Privacy Policy

Effective Date: September 5, 2024

This Privacy Policy describes Blaze Payments, Inc., a Delaware corporation, ("Parent") and its subsidiaries and affiliates including, but not limited to, Blaze Payments, SP. Z.O.O., a private limited company based in Poland that is a wholly owned subsidiary of Parent (all individually and collectively referred to as "company", "we", "us", "our", or "Blaze") collection and processing of personal information applicable when any user ("User or Users") uses our websites, computer software applications ("App" or "Apps"), mobile sites, resources, and other products or technology ("Service" or "Services").

We may offer other products or services that are subject to different or additional privacy policies. These will be provided to you where required. If you have a Blaze account through Blaze's technological portal ("Account") or have taken steps to register, please review the Blaze Financial Privacy Policy for information about how we use personal financial information.

By using our Services, you acknowledge you have read this Policy and understand the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of service.

We may make changes to this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or communicating changes to you via email). We encourage you to review the Privacy Policy whenever you access our Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

This Privacy Policy applies only to Blaze Services. We do not control the privacy practices or the content of any of our business partners, advertisers, sponsors, or other third parties we link to from our Services.

Types of Information Collected

Information You Provide to Us

Blaze collects information, including Personal Information, through your interactions with the Services. "Personal information" means information that can reasonably identify an individual, or as otherwise defined by law.

Some Personal Information we collect is defined as "sensitive" or "special category" under data protection laws only where required to provide our Services. We collect consent where required.

By using our Services, you may provide us with certain information related to the following.

Registration and Profile Information

When you sign up, use our community resources, register to use our Services, create a Blaze tag, sign up for notifications or updates, participate in our User research or feedback surveys, or in any other instance where there is a connection to our Services, you may provide us with certain information. This information may include: your name, address, email address, phone number, identity documents (such as a passport or driver's license), address verification documentation, or photographs.

Communications

If you contact us, we may receive additional information about you, such as your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Financial and Payment Information

If you create an Account, make a transaction through our Services, or otherwise use the Services, financial and payment-related information, such as debit or credit card number, bank account numbers, information about income, account balances, financial transaction history including information about the transactions, amounts, type and nature of the transactions, and when the transaction occurred, credit history, tax information, or other financial and account information, is collected by us or our third-party payment processor on our behalf.

Additional Information

We collect Personal Information you choose to provide us.

Information We Collect When You Use Our Services

When you access or use our Services, we automatically collect information about you, including:

Usage Information

We collect information about your use of our Services to help us understand how you use our Services and to help us improve them. We automatically receive information about your interactions with our Services, like the access times, pages or other content you view, transactions you enter into, and other information related to your usage of the services.

Device Information

We receive information about the computer or mobile device and software you use to access our Services, including IP address, location, web browser type, unique device identifiers, operating system version, mobile network information, and mobile advertising identifiers.

Information Collected by Cookies and Other Tracking Technologies

We may collect information using cookies and other tracking technologies, such as web beacons, pixel tags, web storage, and unique advertising identifiers. We use cookies, beacons, invisible tags, and similar technologies (collectively "Cookies") to collect information about your browsing activities and to distinguish you from other Users of our Services. This aids your experience when you use our Services and allows us to improve the functionality of our Services. Cookies can be used for performance management (i.e., collecting information on how our Services are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details.

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services, your experience, and to see which areas and features of our Sites are popular by counting visits. Web beacons or pixel tags may be used on our Sites or emails and help deliver Cookies, count visits, and allow us to determine whether you have performed a specific action.

Please review your web browser's "Help" section to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept Cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

Google Analytics is one of the providers we use to collect personal information. You can learn about how Google collects and processes data at https://policies.google.com/technologies/partner-sites. You can learn about the controls Google offers to manage the collection and use of your information at https://policies.google.com/privacy. We recommend that you review these other entities' privacy policies.

We incorporate "pixels" provided by Meta Platforms, Inc. on our website. This enables us to track User behavior after a User clicks on a Facebook ad and is redirected to our website. For more information, view the Meta Privacy Policy at https://www.facebook.com/privacy/policy/.

Information We Receive from Other Sources

Third Party Collection

We may receive additional information about you, from third parties such as our service providers, vendors, business partners, data or marketing partners and combine it with information we have about you. We may receive information about you from our partners in connection with fraud, identity verification, and other purposes related to legal compliance.

Publically Available Information

We may collect information from publically available sources, such as social media and other websites.

Data from other Users

We may collect information about you from other Users of our Services through referrals or when they otherwise provide it to us.

Use of Information

The Information we collect about you is used to provide, maintain, and improve our Services, such as to administer your use of our Services and to enable you to enjoy and easily navigate the Sites.

We also use the information we collect to:

• Send you technical notices, updates, security alerts, support, and administrative messages, and to respond to your comments, questions and customer service requests;
• Communicate with you about products, services, offers, and events offered by us and others, and provide newsletters, marketing or promotional materials, and information we think will be of interest to you;
• Monitor and analyze trends, usage and activities in connection with our Services;
• Verify your Personal Information to allow access to our products and Services;
• Understand and analyze how you use our Services and develop new products, services, features, and functionality;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Company and others;
• Personalize and improve the Services and provide advertisements, content or features that match your interests;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Ensure compliance, including enforcing our Terms of service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• Carry out any other purpose described to you at the time the information was collected.

We do not sell your Personal Information in the traditional sense. However our use of third party analytics trackers may be considered a "sale" under applicable data protection laws. To exercise your rights related to your Personal Information, visit the "U.S. Privacy Rights" section of this Privacy Policy.

Processing Information for European Users

We will only process information for our Users located in the European Union (EU), European Economic Area (EEA) or the United Kingdom (UK), if we have a valid "Legal Basis", as defined by the GDPR below:

• Consent. User has given explicit consent to the processing of their personal data for one or more specific purposes. Consent must be freely given, specific, informed, and unambiguous. For example, we may process your information to use Cookies where you have consented to such use.
• Performance of a Contract. Processing is necessary for the performance of a contract to which the User is a party, or to take steps at the request of the User prior to entering into a contract. For example, we may need to process your information to respond to your inquiries or requests.
• Legal Obligation. Processing is necessary for compliance with a legal obligation to which we are subject. This includes obligations under EU or Member State law. For example, we may process your information to comply with tax, labor and accounting obligations.
• Legitimate Interests. Processing is necessary for the purposes of our or a third-party's legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the User. Specifically, we have a legitimate interest in using your information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party's legitimate interests to process your information when these interests are not overridden by your rights and interests.

Transfer of Information and Retention Period

Information Blaze collects about you is transferred, processed, and accessed by us in the United States, or another country where we or our service providers operate. Please be aware your information may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live.

If you are located in the European Economic Area ("EEA") or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Policy.

We take measures to delete your information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When we process information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on our Services we provide to you if we delete some information from or about you, and applicable law.

Information Sharing

We do not disclose information we collect from or about you except as described below or otherwise disclosed to you at the time of collection.

• With vendors, business partners, consultants and other service providers who need access to such information to carry out work on our behalf including to facilitate operation, access and use of our Services, provide Services on our behalf, perform Site-related Services (including, but not limited to, data storage, maintenance services, database management, web analytics, customer relationship management vendors, and improvement of the Sites' features) or assist us in analyzing how our Services are used;
• We may engage in advertising activities on other platforms. We may use tracking and interest-based mechanisms on our website and App to improve ad targeting to specific audiences. If you prefer not to receive personalized ads, you can utilize settings provided by your mobile operating system to limit ad tracking, or install the AppChoices mobile app to learn more about opting out of personalized ads in mobile apps. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.
• We use Astra, Inc. to process ACH transactions. By using our App in any way you consent to Astra's Privacy Policy;
• We use Bridge Ventures, Inc. for stablecoin orchestration. By using our App in any way you consent to Bridge's Privacy Policies;
• We use Dlocal Group Limited to process SPEI transactions. By using our App in any way you consent to Dlocal's Privacy Policies;
• We use Shift4 Payments, LLC to process card transactions. By using our App in any way you consent to Shift4's Privacy Policy;
• We use Approvely, Inc. to process card transactions. By using our App in any way you consent to Approvely's Privacy Policy;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our User agreements or policies, or to protect the rights, property and safety of Blaze or others;
• In connection with, or during negotiations of, any merger, sale of our assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Blaze and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
• With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Your Choices

Account Information

If you create an Account with us, you may edit, update or delete your Account by accessing your Account settings in the App or on the website. Please note that we may retain some information to provide you with support, resolve disputes, and comply with our legal obligations. We may also retain cached or archived copies of information about you for a certain period of time. In addition, we will retain any aggregated, de-identified information which cannot reasonably be used to identify you.

Promotional Communications

You can unsubscribe from our promotional emails via the link provided in the emails or by contacting us at support@blaze.money. If you opt out of receiving promotional messages from us, you will continue to receive non-promotional messages, such as those regarding your Account.

Do Not Track Requests

There is no accepted standard on how to respond to Do Not Track signals. We do not support such requests.

Global Privacy Control

You also can use the Global Privacy Control ("GPC") through a supported browser to signal certain of your opt-out preferences. If you use the GPC, we will process your request for your browser, but it will not apply outside of that browser to your device.

U.S. Consumer Privacy Rights

Certain states in the U.S., including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights related to their Personal Information. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances. To the extent that these laws apply, you may exercise the following rights:

• Right to Know and Access Information. Note that much of the information you are entitled to know or access is disclosed in this Privacy Policy. With this said, you have the right to know about our information practices. You also have the right to access the categories of data we collect, with whom we share or sell that information, and, in some cases, what specific Personal Information we associate with you or your Account.
• Right to Data Portability. If you request a copy of your specific information then we will provide it in an easily accessible format.
• Right to Deletion or Erasure. You may request that we delete the information we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your information, even if you validly requested we delete or erase it.
• Right to Correct Information. You may request we correct or rectify inaccurate information we have collected about you.
• Right to Opt out of Targeting Advertising, Sales, or Profiling. You may opt-out of our use of your Personal Information for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Appeal. If we deny your rights request, you have the right to request an appeal of our decision. To initiate an appeal, follow the instructions provided in the communication denying your request, or contact us at the information provided in this Privacy Policy.
• Non-Discrimination. You have the right to not experience discrimination from us for exercising the rights listed in this section. What we mean by discrimination is denying you access to our Services or limiting the quality of our Services. However, limiting use of, or deleting, your Personal Information may restrict the purposes or uses that rely on that information.

Any requests to exercise User rights can be directed to 941-216-7718.

Please include your email address, full name, and your specific information about your request(s) and, if applicable, specifically what information you do not want to receive. If you would like to update or correct your email address, street address, or other information with us, please include specific details about the information you wish to have updated or corrected.

For requests submitted by email, you must provide enough information that allows us to verify your identity. Only you or your authorized agent may make requests regarding your Personal Information. An authorized agent must have documentation that they are authorized to act on your behalf. Blaze will fulfill or reject your request within the amount of time required by law.

We will confirm that we received your request within ten (10) ten days and will respond within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Nevada Privacy Rights

Nevada residents have the right to opt-out of the sale of their Personal Information. Please note we do not "sell" data as defined by Nevada law.

Notice of Financial Incentive

We may offer you certain benefits in connection with the disclosure of Personal Information. For example, we may offer you the opportunity to be eligible for certain perks and benefits, exclusive offers, and discounts. All benefits are free of charge.

When you participate in these perks and benefits, we will collect and keep the Personal Information you provide, or that you've previously provided. To enhance your experience with us and reward you, and to provide you with tailored benefits,

The benefits to you are reasonably related to our good-faith estimate of the value provided to us by the Personal Information received. The value of Personal Information to us varies by individual and is related to the value of the rewards and discounts provided, minus the costs of providing those benefits. You may withdraw from participation from any rewards program at any time by following the instructions provided upon enrollment.

Third Party Links and Products

Our Services will contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them. The privacy policies of our main service providers can be found in our "Information Sharing" section above.

Privacy Rights for European Users

If you are in the European Economic Area (EEA) or the United Kingdom (UK), you may have additional rights as outlined below:

• Access and Control. You can request to access the information we have about you, update any inaccuracies, restrict or object to how your information is processed, have your data anonymized or deleted, or exercise your right to data portability to transfer your information to another company. You also have the right to file a complaint with a supervisory authority in your country of residence, workplace, or where an issue occurred.
• Withdrawal of Consent. You can withdraw any consent you've previously given us regarding your information at any time, free of charge. This change will apply going forward and will not impact the legality of any processing done before your consent was withdrawn.

To exercise these rights, please contact us using the details provided at the end of this Privacy Policy. We may need to verify your identity before processing your request. Note that there are some exceptions and limitations to these rights, and while updates will be reflected in our active User databases promptly, we may retain information for backups, archiving, fraud prevention, analytics, compliance with legal obligations, or other legitimate purposes.

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Contact Information

If you have any questions, comments, or concerns about this Privacy Policy, please email us at support@blaze.money or write to us at 4283 Express Lane, Suite 9583-793, Sarasota, FL 34249.

U.S. Financial Privacy Notice

Who we are

What we do

Definitions

Blaze Payments, Inc. - 4283 Express Lane, Suite 9583-793, Sarasota, FL 34249 US