Data Protection Policy

In compliance with the provisions contained in the Data Protection Act 2020, we hereby inform you that the personal data communicated will be incorporated into a database operated by EveryData Jamaica Limited (hereinafter EveryData). EveryData is committed to protecting the privacy and confidentiality of its customers and credit information providers’ personal information and has therefore adopted this Data Protection Policy to comply with its obligations under the said legislation. This policy briefly describes how we collect, hold, use and whenever necessary, disclose the information of customers who utilize the services of EveryData.

EveryData does not sell, trade, or rent your submitted information to others.

What information do we collect?

When you access our services on EveryData's online platform, the following personal information will be recorded:

• First Name
• Last Name
• Email Address
• Telephone Number
• Tax Registration Number
• Address

How do we use the information?

EveryData may collect, hold and use the personal information in your customer record as well as collect personal information from and disclose personal information to the third parties identified below, for the following purposes:

• Identifying you and ensuring the accuracy of information contained in your customer record;
• Establishing and administering your account, including determining, maintaining, recording and storing account holdings and transaction information in your customer record;
• Executing transactions with or through the EveryData including transferring funds by electronic or other means;
• Protecting EveryData's own business interests including collecting a debt owed to EveryData or allowing the performance of a transaction; Data Protection Policy - Version April 4, 2022 Page 3 of 5
• Meeting legal and regulatory requirements, including compliance with an order of a court of competent jurisdiction;
• Verifying with any other organization when necessary, information previously given by you;
• Advising you of other products, services or initiatives offered by EveryData or any of its affiliates that may be of interest to you;
• Providing, operating and maintaining the products and services offered;
• Processing and completing transactions, and send related information, including transaction confirmations and invoices;
• Managing our customers’ use of the services, responding to enquiries and comments and providing customer service and support;
• Send customers technical alerts, updates, security notifications, and administrative communications;
• Verifying customers’ identities;
• Investigating and preventing fraudulent activities, unauthorised access to the online platform, and other illegal activities;
• Administering the online platform and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
• To improve the Portal to ensure that content is presented in the most effective manner for you and for your computer;
• For trend monitoring, marketing and advertising purposes related to the products and services offered via the online platform;
• For compliance purposes, for example, to comply with Know Your Client (KYC), Proceeds of Crime (POCA) and Anti-Money Laundering and Combatting the Financing of Terrorism (AML/ CFT) laws;
• As part of our efforts to keep the portal secure and to enhance the customer’s experience while using the online platform;
• To track your use of the online platform in order to improve its design, functionality and effectiveness;
• To measure and report on the success of advertising and marketing campaigns and content and understand opportunities to develop new products; and
• For any other purposes made clear to you at the time you submit your information.

Information Sharing

EveryData does not sell, rent or lease its customer lists to third parties. EveryData may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party.

In addition, EveryData may share data with trusted partners to help us perform statistical analysis; send you email or postal mail; provide customer support; or arrange for deliveries. We may share your information with third-party vendors, consultants and other service providers whom we employ to perform tasks on our behalf. EveryData may also share your information with third parties providing services to us, such as financial institutions, and agents acting on our behalf. All such third parties are prohibited from using your personal information except to provide these services to EveryData and they are required to maintain the confidentiality of your information by virtue of a Nondisclosure Agreement.

EveryData may share your information for compliance purposes with national law enforcement agencies in Jamaica and other countries if requested to do so for compliance purposes. If false or inaccurate information is provided via its services and/or fraud is identified or suspected, details will be passed to fraud prevention agencies. Law enforcement agencies and other organizations may access and use this information in keeping with applicable legislation.

Consent

By using EveryData's services, you consent to the data practices described in this policy statement. EveryData will also rely on the following actions as indications of your consent:

• Your voluntary provision of personal information to EveryData;
• Your express consent or acknowledgment contained within a written, verbal or electronic application process;
• Your consent solicited by EveryData for a specified purpose; or
• Your consent given through your authorized representatives.

Subject to any applicable legal or contractual restrictions and reasonable notice, you may withdraw your consent at any time. If you wish to withdraw consent or discuss the implications of such withdrawal, please contact us by electronic mail at jm.customerservices@everydata.com. Your decision to withhold consent may also limit the products and services that EveryData can provide you.

Right to Access and Correct Personal Information

Except in limited circumstances described in the applicable legislation, you are entitled to access, through a written request, the personal information collected by EveryData. You may verify this personal information and request that any inaccurate information be corrected.

Retention

EveryData will only retain your personal information as long as it is necessary, including updating the product or service offered as required by the Data Protection Act. When we destroy the information, we will take reasonable steps to prevent unauthorized parties from gaining access to the information during the process.

Changes to this Policy

EveryData will occasionally update this Data Protection Policy to reflect company and customer feedback and\ or changes in the applicable legislation. We reserve the right, at our discretion, to change this Data Protection Policy at any time. We encourage you to periodically review this Data Protection Policy to be informed of how EveryData is protecting your information. Your continued use of the EveryData online platform after changes to the Data Protection Policy have been made will be treated as your acceptance of those changes.

Contact Information

EveryData welcomes your comments regarding this Data Protection Policy. If you believe that we have not adhered to this Policy, please contact us at jm.customerservices@everydata.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.

Version April 4, 2022