TASSAT GROUP INC. PRIVACY POLICY

Effective Date: January 2022

Tassat Group Inc. and our subsidiaries (“Tassat,” “we,” “us,” “our”) have created this Privacy Policy because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of Tassat® in connection with your access and use of the Tassat website located at www.tassatpay.com (the “Website”) and our proprietary payments processing platform (the “Platform”) and the services you may access through the Website and Platform

(collectively, “Services”), including, but not limited to, trading and transaction services available to registered users on its Platform, whether accessed through the Website, API, or otherwise.

By visiting our Website, accessing our Platform, and/or registering to use our Services, you are agreeing to the terms of this Privacy Policy, the accompanying Terms of Use, and the Master Subscription Agreement between Tassat and the institution at which you are employed or on whose behalf you will be accessing the Platform or Services (your “Institution”), as applicable, all of which form the “Agreement”. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

If you do not agree to this Privacy Policy, please do not use the Website, Platform and/or Services.

Information We Collect.

In the course of operating the Website and the Platform, and providing the Services, Tassat will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

a.) Contact Information. While it is not necessary to register in order to visit the Website, some of the Services available through the Website and use of the Platform, may require you to be a registered user (“Registered User”). In connection with any registration process, you or your Institution may need to provide certain contact information such as your name, employer, job title, email address, mailing address, and phone number (collectively, “Contact Information”).

Contact Information may be collected for purposes that include administering your access and use of any Services for which you are registered, securely identifying you when you log into a Service, delivering Service-related notifications, providing customer support, and complying with applicable laws and regulations.

b.) Other Information. In addition to the Contact Information, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:

i.              From You. Additional information about yourself that you voluntarily provide to us, such as and mailing list opt-in and opt-out information;

ii.              From Your Activity. Information that we automatically collect when you use the Website and Platform, such as the device from which you access the Website or Platform, your IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website or Platform you visit, and similar information concerning your use of the Website or Platform;

iii.              From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We use cookies to help us collect Other Information and to enhance your experience using the Website and Platform. If you do not want the Website or Platform to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, the Website or Platform may not function properly.

iv.             From Third Party Analytics. We may use one or more third-party analytics services (such as Google Analytics) to evaluate your use of the Website and Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Website or Platform and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Website or Platform, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website or Platform, as the case may be.

Below is a list of analytics providers that we use; however, such list may be subject to change based on how we wish to understand the user experience. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their analytics collection.

For Google Analytics, please visit: https://support.google.com/analytics/answer/6004245?hl=en

How we Use and Share the Information.

 

We use Contact Information and the Other Information (collectively, “Information”) to solicit your feedback, inform you about our products and services, and to provide and improve our Platform, Website and Services. You also authorize us to use and/or share Information as described below.

a.) Parent Companies and Subsidiaries. We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us in connection with product development.

b.) Aggregated Data. In an ongoing effort to better understand our users, our Platform and Website, we might analyze the Information in aggregate form in order to operate, maintain, manage, and improve the Platform and Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.

c.) Service Providers. Tassat may use third parties to provide certain Website and Platform related services, such as maintenance services, hosting services or development services. These other companies will have access to your Information only to the extent necessary for such third party service providers to perform the duties for which it has been retained by Tassat and to the extent permitted by law.

d.) Employers. If you are accessing any Service offered through the Website or Platform as a Registered User of an Institution, Tassat is permitted to provide your Institution with any and all of your Information.

e.) Legal and Contractual Compliance. Tassat may disclose your information to government or law enforcement officials, regulatory agencies or other third parties (such as attorneys or regulatory service providers), as necessary (in our sole discretion) to (i) comply with applicable laws or regulations, (ii) cooperate with governmental or law enforcement investigations, (iii) respond to legal claims or processes, (iv) protect the safety and legal rights of the public or any individual, (v) detect, prevent or remedy any suspected fraud, market manipulation or illegal, tortious or wrongful activity; or (vi) enforce applicable Tassat Terms to which you are bound.

f.) Business Transfers. As we develop our businesses, Tassat may sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

Accessing and Modifying Personal Information and Communication Preferences.

If you are a Registered User of any Services, you may make changes to your personal information, such as updating your user preferences, by logging onto your user account, navigating to the “Support” menu and requesting the Platform administrator to make your

changes. If you are not a Registered User and wish to review, update or correct any of your personal information, or “opt out” from any Website or Platform functionalities, you may contact us at [email protected]. If you are updating or correcting personal information or submitting a request for review of personal information in your capacity as an administrator, on behalf of Registered Users at your Institution, you represent that you have full authorization to provide this information to Tassat. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

Important Notice To Non-U.S. Residents.

The Website, Platform, Services and their servers are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Website, Platform and/or Services, you do so at your own risk.

How We Protect Your Information.

We implement reasonable security measures designed to protect your Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Children.

The Website, Platform and Services are not intended for children under eighteen (18) years of age. Tassat does not market any products or services to children under eighteen (18) years of age or knowingly collect any information from children under eighteen (18) years of age through the Website, Platform or Services. If you are under 18, please do not give us any personal information. We encourage parents and legal guardians to monitor their

children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide us personal information without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

California Residents.

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Tassat may choose to opt out of our sharing their personal information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your personal information to third parties for the direct marketing purposes, please send an e-mail to [email protected].

Nevada Privacy Rights.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at [email protected] with the subject line

“Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

Third Party Websites and External Links. Our Website and Platform may contain links to websites with which we have no affiliation or relationship (“External Links”). Tassat has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any such External Sites. Tassat is not, and will not be, responsible for the privacy practices or security of any such websites, and we urge you to read their privacy policies carefully.

Do Not Track. Tassat does not respond to “Do Not Track” settings or other related mechanisms at this time.

Changes to Our Privacy Policy.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Website and Platform as soon as they go into effect. By accessing the Website, Platform, and/or Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

Contact Us.

If you have questions or comments about our privacy practices, please contact us via email at [email protected].