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Last Updated: October 20, 2025 Effective Date: October 20, 2025 Version: 1.1.0

1. Introduction

Paygentic, Inc. (“Paygentic”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and protect information about you when you use our website, the Paygentic platform (“Platform”), accounts, and any related services (collectively, the “Services”). Paygentic provides billing and payment infrastructure for AI applications, enabling Merchants to configure pricing models, track usage, manage billing, and facilitate payment processing through integrated payment processors and licensed financial institutions. By using our Services, you agree to the terms of this Privacy Policy.

2. Scope

This Privacy Policy applies to:
  • Merchants who use the Paygentic Platform to monetize their products, services, or APIs;
  • End Users (also referred to as “End Customers” or “Consumers”) who purchase services from Merchants via the Platform and/or maintain account balances;
  • Visitors to the Paygentic website;
  • Vendors and service providers who interact with Paygentic;
  • Job applicants and potential users submitting personal information to Paygentic.

3. Information We Collect

3.1 Information You Provide to Us

  • Name, email address, postal address, and phone number
  • Business details (for Merchants), including company name, registration number, and VAT or tax identification number
  • Identity verification data (including government-issued ID, date of birth, and liveness/selfie checks for KYC/AML purposes)
  • Payment method details (e.g., card details, bank account information)
  • Usage data and metrics related to Merchant services
  • Communications with Paygentic (support requests, feedback, inquiries)

3.2 Information We Collect Automatically

  • Device and browser information (device type, operating system, browser type)
  • IP address and geolocation data
  • Usage data, including Platform interactions, account transactions, and feature usage
  • Transaction and billing records
  • API usage and integration data
  • Cookies and similar technologies (see Section 10)

3.3 Information from Third Parties

  • Identity verification services
  • Payment processors and licensed financial institutions
  • Fraud prevention and sanctions screening tools
  • Credit reference agencies and public databases where permitted by law
  • Information provided by Merchants about their End Users as necessary to provide Services

4. How We Use Your Information

We use your information to:
  • Provide and operate the Services, including:
    • Billing and payment infrastructure
    • Account functionality and fund management
    • Payment facilitation through integrated payment processors and licensed financial institutions
    • Real-time usage metering and tracking
    • Invoice generation and billing records
  • Verify your identity and comply with KYC/AML requirements
  • Monitor for fraud, abuse, and prohibited activity
  • Process payments, refunds, and payouts to Merchants
  • Manage platform fees as specified in our Terms and Conditions
  • Communicate with you regarding your account, transactions, or service updates
  • Provide customer support and respond to inquiries
  • Improve and optimize the Services, including AI model training and algorithm development
  • Conduct analytics and research using aggregated, anonymized data
  • Comply with legal obligations and enforce our Terms of Service
  • Prevent security threats and protect the rights and safety of Paygentic, users, and third parties

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data based on the following legal grounds:
  • Performance of a contract: To provide the Services you have requested
  • Compliance with legal obligations: Including KYC/AML laws, sanctions screening, and financial regulations
  • Legitimate interests: Including Platform operation, fraud prevention, service optimization, and business analytics
  • Consent: Where required for specific uses, such as marketing communications (you may withdraw consent at any time)

6. Sharing Your Information

We may share your information with:
  • Payment processors and licensed financial institutions to facilitate payment transactions and maintain account balances
  • Service providers assisting with:
    • Identity verification and KYC/AML compliance
    • Sanctions screening and fraud prevention
    • Customer support and communication services
    • Technical infrastructure and hosting
    • Data analytics and business intelligence
  • Merchants: We share End User information with Merchants as necessary to facilitate transactions and provide Services
  • Financial institutions and payment networks as required for payment processing
  • Tax authorities and regulators, as required by law
  • Law enforcement agencies, when legally obligated to do so or to protect our rights
  • Professional advisors (legal, tax, accounting, auditing)
  • Business transaction parties: In connection with a merger, acquisition, or sale of assets
We do not sell your personal data to third parties.

7. International Data Transfers

Paygentic operates globally and may transfer personal data to countries outside the EEA or UK. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:
  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • UK Addendum to the SCCs (for transfers from the UK)
  • Other legally recognized transfer mechanisms

8. Data Retention

We retain your personal data only as long as necessary to:
  • Provide the Services and maintain your account
  • Comply with legal and regulatory obligations, including:
    • 5-7 years for financial records and transaction data
    • 5 years minimum for KYC/AML records
    • As required by tax and accounting regulations
  • Resolve disputes and enforce our agreements
  • Establish, exercise, or defend legal claims
After the retention period expires, we will securely delete or anonymize your personal data unless longer retention is required by law.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal data:
  • Right to access: Request a copy of the personal data we hold about you
  • Right to rectification: Request correction of inaccurate or incomplete personal data
  • Right to erasure: Request deletion of your personal data (subject to legal retention requirements)
  • Right to restriction: Request that we limit the processing of your personal data
  • Right to object: Object to processing based on legitimate interests
  • Right to data portability: Receive your personal data in a structured, machine-readable format
  • Right to withdraw consent: Where processing is based on consent (without affecting prior processing)
  • Right to lodge a complaint: With your local data protection authority

Exercising Your Rights

To exercise these rights, contact us at: support@paygentic.io We will respond to your request within one month, or as otherwise required by applicable law.

California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:
  • Right to know what personal information is collected
  • Right to know whether personal information is sold or shared
  • Right to opt-out of the sale/sharing of personal information
  • Right to limit use of sensitive personal information
  • Right to correct inaccurate personal information
  • Right to non-discrimination for exercising privacy rights

10. Cookies and Tracking Technologies

We use cookies and similar technologies to:
  • Enable core functionality of the Platform and account system
  • Authenticate users and maintain secure sessions
  • Analyze site traffic and Platform usage patterns
  • Detect fraud and security threats
  • Improve user experience and Platform performance
  • Remember your preferences and settings

Types of Cookies We Use:

  • Essential cookies: Required for the Platform to function
  • Analytics cookies: Help us understand how users interact with our Services
  • Functional cookies: Enable enhanced functionality and personalization
  • Security cookies: Protect against fraudulent activity and security threats
You can manage cookie preferences via your browser settings. Note that disabling certain cookies may limit Platform functionality. For more information, see our Cookie Policy.

11. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or misuse, including:
  • Encryption of data in transit and at rest
  • Access controls and authentication mechanisms
  • Regular security assessments and testing
  • Employee training on data protection
  • Incident response procedures
However, no system can guarantee absolute security. We encourage you to take steps to protect your account credentials and report any suspected security issues immediately.

12. Children’s Privacy

Our Services are not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate parental consent, we will take steps to delete such information.
Our Services may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through our Platform.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The latest version will always be available on our website at www.paygentic.io. Material changes will be communicated via:
  • Email notification to your registered email address
  • Prominent notice on the Platform
  • In-app notifications
Your continued use of the Services after changes take effect constitutes acceptance of the updated Privacy Policy.

15. Contact Us

If you have questions about this Privacy Policy or our data practices, or wish to exercise your privacy rights, please contact us at: Paygentic, Inc. Email: support@paygentic.io Address: 2443 Fillmore St #380-3755, San Francisco, CA 94115, USA Data Protection Officer (for EEA/UK inquiries): Email: dpo@paygentic.io

16. Supervisory Authority

If you are located in the EEA or UK and believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with your local supervisory authority:
  • EEA residents: Contact your national data protection authority
  • UK residents: Information Commissioner’s Office (ICO) - www.ico.org.uk

Last Updated: October 13, 2025