PIN4, INC. – PRIVACY POLICY (UNITED STATES)

PRIVACY PROMISE

Federal and certain state laws require us to inform consumers how we collect, share, and protect their nonpublic personal information. Federal and certain state laws also give consumers the right to limit some but not all sharing. This privacy notice explains our Privacy Promise to consumers to help them understand what we do and don’t do with their information.

Security is Paramount

At Pin4, it is our goal to ensure the privacy of all consumer nonpublic personal information that we receive. The following outlines some of the steps we take on a daily basis to ensure that this information is secure, private, and used only in a manner consistent with the consumer’s wishes. We will safeguard, according to our strict standards of security and confidentiality, any and all information we receive. We use administrative, physical, and technological security techniques and processes designed to protect the integrity and privacy of this information.

Data Collected

In performing the roles described above, Pin4 may receive nonpublic personal information about consumers from the following sources:

1. Information we receive from businesses (sending entities) in relation to orders sent or received by consumers;
2. Information we receive directly from consumers sending or receiving orders; an
3. Information we receive from other parties, including Cash Pick-Up issuing banks, government organizations, etc.

We advise consumers about the general uses of the information we receive about them, and we will gladly and promptly provide additional explanation, if requested.

Use of Information

We will use consumer information solely for the purpose of processing, managing and servicing orders, operating the Cash Pick-Up solution and providing reports with respect to the solution.

Sharing of Information

We will share your information solely for the purpose of processing, managing and servicing orders, operating the Cash Pick-Up solution and providing reports with respect to the solution.

We will only permit authorized employees and authorized third parties such as consultants or contract employees, who are trained in the appropriate handling of sensitive customer information, to have access to consumer information, and only if required by their business responsibilities. Employees or others who violate our Privacy Policy are subject to our disciplinary process, up to and including termination and prosecution.

Customer Notification & Consent

We do not currently conduct any consumer marketing activities using any consumer information. Should this change, we will provide consumers with the opportunity to remove their names used for marketing upon initial consumer contact and subsequently on an annual basis. This opt-out choice includes any products and services offered by Pin4 and any marketing partners, as permitted by law. Consumers may notify us that they want to opt out of such choices by contacting us via U.S. mail, telephone or email at privacy@pin4.com. For convenience, a sample opt out notice is attached as Exhibit A.

Except as permitted by law and outlined above, we limit the release of consumer information. We release information only with a consumer’s consent or request, or when we are required to do so by law or other regulatory authority. When a court order or subpoena requires us to release consumer information, we notify the consumer promptly to provide the consumer with the opportunity to exercise their legal rights. The only exception to this policy is when we are prohibited from notifying the consumer by law or due to a court order, or in cases in which fraud, money laundering or criminal or illegal activity is suspected.

Monitoring/Reporting

The CCO and CEO will regularly monitor compliance with this policy. Periodic quality assurance reviews will be conducted to assess the efficiency and effectiveness of this policy, identifying opportunities for improvement. Pin4 will conduct annual internal audits to assess compliance with this policy. Pin4 may engage third-party auditors to assess the Pin4 privacy program and ensure that it meets industry standards and regulatory requirements. Audit findings, including corrective actions taken, will be documented and reported to senior management.

If our privacy policy is modified, we will attempt to notify any impacted consumers of these changes via e-mail, U.S. mail, or via telephone. We will post our annual privacy policy notice to our website.

Should consumers have any questions, they may e-mail us at privacy@pin4.com.

Exhibit A – Opt-Out Request

Subject: Opt-Out Request

To: privacy@pin4.com
From: [Your Email Address]
Date: [Today’s Date]

Full Name:
[Enter your full name]

Email Address:
[Enter your email address]

Mobile Phone Number:
[Enter your mobile phone number]

I wish to opt out of the following (check all that apply):
☐ Marketing emails or newsletters
☐ Sharing of my personal information with third parties
☐ Targeted advertising or behavioral tracking
☐ All non-essential communications and data sharing

Additional Information or Instructions (optional):
[Provide any additional notes or context]

Signature:
[Typed or handwritten name if scanned]