, a United States entity of the FuturePay Group (“FuturePay”).

3.Definition

“Affiliate” means companies related by common ownership or control. They can be financial and nonfinancial companies.

“Nonaffiliate” means companies not related by common ownership or control. They can be financial or nonfinancial companies.

“Joint marketing” means a formal agreement between non-affiliated financial companies that together market financial products or services to you.

4.What information do FuturePay collect?

The FuturePay products and services you use determine the scope of personal information we collect and share; such information may include:

a.Your Social Security number and bank account data

b.Your account balance and payment history

c.Your transaction records

d.Other information disclosed in Section 2 of our Privacy Policy

5.How FuturePay share your personal information?

5.1All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons FuturePay chooses to share; and whether you can limit this sharing.

5.2If you choose to use FuturePay’s issuing services—which are provided by Stripe and Celtic Bank, FuturePay will share your personal information with these entities refer to Clause 5.1 and Section 3 of our Privacy Policy.

6.How does FuturePay protect your personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. For further details, please refer to Section 7 of our Privacy Policy.

7.How does FuturePay collect your personal information?

When you use FuturePay’s platform and services, we collect your information for various purposes, such as when you register for an account or process a transaction; we also collect your personal information from third parties. For further details, please refer to Section 2 of our Privacy Policy.

8.Why can’t I limit all sharing?

Federal law grants you the right to limit the sharing of information only in the following circumstances:

a.sharing for affiliates’ everyday business purposes—information about your creditworthiness;

b.affiliates from using your information to market to you;

c.sharing for nonaffiliates to market to you.

d.State laws may grant you additional rights to restrict the sharing of information.

8.1For California residents: We will limit information sharing with our affiliates in compliance with the requirements set forth under California law.

8.2For Vermont residents: we will not share information about your creditworthiness with our affiliates, other than as permitted by Vermont law, unless you provide your explicit authorization for such disclosures.

9.Contact Details

If you wish to limit our sharing of your information, please contact us at [email protected].

Futurepay Global Limited

Contact Address: 1580 N Logan St Ste 660 #30327, Denver, CO 80203-1994, US