Maritime Payment Solutions, LLC (MPS) Privacy Policy for Consumers

Privacy Policy for Consumers is an important matter. We provide this policy as required by law to explain our information and Personal Data practices. Please read and retain this policy to learn how we collect and use information about you and your rights to limit the sharing and use of information and Personal Data.

PERSONAL DATA PROTECTION

Maritime Payment Solutions, LLC and its subsidiaries, including Global Technology Partners, LLC (GTP), does not share Personal Data, except as permitted by law. MPS places great importance on your right to privacy and the protection of your Personal Data, and has strict standards and procedures designed to prevent unauthorized access, or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage to all information. MPS has established protocols, controls and relevant policies, procedures and guidance to maintain these standards, taking into account the risks associated with the categories of Personal Data and processing. We store Personal Data on servers with limited access located in secured facilities, and our security measures are evaluated on an ongoing basis. The servers are protected by anti-virus software and firewalls, among other measures. Our safeguards meet or exceed Federal standards for protecting Personal Data. We permit only authorized employees, who have been trained in the proper handling of Personal Data, to have access to that data. If an employee were to violate MPS’s privacy procedures, he or she would be subject to disciplinary action.

This policy applies to individuals who inquire about and/or obtain products or services from MPS for personal, family and household purposes. This policy describes information practices across MPS. However, departments within MPS may have more restrictive information sharing practices.

This policy supersedes all previous notices or statements about practices described in this policy. You should retain a copy of this policy for your records. If we materially change our policy, we will prominently place a notification on our website. You may request a current copy of the policy at any time by visiting our website at gtpprepaid.com.

CATEGORIES OF PERSONAL DATA COLLECTED FOR PROCESSING

We may collect non-public personal information about you from the following sources:

Contact Data: Information you give us on applications or other forms;

Automatically Collected Data: IP addresses, information about your browser, operating system and other Personal Data that are relevant and necessary for the use of the service. Information about your transactions with us and Information about your transactions with other parties.

You are entitled, subject to legal exceptions set out in applicable law, to:

Request access to the Personal Data we process about you: this right entitles you to know whether we hold Personal Data of you and, if so, obtain information on and a copy of that Personal Data.

Request rectification of your Personal Data: this right entitles you to have your Personal Data be corrected if it is inaccurate or incomplete.

Object to the processing of your Personal Data: this right entitles you to request that we no longer process your Personal Data.

Request the erasure of your Personal Data: this right entitles you to request the erasure of your Personal Data, including where such Personal Data would no longer be necessary to support processing.

Request the restriction of the processing of your Personal Data: this right entitles you to request that we only process your Personal Data in limited circumstances, including with your consent.

Request portability of your Personal Data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of Personal Data that you have provided to us, or request us to transmit such Personal Data to another data controller.

Note that most of the Personal Data that we hold about you comes from information you provided, therefore, please ensure that you keep your information correct and up to date by updating your profile/information on the website.

Certain Personal Data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.

To the extent that the processing of your Personal Data is based on your consent, you have the right to withdraw such consent at any time by contacting our Compliance Officer. Please note that this will not affect our right to process Personal Data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If you wish to exercise your right to access your Personal Data, to object to it being processed or to rectify processed data, please contact [email protected] or send a letter to Maritime Payment Solutions  ATTN: ShipMoney, 2605 West Kenosha, Suite 800, Broken Arrow, OK 74012.

SHARING AND USING INFORMATION

MPS reserves the right to share and/or use all information we collect as this policy describes. We do not share information about you with third parties outside of MPS except as permitted by law and then subject to appropriate confidentiality and security measures, including compliance with this privacy policy. The purpose for which we share information is to support payroll services. The third parties with which we share the information help provide these services, such as wire transfer services. When MPS does disclose information about you to third parties under the limited legal exceptions, the third parties are required to treat the information about you they receive in strict confidence; to use it only for the purpose for which it was shared; and not to use the information for their own marketing purposes. MPS remains liable under this Privacy Policy if these third parties process your personal data in a manner inconsistent with the principles unless we can prove that we are not responsible for the event giving rise to any damage. We restrict access to information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect this information.

LEGAL EXCEPTIONS FOR SHARING OF INFORMATION

It is important to understand that, according to the law, MPS may share or use information about you for the following purposes:

In response to lawful requests by public authorities, including to meet national security or law enforcement requirements

To perform services (e.g., printing statements, bill payment, email services and mail house services)

To process your account

To protect the rights, property or safety of MPS, our customers or others (e.g., to protect against fraud)

To comply with a legal requirement or process (e.g., subpoena or court order)

To comply with your request or authorization to share information

You have the opportunity to choose whether to have your personal data used or disclosed. MPS provides you the means and opportunity to opt out of such usage or disclosure if:

Your personal data is to be used for a new purpose materially different from that which was originally authorized

Your personal data is to be disclosed to a non-agent third party

You can invoke your choice to opt out via these mechanisms:

Electronic mail to [email protected]

mail (or alternate postal services) at

Maritime Payment Solutions

ATTN: ShipMoney

2605 West Kenosha, Suite 800

Broken Arrow, OK 74012

PERSONAL DATA RETENTION

MPS will retain the data for as long as we have an ongoing relationship with you and for a reasonable time thereafter.  Please note that some or all of the data may be required in order to provide processing, or as MPS is required to retain certain information by law. MPS may retain your Personal Data longer, based on your legitimate interest or consent. If you terminate your relationship with MPS, we will still apply the practices in our policy to information about you that we maintain.

ONLINE INFORMATION PRACTICES

MPS uses technology that encrypts (scrambles) online information so it transfers privately between you and MPS’s network. Your unique user ID and password help protect information online. While we strive to protect personally identifiable information, we cannot warrant the security of the personally identifiable information transmitted to or received by us. MPS joins with certain third parties to deliver online products and services. MPS and these outside parties may keep some information you provide in order to deliver these services, such as online applications, online surveys, email and cookies.

We may keep information from online tools, online applications and forms, online service subscriptions or business conducted online through internet or wireless devices.

Online surveys – This information is used solely for research to help us improve our customer service and develop a superior website. We may maintain this information in a form that does not identify you.

Email – If you send us an email, we may keep the content of your email. Please be careful about the information you email to us, because email to any public website can sometimes be intercepted. If you agree to receive emails from MPS, we keep the information you give us and may use it to send you email messages regarding your account or for other customer service purposes.

Cookies – A cookie tells us our site was visited by you before and which pages were viewed. Cookies are also used for security purposes when you conduct business online. MPS may use cookie files to enhance the use of our site and redesign of our site, as necessary. Accepting a cookie does not give us access to your computer or any personal information about you. Outside parties, other than vendors who assist us with our website and who are under strict confidentiality requirements by contract, are not given access to our cookie files. MPS uses cookies that do not transmit any personal information about you.

CLIENT IDENTIFICATION NOTICE

Information Collection Procedures for Opening Accounts

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each customer who opens an account. Therefore, all new and existing customers are subject to the identity verification requirements.

When you open an account, we will ask for your name, address, and identification number, and, in the case of an individual, your date of birth. For business accounts, we may also obtain this information for individuals associated with the business. We may also request to see a valid driver’s license or other approved identifying documents. In all cases, MPS is committed to protecting your privacy and identity.

COMPLAINT RESOLUTION

Please contact our Compliance Officer at [email protected] if you have a general question about how MPS protects your Personal Data, if you wish to exercise your rights in relation to your Personal Data rights, or if you wish to make a complaint about MPS use of your Personal Data.