Privacy Notice

This Privacy Notice describes how Key2Pay and its affiliates collectively “Key2Pay” collect and process your personal information through Key2Pay websites, devices, portal, products, services, online and physical offices, that reference this Privacy Notice.

Key2Pay is committed to safeguarding and processing personal information including sensitive personal information, in line with all applicable privacy and data protection laws. The purpose of this privacy notice is to outline Key2Pay commitment to protect personal information and manage this information with the utmost responsibility and care.

How we collect information

Key2Pay collects information when:

• • You visit our website, platforms, applications, servers and any other electronic means belonging to Key2Pay.

• • You contact us through the website by other direct means of communication such as phone calls, emails or visiting our offices.

• • You interact with us, our services or Key2Pay staff.

• • You establish a business relationship with Key2Pay by entering a contract with us or by giving your express consent.

• • You give us instructions, directions or comments related to your account.

• • You establish any other relationship with us or interact with us or our services.

Information about customers Key2Pay collects

We collect your information with the intention of providing a good service as well as complying with the legal requirements that the law establishes for us. Here is the information we request and collect from you:

1. Business license where applicable according to jurisdiction or activity.
2. Evidence of domain ownership if not visible publicly.
3. Bank account information such as account number, credit card number, bank account details, and bank statements.
4. Tax number or tax identification.
5. Commercial information, such as purchase, activities and content.
6. Processing history.
7. Email, phone, address, fax, or contact Information details of people involved in the negotiation, execution of services as well as.
8. Identification and photographs of persons involved in the negotiation.
9.  IP address, your Key2Pay account log-in information.
10. Location data, such as the location of your device or computer which may, in some cases, constitute precise geolocation information.

At Key2Pay we never receive or ask for information about you from other sources, such as information about you from our service providers or third parties that could be involved in the services delivered.

Purposes of use

We use your personal information to operate, provide, develop, and improve the products and services that we offer our customers. These purposes include:

Primary purposes

• • To provide you with the information, products and Services that you have requested from us.

• • To verify and confirm your identity and financial situation.

• • To carry out any transaction that you are carrying out with us.

• • To collect any outstanding fees or commissions that you may have with us.

• • To operate the servers, platforms, applications in an efficient and operational manner.

• • To provide customer service.

• • To protect the applications, servers, platforms, web pages and any digital resource from any attempt at fraud, illegal operation or risk.

• • To comply with any law, rule, or regulation that is applicable to us.

• • To fulfill any contractual obligation that we have with you.

• • To comply with the requirements requested by the authority or any legal or regulatory obligation.

• • To correct or supplement Key2Pay clients’ compliance with requirements made by the authority.

• • To manage our applications, servers, platforms, web pages and any digital resource and for the administration and internal operations of the business, including technical service, data analysis, testing, research and for fine statistics.

• • To contact you for customer service purposes and any other reason we deem necessary.

• • To inform you of changes to our services, policies or guidelines.

• • To provide and send gifts or benefits, including prizes, established from time to time by the Company.

• • As part of our efforts to keep our site safe and secure.

Secondary purposes:

• • Provide you or third parties with information about products and/or services we offer that are similar to those you already have or about which you have requested information.

• • For marketing, advertising and statistics purposes, whether about new or existing products, our own or those of third parties.

• • To award any prize or benefit that Key2Pay establishes and is accepted by the recipient.

• • To contact you for promotional purposes such as promotions and contests.

• • Carrying out metrics, analysis and statistical and academic studies for which Key2Pay undertakes to ensure that your personal information is completely anonymized.

Sharing information

Key2Pay may share your personal information with third parties including subsidiaries, affiliates, holding companies or other entities belonging to Key2Pay corporate group, consortium or controller located within or outside of Canada provided that the disclosure is legally compliant and in accordance with legal and contractual obligations as well as any regulations or internal policies of Key2Pay.

Key2Pay may be required to disclose your personal information to competent authorities or agencies in Canada or any other jurisdiction to the extent that we are required to do so under applicable law or by court or legal request.

Your personal information may be shared and processed by us and/or other members, affiliates, subsidiaries, controlling companies or other entities belonging to or associated with Key2Pay.

Your personal information may be shared with and processed by us or other members, affiliates, subsidiaries, holding companies or other entities belonging to or associated with Key2Pay located within or outside of Canada, agents, vendors, consultants, suppliers or any third party service providers who provide certain services on behalf of Key2Pay.

Such third party recipients or addressees of the information will have access to it only for the purposes of providing the services or to comply with applicable law and for no other purpose. These third parties are not permitted to use your personal information for their own purposes, they may only process it in accordance with our instructions. At Key2Pay we require and supervise that third parties who have access to your information adopt security measures that are appropriate and comply with this Privacy Policy and applicable legislation.

Additionally, Key2Pay could transfer your personal information to third parties contracted by us specifically for advertising or marketing purposes, in any medium, inside or outside of Canada. If this occurs, we will only share the personal information or information that is strictly necessary for the specific purpose, adopting appropriate security measures such as encryption of information and monitoring of use. Under no circumstances will we disclose sensitive data, trade secrets or confidential information that we hold.

This Privacy Notice is not applicable to third party websites that we do not own or control, or to any third-party website where Key2Pay advertisements are displayed.

Limiting collection, use and disclosure of personal information

• • Key2Pay only collects personal information that relates directly to authorized programs or activities.

• • Wherever possible, personal information is collected directly from the individual to whom the information relates, and individuals are informed of the purpose of the collection at the time of the collection.

• • Key2Pay only uses personal information or discloses it to third parties for the purpose for which the information was originally obtained or compiled, for a use consistent with that purpose or for a purpose permitted under this document.

• • The consent of the individual in question must be obtained before his or her personal information is used or disclosed for any other purpose.

• • Any disclosure to third parties will be done pursuant to agreements setting out the requirements for use, safeguarding, retention and disposal of such information, or as required by law.

Security Measures

At Key2Pay, we are committed to the security of your information, which is why we have a framework of internal policies and procedures designed to ensure compliance with the highest regulatory and security standards.

Key2Pay have implemented appropriate physical, technical and administrative security measures to prevent your information from being accidentally lost, used or accessed without authorization, altered or disclosed. We have taken significant precautions to ensure the security of your data. In addition, we limit access to your personal information only to those employees, agents, contractors and other third parties who have a strict need to know and perform their contractual functions. In such cases, the subjects will only process your personal information on our instructions and are subject to the obligation of confidentiality and the obligation to comply with the data protection procedures described herein. We have prepared procedures to handle any suspected violation of the obligations to protect your personal information and, when we have the legal obligation to do so, we will notify you and any applicable authority of any breach.

These security measures include having an office or physical space locked and monitored 24 hours a day, in addition to having security cameras and monitoring at entrances and exits, staff training on the care and handling of information, garbage disposals, restricting access to programs and files, protection and fire systems.

In addition to the above, these security measures also include:

• • Encryption of data in transit and at rest, ensuring the confidentiality and integrity of the information.

• • Access controls and activity logging, ensuring that only authorized personnel can access the information, with continuous monitoring to detect and prevent suspicious activities.

• • Protection of the perimeter network using firewalls and web application security systems, which help block unauthorized access and attacks.

• • Vulnerability management and threat protection, using tools for incident detection and response, as well as anti-malware systems.

• • Zonal redundancy and immutable backup mechanisms, which allow information to be recovered in the event of any incident, avoiding unauthorized alterations or deletions.

At Key2Pay, we are committed to the security of your information. We have procedures in place to handle any suspected security breach and, if necessary, we will notify both you and the relevant authorities of any incident that may affect the integrity of your personal data.

Your rights

• • Access: To request a copy of the personal information we process in relation to you and to be informed about how we use and share your it.

• • Object: To object to the processing of your personal information if case we

• • we are processing your personal information on the grounds of legitimate interests or for the performance of a task in the public interest; or

• • if we are processing your personal information for direct marketing purposes.

The data owner may at any time state the causes or reasons that lead him to request the cessation of the processing of his personal information.

In such circumstances, Key2Pay must decide on the cessation of the use and processing of the data in accordance with the provisions of the law as well as this notice.

• • Correction: To request that we update the personal information we process in relation to you, or to correct your personal information that you think is incorrect or incomplete. In such circumstances, the holder must detail the modifications that he/she requests to be made to the personal information, as well as provide the documents that support the requested correction.

• • Erasure: To ask that we delete personal information that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.

In such case, you must indicate the reasons that motivate you to request the deletion of your personal information held by Key2Pay.

• • Restriction: To request that we restrict the way in which we process or use your personal information, for example, if you dispute the accuracy of your personal information or have raised an objection which is under consideration.

• • Automated decision making: To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar effect to you and to know who we use your personal information in automated decisions.

You may exercise your rights at any time by emailing privacy@key2pay.io or using the details set out in the contacting us section. They will not be an appropriate fee or charge in connection with you exercising your rights.

Key2Pay may need to request specific information from you to help us confirm your identity and ensure your right to access to the personal information requested, or to exercise any of your other rights. This is to ensure that personal information is not disclosed to any person who does not have authority to receive It. Key2pay may also request further information in relation to your request to help us to locate the personal information processed in relation to you, including, for example, the nature and location of your relationship with us.

Key2Pay have the compromise to respond to all legitimate requests in line with the timescales set out in applicable law.

Key2Pay guaranty that you will not be disadvantaged in any way by exercising your rights in relation to the processing of your personal information.

Contacting us

 If you wish to exercise any of your rights, or have questions concerning this notice, please contact us

Address: 22420 Dewdney Trunk Road suite 300a Maple Ridge bc v2x 3j5 Canada

Mail: privacy@key2pay.io

Changes to this Privacy Notice

We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through the means of communication and contact provided to Key2Pay having as effective communication or an appropriate channel, depending on how we normally communicate with you.

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