INTRODUCTION

Ceyron Finance Inc and our affiliates and subsidiaries ( "Company" or "we" or “us” or “our”) respect your privacy and are committed to protecting it by complying with this policy and applicable laws.

This policy describes:

• The types of information we may collect from you or that you may provide when you use our website https://ceyronpartners.com (the "Website") and/or our Cey App For Business mobile application (the "App") as well as any other related products and services offered through the websites and mobile applications we own and that link to this policy (collectively, the "Service(s)").
• How we collect, use, disclose, and protect the personal information of individuals who uses the Services or accesses the Website/App ("you" or “your” or “user”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We do our best to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited legitimate purposes.

Privacy laws generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information generally does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

• When you use access our Website/App or use our Services.
• In email, text, and other electronic messages between you and us in connection with the use of our Services.
• When you use any other websites, mobile apps, official social media platforms, or other online properties through which the Company offers the Services and that are linked to this Privacy Policy.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party Website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every third-party website and/or mobile application you visit.

This policy DOES NOT apply to information that:

• We collect offline or through any other means, including on any other company or third-party website
• You provide to or is collected by any third party, through any application or content that may link to or be accessible from or on the Website/App.
• To online websites or services that we do not own or control, including websites or services of other users of our Services.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, you must decline to use our Services. By accessing or using our Services, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to our Privacy Policy). When you continue to use our Services and/or access our Website/App and after we inform you about the said changes to this Privacy Policy, you accept and consent to those changes. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

INFORMATION WE COLLECT ABOUT YOU AND PARTICPIANTS

We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to identify you directly or indirectly, such as your full name, e-mail address, age, date of birth, phone number, mailing address, government identity cards numbers such as passport Number/ driving license number, Internet protocol (IP) address used to connect your computer or cell phone or digital tablet (“Device”) to the Internet, username, password or other similar identifier and any other identifier we may use to contact you ("personal information").
• Transaction and experience information – When you use our Services or access our Website/App for example, to make payments towards purchases from merchants, to send or receive money, to process payments, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or received, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction.
• Participant information – When you use our Services or access the Website/App, we collect personal information you provide us about the other participants associated with the transaction.
  • Sending money or making a payment: When you send or request money through the Services, we collect personal information such as name, address, telephone number, and financial account information about the participant who is receiving money from you or sending money to you. The extent of personal information required about a participant may vary depending on the Services you are using for sending money or making a payment.
  • Add funds to your accounts: If you use our Services to add funds to your Account or any other account you may have, or if you ask a User to add funds to any of these accounts, wemay collect Personal Data from you about the other party, or from the other party about you to facilitate the request. For example, if you use our Services to recharge your prepaid telecom services, or to request balance be added to your mobile account, we may collect Personal Data and other information including mobile account number from the other participant.
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as age, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Service feature.
• Technical information, including your login information, browser type and version, Device ID, Device type, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website/App, and usage details
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website/App (including date and time), page response times, download errors, referring webpages or sources through which you accessed our Website.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us. For example, by filling in information on the Website/App to create your account or corresponding with us by phone, email, or otherwise. The information we collect directly from you as you use our Services or access our Website/App may include:
• Information that you provide by filling in forms on our Website/App. This includes Personal information provided at the time of signing up or creating an account to use Services. We may also ask you for information when you report a problem with our Services.
• Records and copies of your correspondence (including email addresses, phone numbers) if you contact us.
• Your responses to surveys/polls that we might ask you to complete/participate in for research purposes and promotional purposes.
• Details of transaction information you carry out through our Website. You may be required to provide financial information before you can send money or make a payment through our Website/App.
• Automated technologies or interactions. As you navigate through and interact with our Website/App, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
• Details of your visits to our Website/App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website/App.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website/App and to deliver a better service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Recognize you when you return to our Website/App.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website/App.
• Necessary / Essential Cookies. These cookies are crucial for providing you with services accessible through the Website/App and facilitating the use of certain features. They aid in user authentication and safeguard against fraudulent utilization of user accounts. In absence of these cookies, the requested Services cannot be rendered, and we solely utilize them to deliver our Services to you.
• Web Beacons. Pages of our Website/Apps and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website/App statistics (for example, recording the popularity of certain Website/App content and verifying system and server integrity).
• Telemetry. We may utilize telemetry to gather and send specific technical data and usage information. Telemetry enables us to oversee and analyze the performance of our services, improve user experience, and address any issues. This could encompass details like device type, operating system, browser type, IP address, page load times, errors, and other interactions with our platform.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Services including the Website, App and their contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To respond to correspondence from you, contact you when necessary or request feedback, and send you information about the Company or its services.
• To process orders and transactions that you request.
• To send emails and other communications according to user preferences or that display content that we think will interest users.
• To provide you with notices about your account, including expiration and renewal notices.
• To personalize the Services, Website/App content and communications based on your preferences.
• To notify you about changes to our Website/App or Services we offer or provide though them.
• To improve our Services, marketing, or customer relationships and experiences.
• To conduct activities related to fraud protection, security and debugging.
• To create and manage user accounts or other user profiles.
• To carry out our obligations and enforce our rights arising from any contracts with you or to comply with legal requirements.
• To fulfill the Company’s legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities
• To protect the rights, property or safety of users, the Company, or another party.
• To resolve disputes, if any.

The following categories of persons within the Company will have access to your personal information:

• Customer Service
• Billing
• Persons supporting privacy officer
• Fraud Prevention and Security
• Lawyers and compliance

Please note the said personnel will only have access necessary to complete their duties or carry out mandates of contracts.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated/anonymized/de-identified information about our users, and information that does not identify any individual, without restriction subject to applicable laws. We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our customers and users is among the assets transferred.
• To different third parties we use to support our business such as security and fraud prevention consultants, payment processors and customer service vendors. Please note that these third parties are contractually obligated to keep the personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• To enforce or apply our Terms Of Use and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or other third parties.

  We may also disclose your personal information without your consent:

• To comply with any subpoena or order of the court
• To public body or law enforcement agency to assist in investigation of an offence under Laws of Canada or laws of a specific province of Canada
• To comply with a request of a regulatory body
• To comply with any and all applicable laws.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. We may share personal information with third parties for various purposes, including but not limited to:

• API Integrations
• SDKs (Software Development Kits)
• Pixel Tracking
• Data Aggregators
• Consent Mechanisms

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation and other applicable laws.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance. By submitting your personal information or engaging with the Website/App, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website/App may not be accessible or may not function properly. For more information about tracking technologies, see Information we Collect Through Cookies and Other Automatic Data Collection Technologies.
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our Services, you can opt out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a service experience.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The security measures include:

• Encryption
• Access Controls
• Authentication Mechanisms
• Regular Software Updates and Patch Management
• Firewalls and Intrusion Detection/Prevention Systems (IDS/IPS)
• Secure Coding Practices
• Security Vulnerability Assessments
• Penetration testing
• Security Monitoring and alert mechanisms
• Employee Training and Awareness
• Privacy policies and user consent
• Compliance with regulatory standards, including PIPEDA

The safety and security of your information also depends on you. Where you have chosen a password for access to our Website/App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website/App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website/App.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

PEOPLE UNDER THE AGE OF 18

Our Service is not intended for people under 18 years of age. No one under the age of 18 years may provide any personal information to or on the Website/App. We do not knowingly collect personal information from people under 18. If you are under 18, do not use or provide any information on the Website/App or on or through any of its features, register to use any Services, use any of the interactive or public comment features of our Service, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a person under 18, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at [[email protected]]

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and up-to date. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. You can review and change your personal information by logging into the Website/App and visiting your account profile page. You can also request us to correct any errors or omissions with respect to your personal information. If we are satisfied such request is reasonable, we will correct the relevant information and provide an update about the correction to any third parties with whom your personal information was shared within a year before the date the correction was made. If you want to review, verify, correct, or withdraw consent to the use of your personal information you must send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us.

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 charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. We may request you to pay a minimal fee to provide access to the personal information. You will be provided the access to personal information within 30 business days after it is requested, unless we are provided an extension by the relevant authority or under applicable law.

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. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at [email protected]

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [[email protected]]. Please note that if you withdraw your consent, we may not be able to provide you with any/all Services. We will explain the impact to you at the time to help you with your decision.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make any changes to how we treat our users' personal information, we will notify you through an email/notice on the Website home page and through email. In case you do not agree to the changes you have the option to decline the changes and discontinue the use of our Services. Should you have any requests with regard to such changes you can write to us at [email protected]

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website/App and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. If you want to use any of your rights mentioned in this policy, you can do that by getting in touch with us. However, please understand that these rights are not absolute. This means we might not be able to fulfill your request completely or might have to decline it. We will provide you with reasons if we decline your requests.

Please contact us at: [email protected]

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. While we ask that you reach out to us in the first instance to allow us the opportunity to address your concerns, note you have the right to contact your own provincial data protection supervisory authority.

In case we are unable to address your complaints about how your personal information is handled, you can make a complaint to your provincial data protection supervisory authority or to:

(i) Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec
K1A 1H3

(ii)If you reside in Quebec
Commission d’accès à l’information du Québec
525, boulevard René-Lévesque Est, bureau 2.36
Quebec (Quebec) G1R 5S9