PREAMBLE

DBEX PAY INC. (“DBex Pay Inc.”, “we”, “us” or “Company”) recognizes that its Clients who use dbexpay.co.uk value their privacy.

This Privacy Policy details important information regarding the use and disclosure of Client‘s information collected on dbexpay.co.uk (“the Website”) operated by DBEX PAY INC.

This Privacy Policy describes how DBEX PAY INC. collects, records, holds, stores, uses, discloses, transfers and processes data classified as personal information that DBEX PAY INC. collects from an individual associated with the services available through the Website.

We provide this Privacy Policy to help you make an informed decision about whether to use or continue using DBEX PAY INC. services.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

This Privacy Policy is an initial part of General Terms and Conditions published on the Website.

1 INFORMATION WE COLLECT

1.1 When you create a DBEX PAY INC. account, or otherwise provide DBEX PAY INC. with your personal information through your use of the Website, DBEX PAY INC. collects personal information which may include your:

• Full name;

• Identification number (e.g. passport number, identity card number, etc.) and/or details;

• Company name (if any);

• Home and/or work address;

• Email address;

• Credit card details;

• Bank account details;

• Phone number (mobile and/or fixed line);

• Information about your URL website (if any).

1.2 The full list of required personal information you can find in Know Your Customer Application (Appendix 4 to KYC procedure).

2 CONSENTS FOR COLLECTION, USE AND DISCLOSURE

2.1 Client’s use of the Website and/or registration for DBEX PAY INC. services constitutes your consent to the terms of this Privacy Policy.

2.2 DBEX PAY INC. reserves the right to amend this Privacy Policy at any time with or without notice. When it does, DBEX PAY INC. will also revise the “Date of the last modification” date at the top of this Privacy Policy.

2.3 Company will notify Client by email regarding material changes to this Privacy Policy that will affect information collected from Client in the future. In certain circumstances, however, DBEX PAY INC. may not notify Client, for example, in cases relating to any contravention of the law by Client, collection of debt owed to us or compliance with requests from law enforcement agencies or a court order.

2.4 By continuing to access and use the service on the Website, Client is deemed to have accepted any changes to the provisions of this Privacy Policy.

2.5 If Client provides personal information of any third party to DBEX PAY INC., we assume that you have obtained the required consent from that relevant third party to share and transfer his/her personal information to us.

2.6 Client may withdraw his/her consent under this Privacy Policy at any time by sending an email to compliance@dbexpay.co.uk. Please note that in the event you withdraw your consent, DBEX PAY INC. may suspend its provision of products and/or services to Client.

3 COLLECTIONS OF PERSONAL INFORMATION

3.1 Client use of the Website and/or registration for DBEX PAY INC. services constitutes your consent to the terms of this Privacy Policy.

3.1.1 Opening a DBEX PAY INC. account

By signing up for a DBEX PAY INC. account or use of the DBEX PAY INC. services, Client may be required to enter his/her personal information to store with his/her account.

3.1.2 Use of the DBEX PAY INC. services

If Client uses DBEX PAY INC. services as a guest, he/she may be required to enter his/her personal information for the purposes of fulfilling a transaction.

3.2 DBEX PAY INC. limits its collection of personal information only to information which is necessary for the provision of the DBEX PAY INC. services and the operation of the Website.

3.3 DBEX PAY INC. does not knowingly collect any personal information from any persons under the age of eighteen (18).

4 PURPOSE OF COLLECTION AND USE OF PERSONAL DATA

DBEX PAY INC. reserves the right to collect and use your personal information for the following purposes:

• to comply with any applicable law, regulation, legal process and/or government request, including but not limited to ‘Know Your Customer’ principles, customer due diligence, anti-money laundering and anti-terrorism financing-related purposes;

• market research to understand better your needs in relation to the DBEX PAY INC. services;

• to improve the Website and our products and/or services;

• to fulfill your requests when using our products or services;

• to fulfill transactions with DBEX PAY INC. merchants;

• to communicate with you and other visitors to the Website, to inform you (where necessary) of any upgrades, as well as of other products and services available from DBEX PAY Inc., its affiliates and third parties;

• to allow you to access limited-entry areas of the Website;

• to personalize any of our services and products for you and to deliver targeted advertisements and offers from us and third parties;

• for any billing requirements and to maintain relevant payment records;

• to respond to any claims by third parties or in response to any potential breach of any agreements or policies that govern your use of the Website or any DBEX PAY INC. product or service;

• to protect the rights of DBEX PAY INC. including but not limited to the security or integrity of the Website;

• to identify and resolve any technical problems related to the Website and our products and/or services;

• for our business or operational analysis, marketing and other promotional purposes.

• other purposes required for DBEX PAY INC. services

5 COLLECTION OF OTHER DATA

5.1 DBEX PAY INC. may use cookies, which may track your activity across the Website and record data which includes:

• your computer’s IP address;

• browser type;

• webpages you visited before you came to the Website;

• the pages within the Website which you visited;

• the time spent on those pages, items and information searched for on the Website, access times and dates, and other statistics.

5.2 The data collected may be used by DBEX PAY INC. for the following purposes:

• analysis and evaluation in order to help DBEX PAY INC.to improve the Website, the services and products DBEX PAY INC. provides;

• enabling certain features and functions on the Website, or services, including but not limited to remembering your username, browsing preferences, and other service preferences;

• building up a profile of how you and other users use the Website;

• administering DBEX PAY INC. services to you and to our advertisers;

• establishing usage statistics on the DBEX PAY INC. platform.

• other purposes required for DBEX PAY INC. services

5.3 Most internet browsers provide you the option of turning off the processing of cookies. You may turn off cookies while browsing the Website but this may result in the loss of functionality, restrict your use of the Website and/or delay or affect the way in which it operates.

6 DISCLOSURE, PROCESSING AND RETENTION OF DATA

6.1 DBEX PAY INC. Shall only disclose your information:

• to our employees, independent contractors, subsidiaries, affiliates, consultants, business associates, service providers, suppliers and agents, acting on DBEX PAY INC. behalf for any of the purposes identified under section 4 of this Policy;

• if DBEX PAY INC. has a reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with our rights or property, other users of the Website, products or services, or anyone else that could be harmed by such activities;

• to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.

6.2 Personal information collected from you may also be transferred to a third party in the event:

• DBEX PAY INC. engages its affiliates and/or other third parties to provide certain products and/or services to you on our behalf. In such cases, DBEX PAY INC. will only provide information to such third parties on a ‘need to know’ basis, and DBEX PAY INC. will limit their rights to use and further disclose your personal information as appropriate in the course of their work for DBEX PAY INC.;

• to verify the accuracy of the personal information that has been provided to us;

• to detect, prevent or otherwise address fraud, security or technical issues;

• the business of this Website or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat personal information in accordance with this Privacy Policy; or

• we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.

• other purposes required for DBEX PAY INC. Services

6.3 Where payments to DBEX PAY INC. merchants are made through the Website, DBEX PAY INC. May share personal information, which can include your name, delivery address, and telephone number, for the purposes of enabling the DBEX PAY INC. merchant to fulfil the transaction.

6.4 Information relating to bank accounts and other financial information will never be disclosed to anyone through this Website, unless DBEX PAY INC. Must do so to comply with any applicable law, regulation, legal process and/or government request.

6.5 Where personal information is shared with third parties, DBEX PAY INC. Will exercise all reasonable endeavors to ensure that such third parties keep your personal information secure.

6.6 We may transfer your personal information to countries other than the country in which the data was originally collected. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy and comply with applicable legal requirements providing adequate safeguards for the transfer of your personal information to other countries.

6.7 After your account becomes inactive (that is, if you request to be removed from our database), DBEX PAY INC. Will keep your personal information in its archives for a duration as may be required under any applicable laws or regulations. Your information will be used only as necessary for tax purposes or to prove our compliance with any applicable law.

6.8 The Client is responsible for always maintaining the secrecy of the unique password and account information.

7 ACCESS AND UPDATES TO PERSONAL INFORMATION

7.1 Client has the right to access and review any personal information DBEX PAY INC. has collected and retained from him/her.

7.2 Client is responsible for informing DBEX PAY INC. about changes to his/her personal information from time to time and has the right to request for the amendment of inaccurate or incomplete personal information by submitting a request via email and requests in Personal Cabinet. DBEX PAY INC. will screen and verify all requests before effecting the corrections. Once verified, DBEX PAY INC. will affect the corrections or updates as soon as commercially feasible.

7.3 In order to verify Client’s personal information, DBEX PAY INC. may request Client to provide supporting documentation to corroborate the personal information provided.

7.4 The Client may update or correct his/her personal information and email preferences at any time in Personal Cabinet (“Customer details”).

8 SECURITY SAFEGUARDS

8.1 DBEX PAY INC. protects your personal information by:

• restricting third party access to any personal information;

• maintaining relevant software and technology within the Website and DBEX PAY INC. platform to prevent unauthorized computer access;

• securely destroying your personal information when it is no longer needed for any legal or business purpose.

8.2 DBEX PAY INC. uses SSL (secure socket layer) encryption technology when processing your financial details to keep your personal information safe and secure.

8.3 If Client believes that his/her personal information on the Website has been breached or compromised, please contact DBEX PAY INC. immediately.

8.4 Client’s password is the key to the account. DBEX PAY INC. encourages using unique numbers, letters and special characters. Do not share DBEX PAY INC. password with anyone. If you share your password with others, you will be responsible for all actions taken in the name of your account and you could also be subject to legally binding actions taken on your behalf. If your password has been compromised, or you have grounds to believe it has been compromised, for any reason, you should immediately contact DBEX PAY INC. and change your password.

8.5 Clients are reminded to log off from their account and close the browser when finished using a shared computer.

9 EXTERNAL WEBSITE LINKS

Certain pages of the Website may feature links to external websites owned or operated by third parties. DBEX PAY INC. will not be responsible for the content, information, operation or activities of those websites. DBEX PAY INC. strongly recommends that you cautiously read and understand any third-party websites’ privacy policy before you share your personal information with those websites.

10 CONTACT US

10.1 Visit the Website’s pages for any inquiries related to this Privacy Policy.

10.2 All products and services provided by us are subject to the applicable DBEX PAY INC. General Terms and Conditions found on the Website and governed by the laws of Canada.

10.3 Please contact DBEX PAY INC. with any questions or comments about this Privacy Policy, your personal information, your concern by email: compliance@dbexpay.co.uk.

This Privacy Policy may be revised periodically, and this will be reflected on the webpage of dbexpay.co.uk.