Privacy Policy

LAST UPDATED 10 JULY 2022

of Transaction Cloud Inc. (Transaction Cloud or We), a company incorporated in the USA

We care about your privacy, so We want you to receive full information on the extent to which We process your personal data, including independently, knowingly, and freely decide to entrust us with your personal data for the purposes set in this Privacy Policy. In the Privacy Policy you will find information about what is the scope of this Privacy Policy, who is the controller of your personal data, how We collect your personal data, what is the scope of processing of your personal data, to what extent We collect your personal data, for how long We store them, what are and how We use Cookies, for what purposes We may use your personal data, what entities We may share them with, where We transfer them, how We secure them and what rights you have in relation to the processing of your personal data.

Scope

This Privacy Policy encompasses users of services (Buyers), and vendors (Vendors) of Transaction Cloud, as well as other individuals (Users) who visit the transaction.cloud website. Due to the wide territorial scope of services provided by Transaction Cloud, this document includes that, depending on your place of residence, particular provisions on the protection of personal data of various countries, like the California Consumer Privacy Act (CCPA) or European General Data Protection Regulation (GDPR), may apply to you and you may have specific rights related to the processing of personal data. We reserve the right to process your personal data and respond to your requests only within the limits of the applicable legal provisions.

Data Controller

The Controller, i.e., the entity responsible for processing your personal data is Transaction Cloud Inc., a company incorporated in the State of Delaware in the USA under the file number: 7927747, address: 10 Dorrance St., Suite 700, PMB No. 6923, Providence, RI 02903, USA.

Information We Collect

Transaction Cloud gathers personal data only in accordance with applicable laws.

We collect and process your personal data:

1. to take actions before signing a contract with you as well as to perform the signed contract:

• source: data subjects, regarding the Buyer's email address: the Vendors,

• legal basis for processing: processing is necessary to conclude or to perform a contract concluded with you,

• scope of processing:

• for the Buyers: first and last name, email address, postal code, IP address, the following company's details (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, company's TAX ID number,

• for the Vendors (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, company's TAX ID number, company's phone number, company's bank account details; Vendor's representative personal data: first and last name, date of birth, personal identification number, personal phone number, personal mailing address, IP address (every time the Vendor logs into his account),

• processing period:

• the period of communications with you preceding the conclusion of the contract, but not longer than 6 months from the date of your last contact with us in case no contract was concluded,

• the period of performing the contract,

• after the termination or expiry of the contract, the period necessary to make settlements (no longer than one year) and to defend and pursue claims in connection with the performance of the contract, as well as in connection with the performance of obligations arising from the law,

2. to fulfill our legal, tax and other obligations imposed by the law provisions:

• source: data subjects, regarding the Buyer's email address: the Vendors,

• legal basis for the processing: processing is necessary to comply with a legal obligation,

• scope of processing:

• for the Buyers: first and last name, email address, postal code, IP address, the following company's details (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, company's TAX ID number,

• for the Vendors (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, company's TAX ID number, company's phone number, company's bank account details; Vendor's representative personal data: first and last name, date of birth, personal identification number, personal phone number, personal mailing address, scan of the Vendor's or its representative identification document for KYC (Know Your Client) procedure, IP address (every time the Vendor logs into his account),

• processing period: time necessary to fulfill obligations imposed by the law; for KYC procedure 10 years after the relationship with the Vendor ends.

3. to exchange mailing and e-mail correspondence including handling requests, queries, complaints, and other correspondence:

• source: data subjects, regarding the Buyer's email address: the Vendors,

• legal basis for the processing: processing is necessary for the purposes of the legitimate interest pursued by us or by a third party,

• scope of processing:

• for the Buyers: first and last name, email address, the following company's details (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, other information provided by the Buyer,

• for the Vendors (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, company's phone number; Vendor's representative personal data: first and last name, personal phone number, personal mailing address, personal email address, other information provided by the Vendor,

• for the third parties: (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): first and last name, mailing and email address, phone number, company's details, other information provided to us,

• processing period: until the legitimate interest persists, i.e., until the date on which the further processing of your personal data stops serving its purpose (for example, until We process your request)

4. to defend and pursue claims:

• source: data subjects, regarding the Buyer's email address: the Vendors,

• legal basis for the processing: processing is necessary for the purposes of the legitimate interest pursued by us or by a third party,

• scope of processing:

• for the Buyers: first and last name, email address, postal code, IP address, the following company's details (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, company's TAX ID number,

• for the Vendors (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, company's TAX ID number, company's phone number, company's bank account details; Vendor's representative personal data: first and last name, date of birth, personal identification number, personal phone number, personal mailing address, IP address (when the Vendor logs into his account),

• for the third parties: (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): first and last name, mailing and email address, phone number, company's details, TAX ID number, personal identification number,

• processing period: until the legitimate interest persists, i.e., until the date on which the further processing of your personal data stops serving its purpose,

5. for Transaction Cloud's marketing purposes:

• source: data subjects, third parties,

• legal basis:

• during the term of the contract: our legitimate interest,

• in other cases: your consent,

• scope of processing:

• for the Buyers: first and last name, email address, the following company's details (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address,

• for the Vendors (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): company's name, company's mailing address, company's phone number; Vendor's representative personal data: first and last name, personal phone number, personal mailing address, personal email address,

• for the third parties (provided that the following details are covered by this Privacy Policy only if a relevant regulation on the processing of personal data applies to them): first and last name, mailing and email address, phone number, company's details,

• processing period:

• during the term of the contract: the period of performing the contract,

• based on your consent: until the consent is withdrawn,

6. Certain information is automatically stored when you visit our website to ensure the correct and comfortable use of the website and our services by the Users. This includes details such as your device's operating system (OS), Internet Protocol (IP) address, connection time, type of browser and language, and the website you accessed prior to visiting our website. We also gather information about how you use our products. Please see the section "Cookies" below for more information.

We fully respect the principles of personal data processing resulting from legal regulations, including the principle of data minimization, i.e., We process personal data only to the extent necessary to achieve the purposes for which the data are processed.

Providing your personal data is voluntary, however, failure to provide certain personal information may result in the inability to provide you with our services, especially it may prevent the preparation, conclusion, or performance of a contract.

You can find more information on how We may use your personal data in section "What We Do With Information" below.

Cookies

Our website transaction.cloud uses Cookies. Cookies are tiny text files that a website saves on the hard drive of your device (e.g., computer, laptop, phone). Cookies allow to remember information sent between the website and the browser and to remember data about the websites visited by the Users and their activity on the website, in order to display content tailored to the Users' needs.

We use Cookies for the following purposes:

• identifying Vendors as logged to their accounts and showing that they are logged in,

• remembering data from completed order forms, surveys, or login details,

• adapting the content of the website to the individual preferences of the User and optimizing the use of the website,

• keeping anonymous statistics showing how to use website and researching the needs of Users, with the exception of personal User identification,

• advertising - Cookies enable the presentation of personalized advertisements, tailored to the preferences of the User.

We may use the Cookies for:

• technical cookies:

• to optimize the website and adapting the website to the User's preferences,

• maintain the User's session on the website,

• analytical Cookies:

• to create statistical data on the use of the website by the Users,

• to improve the structure and content of the website,

• marketing Cookies:

• to match the content and forms of information displayed on the website.

The Cookies used by Transaction Cloud can be divided to:

• session and permanent Cookies:

• session Cookies are a temporary information stored in the browser memory until logging out, leaving the website or turning off the web browser; they are necessary for some applications or functionalities to work properly,

• permanent Cookies, are the files that make the use of frequently visited websites easier, e.g., they ensure optimal navigation or content layout; these files remain in the browser's memory for a longer period, which depends on the choice that can be made in the browser settings; these cookies allow information to be transferred to the server each time a website is visited,

• internal and external Cookies:

• internal Cookies -- they come directly from Transaction Cloud,

• external (third party) Cookies -- they come from third parties ex. using Google Analytics -- is such cases the Cookies Policy of these third parties applies).

Information what is the type of a given Cookie file, as well as the date of its storage, can also be found in your web browser options.

You can adjust Cookie settings in your browser.You can opt to set your browser to delete Cookies and reject Cookies if you want. Any functionality would be inaccessible if you have configured your browser to deny Cookies. See your browser's help on adjusting your Cookie settings for more detail on how to deny Cookies.

What We Do With Information

In order to supply, manage, secure, and enhance our products, We use the information that We gather.

We may use your data, for instance, to:

1. improve our services, platform, and how our organization operates,

2. geolocate you (regarding the Buyers, when starting the payment process, to be able to calculate and pay appropriate taxes to the relevant authorities; regarding the Vendors, every time the Vendor logs into his account, in order to prevent misuses),

3. understand and enhancing your experience through our website, goods, and services,

4. provide and distributing the goods and services that you request,

5. order collection, handling, completion, and accounting,

6. provide assistance to the Users and listening to their questions, feedback, and inquiries,

7. invite you to partake in client research,

8. create and maintain online profiles that you create,

9. submit related documents to you, including confirmations, invoices, technical notes, notifications, protection and service warnings, and administrative communications,

10. communicate with you about deals, future activities, and news from Transaction Cloud about goods and services,

11. help clarify your needs and provide you with improved support, connect or combine it with other details that We get from third parties,

12. comply with and implement the regulatory specifications, business guidelines, our regulations, and our terms of use in force,

13. protect, prosecute and discourage illegal, unlicensed, or unconstitutional practices.

Disclosure of Personal Data to Third Parties

No third-party providers are protected by our Privacy Policy. To read about the privacy policy of those third parties, please visit their policies.

We do not disclose your personal data to third parties without your consent except for:

1. We entrust the processing of personal data to third parties working on our behalf (subcontractors), given that these third parties abide by the principles of data protection laid down in the CCPA, GDPR, other relevant legislation, as well as our internal policies and enter into a written agreement with Transaction Cloud requiring third parties to provide at least the same degree of privacy protection as ours (contract for entrusting the processing of personal data),

2. We share the Buyer's data (name, surname, email address, postal code) with the Vendors, to inform a specific Vendor about the payments a Buyer made, in order for the Vendors to provide services for the Buyers; in such a case the Vendor processes the Buyers' data for his own purposes i.e., he also becomes a controller of the Buyer's personal data,

3. We share the personal data with our employees and coworkers on the basis of appropriate authorizations to process personal data, in order to provide services for you,

4. We may share the personal data to comply with the law or to respond to legal requests and legal procedures (ex. to the tax authorities to fulfill our tax obligations),

5. We may share the personal data to protect the interests and property of Transaction Cloud, our agents, Vendors, Buyers, and others, including the compliance of our arrangements, policies, and terms of use (for example, with the courts or other competent authorities, to defend and pursue claims),

6. We may share the personal data in the case of an emergency, including the security of the personal welfare of each person,

7. We may share the personal data for the intent of a business agreement (or settlement of a business deal) involving the selling or conversion of any or part of our business or assets; (business deals may include, for example, any merger, financing, acquisition, divestiture, or bankruptcy transaction or proceeding).

We do not sell personal information.

Data Transfer

Transaction Cloud provides its services in different regions of the world and for this reason may transfer the personal data to third countries, which may have different data protection laws. Any transfer of personal data shall take place only in accordance with applicable laws and ensuring an appropriate level of protection of your data.

Please note, that the data transfer from the European Economic Area to a third country can be made only:

• to countries for which the European Commission has confirmed an adequate level of personal data protection (adequacy decision mechanism), or

• on the basis on Standard Contractual Clauses (template clauses adopted by the European Commission or Data Protection Authority and approved by European Commission), you can ask us for a copy of Standard Contractual Clauses that we use.

Data Security

Transaction Cloud takes your data security very seriously. Organizational and technical safeguards are in place to prevent illegal or improper access to data and to protect data from being inadvertently deleted or destroyed or damaged.

Your personal data are not subject to profiling.

Protection of Your Account Details

Transaction Cloud takes appropriate measures to help secure your information in order to avoid loss, misuse, and unauthorized access, disclosure, modification, and destruction. It is your duty to protect your username and password in order to prevent others from accessing or abusing your accounts and services. You cannot use or reuse the same passwords that you use for other accounts as your password for our services.

Children

If you are under 18 years of age or legally considered a minor in the jurisdiction where you live, you can only use the Transaction Cloud's services with the permission of your parent or legal guardian and only to the extent authorized by the applicable law.

Your Rights Related to the Processing

Transaction Cloud fully respects and implements your rights related to the processing of your personal data. These rights, depending on your place of residence, may apply to you under applicable data protection law provisions, such as CCPA or GDPR.

The rights relating to the processing of personal data are as follows:

1. right to access to your personal data(the right to receive from us the confirmation whether and if so, how We process your personal data),

2. right to request the rectification of personal data

if the personal data are outdated, inaccurate or incomplete,

3. right to request the erasure of personal data („the right to be forgotten")

if your personal data are no longer necessary in relation to the purposes for which they were collected by us, you have withdrawn your consent on which the processing is based and there is no other legal ground for the processing, you have made an objection to the processing, your personal data have been unlawfully processed, the data should have to be erased for compliance with a legal obligation,

4. right to request the restriction of the proceeding of personal data,

when your personal data are inaccurate (for a period enabling us to verify the accuracy of personal data being processed); the data are processed unlawfully but you do not want to erase the data; the data are no longer needed by Transaction Cloud, but they are required by you for the establishment, exercise or defence of legal claims, when you make an objection to the processing of data (pending the verification whether our legitimate grounds override the grounds of objection),

5. right to express the objection to the processing of your personal data

• in case of your objection, when the processing of personal data is based on the legitimate interest of Transaction Cloud, Transaction Cloud shall stop processing your personal data unless proving the existence of significant, legitimate grounds for the processing which objectively should take precedence over the cause of your objection or are necessary to establish, assert or defend the claims, - in case when your objection concerns the processing of your personal data for the direct marketing purposes, your objection or withdrawal of the consent shall result in cessation of processing of your personal data by Transaction Cloud,

6. right to request the data transfer

you are entitled to receive a copy of personal data, which were provided by you to Transaction Cloud if the processing is based on your consent or on a contract, as well as by automated means

7. right to withdraw the consent to the processing of personal data

if the consent is the basis for the proceeding of your data it can be withdrawn by you at any time,

8. right to lodge a complaint with an appropriate supervisory authority.

Please be advised, that when contacting us to execute your rights, before preforming any actions, We can ask you about your place of residence, in a way to establish the law applicable to you. We reserve the right to respond to your request only within the limits of the legal provisions applicable to you.

Specific Notices to California Residents

If you are a California resident there are some specific rules and consumers' additional rights regarding personal data resulting directly from the CCPA.

Please note, that according to the CCPA:

"Personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, for example real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers, but also biometric information.

"Consumer" means a natural person who is a California resident.

"Household" means a group, however identified, of Consumers who cohabitate with one another at the same residential address and share use of common devices or services.

Consumer has the following additional rights regarding the Personal information:

1. upon a verifiable Consumer request:

a) a right to know what Personal information is being collected

In order to execute this right, a Consumer should make a verifiable request, and, after the verification of that request, Transaction Cloud will provide the Consumer with the following information:

§ the categories of Personal information Transaction Cloud has collected about that Consumer,

§ the categories of sources from which the Personal information is collected,

§ the business or commercial purpose for collecting, selling, or sharing Personal information,

§ the categories of third parties to whom Transaction Cloud discloses Personal information,

§ the specific pieces of Personal information Transaction Cloud has collected about that specific Consumer.

The information provided by Transaction Cloud will be limited to 12 preceding months.

b) a right to access Personal information

In order to execute this right, a Consumer should make a verifiable request, and, after the verification of that request, Transaction Cloud shall promptly take steps to disclose and deliver, free of charge to the Consumer, the Personal information required by the Consumer. The information may be delivered by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, readily useable format that allows the Consumer to transmit this information to another entity without hindrance.

c) a right to request the deletion of Personal information

In order to execute the right to delete some or all Personal information, after the verification of that request, Transaction Cloud deletes Personal information, subject to exceptions resulting directly from CCPA. If an exception applies, Transaction Cloud informs you about it in writing.

According to CCPA "Verifiable Consumer Request" is a request that is made by a Consumer, by a Consumer on behalf of the Consumer's minor child, by a natural person or a person registered with the Secretary of State, authorized by the Consumer to act on the Consumer's behalf, or by a person who has power of attorney or is acting as a conservator for the Consumer, and that Transaction Cloud can verify, using commercially reasonable methods.

Transaction Cloud discloses and delivers the required information to a Consumer free of charge within 45 days of receiving an effective Verifiable Consumer Request from the Consumer. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary, provided the Consumer is provided notice of the extension within the first 45-day period. A time period for Transaction Cloud to respond to any Verifiable Consumer Request may be extended by up to 90 additional days where necessary, taking into account the complexity and number of the requests. Transaction Cloud shall inform the Consumer of any such extension within 45 days of receipt of the request, together with the reasons for the delay.

Verifiable Consumer Request:

§ should contain information enabling identification of a Consumer, i.e., Consumer's name and surname, mailing address and email address and in case of a request to access the data, a copy of Consumer's identity document with a photo,

§ if you are acting on behalf of a Consumer, you should provide Transaction Cloud also with a document confirming your entitlement to represent the Consumer, provided that Transaction Clous is authorized to ask the Consumer for authorization,

§ if you act as a household, Transaction Cloud will require all Consumers constituting the household to submit the request.

Verifiable Consumer Request can be made by sending an email containing, respectively, all necessary elements described above to the email address provided in this Privacy Policy.

2. a right to opt-out the sale of Personal information, Transaction Cloud declares that it does not sell and does not disclose Personal information to third parties for marketing purposes. Therefore, Transaction Cloud has not implemented any special procedure to submit Consumer's requests in this regard.

3. a right to non-discrimination,

Transaction Cloud does not discriminate against a Consumer because the Consumer exercised any of the Consumer's rights under CCPA, including, but not limited to, by:

§ denying goods or services to the Consumer,

§ charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties,

§ providing a different level or quality of goods or services to the Consumer

§ suggesting that the Consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

Contact Details

All requests regarding personal data processed by Transaction Cloud, as well as information about your rights in connection with the processing of such data, can be obtained by sending correspondence to the following e-mail address:**contact@transaction.cloud,**through our contact form available here https://transaction.cloud/contactor to the following mailing address:10 Dorrance St., Suite 700, PMB No. 6923, Providence, RI 02903, USA.

Our representative in the European Union Economic Area is:Willans Data Protection Limited, mailing address:2 Pembroke House, 28-32 Upper Pembroke Street, Dublin, Ireland D02 EK84, e-mail:transaction.cloud@willansdps.com

Our representative in the United Kingdom Area is:Willans Data Protection Limited, mailing address:34 Imperial Square, Cheltenham, Gloucestershire GL50 1QZ, United Kingdom, e-mail:transaction.cloud@willansdps.com

Applications are examined with due diligence and without undue delay, usually no later than within one month from the date of receipt of your request. In the event of a complex nature of the request or the number of requests, this period may be extended by another two months, which requires informing you within one month of receiving your request, stating the reasons for the delay. Specific law provisions applicable to you may provide for different deadlines. Regarding California residents, for the information about the appropriate deadline, please check the section entitled "Specific Notices to California Residents" above.

Amendments to This Privacy Policy

This Privacy Policy may be amended from time to time by the Transaction Cloud. We will change the "Last Updated" date above if We make any amendments to this Privacy Policy. You agree that your continued use of our services will constitute your acceptance of such a revised Privacy Policy after such amended Privacy Policy is posted on the transaction.cloud website.