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• Last Updated: 1 July 2026
• Effective Date: 27 July 2022

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At MassPay, we are committed to protecting the privacy of personal information that you share with us. This Privacy Policy is to inform you of how we at MassPay collect, use, and disclose personal information of our customers and website users. MassPay is accountable for the personal information you have supplied to us. Our employees are informed about the importance of privacy and each is responsible for the personal information within his or her control. Our Privacy Officer is responsible for coordinating our compliance with both federal and provincial privacy laws.

Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and provincial privacy acts.

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Your Personal Information

Generally, personal information is any piece of information, factual or subjective, about an identifiable individual. Some examples of the types of personal information that MassPay may hold include your name, address, and contact details.

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Purposes for Which We Collect Personal Information

MassPay identifies the purpose for which your personal information is collected. We do this before or at the time the information is being collected. We may collect, use, and disclose your personal information in order to:

• process an order for the purchase of products;
• administer the delivery, return or exchange of products;
• respond to your questions, comments or requests to customer service;
• better understand your product needs and to offer relevant information or products to meet those needs, including sending you (and others on your behalf) communications by way of postal mail, e-mail, telephone, text message, or other types of electronic messages;
• send news, information about MassPay, and promotional material that we believe may be useful to you, while also analyzing this data for trends and statistics;
  track and analyze your purchases, other transactions, shopping patterns, account activity, and payment history for marketing analysis purposes or tailoring promotional offers to you;
• track and analyze website use to provide a better customer experience such as customized offers and advertisements;
• verify your identity and protect against error and fraud;
• perform tests to implement or modify systems;
• comply with applicable legal and regulatory requirements; and
  achieve other purposes as may, from time to time, be permitted or required by law.

‍MassPay may also collect, use, and disclose personal information to operate approved artificial intelligence, machine learning, automated analysis, or similar technologies (“AI Tools”) for identity and document review, fraud prevention, account-matching support, transaction monitoring, KYB and onboarding support, periodic review support, customer support, operational analysis, financial reconciliation support, data summarization, document or contract review, translation, internal reporting, and other business, compliance, security, and productivity purposes.

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How We Collect Personal Information

MassPay collects your personal information, for the identified purposes, in several ways, including:

• Using our Website;
• Direct interactions with your payor when you provide it, for example, when your payor creates an account or corresponding with us by phone, email, or otherwise;
• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies; or
• Details of transactions you carry out through our Website.

‍MassPay may collect personal information through AI-supported workflows, including when information is submitted to approved AI Tools by authorized personnel, when AI Tools analyze uploaded documents or transaction records, when AI Tools generate alerts or summaries, and when AI Tools create logs, outputs, or metadata relating to their use.

Consent

By providing your information to MassPay, you consent to MassPay using your personal information for the purposes outlined above. Withdrawal of consent to collect, use and disclose your personal information may restrict our ability to provide you with some products. Consent may be expressed (in writing or verbally), or implied, such as when you send us unsolicited personal information, in paper copy, via telephone, or electronically. Your consent can be withdrawn if you notify our Privacy Office in writing.

If you do not wish to have your personal information used for a particular purpose or you do not wish to receive mailings, you can email us to notify us of your wishes. Our practice is that if we wish to collect Personal Information via the Internet about you (such as name, contact information or other account information), MassPay will:

• Expressly ask you for that Personal Information;
• Tell you how we intend to use that Personal Information if you choose to give it to us when we request it.
  
  • For instance, we may wish to use that Personal Information to personalize and tailor our information or products for you; to identify who we are communicating with; or, to inform you of further information relating to our products, or this Website;
• Not share your Personal Information with persons or entities unless in accordance with this Privacy Policy.

‍Artificial Intelligence and Automated Processing

MassPay may use approved AI Tools to support our services and internal business operations. Depending on the context, AI Tools may process names, email addresses, uploaded documents, transaction data, account activity, operational logs, company information, customer or prospect information, and related records. AI Tools may generate summaries, alerts, review notes, discrepancy indicators, risk indicators, draft communications, or recommendations for review by MassPay personnel.

Where AI Tools are used to assist with decisions that may affect a customer, such as identity matching, account restrictions, fraud review, transaction monitoring, onboarding, KYB review, escalation, or investigation, MassPay uses human review processes designed to assess the AI output before or after action is taken, as appropriate. Where required by applicable Canadian privacy law, including Québec privacy law, MassPay will provide information about the use of automated decision-making and, upon request, provide meaningful information about the personal information used, the reasons and principal factors that led to the decision, and available options to request correction, review, or reconsideration.

You may contact us at privacy@masspay.io to request access to, correction of, or review of personal information used in an AI-assisted or automated process.

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Accessing And Correcting Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law, you have the right to request access to and correct the personal information we hold about you.

You can review and change your personal information by logging into the Website and visiting your MassPay account profile page.

If you wish to withdraw your consent, request access to, correct, or delete any personal information that you have provided to us, you may send us an email at privacy@masspay.io. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at dpo@masspay.io.

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Cookies

“Cookies” are a standard for storing small pieces of data on a web client (i.e., the web browser on your computer). Any web server (including this one) may:

• store one or more cookies in your browser; or
• request your browser to transmit the data to the web server.

This Website may store cookies on your web client to better serve you upon your subsequent visits to this Website. By using cookies, websites can track information about visitors’ usage of the site, provide customized content, or even the use of password protection. Note that some browsers can be configured to allow cookies to be accessed by servers other than the originating server. Please note that most web browsers can also be configured to notify the user when a cookie is received, allowing you to either accept or reject it. You can review our Cookie Policy here.

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Biometric Information (Québec Residents)

MassPay may use biometric characteristics or measurements (for example, facial geometry derived from a selfie/liveness check) only to verify or confirm your identity and to help protect against error and fraud. Where MassPay verifies or confirms identity using a biometric process in Québec, MassPay will (a) make any disclosure required to the Commission d’accès à l’information du Québec (CAI) before the process is used, and (b) obtain your express consent. MassPay will collect and use only the minimum biometric characteristics or measurements necessary for identity verification, will not use any other information that could be revealed or inferred from biometric characteristics or measurements for any other purpose, and will destroy the record of the biometric characteristics or measurements (and any related notation) as soon as the purpose of verification or confirmation has been met or the reason for the verification or confirmation no longer exists. If MassPay creates a database of biometric characteristics or measurements in Québec, MassPay will disclose the creation of that database to the CAI promptly and no later than 60 days before it is brought into service.

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‍AI Vendors and Service Providers

MassPay may use third-party AI vendors and related service providers to support AI processing. These providers may process personal information on MassPay’s behalf to provide AI functionality, maintain security, detect abuse, troubleshoot issues, support compliance, and enforce applicable terms. We require service providers to process personal information only for authorized purposes and in accordance with applicable contractual, confidentiality, security, and privacy obligations.

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 consent or authorization.

Some AI vendors and service providers may process personal information outside Canada, including in the United States or other jurisdictions where they or their sub-processors maintain infrastructure or personnel. Where required by applicable law, MassPay uses appropriate contractual, organizational, and technical safeguards for such transfers.

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Safeguarding Information

We will take appropriate measures to ensure that your supplied personal information is stored securely, whether in electronic form or otherwise.

Unfortunately, no data transmission over the Internet can be guaranteed as totally secure. Accordingly, although MassPay strives to protect such information, MassPay cannot ensure or warrant the security of any information you transmit to us or from our online products or services and you do so at your own risk. Once we receive your transmission, we will take reasonable steps to preserve the security of this information in our systems. If you have a login name and/or password for use in conjunction with this Website, you are fully responsible for maintaining the confidentiality of that login name and/or password. Furthermore, you are entirely responsible for all activities that occur under your login name. You agree to immediately notify MassPay of any unauthorized use of your login name and/or password or any other breach of security known to you.

When AI Tools are used, MassPay applies safeguards designed to protect personal information, including approved-tool requirements, access controls, role-based permissions, authentication controls, encryption where available, vendor due diligence, contractual data-protection requirements, usage monitoring, audit logs where available, data minimization, and human oversight for AI-assisted outputs that may affect customers.

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Information Retention

Where we determine that your personal information is no longer required for any purpose we have identified to you, we will take reasonable steps to ensure that it is securely disposed of or rendered anonymous. Some personal information must be retained for specific periods to comply with various laws.

MassPay may retain AI prompts, uploaded documents, AI-generated outputs, summaries, analysis, alerts, risk indicators, audit logs, usage logs, and related metadata as part of its ordinary business records. These records may be stored in internal systems, vendor platforms, compliance archives, case-management tools, ticketing systems, customer files, or other authorized business applications. Retention periods vary depending on the purpose of processing, the type of record, vendor settings, legal and regulatory obligations, security needs, and MassPay’s retention practices.

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Children’s Privacy (Canada)

Our services are not intended for children, and we do not knowingly collect personal information from children under 13; if we become aware that we have, we will delete it. When we process a child’s information, we apply extra safeguards consistent with PIPEDA and applicable provincial laws. Where consent is our legal basis, we obtain meaningful consent appropriate to the child’s understanding and—for Québec residents—we obtain parent/guardian consent for children under 14 (minors 14+ may generally consent themselves unless not in their best interests). We minimize collection, avoid unnecessary profiling or marketing to minors, use high-privacy defaults, keep data only as long as needed, and protect it with appropriate security. Parents/guardians may request access, correction, or deletion of their child’s information using the methods in this Policy; we will verify identity and relationship before responding. Contact privacy@masspay.io with questions or requests.

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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 Privacy Policy on our Website and update the Privacy Policy’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

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Contact Information

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices.

Please contact us at: privacy@masspay.io

You have the right to complain to us if you feel we have collected, used, or disclosed your personal information in an improper way. You may do so by lodging a complaint in writing with our Privacy Office, and you will be entitled to a response within 30 days. If you feel further action is required to address your complaint, you may seek the involvement of the Privacy Commission in Ottawa.

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

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