1. Introduction

1.1 Our Commitment to Privacy

Network Pay LLC ("Network Pay," "we," "us," "our") respects your privacy and is committed to protecting your personal information.

This Privacy Policy describes:

• What information we collect about you
• How we use your information
• When and with whom we share your information
• How we protect your information
• Your rights and choices regarding your information
• How to contact us with privacy questions

1.2 Scope

This Privacy Policy applies to:

• Our website and mobile applications
• Payment collection services provided by Network Pay LLC as an authorized agent of payee
• Connected checkout services
• All related services and communications

1.3 Our Role

Network Pay LLC operates as an authorized agent of payee, collecting fiat currency payments on behalf of sellers (Principals) pursuant to written agency agreements. We collect and process your personal information solely in connection with processing your payment transactions and complying with applicable laws.

1.4 Acceptance

By using our services, making a payment, or providing us with your information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

1.5 Changes to this Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending notice to your registered email address (if we have it)
• Displaying a notice on our Platform

Your continued use of our services after changes become effective constitutes your acceptance of the updated Privacy Policy.

2. Information We Collect

2.1 Information You Provide to Us

We collect information you provide when making a payment, including:

2.1.1 Payment Information

• Full name (as it appears on your payment method)
• Billing address
• Email address
• Phone number (if provided)
• Payment method details:
• Credit/debit card number, expiration date, CVV (tokenized — we do not store full card numbers)
• Bank account and routing numbers (for ACH payments)
• Wire transfer details

2.1.2 Transaction Information

• Transaction amount and currency
• Date and time of transaction
• Products/services purchased (as provided by the Principal)
• Principal (seller) identity
• Order reference numbers

2.1.3 Communication Information

• Emails, messages, or inquiries you send to our support team
• Dispute or chargeback documentation you provide
• Feedback and survey responses

2.2 Information Collected Automatically

When you interact with our Platform, we automatically collect:

2.2.1 Device and Browser Information

• Device type and model
• Operating system and version
• Browser type and version
• Screen resolution
• Language preferences

2.2.2 Network Information

• IP address
• Internet service provider
• Approximate geographic location (city/region level, derived from IP)

2.2.3 Usage Information

• Pages viewed and features used
• Checkout flow interactions
• Transaction history
• Error logs

2.2.4 Cookies and Tracking Technologies

• Session cookies (essential for checkout functionality)
• Security cookies (fraud prevention)
• Analytics cookies (to improve our services, with your consent)

For details on cookies, see Section 7 below.

2.3 Information from Third Parties

We may receive information about you from:

2.3.1 Payment Partners

• Card networks (Visa, Mastercard, etc.): Authorization responses, chargeback notifications
• Payment processors: Transaction processing data
• Banking partners: ACH and wire transfer confirmations

2.3.2 Principals (Sellers)

• Order details and fulfillment information relevant to your transaction
• Customer support correspondence forwarded for payment-related issues

2.3.3 Fraud Prevention Services

• Device reputation scores
• Fraud risk assessments
• Watchlist and sanctions screening results

3. How We Use Your Information

3.1 Payment Processing

We use your information to:

• Process and complete your payment transaction
• Authorize payments through card networks and banking partners
• Generate transaction confirmations and receipts
• Coordinate settlement with Principals

3.2 Fraud Prevention and Security

We use your information to:

• Detect, prevent, and investigate fraud and unauthorized transactions
• Verify your identity and payment authorization
• Screen transactions against sanctions and watchlists
• Monitor for suspicious activity patterns
• Protect the security of our Platform and systems

3.3 Legal and Regulatory Compliance

We use your information to:

• Comply with applicable laws and regulations
• Respond to legal process (subpoenas, court orders)
• Cooperate with law enforcement and regulatory authorities
• Maintain records as required by law
• Support chargeback and dispute resolution processes

3.4 Customer Support

We use your information to:

• Respond to your inquiries and support requests
• Resolve billing disputes and chargebacks
• Coordinate with Principals on refund requests
• Communicate important service updates

3.5 Service Improvement

We use aggregated and anonymized information to:

• Analyze transaction patterns and service performance
• Improve our checkout experience and payment processing
• Develop new features and services
• Conduct internal research and analytics

4. How We Share Your Information

4.1 With Principals (Sellers)

We share transaction details with the Principal on whose behalf we collected your payment, including:

• Your name and billing information
• Transaction amount and payment status
• Order reference information

This sharing is necessary for the Principal to fulfill your order and provide customer support.

4.2 With Payment Partners

We share payment information with our processing partners to complete your transaction:

• Card networks (Visa, Mastercard, etc.): Card details for authorization
• Payment processors: Transaction data for processing
• Banking partners: Account details for ACH and wire transfers
• 3D Secure providers: Cardholder verification data

4.3 With Fraud Prevention Services

We share information with fraud prevention services to protect you and our platform:

• Device and browser fingerprints
• Transaction patterns
• IP addresses and geolocation data

4.4 With Affiliated Entities

We may share information with our affiliated entity (Network Clearing LLC) for:

• Coordinated service delivery (e.g., when a Principal uses both Network Pay and Network Clearing)
• Consolidated compliance and risk management
• Customer support coordination

4.5 With Law Enforcement and Regulators

We may disclose your information when required by:

• Applicable law or regulation
• Court order, subpoena, or legal process
• Law enforcement requests
• Regulatory examination or inquiry

4.6 With Service Providers

We share information with service providers who assist in our operations:

• Cloud hosting and infrastructure providers
• Customer support tools
• Analytics services (using anonymized data)
• Security and monitoring services

All service providers are bound by contractual obligations to protect your information and use it only for the purposes we specify.

4.7 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such transfer and any changes to this Privacy Policy.

4.8 With Your Consent

We may share your information with other parties when you have given us explicit consent to do so.

5. How We Protect Your Information

5.1 Technical Safeguards

• Encryption: All data is encrypted in transit (TLS 1.2+) and at rest
• Tokenization: Card numbers are replaced with tokens — we do not store full card numbers
• PCI-DSS Compliance: We maintain compliance with Payment Card Industry Data Security Standards
• Access Controls: Role-based access to personal data on a need-to-know basis
• Monitoring: 24/7 security monitoring and intrusion detection
• Firewalls: Network-level protection against unauthorized access

5.2 Organizational Safeguards

• Employee background checks for personnel handling personal data
• Security awareness training for all staff
• Incident response procedures for data breaches
• Regular security assessments and vulnerability testing
• Vendor security assessments for third-party service providers

5.3 Data Breach Notification

In the event of a data breach affecting your personal information, we will:

• Investigate the breach promptly
• Take steps to contain and remediate the breach
• Notify affected individuals as required by applicable law (typically within 72 hours of discovery)
• Notify applicable regulators as required
• Provide guidance on steps you can take to protect yourself

6. Data Retention

6.1 Retention Periods

We retain your personal information for as long as necessary to:

| Data Type | Retention Period | Reason | | :--- | :--- | :--- | | Transaction records | 7 years | Legal/regulatory requirements | | Payment card data | Not stored (tokenized) | PCI-DSS compliance | | Customer support records | 3 years after resolution | Service quality and dispute resolution | | Fraud screening data | 5 years | Fraud prevention and investigation | | Website analytics | 2 years (anonymized) | Service improvement | | Chargeback/dispute records | 7 years | Legal/regulatory requirements |

6.2 Deletion

After the applicable retention period, we will securely delete or anonymize your personal information. You may request earlier deletion, subject to our legal and regulatory obligations (see Section 8).

7. Cookies and Tracking Technologies

7.1 Types of Cookies We Use

| Cookie Type | Purpose | Duration | | :--- | :--- | :--- | | Essential | Required for checkout functionality and security | Session | | Security | Fraud prevention and bot detection | Session to 30 days | | Analytics | Understanding how our services are used (anonymized) | Up to 2 years |

7.2 Your Cookie Choices

• Essential cookies cannot be disabled as they are necessary for our services to function
• Analytics cookies can be managed through your browser settings or our cookie preferences tool
• Most browsers allow you to block or delete cookies through browser settings

7.3 Do Not Track

We honor Do Not Track (DNT) browser signals. When we detect a DNT signal, we do not use analytics or non-essential tracking cookies.

8. Your Rights and Choices

8.1 Access

You have the right to request a copy of the personal information we hold about you.

8.2 Correction

You have the right to request correction of inaccurate or incomplete personal information.

8.3 Deletion

You have the right to request deletion of your personal information, subject to our legal and regulatory retention obligations.

8.4 Portability

You have the right to request your personal information in a structured, commonly used, machine-readable format.

8.5 Objection and Restriction

You have the right to object to or request restriction of certain processing of your personal information.

8.6 How to Exercise Your Rights

To exercise any of these rights, contact us at:

• Email: privacy@networkpay.us
• Mail: Network Pay LLC, Attn: Privacy, 1001 S Main St Suite 600, Kalispell, MT 59901

We will respond to your request within 30 days. We may ask for verification of your identity before processing your request.

8.7 Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

9.1 Categories of Information

In the preceding 12 months, we may have collected the following categories of personal information:

• Identifiers: Name, billing address, email, IP address
• Financial Information: Payment card details (tokenized), bank account details
• Commercial Information: Transaction records, purchase history
• Internet/Electronic Activity: Browsing history on our Platform, device information
• Geolocation Data: Approximate location from IP address

9.2 Sale and Sharing

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

9.3 California Rights

You have the right to:

• Know what personal information we collect, use, and disclose
• Delete your personal information (subject to exceptions)
• Opt out of the sale or sharing of personal information (not applicable — we do not sell or share)
• Non-discrimination for exercising your rights

9.4 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's authority.

10. International Data Transfers

10.1 Location of Processing

Your information is primarily processed and stored in the United States. By using our services, you consent to the transfer of your information to the United States.

10.2 EU/EEA/UK Users

If you are located in the EU, EEA, or UK, the transfer of your data to the United States is based on:

• Your explicit consent to the transfer
• Necessity for the performance of a contract (processing your payment)
• Standard contractual clauses or other approved transfer mechanisms

10.3 Legal Basis for Processing (GDPR)

If GDPR applies to you, our legal bases for processing are:

• Contract performance: Processing your payment (Article 6(1)(b))
• Legal obligation: Compliance with applicable laws (Article 6(1)(c))
• Legitimate interests: Fraud prevention, service improvement (Article 6(1)(f))
• Consent: Analytics cookies and marketing (Article 6(1)(a))

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn that we have collected information from a child, we will delete it promptly.

12. Third-Party Links

Our Platform may contain links to third-party websites (including Principal websites). We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party websites you visit.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices:

Network Pay LLC Attn: Privacy Officer 1001 S Main St Suite 600 Kalispell, MT 59901

Email: privacy@networkpay.us General Support: support@networkpay.us

Last Updated: February 20, 2026
Version: 2.1

© 2026 Network Pay LLC. All rights reserved.