Effective Date: June 8th, 2021

Privacy and security are extremely imperative to us at Paypound. This user Privacy Policy (“Policy”) is supposed to assist you (the “end user”) understand how we at Paypound collect, use, and share user information in our possession to operate, advance, progress, and defend our services, and as otherwise outlined during this Policy. Please take some time to read this Policy cautiously.

Please note: this Policy applies to Paypound Ltd. and its subsidiaries, including Paypound LDA. Paypound LDA is the registered company DBA as Paypound (Collectively, “Paypound”, “we”, “our”, and “us”). To determine the relevant Paypound entity that is responsible for processing your information, please see the “Contacting Paypound” section below.

A quick note about Paypound

Paypound believes in unlocking financial freedom for everyone. Our technology provides a simple way for you to attach your checking account and other financial accounts to software applications which will assist you do things like but retirement, accomplish your spending, streamline credit applications, or transfer money. These applications and platforms are built and provided by our business customers and powered by Paypound. By delivering access to high-quality, usable financial account data that we’ve translated and standardized, we enable developers to specialize in building experiences that benefit you.

About this Policy

Our goal with this Policy is to provide a simple and straightforward explanation of what information Paypound collects from and about end users (“End User Information”), and how we use and share that information. We value transparency and need to supply you with a transparent and concise description of how we treat your user Information.

Please note that this Policy only covers the information that Paypound collects, uses, and shares. It does not inform what developers do with any End User data we provide to them (or any other info they may collect about you separately from Paypound). This Policy also doesn’t cover any websites, products, or services provided by others. We reassure you to go through the privacy policies or notices of developers or those third parties for evidence about their practices.

Our Data Practices:

Information We Collect and Categories of Sources

As explained in detail below, Paypound has accumulated identifiers, location data, commercial information, electronic network activity data, professional details, inferences, and other types of End User Information.

Information you provide.

When you connect your financial accounts with a developer application or otherwise connect your financial accounts through Paypound, where applicable, we collect identifiers and login information required by the provider of your account, like your username and password, or a security token. In some cases, we also collect your telephone number , email address, security questions and answers, and one-time password (OTP) to help verify your identity before connecting your financial accounts. When providing this information, you give the developer and Paypound the authority to act on your behalf to access and transmit your End User Information from the relevant bank. You may also provide us with identifiers and other information, including your name, email address, and telephone number , once you contact us or enter any such information on our websites.

Information we collect from your financial accounts.

The info we obtain from the financial product and service providers that preserve your financial accounts varies depending on a number of factors, including the specific Paypound services developers use, also because the information made available by those providers. But, generally , we collect the subsequent sorts of identifiers, commercial information, and other personal information from your financial product and repair providers:

Identifiers and knowledge about the account owner(s), including name, email address, phone number, date of birth, and address information;

Information about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and an outline of the transaction; and

Professional information, including information about your employer, in limited cases where you’ve connected your payroll accounts or provided us together with your pay stub information.

The data collected from your financial accounts includes information from all accounts (e.g., checking, savings, and credit card) accessible through one set of account credentials.

Information we receive from your devices.

When you use your device to attach to our services through a developer’s application, we receive identifiers and network activity information that device, including internet protocol (IP) address, time zone setting and site, device location, hardware model, OS , which features within our services you access, browser data, and other technical information about the device. We also use cookies or similar tracking technologies to gather usage statistics and to assist us provide and improve our services.

Information we receive about you from other sources.

We also receive identifiers and commercial information about you directly from the relevant developer or other third parties, including our service providers, bank partners, and identity verification services. For example, developers may provide information such as your full name, email address, phone number, or information about your financial accounts and account transactions, and our bank partners or service providers may provide information such as the status of a transaction you have initiated.

Inferences we derive from the data we collect.

We may use the information we collect about you to derive inferences. For example, we may infer your location or your annual income based on the information we have collected about you from you or other sources.

How We Use Your Information

We use your End User Information for a number of business and commercial purposes, including to operate, improve, and protect the services we provide, and to develop new services. More specifically, we use your End User Information:

To operate, provide, and maintain our services;

To improve, enhance, modify, add to, and further develop our services;

To protect you, developers, our partners, Paypound, and others from fraud, malicious activity, and other privacy and security-related concerns;

To develop new services;

To provide customer support to you or to developers, including to help respond to your inquiries related to our service or developers’ applications;

To investigate any misuse of our service or developers’ applications, including violations of our Developer Policy, criminal activity, or other unauthorized access to our services;

To comply with contractual and legal obligations under applicable law; and

For other notified purposes with your consent.

Our Lawful Bases for Processing (EU End Users Only)

For individuals in The European Union (EU our legal basis for processing your End User Information will depend on the information concerned and the context in which we collected or processed it. Generally, however, we will normally only collect and process End User Information where:

we need to fulfill our responsibilities and obligations in any contract or agreement with you (for example, to comply with our end user services agreements);

to comply with our legal obligations under applicable law;

the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to safeguard our services; to communicate with you; or to provide or update our services); and you have given your consent to do so.

To the extent we rely on consent to collect and process End User Information, you have the right to withdraw your consent at any time per the instructions provided in this Policy.

How We Share Your Information

We share your End User Information for a number of business purposes:

With the developer of the application, you are using and as directed by that developer (such as with another third party if directed by you);

To enforce any contract with you;

With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or developers;

With your connected financial institution(s) to help establish or maintain a connection you’ve chosen to make;

If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);

In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);

Between and among Paypound and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;

As we believe reasonably appropriate to protect the rights, privacy, safety, or property of you, developers, our partners, Paypound, and others; or

For any other notified purpose with your consent.

We may collect, use, and share End User Information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.

We do not sell or rent personal information that we collect.

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

CATEGORIES OF PERSONAL INFORMATION

CATEGORIES OF PARTIES WITH WHOM PERSONAL INFORMATION MAY BE SHARED

Identifiers

Financial information

Commercial information

Location information

Professional information

Electronic network activity information

Inferences

Developer(s) of application(s) you use, and as directed by the developer

Financial institutions

Providers of payments services

Partners and contractors in connection with the services they perform for us or developers

Professional advisors

Data analytics providers

Cloud storage providers

Software development services providers

Fraud prevention services providers

Identity verification services providers

Paypound group entities

Third parties when compelled by law, such as to law enforcement or other governmental authorities

Our Retention Practices

We retain End User Information for no longer than necessary to fulfill the purposes for which it was collected and used, as described in this Policy, unless a longer retention period is required or permitted under applicable law. As permitted under applicable law, even after you stop using an application or terminate your account with one or more developer, we may still retain your information (for example, if you still have an account with another developer). However, your information will only be processed as required by law or in accordance with this Policy.

Please refer to the “Your Data Protection Rights” section for options that may be available to you, including the right to request deletion of End User Information. You can also contact us about our data retention practices using the contact information below.

Some Final Details…

International Data Transfers

We operate internationally, and as a result, will transfer the information we collect about you across international borders, including from the EEA or UK to the United States, for processing and storage. To the extent that the information we collect about you is transferred from the EEA to territories/countries for which the EU Commission has not made a finding that the legal framework in that territory/country provides adequate protection for individuals’ rights and freedoms for their personal data, we may transfer such data consistent with applicable data protection laws based on prior assessment of the level of data protection afforded in the context of the transfer, including through the use of the EU Commission-approved standard contractual clauses, if necessary in combination with additional safeguards. You can ask for a copy of these standard contractual clauses by contacting as set out below.

Your Data Protection Rights

Under applicable law, and subject to limitations and exceptions provided by law, if you are located in the Eu , and in certain other jurisdictions, you may have certain rights in relation to the End User Information collected about you and how it is used, including the right to:

Access End User Information collected about you;

Request that we rectify or update your End User Information that is inaccurate or incomplete;

Request, under certain circumstances, that we restrict the processing of or erase your End User Information;

Object to our processing of your End User Information under certain conditions provided by law;

Where processing of your End User Information is based on consent, withdraw that consent;

Request that we provide End User Information collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where technically feasible; and

File a complaint regarding our data protection practices with a supervisory authority (if you are in the EU)

Under the California Consumer Privacy Act (“CCPA”), and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights with respect to End User Information we have collected about you that constitutes personal information under the CCPA:

To request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months (including personal information disclosed for business purposes);

To request deletion of your personal information;

To opt-out of any “sales” of your personal information, if a business is selling your information; and

To not be discriminated against for exercising these rights.

To exercise your access or deletion rights, where applicable, you can submit a request using our online form (available here). You can also contact us as described in the “Contacting Paypound” section below to exercise any of your data protection rights, where applicable. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

We will consider all such requests and provide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain information may be exempt from such requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.

Changes To This Policy

We may update or change this Policy from time to time. If we make any updates or changes, we will post the new policy on Paypound’s website at https://paypound.ltd . We will also notify developers of any material changes in accordance with our developer agreements, as they are generally best positioned to notify their end users about such changes to this Policy, as appropriate.

Contacting Paypound

If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at hello@paypound.ltd