LAST UPDATED: January 16, 2022 1. Introduction Thank you for choosing to be part of Mercury (“company”, “we”, “us”, or “our”). Mercury is an online platform that offers financial services, it is used by hundreds of thousands of people to save in dollars, send money, make local payments, transfer money in electronic payment processors to a local bank account; among other things, all in quick times and with very low fees. When you sign up with Mercury you will get a dollar-denominated account, which is connected to electronic payment processors and banks in most parts of the world through a peer-to-peer network. Users maintain their balance in dollars and can add or withdraw to and from their account, as well as send and request money nationally and internationally. Here at Mercury, we take privacy very seriously and, through this privacy notice, we are going to explain to you what information we collect, how we use it and what rights you have in relation to it; take some time to read it carefully. If there are any terms in this privacy policy that you do not agree with, or if you have any questions or concerns about our policy or our practices with regards to your personal information, please contact our Privacy Officer at digitalrights@Mercury.io. This privacy policy applies to all information collected through our websites (https://www.Mercury.com/), our mobile applications ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites"). Please note: Acceptance of the Privacy Policy By accessing and using our Services, you accept the terms of this Privacy Policy and consent to the collection, use and disclosure of your personal information as described below. Remember that the refusal to give your personal data may prevent you from using our services. Mercury reserves the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Services before the change takes effect. Summary What information do we collect? How do we use your information? Will your information be shared with anyone? Do we use cookies and other tracking technologies? How do we handle your social logins? Is your information transferred internationally? What is our stance on third-party websites? How long do we keep your information? How do we keep your information safe? Do we collect information from minors? What are your privacy rights? Do we make updates to this policy? How can you contact us about this policy? 2. What information do we collect? 2.1 Personal information (PI) you voluntarily disclose to us. → In Short: We collect the personal information you provide to us such as name, date of birth, full address, contact information, passwords and security data, payment information, and social media login data. We collect personal information that you voluntarily provide to us, both during online and offline activities, such as when registering at the our website or App, expressing an interest in obtaining information about us or our products and services, when participating in activities on the platform (such as posting messages in our online forums or entering competitions, contests or giveaways), events, or otherwise contacting us. The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following: • Name and contact data: when you create an account or use the services of Mercury Services, we, or our providers acting on our behalf, may collect the following types of information to comply with our legal obligations: your name, date of birth, social security number, driver identification number, personal identification number, address, telephone, email, full bank account details and / or credit card numbers that you link to your Mercury account or enter when you use Mercury services, your Country and State. Mercury will use this information to satisfy your requests and provide the corresponding Services. • Credentials: we collect passwords, password hints, and similar security information used for authentication and account access; • Transaction data: Mercury collects transaction details related to your use of its Services, including the type of service requested, the date and time the service was provided, the amount charged and other details related to the transaction. • Social Media login data: we provide you with the option to register using social media account details, like your Facebook, Google or other social media account; if you choose to register in this way, we will collect the Information described in the section called "Social Logins" below. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. 2.2 Information automatically collected → In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites. We automatically collect certain information when you visit, use or navigate the Sites; this information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes. In some cases the collection is done through the use of cookies, pixel tags and similar technologies that create and maintain unique identifiers. For more information about these technologies, you can consult our Cookie Policy. 2.3 Information collected through our App → In Short: We may collect information regarding your geo-location, mobile device, push notifications, and Facebook permissions when you use our apps. Please note: Important information about platform permissions Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that applications cannot access without their consent. And these platforms have different permission systems to obtain your consent. The platform will notify the user of the first time that the Mercury application requests permission to access certain types of data and will allow him to give his consent (or not) to that request. Android devices will notify you of the permissions that the Mercury application searches for before you first use it, and your use of the application constitutes your consent. If you use our App, we may also collect the following information: • Geo-Location information: if you allow the Mercury application to access location services through the permission system used by your mobile operating system ("platform"), we may collect the exact location of your device when the application is running in the foreground or in the background. We can also derive your approximate location from your IP address. • Mobile device access: we may request access or permission to certain features from your mobile device. If you allow the Mercury application to access your device's address book through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Statement or at the time of consent or collection. If you wish to change our access or permissions, you can do it in your device’s settings. • Mobile device data: we may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address. • Communication data: the Services offered by Mercury facilitate communication between verified Members. In connection with the facilitation of this service, Mercury receives communication data, including the date and time of communication and the content of the communication. • Push notifications: we may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. • Registration information: when a client interacts with the Services, we collect server logs, which may include information such as the device's IP address, dates and times of access, the features of the application or pages visited, application crashes and other system activity, the type of browser and the third-party site or service you were using before interacting with our Services. • Facebook permissions: we, by default, access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page. 2.4 Information collected from other Sources → In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources. Mercury may also receive information from other sources and combine it with the information it collects through its Services: for example, when a customer requests services, other members can provide us with a User rating after making a P2P transaction. We may receive data about its customers through third parties: this may include technical data from analytical and advertising partners such as Google, public databases, credit bureaus, identity verification partners, resellers and channel partners, joint marketing partners and social media platforms. Identity verification partners use a combination of government records and public information available about you to verify your identity. This information includes your name, address, job function, public employment profile, credit history, status on the sanctions lists maintained by public authorities and other relevant data. Mercury obtains such information to comply with its legal obligations, such as anti-money laundering laws. 3. How do we use your information? → In Short: in general, we use personal information to create, develop, operate, deliver and improve our services, content and advertising, as well as for loss prevention and fraud prevention purposes. We use personal information collected via our site for a variety of business purposes described below: • With your consent (“Consent”); • Legitimate business interests ("Business Purposes"); • In order to enter into or perform a contract with you ("Contractual"); • For compliance with our legal obligations ("Legal Reasons"). We use the information we collect or receive: • To facilitate account creation and login process, with your Consent. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed "Social Logins" for further information. Moreover, we use your data to verify your identity by comparing your personal information with third-party databases. • To send you marketing and promotional communications, for Business Purposes and/or with your Consent. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below). • To send you administrative information, for Business Purposes, Legal Reasons and/or possibly Contractual reasons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies. • To fulfill and manage your transactions, for Contractual reasons. We may use your information to fulfill and manage your transactions and exchanges made through the Sites. • To post testimonials, with your Consent. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us. • To deliver you targeted advertising, for our Business Purposes and/or with your Consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. • To request feedback, for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Sites. • To protect our Sites, for Business Purposes and/or Legal Reasons. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention) and for complying with our national and international legal obligations. • To enable user-to-user communications, with your consent. We may use your information in order to enable user-to-user communications with each user's consent. • To enforce our terms, conditions and policies, for Business Purposes, Legal Reasons and/or possibly Contractual. • To respond to legal requests and prevent harm, for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. In general, we can use your information to resolve disputes, charge fees and solve problems. • For other Business Purposes: we may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience. We also use the information for quality control and staff training. 4. Will your information be shared with anybody? → In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. We take care of allowing your personal information to be accessed only by those who really need it to perform their tasks and duties, and sharing it with third parties who have a legitimate purpose to access it. Note that Mercury will never sell or rent your personal information. We may share the information we collect about you as described in this Privacy Policy or as described at the time of collection or exchange, including the following: • Identity Verification: we share your information with third-party identity verification services to comply with applicable regulations and to keep track of our users and prevent illegal activities. This allows Mercury to confirm your identity by comparing the information you provide us with public records and other third-party databases. These service providers may create derived data based on your personal information that can be used only in connection with the provision of identity verification and fraud prevention services. Mercury’s ID-Verification partners are: Onfido Limited We share your information with Onfido Limited ("Onfido") to verify your identity and carry out the necessary regulatory controls. Mercury only shares your information with Onfido in accordance with this Privacy Policy. The information shared with Onfido is treated by Onfido in accordance with its Privacy Policy, available at https://onfido.com/us/privacy/ . Kount Inc. We share your information with Kount Inc. ("Kount") to track transactions and detect fraud. Mercury only shares your information with Kount in accordance with this Privacy Policy. The information shared with Kount is treated by Kount in accordance with its Privacy Policy, available at https://www.kount.com/legal/privacy-policy . Go to Section 14 for more information about Mercury’s Verification Process. • Compliance with laws and regulations: we may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). • Vital interests and legal rights: we may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. • Vendors, consultants and other third-party service providers: we may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may also allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time: this information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. • Business transfers: we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. • Third-Party advertisers: we may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you (see our cookie policy for more details). • Affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us. • Business Partners: we may share your information with our business partners to offer you certain products, services or promotions. • We may disclose your personal information for any other purpose with your consent. • Other users and general public: with other members so that they can carry out a requested peer-to-peer transaction. Moreover, when you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Site or App, such personal information may be viewed by all users and may be publicly distributed outside the Site and our App in perpetuity. If you interact with other users of our Sites and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile. 5. Do we use cookies and other tracking technologies? → In Short: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies to access or store information. In particular, Localization Cookies help Mercury to provide a localized experience: we use them to verify if our service is provided in your country and for providing the service in your preferred language. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy. In addition to our own cookies, we may also use various third parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on. Go to Appendix B of our Cookie Policy for the full list of Mercury’s Third Party Services. 6. How do we handle your social logins? → In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you. Our Sites offers you the ability to register and login using your third party social media account details (like your Facebook or Google logins): where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites; please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider, so we recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps. 7. Is your information transferred internationally? → In Short: We may transfer, store, and process your information in countries other than your own. We share information globally, both internally within Mercury and externally with our partners and with those with whom you connect and share worldwide in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside where you live for the purposes described in this policy. Please note that these data transfers are necessary to provide you with our services. We use standard contractual clauses, rely on the European Commission's adequacy decisions on certain countries, as appropriate, and obtain your consent for these data transfers to the United States and other countries. If the country of destination does not have data protection or other laws as comprehensive as those in your country, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law. Below, the tool Mercury is currently using for international data transfer to be lawful: • European Commission's Standard Contractual Clauses: such measures implementing the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws (our Standard Contractual Clauses can be provided upon request). We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request. 8. What is your stance on third-parties websites? → In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites. The Sites may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties: any data collected by third parties is not covered by this privacy policy and we are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions. 9. How long do we keep your information? → In Short: we keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). In general, we keep your personal information for five years from the date you cease to be our client, as required by the BSA/AML laws Mercury must comply with. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible. 10. How do we keep your information safe? → In Short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented security measures to prevent your personal information from accidentally lost, used or accessed in an unauthorized manner, altered or disclosed. Mercury has implemented appropriate technical and organizational security measures designed to protect the security of any personal information processed: we protect your personal information by maintaining physical, electronic and procedural safeguards. We use network safeguards such as firewalls and data encryption and authorize access to personal information only for those who require access to fulfill their work responsibilities. However, please remember that we cannot guarantee that the internet itself is 100% secure; although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment, use a secure password and take personal basic security measures (for example, do not share your account details and passwords with other people and remember that Mercury never asks for your password or other account details via email, text message or similar ways). In addition, we cannot guarantee or guarantee the security or confidentiality of the information you transmit to us or receive from us over the Internet or wireless connection, including email, telephone or SMS, since we have no way to protect that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address or postal address indicated in Section 13. 11. Do we collect information from minors? → In Short: We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age: by using the platform, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us as soon as possible (Section 13 for contact details). 12. What are your privacy rights? → In Short: In some regions, such as the EU, the European Economic Area, many LATAM countries and several US states, you have rights that allow you greater access to and control over your personal information; this means you may review, change, or terminate your account at any time. The digital rights provided by the privacy regulations of reference may include: • The right to request access and obtain a copy of your personal information; • The right to request rectification or erasure; • The right to restrict the processing of your personal information; • If applicable, the right to data portability; • if applicable, the right to object to the processing of your personal information. For any request or information about your digital rights, please see our Digital Rights Policy. 13. Do we make updates to this policy? → In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. Mercury’s Verification Process In order to use Mercury, we need to collect some of your personal information to comply with applicable laws and regulations. There are four levels of identification and/or verification depending on the services and products you may want to access. How can you contact us about this policy? If you have questions or comments about this policy, email our Privacy Officer at digitalrights@Mercury.io or notify us via post mail to: Mercury Inc. 8 The Green, Suite A Dover, DE, 19901 We will reply as soon as possible. Appendix I - Terms and Definitions “Biometric data” means personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data. “Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. “Controller” (or “Data Controller”) is the natural or legal person, public authority, agency or any other body, which alone or jointly with others, determines the purposes and means of the processing of personal data. “Data Subject” an identified or identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Encryption” is the process of encoding data with an algorithm so that it is unintelligible and secure without the key. Used to protect data during transmission or while stored. “Encryption Key” is an alphanumeric series of characters that enables data to be encrypted and decrypted. “International organization” an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries”. “Personal Data” (PD) means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. “Processor” (or Data Processor) is a natural or legal person, public authority, agency or any other body which processes personal data on behalf of a Data Controller. “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. “Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. “Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future. “Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. “Sensitive Data” is the data regarding racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, data concerning a natural person's sex life or sexual orientation, data relating to criminal convictions and offences, or related security measures “Supervisory Authority” (SA) means an independent public authority which is established by the State. “Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.