YPOP Inc. (“Axepay” “we”, “us” or “our”) understands that privacy is important to our customers including our YPOP Merchants, Registered Users, YPOP Users and our online visitors (collectively our “Customers”). We respect your privacy and we will continually work to protect the privacy of our Customers who access the YPOP Platform and the YPOP Services through any computer, mobile phone, tablets, laptops, web or mobile application or any other wireless devices/technology or access device. This Privacy Policy (together with our Website Terms and the YPOP Terms and Conditions of Service and any other documents referred to in either) sets out the basis on which any personal information and data we collect about you, that you provide to us, and that is provided to us by third parties will be processed by us.

As an organization engaged in commercial activities, we are committed to complying with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), and with any other Canadian and provincial privacy laws applicable to our operations.

Please read carefully the following Privacy Policy, which explains how we collect, use, and process the Personal Information (defined below) that we collect about you. By registering as an Axepay merchant (“YPOP Merchant”), registering for an YPOP Account (“Axepay Registered User”) or visiting and/or using any of the following (“Axepay User”): the YPOP'swebsite, www.axepay.com, (our “Website”), Axepay’s Platform (“YPOP'sPlatform”), YPOP'sApp (our “App”), and other online products and services (YPOP Platform, Website, App and other online products and services collectively referred to as the “Axepay Services”), you agree, that you have read and understand this Privacy Policy and accept and consent to the collection, use and disclosure of your Personal Information in accordance with the terms and conditions and practices described in this Privacy Policy. In most cases, we will ask you to provide explicit consent (through agreeing to a revised version of this Privacy Policy) if we intend to collect, use or disclose your Personal Information otherwise than as indicated in this Privacy Policy, however, sometimes your consent may be implied through your conduct with us.

This Privacy Policy is incorporated within both the YPOP Website Terms and the YPOP Terms and Conditions of Service. All capitalized terms not defined herein will have the definition provided for in the Website Terms or YPOP Terms and Conditions of Service.

Your use of the YPOP Services and any dispute over privacy, is subject to this Policy and any of the applicable Terms and Conditions for use of the YPOP Services, including the limitations on damages and the resolution of disputes. Please note that regardless of the applicable law set forth in the Terms and Conditions for use of the YPOP Services, any disputes arising under this Privacy Policy will be interpreted in accordance with the Governing Law provision set out below.

If you do not agree with this Privacy Policy, delete all cookies from your browser cache after visiting our Website and do not visit or use the YPOP Services. Your continued use of the Axepay Services signifies your acceptance of this Privacy Policy.

We may periodically post changes to this Privacy Policy and it is your responsibility to review this Privacy Policy on a regular basis.

Please note you must be at least eighteen (18) years old, or of the applicable age of majority in the country of your residence, to use the YPOP Services.

Personal Information

The term “Personal Information”, as used in this Policy, refers to any information that can be used to identify a specific person, or any anonymous information (for example, IP Address) that is linked to a specific person. Personal information does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. Personal Information also does not include business information including but limited to a business address, business title, professional designation(s) or business telephone number.

WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT?

We collect information in the following ways:

• When you provide it directly to us.
• from third party service providers used to obtain verification information about you or your company, to verify your identity, and prevent fraudulent activity.
• from other YPOP Customers for the purpose of providing the Axepay Services to you.
• automatically as you use the YPOP Services either directly or through a third party.
• passively through technology such as “cookies” or web server logs.

The types of information we collect about you depends on whether you are an YPOP Merchant, YPOP Registered User, or YPOP User as well as your particular interaction with the Axepay Services.

When you register for the YPOP Services as an YPOP Merchant or YPOP Registered User, we collect information to establish and maintain your YPOP Account and when you provide information as part of our identity or account verification process the information we may collect, where permitted by applicable law:

• Contact information such as your name, date of birth, residential and mailing address, phone, email, passport, driver’s license, taxpayer identification and other similar information
• Financial information such as your bank account or the bank account of your business and routing numbers, credit card and/or debit card numbers that you link to your YPOP Account or input when you use the YPOP Services.
• We may require you to provide additional information which we may use together with third party service providers acting on our behalf for identity verification purposes, and to verify your address or to manage risk. This information may include your taxpayer or government identification number, images of your government-issued photo identification, passport, national ID card, residence verification information, such as utility bill details and other similar personal information. We may also obtain information about you from third parties such as credit bureaus and identity verification services
• Information about your business including the goods and services you sell
• You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook and Twitter or similar social media sites in your country of residence). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third party with your YPOP Account or the Services you authorize us to have access to this information and you agree that YPOP may collect, store and use this information in accordance with this Privacy Policy
• Calls, emails and other correspondence
• Any additional information you may disclose to our customer support team
• Any other information that you choose to provide to us.

When you use the YPOP Services, we collect information you upload or send through the YPOP Services including:

• When you use the YPOP Services to make, accept, request or record payments or transfers, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions
• We may continuously collect information about your computer, mobile device, or other access device for fraud prevention purposes, to monitor for possible breach of your YPOP Account, and to identify any malicious software or other activity that may harm YPOP or any of its Customers
• When you complete a transaction with the YPOP Services you may need to enter certain information about yourself. This information may include your full name, address, date of birth, and details about the payment method you are using
• Information about your business including the goods and services you sell
• Information about your business including the goods and services you sell
• Information you provide to an YPOP Merchant using the Axepay Services. For example, YPOP Merchants may send to us any information you have provided them, including your personal details (e.g., name, contact information) and details regarding your past and current purchases and activity on their website or online platform. Additionally, we may receive information about you from the provider of the payment method you use through the Axepay Services to the extent such information is necessary to process your transaction, or if it later becomes necessary during an investigation into fraudulent or otherwise suspicious transactions
• We also collect your IP address and your geolocation information in order to show you offers available in your location, and send you reminders about the YPOP Services
• We collect information through Cookies and other tracking technologies when you use the YPOP Services which is sent to us through your computer, mobile phone, tablets, laptops, web or mobile application or any other wireless devices/technology or access device. This is more particularly described in the section below entitled “Cookies and other Tracking Technologies”
• Calls, emails and other correspondence
• We may also collect additional information you may disclose to our customer support team
• any other information YPOP may need to perform or improve the YPOP Services or to help any third parties perform their services in connection with the YPOP Services
• Any other information that you choose to provide to us.

We also collect information when it is provided to us by third party service providers in connection with your registration or use of the YPOP Services including:

• Information we receive about you from banking references, credit reporting agencies, and other third parties such as entities that assist us in validating your identity, among others. We may combine this with other information that we collect about you
• By applying or signing up for an YPOP Account, you authorize and consent to our obtaining from, and disclosing to, third parties, from time to time, any information about you in connection with the processing of any credit investigation, identity or account verification, fraud detection, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship
• When you use the YPOP Services or use third party services which use the YPOP API, we collect information sent to us through your computer, mobile phone, tablets, laptops, web or mobile application or any other wireless devices/technology or access device. This is more particularly described in the section below entitled “Cookies and other Tracking Technologies”

USE OF INFORMATION, SHARING AND DISCLOSURE OF PERSONAL INFORMATION

We may use Personal Information to provide you with a secure, smooth, efficient, and customized experience. We may use your Personal Information to:

• Provide YPOP Services and processing or record payment transactions or transfers and provide customer support you request
• Process transactions, display historical transaction information and send notices about your transactions
• To verify your identity or verify it with third parties
• Resolve disputes, collect fees, and troubleshoot problems
• Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted YPOP Terms and Conditions of Service
• Customize, measure, and improve YPOP Services and the content and layout of the YPOP Platform, Website, App and applications
• Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences
• We may email you marketing communications regarding products and services from time to time. We will only use your email address for these purposes with your consent. Should you wish to withdraw your consent for email communications, please contact us or click the unsubscribe button at the bottom of the email communication.
• Complying with the legal obligations, requirements or arrangements for disclosing personal information that apply to us or that we are expected to comply according to:
  1. Any law binding or applying to us existing currently and in the future including all applicable anti-money laundering laws, anti-terrorist financing laws
  2. Any guidelines or guidance given or issued by any legal, regulatory, government, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers existing currently and in the future
  3. Any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on us by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations.

We may share personal information as follows:

• With YPOP Merchants who use the YPOP Services so they can facilitate merchant payments and confirm the identification of the purchaser. These merchants may be outside of Canada and are only given the information they need to perform their specific functions. We do not authorize YPOP Merchants to use your personal information for their own purposes. In addition to the disclosures reasonably necessary for the purposes identified above, we may disclose your personal information to the extent that it is permitted or required to do so by law. Please note that Axepay Merchants you interact with may have their own privacy policies, and YPOP is not responsible for their operations, including, but not limited to, their information practices
• With any agent, contractor or Third-Party Service Providers under contract who help with parts of our business operations such as fraud prevention, marketing, technology services, administrative, foreign exchange, payment or other services to us in connection with the operation of the YPOP Services
• With financial institutions, payment networks, payment card associations, and other entities in connection with the payment or money transfer process
• With our Third-Party Service Providers when they need it to process a transaction you initiated. We have contracts with banks, other third party financial institutions and third party payment processors for every payment method we offer on our service. When you authorize a transaction, we will transmit to the relevant Third Party Service Provider any information they require to process this transaction. What information is required will vary by payment type, but may include your name, address, and details of the purchase you are attempting to make
• With our Third-Party Service Providers for inclusion on their blacklists or lists of terminated merchants and to help us engage in our fraud reduction efforts
• With our Third-Party Service Providers for inclusion on their blacklists or lists of terminated merchants and to help us engage in our fraud reduction efforts
• With fraud prevention and detection service providers for the purpose of detecting and preventing fraudulent activity. Such service providers may keep records of information provided and use it when providing fraud detection and prevention services to other users of their databases
• Local or foreign legal, regulatory, government, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, provided that:
  1. we are compelled to do so by subpoena, court order or other legal process
  2. we must do so to comply with local or foreign laws, statutes, rules or regulations, including debit and credit card rules or in compliance of any guidelines or guidance given or issued by any legal, regulatory, government, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers which we are expected to comply
  3. we are compelled to do so pursuant to any of our contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside Canada and may be existing currently and in the future
  4. we believe in good faith that the disclosure is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Axepay Terms and Conditions of Service
  5. other third parties with your consent or direction to do so
  6. any other person under a duty of confidentiality to us including any of our affiliated companies which has undertaken to keep such information confidential
• In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar events, any information in our possession may be transferred to our successor or assign.

Failure to provide the requested personal information may result in us being unable to comply with our regulatory and statutory duties, obligations, functions and requirements and the requests, requirements, directions and orders from the financial regulators.

We will not sell or otherwise share your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize YPOP Services, content and advertising.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We and our third-party service providers use cookies and other tracking mechanisms (including tracking technologies designed for mobile applications) to track information about your use of the YPOP Services. The cookies and other tracking mechanisms will collect and store non-personally-identifiable information from the Axepay Services and we may collect and store information locally on your computer, mobile phone, tablets, laptops or any other wireless devices/technology or access device (“Access Devices”). YPOP may combine this information with other personal information we collect from you and our third-party service providers may also do so on our behalf.

When you access any of the YPOP Services we may place small data files called cookies or pixel tags on your Access Devices. Cookies are small text files that are placed on your Access Devices by websites that you visit and are a feature of web browser software that allows us to recognize the Access Device used to access a website and to provide information such as the usage of the Axepay Services in order to improve them.

We also may collect information using web beacons. Web beacons are electronic images that may be used in the Axepay Services. We may use web beacons to deliver cookies, track the number of visits to our website, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.

Cookies store information accessed through your browser to streamline activities on related websites, and make the online experience easier and more personalized. Information gathered automatically through cookies and other tracking technologies such as web-server log files and web beacons may include computer or mobile device information, including IP address, operating system, browser type, device name and type, operating system, location data and certain characteristics of, and performance data about your device, mobile network information such as your carrier/operating system including device and connection type, and standard web log information such as your browser type, traffic to and from the YPOP Services and the pages you accessed on the YPOP Services and interaction with other retail technology such as use of NFC Tags, QR Codes or use of vouchers.

We use cookies and other tracking technology data to measure web traffic and usage activity on the YPOP Services for purposes of improving and enhancing the functionality of the Axepay Services, to look for possible fraudulent activity, and to better understand the sources of traffic and transactions. Cookies also allow our servers to remember your account information for future visits and to provide personalized and streamlined information. Log files are used to monitor, measure, analyze, improve, and troubleshoot the Axepay Services. You can choose to disable cookies but this may limit your ability to use the YPOP Services.

We also use Local Shared Objects, commonly referred to as "Flash cookies," to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud and to support the YPOP Services.

In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technology to identify the fact that you have used the YPOP Services, and we may provide that information to one or more third party advertising networks. Web beacons are electronic images that may be used in the YPOP Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. This anonymous statistical information about how you use the YPOP Services and the location from which you access the YPOP Services may include the time, date and length of your visit to the YPOP Services, pages viewed, links clicked and other non-personally identifying information. Those advertising networks may recognize the web beacon or cookie associated with your visit to or use of the YPOP Services or when you visit other websites on which they serve advertising, and they may make decisions about the advertisements you see based on it.

Although you may have Do Not Track enabled in your browser, we may still set cookies to reduce fraud and help you use the YPOP Services.

CHOICE AND DATA RETENTION

We are required to collect certain Personal Information to confirm your identity and comply with our legal and regulatory obligations. If you elect to not provide Personal Information in optional fields it may limit your ability to use the YPOP Services. You can update your YPOP Account information by logging into your YPOP Account and making a request to update your Personal Information.

We may occasionally email/ SMS you with information about offers or new services. You can opt out of these email/SMS communications by replying with unsubscribe in the subject line, or via an unsubscribe link included in such communications. If you do not want us to use your details for us to market to you, and/or to pass your details on to third parties for marketing purposes, please contact us through the phone number or email address listed below. You will also be able to unsubscribe from any marketing emails and SMS messages sent to you by YPOP using a link provided in the email or the SMS message. However, you will continue to receive certain email and/or SMS communications related to your YPOP Account including information regarding transactions and your relationship with YPOP.

If you wish to opt out of having cookies set on your browser (as described above), the only way to ensure that this happens is to manage the settings on your web browser to delete all cookies and disallow further acceptance of cookies. For more information, refer to your browser's technical information. You may also consider visiting aboutcookies.org, which provides helpful information about cookies. Note that disabling cookies on your browser prevents YPOP from tracking your activities in relation to the YPOP Services. However, it may also disable many of the features available through the YPOP Services. We therefore recommend that you leave cookies enabled.

HOW TO ACCESS AND CHANGE YOUR PERSONAL INFORMATION

You can review and edit your Personal Information at any time by logging into your YPOP Account and making a request. If you close your YPOP Account, we will mark your YPOP Account in our database as "Closed," but will keep your account information in our database for a period of time described above. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your YPOP Account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law or in accordance with this Privacy Policy.

DEACTIVATING YOUR ACCOUNT

If you wish to deactivate your YPOP Account, you may do so by logging into your YPOP Account and making the request. However, even after you deactivate your YPOP Account, we may retain archived copies of information about you and any transactions or Axepay Services in which you may have participated for a period of time that is consistent with applicable law, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with the YPOP Services, to assist with investigations, to enforce the YPOP Terms and Conditions of Service or other applicable agreements or policies, or to take any other actions consistent with applicable law.

PROTECTION AND STORAGE OF PERSONAL INFORMATION

Throughout this Policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.

We have a variety of obligations to retain the data that you provide us, both to ensure that transactions can be appropriately processed, settled, refunded or charged back, to identify fraud, and also to comply with laws applicable to us and to regulatory authorities, and for our Third-Party Service Providers including our banking providers and payment processors. Even if you close your Axepay Account we will retain certain information as necessary to meet our legal and regulatory obligations.

We store and process your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, on our computers in our data center where YPOP facilities or our Third-Party Service Providers are located, and we protect it by maintaining technical, physical, and administrative safeguards in compliance with applicable laws. We may store your Personal Information in locations outside the direct control of Axepay, for instance, on servers or databases co-located with hosting providers.

We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Full debit and credit card data is securely transferred and hosted off-site by a payment supplier in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to YPOP employees.

We take reasonable measures including technical, physical and administrative safeguards to protect the personal information in our custody against loss, theft, unauthorized access or use, modification and disclosure. We store all the personal information you provide us on secure servers.

YPOP is not able to guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

UPDATES TO THE PRIVACY POLICY

This Privacy Policy may be revised, modified, and/or updated at any time, without prior notice, at the sole discretion of YPOP. We will provide you with alerts regarding this Privacy Policy by posting them on our Website and we will make the amended Privacy Policy available on our Website. Such notices in relation to this Privacy Policy shall be considered to be received by you within twenty-four (24) hours of the time it is posted to our Website. Please review this Privacy Policy periodically to check for updates. If any changes are material and/or retroactive, we may provide an opportunity to “opt-in,” as appropriate under the circumstances.

CONTACT US

If you have any questions or suggestions about this Privacy Policy or any of our privacy-related practices, please contact us at:
Axepay Inc.
privacy@ypop.com

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