This privacy policy ("Policy") informs you of practices when handling your Information through the Services (both as defined below). In this Policy, "Nearpay", "we" or "us" refers to Nearpay Inc., a company registered in Delaware with its registered address located at 251 Little Falls Drive, Wilmington, DE 19808. We are the data controller under the applicable privacy laws.

For this Policy, "Information" means any information relating to an identified or identifiable individual. This includes Information you provide or generate when you use: (a) our apps, including Tonearpay and Twist (each an "App" and collectively the "Apps"); and (b) nearpay.com and any other dedicated Nearpay websites, such as tonearpay.com and twist.com which link to this policy ("Website" and together with the "Apps" the "Services"). When you use the Services, you accept and understand we collect, process, use, and store your Information as described in this Policy. If you do not agree with this Policy, you must not use any of the Services. If you change your mind in the future, you must stop using the Services and you may exercise your rights with your Information as set out in this Policy.

Information we collect

We will collect and use the following Information about you:

• Information you provide to us
• Registration information: for example, when you create an account on the Website, you will be asked to provide your name, job title, email, phone number, VAT ID, and password. For Nearpay Pro, Nearpay Business, or Twist Unlimited customers, which are paid Services, we also collect your billing address, transaction information, tax identification number, Stripe identification number, mobile phone number, and invoice address ("Payment Information").
• Information collected via voluntary activities: for example, when you communicate with us via email or participate in surveys, we ask you to provide your email address and any Information you choose to provide to allow us to assist you. The information we collect from you varies depending on the survey. Still, we typically ask you questions about your interests and habits, your opinion about different products and services, and what you‘d like to be offered in the future. We also collect your ratings, opinions, preferences, questions, pictures, and responses associated with that survey.

• Information we automatically collect or is generated about you when use the Services
• Identifiers include your IP address, device ID, and device information (such as model, brand, and operating system).
• Geolocation information, such as your GPS information when you use the location reminder feature of the Services. Where required, we will obtain your consent before collecting such information.

Cookies: we use cookies and similar technologies ("Cookies") to enhance your experience when using the Services. For more information about our Cookies policy, see below the How We Use Cookies and Similar Technologies section.