Privacy Statement

OUR COMMITMENT TO PRIVACY

SQRIL knows that you care about how your personal information is used and disclosed, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this Privacy Statement easy to find, we make it available from the home page of the SQRIL website at sqril.io (the "website") and through our mobile applications. You may also email us at privacy@sqril.io with any privacy-related questions you have.

APPLICABILITY OF PRIVACY STATEMENT

This Privacy Statement applies to all information we collect through our Services from current and former SQRIL users. SQRIL is the data controller of this information. "Services" means any products, services, rewards programs, content, features, technologies, or functions, and all related websites, applications and services in connection with a SQRIL account. When you are no longer our customer, we continue to disclose your information as described in this Statement. This Statement only applies to the Services and does not apply to the practices of any other SQRIL service.

SQRIL is always improving. As the Services evolve we may occasionally update this Privacy Statement to reflect changes to our business, Services, or applicable laws. If the revised version requires notice in accordance with applicable law, we will provide you with 30 days prior notice by posting notice of the change on the "Privacy Statement" page of our website and mobile apps, otherwise the revised Privacy Statement will be effective as of the published effective date. If you are a new customer or are receiving this Privacy Statement for the first time and there is an upcoming change described on the "Privacy Statement" page of our website and mobile app at the time you receive this Privacy Statement, such upcoming change will apply to you on the indicated effective date.

Throughout this Privacy Statement, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific person.

This Privacy Statement also applies to all information we collect from non-SQRIL users who receive a payment from SQRIL users.

THE INFORMATION WE COLLECT

When you visit the website or use our mobile application or other Services, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service.

If you open a SQRIL account, we collect the following information from you:

• •Account Information - machine or mobile device ID and other similar information.
• •Identification Information - your name, street address, email address, date of birth, and Social Insurance Number ("SIN") (or other governmental issued verification numbers).
• •Device Information - information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others.
• •Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to disclose your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device.
• •Financial Information - bank account online login information, bank account and routing numbers and credit cards linked to your SQRIL account. SQRIL does not disclose financial information with third party social networking services such as those listed in the prior bullet.
• •Biometric Information - when you consent in the user experience, we collect face scans to authenticate your account and manage fraud and risk.
• •Audio, electronic, visual or similar information - Call recordings when you talk to customer service or sales.
• •Professional or employment information – including business information, contact emails, phone numbers and taxpayer ID numbers.
• •Information you provide when you contact us – your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account status, repayment history, information about others if you choose to share it with us.

We may also collect the above data from other third parties, including service providers, internet service providers, partners and merchants, credit reporting agencies, government entities, data brokers, data analytics providers, advertising networks, payment networks and financial institutions.

We are committed to providing a safe, secure and all-around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address or other information in order to comply with law or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.

When you are using the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or your operating systems or other access device for fraud prevention and other similar purposes.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team, store results when you respond to a survey, or when you use SQRIL services.

INFORMATION FROM CHILDREN

The Services are not directed to children under the age of 18. If we obtain actual knowledge that we have collected personal information from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.

HOW WE USE COOKIES

When you visit or use our Services, or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a customer; customize Services, other content and advertising, measure the effectiveness of promotions, perform a wide range of analytics, mitigate risk and prevent potential fraud, and to promote trust and safety across our Services.

Certain Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of certain Services may be limited or not possible.

Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

Please review our Statement on Cookies and Tracking Technologies to learn more about how we use Cookies.

HOW WE PROTECT & STORE PERSONAL INFORMATION

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state laws and regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal information as well, including never sharing your SQRIL password with anyone.

If SQRIL learns of a systems security breach, we may attempt to notify you electronically so you can take appropriate protective steps. By using the Services, you agree that SQRIL may communicate with you electronically. SQRIL may post a notice on the website or mobile applications if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at privacy@sqril.io.

HOW LONG WE STORE YOUR PERSONAL INFORMATION

We retain your Personal Information for as long as needed or permitted in context of the purpose for which it was collected and consistent with applicable law.

The criteria used to determine our retention period is as follows:

• •Personal Information used for the ongoing relationship between you and SQRIL is stored for the duration of the relationship plus a period of 10 years, unless we need to keep it longer, such as:
• •a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under Anti-Money Laundering obligations
• •litigation, investigations, audit, and compliance practices, or to protect against legal claims.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Our primary business purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:

• •provide the Services and customer support you request;
• •process transactions and match payments, and to send notices about your transactions or your network activity;
• •resolve disputes, collect fees, and troubleshoot problems;
• •prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information;
• •create an account connection between your SQRIL account and a third-party account or platform;
• •customize, personalize, measure, and improve our services and the content and layout of our website, including showing you location-based promotions and business profiles;
• •send you updates about new products and services that we are offering to customers;
• •compare information for accuracy and verify it with third parties;
• •perform other duties as required by law;
• •if you elect to disclose your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-based options, functionality, offers, advertising, search results, or other location-based content.

HOW WE DISCLOSE PERSONAL INFORMATION WITH OTHER PARTIES

SQRIL does not disclose your personal information with third parties for their promotional or marketing purposes.

Some personal information is public information and may be seen by anyone on the internet, whether or not they have a SQRIL account. Public information may also be seen, accessed, reshared or downloaded through SQRIL's APIs or third-party services that integrate with our products.

• •Public information for personal profiles includes your SQRIL username, profile photo, first and last name, month and year of SQRIL account creation, and public transactions in which you've been involved.

In addition to any public information, your SQRIL friends list may be seen by any logged-in SQRIL user; you may adjust or turn off this setting in the privacy section in your account settings.

We may disclose your personal information with:

• •Companies that SQRIL plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this Privacy Statement with respect to your personal information. If your personal information could be used contrary to this Statement, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.
• •Law enforcement, government officials, or other third parties if SQRIL is compelled to do so by a subpoena, court order or similar legal procedure; when it is necessary to do so to comply with law; or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the SQRIL User Agreement, or as otherwise required by law.
• •Third party service providers who assist us in providing Services to you or who provide fraud detection or similar services on our or any vendor's behalf.
• •Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
• •Financial institutions and databases maintained by payment networks to facilitate payment processing.
• •Partners and merchants, their service providers and others involved in a transaction or our rewards program. For example when you use the Services to initiate purchases, or when you participate in transactions through the payment networks, we may disclose information about you and your SQRIL account with the other parties (or their service providers) involved in processing your transactions. Please note that personal information shared with partners and merchants (or their service providers) involved in a transaction is subject to the partner' and merchant' own privacy policy and procedures.
• •For our businesses and their beneficial owners, we report personal information to databases maintained by the card networks pursuant to the card scheme rules to fulfill listing and reporting obligations.
• •Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform or to send money to a payment network recipient.
• •For the purposes of this Privacy Statement, an "account connection" with such a third party is a connection you authorize or enable between your SQRIL account and a non-SQRIL account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, SQRIL and the third-party will exchange your personal information and other information directly. Examples of account connections include, without limitation: linking your SQRIL account to a social media account or social messaging service; connecting your SQRIL account to a third-party data aggregation or financial services company, if you provide such company with your SQRIL account log-in credentials; or using your SQRIL account to make payments to a merchant.
• •If you connect your SQRIL account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party's service. For example, if you connect your SQRIL account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.
• •Information that we disclose with a third-party based on an account connection will be used and disclosed in accordance with the third-party's privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that SQRIL discloses with a third-party account or platform such as a social media account may in turn be disclosed with certain other parties, including the general public, depending on the account's or platform's privacy practices.

SQRIL does not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under the control of SQRIL and is subject to the terms of use and privacy policies of such third parties.

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You can review and update your personal information in your account settings at any time by logging in to your account.

LINKS TO OTHER SERVICES OR SITES

The Services may contain links to (or allow you to link to) other third-party services or websites. SQRIL does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personally identifiable information.

HOW TO CONTACT US

If you have questions or concerns regarding this Privacy Statement, or any feedback pertaining to your privacy and the Services that you would like us to consider, please email us at privacy@sqril.com

Consumer Privacy Notice

SQRIL is a service provided by 1421069 BC LTD. ("SQRIL"). The following Consumer Privacy Notice applies to you if you are an individual who resides in the United States and use the Services for your own personal, family or household purposes.