Privacy Policy

Last updated: September 22, 2025

This Privacy Policy describes how Pay Governance LLC (“Pay Governance” or “we” or “us” or “our”) collects, uses, and discloses your Personal Information when you use our website (www.paygovernance.com) or any other websites that link to this Privacy Policy (together the “Websites”), when you interact and communicate with us electronically or offline, when you register for or participate in our events, and when you use our services (altogether, our “Services”).

Before providing any of your Personal Information to us, please review this Privacy Policy carefully. By using our Services, you acknowledge and agree to the collection and use of your Personal Information in accordance with this Privacy Policy.

Please note that most of our clients are businesses, and we may receive and use Personal Information when we provide services to those clients. When this happens, we use your Personal Information pursuant to our contract with our client. That client’s privacy policy applies to your Personal Information, not ours.

Collecting Your Personal Information

“Personal Information” refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. We may collect Personal Information directly from you when you use our Services, as well as automatically through our use of cookies and other data collection technologies on our Websites. We may also collect your Personal Information through third-party sources, such as social media platforms (if you interact with us through your social media account), references you list on applications and forms, and third parties you direct us to collect your Personal Information from. We will treat Personal Information collected from third-party sources in accordance with this Privacy Policy, but we are not responsible or liable for the accuracy of the information provided by third parties or for the third-party policies or practices. The categories ofPersonal Information we collect from you depend on your interactions with us. Generally, we collect the following categories of Personal Information about you:

‍Identifiers, such as your first name, last name, email address, and phone number, and IP address.‍
Protected Characteristics, provided with special protection under applicable law, such as your age, race, citizenship, gender, medical information, and disability information.‍
Commercial information, such as Services you have purchased, obtained, or considered from us.‍
Professional or employment-related information, such as information about your current and former employment, professional degrees and certifications, education background, information about references you list on your application form, certain Identifiers (in order to contact you), and other employment-related information, including your employment goals and objectives.‍
Internet or other electronic network activity information, such as your browser type and version, the pages of our Websites you visit, the time and date of your visit, the time spent on the Websites, unique device identifiers and other diagnostic data.‍
Audio, electronic, visual, and similar information, such as when you participate in a video call, when you visit our facilities, or when you attend our events.‍
Profile Information, such as information about your preferences and characteristics (including inferences drawn from other personal information). We may collect this information in order to understand your preferences and tailor our services and communications to you. In addition, if you visit our premises or attend one of our events, we may collect information to protect the health and safety of you, our personnel, clients, guests, and the general public, such as health and travel information.‍
Any other Personal Information you choose to provide to us.

Using Your Personal Information

We may use your Personal Information for the following business purposes:

To provide and maintain our Services to you
To manage your account with us, including managing your preferences
To communicate with you and respond to your questions and requests
To evaluate your employment application
To provide you with news, special offers and general information about other Services and events which we offer, unless you have opted not to receive such information
To administer and improve our Websites, including measuring Website effectiveness, diagnosing problems, and analyzing Website traffic
To provide you with relevant advertising and marketing materials
To comply with our legal, regulatory, and risk management obligations, including establishing, exercising and/or defending legal claims
For other purposes consistent with the context of the collection of your information, or as otherwise disclosed to you prior to the use of your information

Some of the information we collect may be considered “Sensitive” Personal Information under privacy laws. We use your Sensitive Personal Information only for legitimate business purposes, including to (i) perform services or provide goods reasonably expected by an average person; (ii) detect security incidents; (iii) resist malicious, deceptive, or illegal actions; (iv) ensure the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) perform or provide internal business services; or (vii) to verify or maintain the quality or safety of a service or device.

Cookies and Other Tracking Technologies

Cookies:

We use cookie technology to improve your experience on our Websites and gather data for website statistical reporting and analytics.

A cookie is a small piece of information sent by a website that is saved on your hard disk by your computer’s browser. It holds information a site may need to personalize your experience (i.e.,rotating images on our Website’s home page) and gathers website statistical data, such as which pages are visited, what is downloaded, the Internet provider’s domain name and country that our visitors come from and the addresses of sites visited immediately before and after coming to our Websites.

In particular, we use Google Analytics to analyze our site traffic and use, and to provide certain advertising materials that may be of interest to you. For more information about how Google may use data collected through Google Analytics, please view this link: www.google.com/policies/privacy/partners/.

At this time, we do not use cookies for targeted online advertising.

Do Not Track (“DNT”):

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a "Do Not Track"("DNT”) setting. We do not currently recognize or respond to DNT signals. Please see above for information about our use of cookies.

Disclosing and Sharing of Your Personal Information

We do not sell your Personal Information. However, we may disclose your Personal Information in the following situations and to the following third parties:

‍With Service Providers: We may share your Personal Information with third party companies or individuals that we contract with in order to receive services from them (“Service Providers”). These services may include, among other things, payment processing, maintaining our databases, providing communications materials and assistance, and assisting us in providing our Services to you. Our policy is to require our Service Providers not to use, disclose, or sell your Personal Information for the Service Provider’s own purposes outside of providing us services.
‍In Corporate Transactions: If the Company is involved in a merger, acquisition, asset sale, reorganization, liquidation, or other type of similar corporate transaction, we may transfer or assign your Personal Information aspart of the transaction or sale.
‍With Affiliates: We may share your Personal Information with our affiliates, such as our subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
‍To Fulfill Our Legal Obligations: Under certain circumstances, we may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Additionally, we may disclose your Personal Information in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend our rights or property, prevent or investigate possible wrongdoing in connection with the Services, protect the personal safety of our clients, personnel, or the public, or protect against legal liability.
‍Publicly, or With Your Permission: When you share Personal Information on public forums, such as through events on online, such information may be viewed by other individuals and we cannot control how others may further use or disclose such information. We may otherwise share your Personal Information to other third parties with your permission.

Retention of Your Personal Information

We retain your information as long as reasonably necessary for the respective purpose. In determining the criteria by which to retain or dispose of your information, we consider the type, sensitivity, context, and purpose of collecting the information.

Security of Your Personal Information

The security of your Personal Information is important to us, and we maintain administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of your information in our custody and control. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or guarantee its absolute security.

Notice to California Residents

California residents have certain rights under the California Consumer Privacy Act (“CCPA”) and the California Shine the Light law.

CCPA Disclosures

Within the preceding 12 months, we have collected the categories of Personal Information listed above in the section entitled "Collecting Your Personal Information."
We have collected these categories of Personal Information directly from you, when you use our Services, from third parties, and automatically when you use our Websites for the purposes described in the section entitled "Collecting and Using Your Personal Information."
We have disclosed your Personal Information for business purposes consistent with and to the categories of third parties identified in the section above entitled "Disclosing and Sharing of Your Personal Information."

“Selling” and “Sharing” of Personal Information:

Within the preceding 12 months, we have not“sold” or “shared” your Personal Information, as those terms are defined in the CCPA. As such, we do not knowingly sell or share the Personal Information of minors under 16 as defined in the CCPA.

California's Shine the Light Law

We do not share your Personal Information to third parties for the third parties’ direct marketing purposes.

Your Rights under the CCPA

Depending on where you live, you may have the following rights with respect to your Personal Information, subject to any applicable exemptions:

The Right to Know or Access. You may have the right to request to know: (i) the categories of Personal Information we have collected; (ii) the categories of sources from which we collected your Personal Information; (iii) the purpose for collecting or disclosing your Personal Information; (iv) the categories of third parties with whom we have disclosed your Personal Information; and (vi) the specific pieces of Personal Information we have about you.
The Right to Request Deletion. You also may have the right to request the deletion of your Personal Information that we have about you, subject to certain exceptions.
The Right to Correct Inaccurate Personal Information. You may have the right to request that we correct any inaccurate Personal Information that we may have about you.
The Right to Non-Discrimination. If you choose to exercise any of your rights, we will not discriminate against you in anyway. If you exercise certain rights, however, please understand that you may be unable to use or access certain features of our Services.

Exercising Your CCPA Rights

To the extent any of the above rights are applicable, you may exercise your rights by emailing us at policy@paygovernance.com or calling us at (877) 883-0445.

We will take steps to verify your identity before processing your consumer request. We will not fulfill your request unless you have provided sufficient information for us to verify you are the individual about whom we collected Personal Information. We may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a consumer request. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

We will make our best effort to respond to a verifiable consumer request within forty‑five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. Within ten (10) days of receiving the request, we will confirm receipt and provide information about its verification and processing of the request. We will maintain records of consumer requests made pursuant to the CCPA and similar laws as well as our response to said requests fora period of at least twenty‑four (24) months.

The CCPA and similar laws may give you a right to appeal any denials of your request to exercise your rights. If we deny your request and you would like to submit an appeal, please contact us at policy@paygovernance.com.

Children's Privacy

Our Services are not intended for any person under the age of 16, and we do not have any knowledge of collecting Personal Information from individuals under the age of 16. If you believe a person under16 has provided us with Personal Information, please contact us at policy@paygovernance.com.

Links to Other Websites

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We suggest you review the privacy policy of the third-party site to understand how that third party handles your Personal Information. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to This Privacy Policy

This Privacy Policy is effective as of the“Last Updated” date at the top of this Privacy Policy.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and will endeavor to notify you via other methods if the changes are material.

We will let you know via email and/or a notice on our Websites prior to the change becoming effective and will update the "Last Updated" date at the top of this Privacy Policy.

We suggest that you review this Privacy Policy periodically for any changes.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

•By email: policy@paygovernance.com

• By visiting this page on our website: https://www.paygovernance.com/contact-us

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