PRIVACY POLICY

Here at Cobalt, we respect your concerns about privacy. The following statements relate to the use of cookies, collection of data, information security and privacy standards applicable to all users of this application. For the purpose of this Privacy and Cookies Policy, “Cobalt.info, Cobalt Payments”, “Cobalt” ,“we” and “us” refers to Cobalt Payments Inc. and its subsidiaries, as the context requires. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. See “Region-Specific Information” below. Please read this policy carefully. If you have any questions, please contact us at: Support@Cobalt.info

Cobalt Payments provides payment products and services for commercial and non-commercial enterprises. Those products and services include payment card processing, point-of-sale terminals, Virtual Terminal, API & Gateways, management and support tools, merchant accounting and Merchant Cash Advance. For our customers, information about disclosures, transfers and other processing of personal information as part of our payment processing function is set out in the documentation provided to them during the boarding process and is outside of the scope of this policy, which relates only to information we obtain through this application.

Data We Collect

Your use of the Cobalt site and/or your registration for Cobalt products constitute your consent to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Cobalt website or any of our Cobalt products.

Cobalt may occasionally update this Privacy Policy. If we modify our Privacy Policy, we will post the revised statement here, with an updated revision date. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an e-mail and/or posting a notice on our corporate website.

In addition Cobalt will seek a customer’s prior consent, by e-mail, for any new uses or proposed disclosures of information collected from the customer prior to the change. Cobalt will notify customers by e-mail of changes to this policy that will affect information collected from them in the future. In certain circumstances, however, Cobalt will not inform and obtain the consent of the customer, such as in connection with an investigation of a breach of an agreement, contravention of laws, an emergency where the life, health or security of an individual is threatened, the collection of a debt or in compliance with the request of a law enforcement agency or a court order.

A customer may withdraw his, her or its consent for collection, use and disclosure at any time by sending an e-mail to info@Cobalttechnologies.com. Please note that, if you do, Cobalt may suspend its provision of products to you. Your username and password, both of which you will use to log in to this application, Information you provide if you report a problem with our application; Records of any correspondence we have with you and other information required to establish a merchant processing account with us.

How We Use the Personal Information We Obtain

• Subject to your consent if required by law, we may use your personal information for the following reasons (List is subject to change):

• To improve and personalize your experience when you use this application;

• To contact you regarding any inquiry you make or to fulfil a request, such as, for example, a request for information about our products and services;

• To improve our products and services and for the development of future products and services;

• For internal record keeping and administration of records;

• For statistical analysis

• To contact you by email and, if you have signed up for the service, to share e-newsletter or any other updates, communications or publications;

• For direct marketing purposes subject to your consent if required by applicable law (see “Managing Your Preferences” below);

• As necessary to set up and administer your sign up to, and use of, the log in facility available on this application; and

• For compliance with applicable laws and/or regulations and as otherwise required or permitted by applicable laws and/or regulations.

• to develop and provide our web site and our products for our customers;

• to fulfill your requests for products or information;

• to communicate with customers and site visitors, when necessary, and to inform customers of upgrades, as well as of other products available from Cobalt, its affiliates and third parties.

• to bill accounts and maintain payment records;

• to comply with any applicable law, regulation, legal process or government request;

• to respond to a legitimate claim, or to address our reasonable belief, that you are violating the rights of any third party or any of the agreements or policies that govern your use of the Cobalt site or any Cobalt product or service;

• to protect the services, products or rights of Cobalt, including but not limited to the security or integrity of the Cobalt site; and

• to identify and resolve technical problems concerning the Cobalt site and its products.

• Cobalt also uses personal information in an aggregate form (i.e., not individually attributable to you) for its business analysis, operational, marketing and other promotional purposes.

• If we hire other companies to provide some products or services on our behalf, then we will only provide those companies the personal information they need for the Privacy Policy Purposes, and we will limit their rights to use and further disclose your personal information as appropriate in the course of their work for us

Disclosures of the Personal Information

Portions of our services may be provided by organizations with which Cobalt Payments has a contractual relationship, including processors, affiliates, subcontractors, and, accordingly, your personal information may be disclosed to them. We take steps aimed at ensuring that all such persons process your personal information as disclosed by us only as necessary for their service delivery and for no other purpose.

We also may disclose your personal information in order to obtain commercial and credit information to establish, maintain or renew a customer’s contract(s), as may be required to provide any of the services for which a customer has subscribed, to comply with the rules and regulations of any credit or debit card payment network or otherwise in accordance with this policy.

We may also disclose your personal information:

In response to a court order or a request for cooperation from a regulatory, law enforcement or other government agency; to establish or exercise our legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;

When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; to protect and defend the rights, property or safety of Cobalt Payments, its customers, staff, suppliers or others; and

We do not sell, share, trade or lease your personal information to others in ways different from what is disclosed within this policy, agreed to contractually by our customers or otherwise with their permission; provided, if you were referred to Cobalt Payments for services via a third party, such as another independent services provider, we may share information with such third party in accordance with our business relationship with you and that third party.

Third Party Links & Advertising

Our applications may link through to third-party applications, and those processes may involve the placement of third-party cookies on your machine or device. We do not control the third-party cookies used for these purposes. We encourage you to review the privacy practices of these third-party sites prior to accessing or navigating those sites.

We may, from time to time, partner with ad networks and other online advertising providers in order to serve ads on behalf of us or other non-affiliated parties on our applications and across the Internet. These ads may be presented to you based on products and services the advertising providers think are relevant to your interests. These preferences may be inferred based on information collected about your browsing behavior on our applications and other non-affiliated sites and apps across time. We adhere to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles. To learn more about, or opt-out of, this type of advertising from participants in the DAA, you can visit www.aboutads.info.

Login Details and Your Responsibility

Subject to your consent if required by law, we will collect and process your personal information as necessary to set up and administer your sign up to, and use of, the log in facility available on this application. We will use “cookies” to “remember” the machine or other device you use to access this application (see “Cookies” below). Please remember that if we contact you, we will never ask you for your password in an unsolicited email, message or phone call. If you choose to use the log in facility available on this application, you are required to adhere to the following security procedures in relation to your username (currently, your email address) and password, which are referred to as “login information”:

• Keep your login information secret and secure at all times and do not disclose it to any other person or allow any other person to use it;

• Do not write down or record in any form your login information or store it on any software, including a password save feature;

• Destroy any notice from us concerning your login information as soon as you have read and understood it;

Should you become aware or have reason to suspect that your login information has been lost or disclosed to, or seen or accessed by, someone other than yourself, immediately notify Cobalt Payments at the email address provided above;

Do not leave your computer or other device unattended while you are using the log in facility available on this application or let anyone else use your computer or other device unless and until you have logged out; and

Use particular caution if you access the log in facility available on this application from a public or shared computer, to ensure that other people are not able to see seen your login details.

Managing Your Preferences

Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and services as well as those of our affiliates and third parties, and we may permit those affiliates or other third parties to send their own direct marketing to you. Our direct marketing may be by email, telephone, post or SMS or such other method(s) as may become relevant. In addition, Cobalt Payments may provide direct marketing information and permit others to do that as allowed by our customers’ respective contracts.

We will take steps to seek to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

Commitment to Security, Privacy and Standards

We take seriously our responsibility to protect the security and privacy of the information we receive via this application. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide via this application against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. Suspected computer mischief may be reported to the appropriate authorities.

Please remember that communications over the internet such as emails are not secure. We seek to keep secure all confidential information and personal information submitted to us through this application in accordance with our obligations under applicable laws and regulations. However, like all application operators, we cannot guarantee the security of any data transmitted through this application.

IP Addresses

An IP address is a number which recognizes the computer or other device used to access the internet. Typically, a web server automatically collects IP addresses and uses them to administer a application. IP addresses are used in conjunction with cookies for the purpose of “remembering” computers or other devices used to access this Application. For further details, see “Cookies” below.

Cookies

A “cookie” is a text file that applications send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. This application’s uses of cookies includes those cookies that are strictly necessary to enable the features of the application, performance cookies to see how visitors use the application, and functionality cookies that enable the webpage to “remember” machines or devices, personalize application content and tailor user experience. In addition, cookies may be used to help us define our audience so that we can make appropriate changes to this application (“Demographics” cookies) and target advertisements to users when they are browsing this application and other applications (“Interest Reporting” cookies), in each case by reference to anonymous identifiers, not personal information. Additional information about the types of cookies we may use is provided below.

Classification of Cookies

Cookies can be classified by duration and by source:

Duration. This application uses both “session” and “persistent” cookies. “Session” cookies are temporary, and they are destroyed when you close the browser and terminate your ‘active session’ during which you visited this application. “Persistent” cookies remember you on subsequent visits. “Persistent” cookies are not deleted when you close your browser, and they will remain on your computer or other device unless you choose to disable them (see below for how to disable cookies). “Persistent” cookies include the “Interest Reporting” and “Demographics” cookies.

Function of Cookies

The cookies that we may use on this application fall into the following categories:

Essential (“strictly necessary”) Cookies. These cookies are essential in order to enable you to navigate this application and use its features. They are deleted when you close the browser.

Functionality Cookies. These cookies allow us to remember choices you make and provide enhanced, more personal features. For example, we may use cookies to “remember” the machine or other device you use to access this application. We use these functionality cookies to recognize you when you return to this application. This enables us to personalize our content for you and remember your preferences, such as language, text and font size.

Interest Reporting and Demographics Cookies. These cookies use anonymous identifiers to track users’ browsing habits on this and other applications as they browse pages, videos and content, which allow us to define our audience so we can make appropriate changes to this application and target advertisements to users on this and other applications.

Changes & Updates

We may change this policy from time to time by updating this page. We will not necessarily bring changes or updates to your attention, so please revisit this page periodically to re-read this policy and to ensure you are aware of any changes when you visit the application. If there are substantive changes, including to the cookies we use, at our discretion, we may bring those to your attention, for example, by a message posted on the landing page of this application, which all users see on their next visit, or by a repeat cookies banner.

Children

This Application is not intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 18. Please do not use this application if you are under the age of 18.

Security

We store and process your information on our servers located within the United States. We maintain technical, physical and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Examples of methods in place to protect your data include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. You are responsible for ensuring the security of your password(s) and account registration information.

Contact Us

If you have any questions about this privacy policy you may contact us at: Support@Cobalt.info, 860.270.0552, or Mailing Address: Cobalt Payments, Inc. 2075 Silas Deane Hwy Suite 2C Rocky Hill, CT 06067, Attention: Legal Dept.