Regulated Services by Paytrix in the EU

For Paytrix EU, where Paytrix Ireland is a Regulated entity:

Paytrix Ireland Limited, company registration number 13854323 is located at 20 Harcourt Street, Dublin, D02 PF99, Ireland. This Privacy Policy is written as of the 13-05-2022 and defines how we collect and process the data contained in this policy and other data obtained during our due diligence process, for the purposes of compliance and for the performance of our contract.

For the purpose of this Policy Paytrix will be considered as a Data Controller for this purpose.

What Information we will collect:

For most clients, Paytrix will collect:

For Individual clients

• Name
• DOB
• Address
• Phone Number
• Email Address
• Place of Birth
• Passport number or ID number
• Biometric information such as Selphie photos.

For Corporate Clients:

We will connect details on the signers and authorised account contacts, in keeping the Individuals Clients section detailed above, as well as;

• Company Name
• Number
• Address
• Contact Details
• Details of your individual Ultimate Beneficial Owners and Controllers

How We get the information and why we have it:

Paytrix will only hold data for use in processing payment services on the basis of the consent of its service users.

In order to fulfil our contract with you, we will require that data be passed to 3rd parties who will process data on behalf of Paytrix. This will include us passing your name or the name of your company to our banking partners in order to comply with the EU Wire Regulations, passing details to credit agencies to comply with AML legislation and passing details of your trade to regulatory bodies, such as for transaction reporting reasons.

Paytrix may also collect other data from public sources (such as company records) or may purchase other data (such as credit data) in order to help facilitate our contract with you, or to meet our compliance obligations. A full list of where your data may be passed is available on request.

Paytrix will not sell your data to 3rd parties for the purposes of marketing, or share your data with parties for any reason other than for the performance of contract, or compliance with legislative requirements. Paytrix will not intentionally collect any information which is considered sensitive but may discover such information during our conversations with you. Paytrix will take all possible steps to protect this sensitive data.

Your data will be stored securely in the EU and UK. I consent to Paytrix accessing, processing, storing and transferring of my personal data in accordance with the terms of this notice. I consent to the use of my personal data for the provision of marketing by Patrix, to you, the provision of payment services and acknowledge that Paytrix is required by law to retain all data for a period of 5 years from the point at which we cease to trade with you (as required by Anti Money Laundering Legislation).

Where we process data on behalf of your clients, beneficiaries, employees or shareholders (For example, to complete due diligence), you confirm that you have obtained the relevant permissions and consents to do in line with your own GDPR obligations.

In some jurisdictions, we may be required to hold this data for longer periods, in which case we will inform you of this.

Our Legal Basis for processing your data:

Paytrix will only hold data for use in processing payment services on the basis of the consent of its service users

Your data protection rights:

Under data protection law, you have rights including:

• Your right of access

You have the right to ask us for copies of your personal information.

• Your right to rectification

You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances, where this does not conflict with our overriding legal obligations as a regulated firm.

• Your right to restriction of processing

You have the right to ask us to restrict the processing of your personal information in certain circumstances.

• Your right to object to processing

You have the right to object to the processing of your personal information in certain circumstances, where this does not conflict with our overriding legal obligations as a regulated firm.

• Your right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at [insert email address, phone number and or postal address] if you wish to make a request.

How to complain:

If you have any concerns about our use of your personal information, you can make a complaint to us at Paytrix Ireland Limited, 20 Harcourt Street, Dublin, D02 PF99.

You can also complain to the Data Protection Commission if you are unhappy with how we have used your data.

21 Fitzwilliam Square South

Dublin 2

D02 RD28

Ireland

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Sensitive Data — Processing

As a general standard, Paytrix will not attempt to obtain sensitive personal data, even when it is processing data, including all elements of Sensitive Personal Data as defined in Article 9 of the GDPR Legislation.

To enforce this, Paytrix shall:

• Not create any field or location in its CRM in which it is required that we obtain or store Sensitive data.
• Not create any field or location in which it is expected, or that an expectation is made, that we would hold sensitive data, even when such a field is voluntary.
• Will not request, from the controller, any sensitive personal data as part of our application forms or similar.
• Specifically seek to exclude Sensitive Data from its contracts with controllers.
• Review all agreements and process provided by Data controllers to ensure that the data we hold is not Sensitive.

Where exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations such as requests for information from police forces or government agencies) Paytrix may obtain and process this data on a case-by-case basis, with agreement of the DPO.

Paytrix concedes that, despite the controls above, situations may arise in which certain data may become known or available to Paytrix, for example a non-exhaustive list of situations in which this may occur:

• Knowledge of certain client’s weekend activities as part of standard conversation may result in knowledge of their political affiliations.
• A client’s references to a partner, boyfriend/girlfriend may provide hints or information about the individuals sexual orientation.
• A client may have health-related issues which resulted in them being unable to reply to emails, which they may openly disclose to us during calls or emails.

Paytrix acknowledges that such information may be linked to existing email chains which we need to retain, or which are of commercial value such as email chains which include trade confirmations from clients. For this reason, Paytrix will not:

• Utilize this data for marketing purposes
• Share this data with external 3rd parties, except where required to by law
• Store this data in such a way that it is categorizable, searchable or manipulatable and may result in it being easily utilized for purposes other than day to day relationship management. Paytrix will attempt to make this data, and store this data, in an unstructured manner.