Last Updated: August 14, 2025

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1. Information Collection & Use

We collect personal and non‑personal information necessary to provide and improve our services, comply with legal obligations, and communicate with you. Personal data may include:

Identifiers: name, contact details, government-issued IDs

Financial data: transaction records, account history

Device and usage data: IP address, browser type, referral URLs

Demographic or employment data, as applicable

We collect information directly from you (e.g. applications, forms), automatically (e.g. cookies, server logs), and via third parties (e.g. service providers, identity verification services).

2. How We Use Your Data

We use personal information for:

Processing transactions and providing financing services

Managing your account and supporting customer service

Conducting fraud detection, risk assessment and compliance

Communications regarding updates, changes, marketing opt‑ins (where permitted)

Improving our offerings and website functionality

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3. Information Sharing

We may disclose personal data to:

Affiliates, subsidiaries, or service providers for business operations

Government or law enforcement agencies as required by law

Professional advisors and vendors under confidentiality measures

Successor entities in the event of a merger or acquisition

We do not sell your personal information for marketing purposes.

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4. Data Protection

OWLPAY INC. uses appropriate organizational and technical safeguards — including encrypted systems, secured facilities, access controls, and staff training — to protect your data. However, no system is entirely immune to unauthorized access.

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5. Cookies & Tracking

We use cookies and similar technologies to:

Enhance site performance

Analyze usage and user behavior

Deliver tailored content and services

Most browsers allow you to disable cookies, which may limit certain functionality on our site.

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6. International Transfers

Your data may be transferred, stored, or processed in countries outside your own jurisdiction. Where required, we ensure appropriate safeguards are in place to maintain data protection standards.

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7. Data Retention

We retain personal data only as long as necessary for business, legal, or regulatory purposes. When retention is no longer required, we securely dispose of or anonymize data.

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8. User Rights & Requests

If you reside in certain jurisdictions (e.g. California), you may have rights including access, correction, deletion, and objection to processing. Data collected under financial regulatory regimes (e.g. GLBA) may be exempt from certain deletion requests. To exercise your rights:

Submit a request via our [Data Access Portal] or contact us directly

Provide verification information to confirm your identity or authority

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9. Children’s Privacy

We do not knowingly collect personal data from individuals under 18. If we become aware that such data has been collected, we will take steps to delete it.

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10. Contact Us

For privacy-related inquiries or requests, please contact:

OWLPAY INC.

Privacy Team

info@owl-pay.com

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11. Policy Updates

We may update this policy periodically to reflect changes in operations or legal requirements. The updated version will be identified by a revised “Last Updated” date. Significant changes will be communicated prominently.

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