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• Last Updated: 1 July 2026
• Effective Date: 1 July 2022

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This Privacy Notice for California Residents supplements the information contained in MassPay’s General Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), the CPRA and any and all amendments thereof. Any terms defined in the aforementioned statutes have the same meaning when used in this Notice.

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Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected personal information found in the following categories in the last twelve (12) months:

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MassPay may process personal information through approved artificial intelligence, machine learning, automated analysis, or similar technologies (“AI Tools”). Depending on the applicable service or business process, AI Tools may process identifiers, customer records information, commercial or transaction information, internet or electronic network activity information, inferences, and sensitive personal information where necessary for authorized compliance, fraud-prevention, financial, identity-verification, security, or service purposes.

AI-related records may include prompts, uploaded documents, summaries, extracted document text, AI-generated responses, alerts, risk indicators, review notes, usage logs, audit logs, and related metadata. These records may be associated with customers, users, prospects, business contacts, or MassPay personnel depending on the context.

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Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
• We obtain the categories of personal information listed above from the following categories of sources:
  
  • Directly from you. For example, by visiting the website, filling in forms on the website, subscribing to our Services, or by corresponding by phone, email, or otherwise.

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Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the information. For example, if you ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to use or pay for services, we will use that information to process your payment information and provide you with a receipt. We may also save your information to communicate with you.

• Website: To provide, support, personalize, and develop our Websites and webpages, products, and services, including the delivery of content, product and service offerings and targeted offers via email or phone.
• Fraud and Security Purposes: To create, maintain, customize, and secure your account with us and to process your requests, transactions, and payments and prevent transactional fraud. To also help maintain the safety, security, and integrity of our Website, Services, databases and other technology assets, and business.
• Service and Support: To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• Legal and Regulatory Requirements: To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To provide services and information.
• To manage day to day business needs including, but not limited to, payment processing and financial account management, business planning and forecasting, security and fraud prevention, and compliance with legal and regulatory oblications.
• We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice..

‍MassPay may use personal information with AI Tools for the following business purposes:

• To support identity review, document review, name matching, account-matching, onboarding, KYB review, periodic review, transaction monitoring, fraud prevention, risk review, escalation, and investigation;
• To generate summaries, alerts, explanations, review notes, draft communications, reports, workflow recommendations, and operational analysis;
• To support customer service, internal productivity, financial reconciliation, compliance review, legal or contract review, sales support, marketing drafting, translation, training materials, and business reporting;
• To maintain the security and integrity of our systems, services, databases, applications, accounts, and business operations;
• To comply with legal, regulatory, audit, tax, accounting, reporting, and compliance obligations.

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Sharing Personal Information

We do not disclose your personal information to third parties unless we have your permission or are required by law to do so.

MassPay may disclose personal information to AI vendors, cloud providers, analytics providers, customer-support tools, compliance tools, productivity tools, and related service providers for the business purposes described in this Notice. These service providers may process personal information to provide AI functionality, maintain security, detect abuse, troubleshoot issues, support compliance, and enforce applicable terms.

MassPay does not authorize AI vendors or service providers to use customer personal information, uploaded documents, prompts, outputs, logs, confidential business information, or regulated financial information to train public or general-purpose AI models unless MassPay has provided appropriate notice and obtained any required authorization.

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Disclosures of Personal Information for a Business Purpose

• In the preceding twelve (12) months, no disclosures of personal information for a business purpose have occurred.

Sales of Personal Information

• In the preceding twelve (12) months, we have not sold personal information.

‍Sensitive Personal Information and AI

MassPay does not use or disclose sensitive personal information for purposes other than those permitted by applicable law, such as providing our services, preventing fraud, maintaining security, verifying identity, processing payments, performing compliance obligations, or other authorized business purposes. Where sensitive personal information is processed through AI Tools, MassPay limits such processing to approved purposes and applies appropriate safeguards, including access controls, vendor controls, data minimization, and human oversight.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Depending on applicable law and the nature of the processing, California consumers may have the right to know about personal information processed through AI Tools, request deletion or correction of personal information contained in AI-related records, request information about automated decision-making technology, opt out of certain automated decision-making uses, or request review of certain AI-assisted or automated decisions. We will respond to such requests in accordance with applicable law.

Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

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Artificial Intelligence and Automated Decision-Making Technology

MassPay may use AI Tools and automated decision-making technology to support business, compliance, fraud-prevention, customer-support, operational, and security processes. In most cases, AI Tools are used to assist MassPay personnel and do not make final customer-facing decisions without human review.

AI-supported processes may help identify potential discrepancies, fraud indicators, transaction trends, account-risk issues, KYB review items, rail-recovery issues, customer-support alerts, or other operational matters. AI outputs may affect or inform human review of account access, onboarding, fraud flags, transaction monitoring, escalation, investigations, or other service-related decisions.

Where required by applicable law, MassPay will provide California consumers with notices, rights, and choices relating to automated decision-making technology, including any applicable right to access information about the use of automated decision-making technology, opt out of certain uses, or appeal or request review of certain decisions. You may contact us at privacy@masspay.io if you believe an AI-assisted or automated process has affected you and you would like to request review, correction, reconsideration, or additional information.

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Exercising Access, Data Portability, and Deletion Rights

To exercise your rights to know or delete described above, please submit a verifiable consumer request by either:

• Completing a California Consumer Request Form and emailing it to privacy@masspay.io with the subject line “California Rights Request.”
• Emailing us at privacy@masspay.io.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only submit a request to know twice within a twelve (12) month period.

The request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to understand, evaluate, and respond to it properly.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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Response Timing and Format

We will confirm receipt of your request within ten (10) business days. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your verifiable consumer 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.

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Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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Minors’ Privacy and Rights (California Residents Under 18)

• Not Directed to Children Under 13. Our Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will delete it and take reasonable steps to remove it from our records. A parent or guardian who believes we may have collected information from a child under 13 may contact us at privacy@masspay.io.

• No Sale or Sharing of Minors’ Personal Information Without Opt-In. We do not sell or share (for cross-context behavioral advertising) the personal information of consumers we know are under 16. If our practices change, we will first obtain opt-in consent: from a parent/guardian for consumers under 13, and from the minor for consumers ages 13–15. Any such opt-in may be withdrawn at any time using the methods in “Exercising Access, Data Portability, and Deletion Rights.”

• Parental/Guardian Requests on Behalf of Minors. A parent or guardian may submit a verifiable request on behalf of their minor child to know, delete, or correct personal information using the methods listed in this Notice. We will take additional steps to verify the requester’s identity and relationship to the child before responding.

• California “Online Eraser” for Users Under 18. If you are a registered user under 18, you may request removal of content or information you publicly posted on our Services by emailing privacy@masspay.io with the subject line “Minor Removal Request.” We will remove or anonymize such content where required by law; note that removal may not ensure complete or comprehensive deletion (for example, if the content has been re-posted by others or archived by search engines).

Verification and Age-Assurance. Where the law requires consent or additional protections based on age, we may implement reasonable measures to verify age or obtain and verify parental/guardian consent. We will not condition a minor’s privacy rights on participation in unnecessary data collection.

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Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@masspay.io.

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Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated Policy on our Website and update the Policy’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

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Contact Information

If you have any questions about this Privacy Policy, please contact us at: privacy@masspay.io.

If you need to access this Policy in an alternate format due to having a disability, please contact us at privacy@masspay.io.

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