Privacy Policy

EMTECH Solutions Inc. (“EMTECH,” “We,” “Our,” or “Us”) is committed to modernising central banking infrastructure for financial inclusion and resilience. To that end, EMTECH builds easy to deploy, highly secure, cloud-based software for central banks and other regulators to become more innovative, provide financial inclusion and build infrastructure resilience in the era of open banking and digital currency. We are committed to protecting and respecting your privacy. This Privacy Policy has been created in order to demonstrate our firm commitment to your privacy. SCOPE This Privacy Policy applies to personal information processed by us, including on our websites, platforms, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, platforms, and other offerings are collectively called “Services.” An Important Note: This Privacy Policy does not apply to any of the personal information that we process on behalf of regulated entities (“Customers”) through their use of our Services (“Customer Data”). Our Customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our Customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our Customers. PERSONAL INFORMATION EMTECH MAY COLLECT FROM YOU The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. We may collect personal information that you provide to us, including:

• Information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our website, subscribing to our Services, requesting, applying for or entering further services (including, but not limited to, promotion), making an enquiry or reporting a problem. This may include, but is not limited to, information such as your name, address, phone and email address.

• In order to improve our communications with you as well as improve our products and Services, we may ask you to provide us with additional information about you such as your professional interests and your experiences with us as well as more detailed contact preferences. When you provide us with any personal information you consent to us collecting and using that information according to your preferences.

• If you contact us, we may keep a record of that correspondence.

• We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

• Details of transactions you carry out through our Services and of the fulfillment of your orders.

• Details of your visits to our Services and the resources that you access and/or download.

• To register for our Services, we may require you to provide the following categories of personal information: name of account holder, email, address, phone number, financial details (e.g., credit card numbers and billing address via Stripe), and company/workplace details. Your provision of this personal information is always voluntary, but if certain personal information is not provided you may not be able to utilize the Services.

We may collect personal information automatically when you use our Services, including:

Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. - Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

- Operationally Necessary.This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behaviour, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

- Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (e.g., Google Analytics, WordPress and Jetpack) (see Analytics below);

- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

- Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:- Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.

- HOW EMTECH USES YOUR PERSONAL INFORMATION. We use personal information held about you in the following ways:

• To provide you with our Services, including to manage your information and accounts; provide access to certain areas, functionalities, and features of our Services; and answer requests for customer or technical support.

• To ensure that content from our Services is presented in the most effective manner for you.

• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

• To notify you about changes or updates to our Services.

• To carry out our obligations arising from any contracts entered into between you and us.

To pursue our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention.

To allow you to participate in interactive features of our Services, when you choose to do so.

To comply with our legal obligations, including enforcing our agreements and policies.


• We may disclose your personal information to any of our subsidiaries, our parent company and any of our parent company’s other subsidiaries.

• We may disclose your personal information to third parties:

- If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction.

- Providing us with hosting, payment processing, and related services.
- Understanding the use of our Services and making improvements.
- Administering a mailing list for customers that have registered for such list.
- Responding to requests from or providing any necessary notices to you.
- Protecting the security or integrity of our Services.
- Otherwise administering or managing the software for our Services.

• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

• APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in the “Contacting EMTECH” Section below.


• APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in the “Contacting EMTECH” Section below.

• Subject to compliance with legal obligations, as soon as personal information is being processed, you have the following rights:

- Right of access You have the right to obtain (i) confirmation whether we are processing your personal information; (ii) access to or a copy of your personal information.
- Right to rectification You have the right to request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information.
- Right to restriction of processing You have the right to demand a restriction of processing for your personal information. This may result in us being able to longer offer you services. However, if we stop processing the personal information, we may use it again if there are valid grounds under data protection law for us to do so (e.g., to comply with regulatory obligations, to defend against legal claims, to protect another natural or legal persons, or for reasons of important public interest.
- Right to erasure (‘right to be forgotten’) You have the right to have your personal information erased without undue delay. This does not include your personal information that has to be stored due to statutory provisions or in order to assert, execute or defend legal claims. Please note that after deleting the personal information, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
- Right to data portability
You have the right to receive your personal information provided to us in a structured, commonly used and machine-readable format. The relevant subset of personal information is data that you provide to us with your consent or for the purposes of performing our contract with you.
- Right to object You have the right to object at any time, on grounds relating to your particular situation, to processing of your personal information. EMTECH shall no longer process your personal information unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is for the establishment, exercise or defense of legal claims.
- Right to withdraw your consentYou have the right to withdraw your consent under the data protection law at any time. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available.

To conduct our Services, we use third party service providers to provide EMTECH with necessary services. We may transfer your personal information to these service providers for further processing based on your consent with this privacy policy or on the basis of your agreement to use our services. All transfer of data is undertaken by way of secure connections to these service providers. These service providers only receive your personal information that is adequate, relevant and limited to what is necessary in relation to the purposes for which your personal information are processed. These include the following categories of service providers: identification service providers, identity verification providers, monitoring services, server hosting providers, newsletter senders, customer relationship or support services, website hosting services, email sending services, web traffic analysis providers. Additionally, through our services your data may be transferred to third parties so that you may register and maintain an account and/or business relationship with those services. You will be asked to consent to the transfer and continual transfer of your personal information to those individual third-party services upon the first transfer of your personal information. You may revoke your consent to their access to your personal information on our servers at any time. We may however be required to store your personal information on their behalf and send personal information to them again if there is a legal obligation to do so. CHILDREN’S INFORMATION The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described below in the “Contacting EMTECH” Section. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account. LINKS TO OTHER SITES The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. INTERNATIONAL DATA TRANSFERS All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses. For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below in the “Contacting EMTECH” Section. RETENTION OF PERSONAL INFORMATION We retain the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We will not retain your personal information for longer than is necessary for the purpose it was collected. You may cancel your account with EMTECH at any time, in which case we will delete your data once all outstanding transactions are settled and once we confirm there are no legal retention obligations to continue storing the data. Should we have a legal obligation to continue storing your personal information, either on our own behalf, or on behalf of a third party, we will delete the data as soon as that legal obligation ends. In case you provide your consent to process your personal information with EMTECH in order to participate in third party services who have legal obligations to collect and process your personal information to be eligible to participate in those third-party services, then EMTECH is a data processor on behalf of those third parties regarding the personal information processing required for that eligibility. Information on such third parties is provided in our Services or if by contacting us as set forth in the “Contacting EMTECH” Section below. CHANGES TO OUR PRIVACY POLICY We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect. CONTACTING EMTECH EMTECH is the controller of the personal information we process under this Privacy Policy. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: Attn: Legal EMTECH SOLUTIONS, INC 1463 5th Ave New York, NY 10027 United States Comments, suggestions or materials sent or transmitted to EMTECH shall be deemed to be non-confidential.

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