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Privacy Policy

Effective date: August 1, 2018. Transcard, LCC and its affiliates (collectively “Transcard”,
“we” and “us”) respect your privacy. We offer products and services to corporate clients
and financial institutions that enable the disbursement of funds.

This Privacy Policy describes the types of Personal Data we collect through our products
and services (“Services”) and via our online presence, which includes, and our Paynuver app for Apple and Android
mobile devices (“Sites”). This policy also describes how we use Personal Data, with
whom we share it, your rights and choices, and how you can contact us about our
privacy practices. This policy does not apply to third-party websites, products, or
services, even if they link to our Services or Sites, and you should consider the privacy
practices of those third parties carefully.

1. Overview

Transcard obtains Personal Data about you from various sources to provide our Services
and to manage our Sites. “You” may be a user of a prepaid product, a user of our
Payment account through our website or app (“User”), or a customer of a client
(“Customer”). If you are a Customer, Transcard will generally not collect your Personal
Data directly from you unless we are contractually or regulatorily required to do so.

2. Personal Data We Collect

a. Personal Data that we collect about you.

Personal Data is any information that relates to an identified or identifiable individual.
The Personal Data that you provide directly to us through our Sites will be apparent
from the context in which you provide the data. In particular:

• When you register for a Paynuver account we may collect your full name, email
address, telephone number, postal address and additional information based upon
your payment preferences, which may include your checking account routing
number, debit card number, prepaid card number, admin number, CVV and / or
social security number.

• When you are a Customer, we may collect your full name, email address and user
credentials originally created by our client.

• When you respond to Transcard emails or surveys, we collect your email address,
name and any other information you choose to include in the body of your email or
responses. If you contact us by phone, we will collect the phone number you use to
call Transcard. If you contact us by phone as a User, we may collect additional
information in order to verify your identity.

• If you are a User, you will provide your contact details, such as name, postal address,
telephone number, and email address. As part of your business relationship with us,
we may also receive financial and personal information about you, such as your date
of birth and government identifiers associated with you and your organization (such
as your social security number, tax number, or Employer Identification Number).

• If you are a Customer, when you make payments or conduct transactions through a
User’s website or application, we will receive your transaction information.
Depending on how the User implements our Services, we may receive this
information directly from you, or from the User or third parties. The information that
we collect will include payment information (such as prepaid or debit card number,
or bank account information), purchase amount, date of purchase, and payment
method. Different payment methods may require the collection of different
categories of information. The User will determine the payment methods that it
enables you to use, and the payment method information that we collect will
depend upon the payment method that you choose to use from the list of available
payment methods that are offered to you by the User.

• When we conduct fraud monitoring, prevention and detection activities, we may also
receive Personal Data about you from our business partners, financial service
providers, identity verification services, and publicly available sources (e.g., name,
address, phone number), as necessary to confirm your identity and prevent fraud.
Our fraud monitoring, detection and prevention services may use technology that
helps us assess the risk associated with an attempted transaction that is enabled on
the User’s website or the application that collects information.

• You may also choose to submit information to us via other methods, including: (i) in
response to marketing or other communications, (ii) through social media or online
forums, (iii) through participation in an offer, program or promotion, (iv) in
connection with an actual or potential business relationship with us, or (v) by giving
us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our Sites.

Our Sites use cookies and other technologies to function effectively. These technologies
record information about your use of our Sites, including:

• Browser and device data, such as IP address, device type, operating system and
Internet browser type, screen resolution, operating system name and version, device
manufacturer and model, language, plug-ins, add-ons and the language version of
the Sites you are visiting;

• Usage data, such as time spent on the Sites, pages visited, links clicked, language
preferences, and the pages that led or referred you to our Sites.

• We use Google Analytics on our Sites to help us analyze Your use of our Sites and
diagnose technical issues.

3. How We Use Personal Data

a. Our products and services. We rely upon a number of legal and regulatory frameworks to ensure that our use of
your Personal Data is compliant with applicable law. We use Personal Data to facilitate
the business relationships we have with our Users, to comply with our financial
regulatory and other legal obligations, and to pursue our legitimate business interests.
We also use Personal Data to complete payment transactions and to provide payment-
related services to our Users.

b. Marketing and events-related communications.
We may send you email marketing communications about Transcard products and
services, invite you to participate in our events or surveys, or otherwise communicate
with you for marketing purposes, provided that we do so in accordance with the
consent requirements that are imposed by applicable law. When we collect your
business contact details through our participation at trade shows or other events, we
may use the information to follow-up with you regarding an event, send you
information that you have requested on our products and services and, with your
permission, include you on our marketing information campaigns.


4. How We Disclose Personal Data.

We share your Personal Data with trusted entities, as outlined below.

a. Transcard. We share Personal Data with other Transcard entities in order to provide
our Services and for internal administration purposes.

b. Service providers. We share Personal Data with a limited number of our service
providers. We have service providers that provide services on our behalf, such as
identity verification services, website hosting, data analysis, information technology and
related infrastructure, customer service, email delivery, and auditing services. These
service providers may need to access Personal Data to perform their services. We
authorize such service providers to use or disclose the Personal Data only as necessary
to perform services on our behalf or comply with legal requirements. We require such
service providers to contractually commit to protect the security and confidentiality of
Personal Data they process on our behalf. Our service providers are predominantly
located in the United States of America.

c. Business partners. We share Personal Data with third party business partners when
this is necessary to provide our Services to our Users. Examples of third parties to whom
we may disclose Personal Data for this purpose are banks and payment method
providers (such as Visa, Mastercard and other payment networks) when we provide
payment processing services, and the professional services firms that we partner with
that utilize our Services.

d. Our Users and third parties authorized by our Users. We share Personal Data with
Users as necessary to maintain a User account and provide the Services. We share data
with parties directly authorized by a User to receive Personal Data. The use of Personal
Data by an authorized third party is subject to the third party’s privacy policy.

e. Corporate transactions. In the event that we enter into, or intend to enter into, a
transaction that alters the structure of our business, such as a reorganization, merger,
sale, joint venture, assignment, transfer, change of control, or other disposition of all or
any portion of our business, assets or stock, we may share Personal Data with third
parties for the purpose of facilitating and completing the transaction.

f. Compliance and harm prevention. We share Personal Data as we believe necessary: (i)
to comply with applicable law, or payment method rules; (ii) to enforce our contractual
rights; (iii) to protect the rights, privacy, safety and property of Transcard, you or
others; and (iv) to respond to requests from courts, law enforcement agencies,
regulatory agencies, and other public and government authorities, which may include
authorities outside your country of residence.

5. Your Rights and Choices.

You have choices regarding our use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us. If you no longer want to
receive marketing-related emails from us, you may opt-out via the unsubscribe link

included in such emails. We will try to comply with your request(s) as soon as
reasonably practicable. Please note that if you opt-out of receiving marketing-related
emails from us, we may still send you important administrative messages that are
required to provide you with our Services.

b. How you can see or change your account Personal Data. If You would like to review,
correct, or update Personal Data that You have previously disclosed to us, You may do
so by signing in to your account or by calling the applicable customer service number
associated with your Service.

c. Your data protection rights. Depending on your location and subject to applicable
law, you may have the following rights with regard to the Personal Data we control
about you:

• The right to request confirmation of whether Transcard processes Personal Data
relating to you, and if so, to request a copy of that Personal Data;

• The right to request that Transcard rectifies or updates your Personal Data that is
inaccurate, incomplete or outdated;

• The right to request that Transcard erase your Personal Data in certain circumstances
provided by law;

• The right to request that Transcard restrict the use of your Personal Data in certain
circumstances, such as while Transcard considers another request that you have
submitted (including a request that Transcard make an update to your Personal
Data); and

• The right to request that we export to another company, where technically feasible,
your Personal Data that we hold in order to provide Services to you. Where the
processing of your Personal Data is based on your previously given consent, you have
the right to withdraw your consent at any time. You may also have the right to object
to the processing of your Personal Data on grounds relating to your particular

d. Although we do our best to honor the privacy preferences of our users, we are
unable to respond to Do Not Track signals set by your browser at this time.

e. Process for exercising data protection rights. In order to exercise your data protection
rights, you may contact Transcard as described in the Contact Us section below. We
take each request seriously. We will comply with your request to the extent required by
applicable law. We will not be able to respond to a request if we no longer hold your
Personal Data. If you feel that you have not received a satisfactory response from us,
you may consult with the data protection authority in your country.

For your protection, we may need to verify your identity before responding to your
request, such as verifying that the email address from which you send the request
matches your email address that we have on file. If we no longer need to process
Personal Data about you in order to provide our Services or our Sites, we will not
maintain, acquire or process additional information in order to identify you for the
purpose of responding to your request. If you are a Customer of a Transcard User,
please direct your requests directly to the User.

6. Security and Retention.

We make reasonable and appropriate efforts to ensure a level of security appropriate
to the risk associated with the processing of Personal Data. We monitor and make
changes to our data security processes as deemed appropriate. We maintain
organizational, technical and administrative measures designed to protect Personal
Data within our organization against unauthorized access, destruction, loss, alteration
or misuse. Unfortunately, no data transmission or storage system can be guaranteed to
be 100% secure. If you have reason to believe that your interaction with us is no longer
secure (for example, if you feel that the security of your account has been
compromised), please contact us immediately.

If you are a Transcard User, we retain your Personal Data as long as we are providing
the Services to you. We retain Personal Data after we cease providing Services to you,
even if you close your Transcard account, to the extent necessary to comply with our
legal and regulatory obligations, and for the purpose of fraud monitoring, detection and
prevention. We also retain Personal Data to comply with our tax, accounting, and
financial reporting obligations, where we are required to retain the data by our
contractual commitments to our financial partners, and where data retention is
mandated by the payment methods that we support. Where we retain data, we do so in
accordance with any limitation periods and records retention obligations that are
imposed by applicable law.

7. Use by Minors.

The Services are not directed to individuals under the age of thirteen (13), and we
request that they not provide Personal Data through the Services.

8. Updates To this Privacy Policy and Notifications.

We may change this Privacy Policy from time to time to reflect new services, changes in
our Personal Data practices or relevant laws. The “Last updated” legend at the top of
this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are
effective when we post the revised Privacy Policy on the Services. We may provide you
with disclosures and alerts regarding the Privacy Policy or Personal Data collected by
posting them on our website and, if you are a User, by contacting you through email
address and/or the physical address listed in your Transcard account.

9. Links To Other Websites.

The Services may provide the ability to connect to other websites. These websites may
operate independently from us and may have their own privacy notices or policies,
which we strongly suggest you review. If any linked website is not owned or controlled
by us, we are not responsible for its content, any use of the website or the privacy
practices of the operator of the website.

If You have any questions or complaints about this Privacy Policy, please contact us:

Email at

Phone at 423-553-5200

Physical mail to:

Transcard, Attn. Compliance, 1010 Market Street, Chattanooga, TN 37402