Privacy PolicyCariPay Inc./LLC/LTD DBA/Be!

This is the privacy policy of CariPay Inc. registered in Georgetown, Guyana and Companyregistration number 9379 with the registered office at Lot 225, South Road, Lacytown, Georgetown4, Guyana

CariPay Inc. provides an online payment gateway platform via the company Website (the “site”), ourplatform and its related services (collectively, the “Service(s)”). The services are operated by CariPayInc.(the “company”, “we”, “us”, “CariPay Inc./LLC/LTD DBA/Be!”) for users of the Service(“you”).

The fundamental principles of CariPay Inc. regarding privacy:

• We don’t ask you for personal information unless absolutely necessary.
• We don’t store personal information unless required for the on- going operation of one of our services.
• We don’t share your personal information with anyone except to comply with the law.
• We aim to make it as simple as possible for you to control what information you share with us.

CariPay Inc. adheres to the General Data Protection Regulation (Regulation (EU) 2016/679).Below is our privacy policy which incorporates these principles. If you have questions about theprivacy policy, please contact us at support@hellobe.com

This privacy policy applies to the legal representatives and ultimate beneficial owners of all past,present and prospective merchants (webshops/(online) retailers) and other commercial contractingparties such as independent sales agents, anyone involved in any transaction with our platform,including non- CariPay Inc. customers such as consumers/payees and anyone visiting our Site.

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Non-Personally-identifying Information

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We collect non-personal information − data in a form that does not permit direct association with anyspecific individual. We may collect, use, transfer, and disclose non-personal information for anypurpose. The following are some examples of non-personal information that we collect:

We may collect information such as language, location, browser type, referral source, length of visitand the time zone where CariPay Inc. services are used or accessed.

We also may collect information regarding customer activities on our website, through our paymentgateway and from our other products and services.

This information is aggregated and used to provide more useful products to our customers by helpingus understand which parts of our website, devices, and services are of most interest. CariPay Inc. mayalso display this information publicly or provide it to others. However, CariPay Inc. does not disclosepersonally-identifying information.

If you send us a support request (for example via a support email or via one of our feedbackmechanisms), we reserve the right to publish the non- personally identifiable parts of it in order tohelp us clarify or respond to your request or to help us support other users.

If we combine non-personal information with personal information the combined information will betreated as personal information for as long as it remains combined.

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Personally-identifying Information

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CariPay Inc. also collects personally-identifying information – data in a form that permits directassociation with any specific individual. This type of information is required to perform paymentprocessing services and helps us provide better support for all of our users. We have two types ofpersonally-identifying information:

• Information you provide us: This is the information you provide us when you use ourservices, make a transaction via our platform, and when you communicate with us throughemail, our site, portal, telephone or any other electronic means.
• Information we get from your use of our product: We use various technologies to collect andstore information when you use a CariPay Inc. product or service, and this may includesending one or more cookies or anonymous identifiers to your device. Such information mayinclude you or your customer’s personal and non-personal data:
• Name including first name and family name
• Contact information (email, phone, billing address, shipping address etc.)
• Card Payment Details (Card number, Card holder name, Card Expiry date, CVC details)
• Bank and/or issuer details
• Transaction related information such as items purchased, the value, the time.
• Information regarding the incoming requests to our platform such as user-agent, origin, IPaddress etc

We strictly do not store any sensitive data relating to your health, ethnicity, religious or politicalbeliefs.

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Lawful Basis

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Legal Basis Personal Information of Merchant’s Customers and Website Vis. The informationwe collect in relation to the Services is information necessary in order to perform the contract that isbetween you and the merchant (for the purchase of goods/services) if you are a merchant’s customeror for the maintenance of our website if you are a visitor. On this basis CariPay Inc. is considered tobe undertaking lawful processing as set forth under applicable data protection laws (the General DataProtection Regulation).

We only process your personal data for legitimate business reasons as specified below:

• Website: to present the website and its contents to you and improve the website
• Services: To provide the Services to merchants and to carry out our obligations arising out ofthe agreements with such merchants and to process and complete purchase requests and othertransactions
• Disputes: To resolve any disputes between merchants and you, such as refund requests orchargebacks
• Risk Management: To manage risk, or to detect, prevent, or remediate fraud or otherpotentially prohibited or illegal activities and to investigate and prevent fraudulenttransactions, unauthorized access to the Service, and other illegal activities
• Customer Support: To allow CariPay Inc. merchants to provide customer service and fulfilltheir obligations to you
• Requests: to comply with legal proceedings and or requests from government/ supervisorybodies and/or payment schemes (SEPA, Visa, Mastercard) – depending upon your chosenpayment method and the governing scheme of such payment method).

Legal Basis Personal Information of Merchants. The information we collect in relation to theServices is information necessary in order to ensure our alliances are able to comply with applicableanti-money laundering regulations and to perform the contract that is between you and us (forpayment processing services). On this basis CariPay Inc. is considered to be undertaking lawfulprocessing as set forth under applicable data protection laws of Guyana in line with the EU theGeneral Data Protection Regulation.

We only process your personal data for legitimate business reasons as specified below:

• Administration: When you open a merchant account with us we are legally obliged to collectpersonal data that verifies your identity and to assess whether we can accept your company asa customer. We need your contact information to be able to contact you.
• Services: To contact you and provide you with information, products or services that yourequest from CariPay Inc. and to send updates, news, promotions and/or newsletters regardingthe Service or to sell the Service
• Feedback: We may store the feedback you provide us about our services or and share thiswithin our team to make improvements to our services or website. We might also store noteson our interactions with us to customize products and services for you.
• Data Security: We are duty bound to safeguard your personal data against threats such asfraud, laundering and other criminal usage of your data. We may use your information toprotect you from fraudulent activities.
• Portal: To provide you access to our portal which will provide access to for instancetransaction reports and refunds processing.
• Reporting: From time to time, we may use your personal information to anticipate andresolve problems with any services provided to you and to comply with legal and/orregulatory requirements and other statutory requirements.
• Risk Management: to manage risk, or to detect, prevent, or remediate fraud or otherpotentially prohibited or illegal activities.
• Illegal Use: to investigate and prevent fraudulent transactions, unauthorized access to theService, and other illegal activities
• Requests: to comply with legal proceedings and or requests from government/ supervisorybodies and/or credit card associations/ payment schemes (American Express, Visa, Mastercardand others you may have chosen to accept) – depending upon the governing scheme of suchpayment method chosen by your customers).
• Alliances: To submit applications or provide information to our alliances as set forth underour agreement with you.

Please note that personal data provided by you is processed and stored only in Guyana. In certaincircumstances your information may be processed outside of Guyana such as when we engage thirdparties based outside of Guyana to assist us with the services that you have requested from us. In suchcircumstances, we will take all steps necessary to ensure that any of your information is adequatelyprotected and processed in accordance with this Privacy Policy. You consent to this transfer andprocessing of your information.

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Cookie Policy

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CariPay Inc. wants to ensure that your visit to our website is as useful and seamless as possible. Tohelp us do this, we use cookies and similar technologies to make our website work well for you.

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What are ‘cookies’?

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Cookies are text files that are stored by the web browser on your computer or mobile device. Theyallow websites to store things like user preferences. You can think of cookies as providing a‘memory’ for the website so that it can recognize you when you come back and respondappropriately.

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What type of cookies do we use?

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The cookies we use fall into 2 main categories. These categories are described below:

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1. Essential cookies

These cookies are necessary to help you access and move around our site and use all its features.Without these cookies, our website would not work properly and you would not be able to use certainfeatures.

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2. Analytics cookies

We use cookies to help us understand how our website is being used and how we can improve yourexperience on it. “Analytics” cookies can provide us with anonymous information to help usunderstand which parts of our website interest our visitors and if they experience any errors. We usethese cookies to test different designs and features for our sites and we also use them to help usmonitor how our visitors reach and use our sites.

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Managing your cookie settings

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You can manage cookies through the settings of your web browser. You can have the browser notifyyou when you receive a new cookie, delete individual cookies or delete all cookies. Please note that,if you choose to delete cookies from our website, your access to some functionality and areas of ourwebsite may be degraded or restricted.

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Protecting Personally-identifying Information

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CariPay Inc. discloses potentially personally-identifying and personally-identifying information tothose of its employees, contractors and affiliated organizations that (i) need to know that informationin order to process it on CariPay Inc. behalf, for example a bank requires your details, and (ii) thathave agreed not to disclose it to others.

CariPay Inc. will not rent or sell potentially personally-identifying and personally-identifyinginformation to anyone.

CariPay Inc. takes all measures reasonably necessary to protect against the unauthorized access, use,alteration or destruction of potentially personally-identifying and personally-identifying information.

All CariPay Inc. employees engaged in the processing of Personal Data are informed of theconfidential nature of the data, have received appropriate training on their responsibilities and haveexecuted written confidentiality agreements.

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Disclosure of Personal Information to Third Parties

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If CariPay Inc., or substantially all of its assets, were acquired, or in the event that CariPay Inc. goesout of business or enters bankruptcy, user information would be one of the assets that is transferred oracquired by a third party. You acknowledge that such transfers may occur and that any acquirerof CariPay Inc. may continue to use your personal information as set forth in this policy.

Other than to its alliances (payment method issuers, acquirers, banks etc), employees, contractors andaffiliated organizations as described above, CariPay Inc. discloses potentially personally-identifyingand personally-identifying information only in response to a subpoena, court order or othergovernmental request, or when CariPay Inc. believes in good faith that disclosure is reasonablynecessary to protect the property or rights of CariPay Inc., third parties or the public at large.

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Third-Party Privacy Policies

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The data shared by CariPay Inc. with third parties is strictly limited to the particular task we need thethird party to perform. CariPay Inc.services may contain links to third-party websites, products, andservices. Our services may also use or offer products or services from third parties − for example, athird-party CariPay Inc. app. Information collected by third parties, which may include such things aslocation data or contact details, is governed by their privacy practices. We encourage you to learnabout the privacy practices of those third parties.

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Updating Your Personal Information

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You can help ensure that your contact information and preferences are accurate, complete, and up todate by logging in to your account. For other personal information, we make good faith efforts toprovide you with access so you can request that we correct the data if it is inaccurate or delete thedata if CariPay Inc. is not required to retain it by law or for legitimate business purposes. We maydecline to process requests that are unreasonably repetitive, require disproportionate technical effort,jeopardize the privacy of others, are extremely impractical, or for which access is not otherwiserequired by local law. Access, correction, or deletion requests can be made throughsupport@hellobe.com

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Your Rights

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We respect your rights as a customer and ensure we uphold all of these while processing yourpersonal data.

• Right to Access Information: You have the right to ask us for all your personal data that wehave stored.
• Right to Rectification: If you find any of your personal data we have stored is incorrect, youhave the right to ask us to rectify it. In case we have shared the relevant data with a thirdparty, we will duly notify the third party.
• Right to object to processing: You have the right to object to CariPay Inc. using your data,including for legitimate business reasons. We will consider your objection and make availablealternative methods for processing wherever possible without unduly burdening you.
• Right to object to automated decisions: Our systems may sometimes make automateddecisions based on your personal information with your consent if this is necessary to fulfilour contract with you. You have the right to object to such automated decisions and ask for anactual person to make the decision.
• Right to Restrict Processing: You have the right to ask us to restrict using your personal dataif you believe that we are processing your data illegally, or if you have objected to ourlegitimate use of your data for fulfilling our business requirements.
• Right to Data Portability: You have the right to ask us to port your personal data to anotherservice provider. This applies to the personal data we process with your consent, on the basisof a contract with you or by automated means.
• Right to Erasure: You have the right to ask us to erase your data if we are no longer in needof the data or you withdraw your consent to our legitimate use for our business requirements.This is also applicable in scenarios where CariPay Inc. is unlawfully processing your dataand/or the Guyanese government requires CariPay Inc. to erase your personal data.
• Right to Complain: You have the right to complain to CariPay Inc if you feel your personaldata is not being treated in the correct manner. You may also contact the data protectionauthority in your country.

In cases where we are unable to process your request, we will let you know within a reasonabletimeframe why we denied it if it is permitted legally. If you want to exercise your rights or submit acomplaint, please contact us at support@hellobe.com

Besides any other remedies given by you under law, you will have the right to redress and to lodge acomplaint with the data protection authorities in Guyana, if you feel that CariPay Inc. processing ofyour personal information infringes applicable data protection laws. Please visit the website of thedata protection authorities in Guyana to obtain more information on how the complaint procedures work.

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Policy Changes

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CariPay Inc. may change its Privacy Policy from time to time to remain compliant with any changesin law or to reflect how we process your personal data. CariPay Inc. encourages visitors andmerchant’s customers to frequently check this page for any changes to its Privacy Policy. Yourcontinued use of CariPay Inc. products and services after any change in this Privacy Policy willconstitute your acceptance of the change

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