Privacy Policy

Last updated: September 2023

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, 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.

Collecting and Using 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 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 of Personal 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.

• Commercial information, such as Services you have purchased, obtained or considered from us.

• Professional or employment-related information, such as information relating to the business or organization you represent when you interact with us.

• 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.

• Any other Personal Information you choose to provide to us.

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

• To communicate with you and respond to your questions and requests

• 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

If you are applying for an employment opportunity with us, we may collect the following categories of Personal Information directly from you or from our third-party partners such as our recruiting partners for purposes of assessing your qualifications for recruitment and hiring:

• Identifiers, such as your name, email address, phone number, IP address, or other similar identifiers and contact information.

• Professional or employment-related information, such as your work experience.

• Any other Personal Information you wish to share in your application for employment, which, should you choose, could include your sensitive personal 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 for online advertising purposes.

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/.

Do Not Track (“DNT”):

Some web browsers may allow you to set a “Do Not Track” setting. Our Website does not currently recognize or respond to DNT signals.

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 any purpose other than for providing services to us.

• 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. You acknowledge that such transfers or assignments may occur and are permitted by and subject to this Privacy Policy.

• 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 will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or when we are legally obligated to retain this data for longer time periods.

Security of Your Personal Information

The security of your Personal Information is important to us, and we are committed to protecting the information we collect. We use appropriate, commercially reasonable safeguards to maintain the privacy and security of your Personal Information. 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

In general, within the preceding 12 months:

• We have collected the categories of Personal Information listed above in the section entitled "Collecting and Using 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 the section above entitled "Disclosing and Sharing of Your Personal Information."

• We have not “sold” or “shared” your Personal Information, as those terms are defined in the CCPA.

Your Rights under the CCPA

If you are a resident of California, you have the following rights under CCPA:

• The Right to Know.You have the right to request to know: (i) the categories of Personal Information we have collected; (ii) the sources from which we collected your Personal Information; (iii) the purpose for collecting, sharing, or selling your Personal Information; (iv) the categories of third parties with whom we have disclosed, shared, or sold your Personal Information; and (vi) the specific pieces of Personal Information we have about you.

• The Right to Request Deletion.You also have the right to request the deletion of your Personal Information that we have about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.

• The Right to Correct Inaccurate Personal Information. You 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 any way. 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

If you are a California resident, you can 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 request to know or request to delete. 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 request to know or a request to delete. 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.

California's Shine the Light Law

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

Children's Privacy

Our Services are not intended for any person under the age of 18, and we do not have any knowledge of collecting Personal Information from individuals under the age of 18. In particular, we do not knowingly sell or share the Personal Information of minors under 13 for targeted advertising purposes without the consent from the minor’s parent or guardian. We also do not knowingly sell or share Personal Information of minors between 13 and 16 years old without the minors’ own consent. If you believe a person under 18 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

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