Our Values

Trust is the foundation of the Chargezen platform and includes trusting us to do the right thing with your information. Three main values guide us as we develop our products and services. These values should help you better understand how we think about your information and privacy.

Why We Process Your Information

We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process your subscription payments to use the Chargezen platform), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). Laws in the European Economic Area ("EEA") and in the United Kingdom ("UK") call these reasons "legitimate interests." These "legitimate interests" include:

• Preventing risk and fraud
• Answering questions or providing other types of support
• Helping merchants find and use apps through our app store
• Providing and improving our products and services
• Providing reporting and analytics
• Testing out features or additional services
• Assisting with marketing, advertising, or other communications

We only process personal information for these "legitimate interests" after considering the potential risks to your privacy and balancing any risks with certain measures—for example, by providing clear transparency into our privacy practices, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.

We may also process your personal information where you have provided your consent. In particular, where we cannot rely on an alternative legal basis for processing, where you direct us to transfer information to a third party, where we receive your data from a third party is sourced and it already comes with consent or where we are required by law to ask for your consent.

Depending on whether you are a merchant, customer, partner, user or visitor, please refer to our supplemental privacy policies, as relevant, to understand our purposes for processing, categories of recipients and legal basis for processing for each type of personal data.

Your Rights Over Your Information

We believe you should be able to access and control your personal information no matter where you live. Depending on how you use Chargezen, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information. We will not charge you more or provide you with a different level of service if you exercise any of these rights. Please note that a number of these rights apply only in certain circumstances, and all of these rights may be limited by law.

If you buy something from or otherwise provide your information to a Chargezen-powered store and wish to exercise these rights over information about your purchase or interaction, you need to directly contact the merchant you interacted with. We are a processor and process information on their behalf. We will of course help our merchants to fulfill these requests to the extent required by law, such as by giving them the tools to do so and by answering their questions.

If you are a merchant, partner, Shop user, Chargezen employee, website visitor or other individual that Chargezen has a direct relationship with, please submit your data subject request through our online portal. Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond.

If you are not happy with our response to a request, you can contact us to resolve the issue. If you are located in the EEA or UK, you also have the right to lodge a complaint with your local data protection or privacy authority at any time.

Where We Send Your Information

We are a Canadian company, but we work with and process data about individuals across the world. To operate our business, we may send your personal information outside of your state, province, or country, including to the United States. This data may be subject to the laws of the countries where we send it. We take steps to protect your information when we send your information across borders.

Transfers outside of Europe and Switzerland

If you are located in the EEA, the UK, or Switzerland, your personal information is controlled by our Irish affiliate, Chargezen International Ltd. Your information is then sent to other Chargezen locations and to service providers who may be located in other regions, including Canada (where we are based) and the United States. When we send your personal information outside of the EEA, UK or Switzerland, we do so in accordance with applicable law.

If you are in the EEA, the UK, or Switzerland, when we send your personal information to Canada it is protected under Canadian law, which the European Commission has found adequately protects your information. If we then send this personal information outside of Canada (for example, when we send this information to our Subprocessors), this information is protected by contractual commitments that are comparable to those provided in the Standard Contractual Clauses.

Finally, while we do what we can to protect your information, we may at times be legally required to disclose your personal information (for example, if we receive a valid court order). For information about how we respond to such orders, please review our Guidelines for Legal Requests.

How Long Do We Retain Your Information

We will retain your personal data only for as long as necessary to fulfill the purposes for which we have collected it. To determine the appropriate retention period, we consider the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our policies. If you stop using our services or if you delete your account with us, we will delete your information or store your information in an aggregated and anonymized format.

Our Use of Machine Learning

One of the ways in which we are able to help merchants using Chargezen is by using techniques like "machine learning" (some laws, including certain EEA and UK laws, may refer to this as "automated decision-making") to help us improve our services. When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don't have legal or similarly significant effects (for example, reordering how apps might appear when you visit the app store).

How We Protect Your Information

Our teams work tirelessly to protect your information, and to ensure the security and integrity of our platform. We also have independent auditors assess the security of our data storage and systems that process financial information. However, we all know that no method of transmission over the Internet, and method of electronic storage, can be 100% secure. This means we cannot guarantee the absolute security of your personal information.

You can find more information about our security measures at /security.

How We Use "Cookies" and Other Tracking Technologies

We use cookies and similar tracking technologies on our website and when providing our services. For more information about how we use these technologies, including a list of other companies that place cookies on our sites, a list of cookies that we place when we power a merchant's store, and an explanation of how you can opt out of certain types of cookies, please see our Cookie Policy.

How You Can Reach Us

If you would like to ask about, make a request relating to, or complain about how we process your personal information, please contact Chargezen Support, or mail us at one of the addresses below.

If you are a merchant, partner, Shop user, Chargezen employee, website visitor or other individual that Chargezen has a direct relationship with and you are located in the EEA or UK, Chargezen International Ltd is the controller of your personal data.

United States Regional Privacy Notice

This United States Regional Privacy Notice ("US Notice") supplements our Privacy Policy and all supplemental privacy policies on www.Chargezen.com (together, the "Chargezen Privacy Policies").

This US Notice is for individuals residing in certain US states and is designed to help you better understand how we collect, use, and disclose your personal information and, depending on how you use Chargezen and where you reside, how to exercise available rights under various applicable privacy laws in the US, specifically the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the "US Privacy Laws").

What Information We Collect and Share About You

To provide our apps and services to you, we must process information about you, including personal information. We do not "sell" your personal information as that term is defined under US Privacy Laws.

Here is a summary of the categories of personal information we may have collected about you over the past 12 months:

Your Rights Over Your Information (US Residents)

Depending on where you live, how you use Chargezen, and subject to certain exceptions, you may have some or all of the following rights:

• Right to Know: The right to request that we disclose to you the personal information we collect, use, or disclose about you.
• Right to Request Correction: The right to request that we correct inaccurate personal information that we maintain about you.
• Right to Request Deletion: The right to request that we delete personal information that we have collected about you.

To exercise your rights, please submit a request through our online portal. We will not discriminate against you for exercising any of these rights.