Spectrum Privacy Policy

Effective date: March 5, 2025

Spectrum Global Payment Solutions, Inc. (“Spectrum,” “we,” “us,” or “our”) provides money transmission services (“Services”) as a service provider to third parties and to our own customers. This Privacy Policy describes our practices related to the use, storage and disclosure of information we collect from or about you in the course of providing the Services whether through our website spectrum-gps.com or mobile applications (collectively, our “Site”) or third-party websites or mobile applications. We reserve the right to modify this Privacy Policy at any time and without prior notice. This Privacy Policy is incorporated into and is a part of our Terms and Conditions. By accessing our Site or using the Services, you are consenting to our collection, use, storage and disclosure of information as set forth in this Privacy Policy.

• Our Security Procedures
• Collection and Use of Information
• Location Information
• Disclosure of Personal Information
• Access to Your Information
• Your Choices
• Cookies
• Do Not Track Signals
• Data Retention
• Protecting Children's Privacy
• Links to Third-Party Websites
• California Consumer Privacy Act Notice
• Revisions to Privacy Policy
• Contacting Us
• Federal Consumer Privacy Notice

Our Security Procedures

We maintain physical, technical and administrative safeguards that comply with federal standards to safeguard your personal information. Personal information includes "nonpublic personal information," which is nonpublic information about you that we obtain in connection with providing a financial product or service to you. We also take steps to safeguard your information and restrict access to your personal information to employees who need to know that information to provide products or services to you. When your personal information is transmitted via the Services, it will be protected using encryption technology.

While we take steps to protect your personal information and keep it secure, you also play a role in protecting your information. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your personal information. You can help to maintain the security of your transactions by not sharing with anyone your log-in credentials for any account used to send instructions for Services. If we receive instructions from an account accessed using your log-in credentials, we will assume that the instructions have been authorized by you.

Collection and Use of Information

We may collect the following types of personal information about you from the following sources:

• Information we receive from you when you register to use the Services, when you contact us, when you use the Services or when you provide information to us through other forms. This information may include, but is not limited to: identifiers (e.g., name, address, mobile phone number, and email address), protected information (e.g., social security or driver's license number, financial account information, and log-in information, such as a username and password), electronic network activity information (e.g., automatically collected information; see below), audio information (e.g., recorded customer service calls), sensitive personal information as defined by the CCPA (see below), and information about transactions that you initiate or receive.
• Information we receive about your transactions with us from members of our corporate family ("affiliates") or others.

We (or our service providers acting on our behalf) may automatically collect personal information about your use of the Services. This information includes information that may identify you, as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with your personal information. We also use cookies and similar technologies (see below) to collect information. Information that we automatically collect in connection with your use of the Services may include:

• Device information, such as your hardware model, operating system version, unique device identifiers, and mobile network information, including your mobile phone number. We may associate your device identifiers or mobile phone number with your account.
• Log information from your devices, their software, and your activity using the Services, which may include:
  • The device's Internet Protocol (“IP”) address;
  • Identification numbers associated with your devices;
  • Device event information, such as crashes, system activity, and hardware settings;
  • Location preferences;
  • Page views, clickthroughs, referral and exiting URLs, and time spent on pages;
  • Date and time stamps associated with transactions [or your access to our Site]; and
  • System configuration information and other interactions with the Services.

We may use your personal information internally for our own business purposes, including, but not limited to:

• Responding to your inquiries and other messages
• Providing marketing materials and emails of our own products and services or those of our third-party business partners
• Audience measurement and analytics (e.g., understanding of how our Site is used, the locations where you engage with the Services, and engagement with social media and other marketing channels, such as email, and measuring clickthroughs from URLs, where applicable)
• Providing location-specific services, where available
• Cybersecurity and fraud detection
• Compliance with applicable law
• Responding to lawful requests by public authorities
• Establishing, exercising or defending legal claims
• Optimizing our Site and the Services
• A merger, dissolution, reorganization or similar corporate event or the sale of all or substantially all of our assets (including, in each case, any due diligence relating thereto)
• Internal purposes aligned with consumer expectations
• As otherwise either disclosed to you (e.g., via “just-in-time” notices) or pursuant to your consent.

Please read our Federal Consumer Privacy Notice below for information on our collection and use of your non-privacy personal information.

We may use Analytics and other aggregated data that does not identify you personally for research and commercial purposes. We may use your postal address or email address to contact you to respond to your inquiries or to provide information on our, our affiliates' or third parties' products or services.

Location Information

Location services may be required for the use of the Services. Precise location information may be accessed with your consent when you are registering to use the Services or choose to use location-based services. You control your location information preferences through your device settings. If you disable location information, some services may not be available to you.

Disclosure of Personal Information

We may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. We may disclose your public, aggregated, or otherwise non-personal information, such as usage statistics of the Services, to third parties.

We may disclose personal information about you to third parties without your consent in certain circumstances; for example, we may provide such information: (1) to third parties to assist us in processing your money transmittal or provide another service or product you have requested; (2) to our service providers, agents and contractors who work on our behalf to provide services you request; (3) to comply with federal, state, or local laws, rules, and other applicable legal requirements; or to comply with a properly authorized civil, criminal, administrative, or regulatory investigation subpoena or summons by federal, state, or local authorities; or to respond to judicial process or government regulatory authorities having jurisdiction for examination, compliance, or other purposes as authorized by law; (4) to consumer or credit reporting agencies, (5) in connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit, if the disclosure concerns solely information about consumers of that business or unit, or (6)(A) to protect the confidentiality or security of our records pertaining to the consumer, the service or product, or the transaction therein; (B) to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability; (C) for required institutional risk control or resolution of customer disputes or inquiries; (D) to persons holding a legal or beneficial interest relating to the consumer; or (E) to persons acting in a fiduciary or representative capacity on behalf of the consumer.

Please read our Federal Consumer Privacy Notice below for information on our disclosure of your non-privacy personal information and your choices in that regard.

Access to Your Information

After you register on our Site or to use the Services, you may review your information and preferences by visiting the Profile page. There you may make any changes or corrections to your information or preferences. If you have any questions, you may contact us as indicated in the “Contacting Us” section below.

Your Choices

You may control our Site features that collect specific types of information. You can stop all collection of information by uninstalling the mobile application from your device.

You can choose not to receive promotional emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your account or your transactions with us.

You can choose to delete or block cookies by setting your device browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies, performance of our Site may be impaired, and certain features may not function at all.

You may at any time opt out from allowing our access to your location information by disabling location tracking features in your device settings. Turning off your device's location tracking features may prevent certain location-based services from functioning.

Cookies

We use cookies, tracking pixels, web beacons, and similar technologies to personalize our Site for you, to collect aggregate information about Site usage by all of our users, and to remember your preferences. A cookie is a text file that our Site transfers to your mobile device for record-keeping purposes and to enhance the quality of your experience with the App. The cookie assigns a random, unique number to your mobile device. Our cookie records "clickstream" information (data reporting on your use of our Site). Site use cookies may stay on your browser into the future until they expire or you delete them. We also use technology that assists in the functionality of our Site. These cookies usually are erased when you close your browser window.

We may permit certain third parties to place cookies through the Services to provide us with better insights into the use of our services and user demographics and to provide relevant advertising to you. These third parties may collect information about your online activities over time and across different websites when you use the Services. For example, we utilize Google Analytics to analyze usage patterns for the Services. Google Analytics generates a cookie to capture information about your use of the Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for the Services, as indicated above, to perform analytic or marketing functions where you are notified of them and have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.

By accessing or using the Services, you consent to the placement of cookies on your devices as described in this Privacy Policy. Further general information about cookies and how they work is available at www.allaboutcookies.org.

Do Not Track Signals

Except as provided in this Privacy Policy, we do not use technology that recognizes or responds to “do-not-track” signals from your web browser.

Data Retention

Our operational systems will store information you provide to us for as long as you use the Services. Please note that some or all of the information you provide may be required in order for our Site to function properly, and we may be required to retain certain information by law. If you close your profile established to use the Services, we will retain certain account data, such as transaction history, for a reasonable time.

Protecting Children's Privacy

Our Site is not designed nor intended to be attractive to use by children under the age of 18 ("Minors"). We do not knowingly collect information from or market to Minors. If you are under the age of 18, please do not submit any information to us.

Links to Third-Party Websites

When you use the Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to the Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to our Site and the Services.

California Consumer Privacy Act Notice

This California Consumer Privacy Act (“CCPA”) privacy notice (this “CCPA Notice”) is part of our Privacy Policy and applies only to our processing of “personal information” of California “consumers” (as the terms “personal information” and “consumer” are defined under the CCPA) (collectively, “Consumers, “you,” or “your”). Any capitalized terms not defined in the Privacy Policy shall have the meaning given to them in the CCPA. For clarity, personal information within the scope of our Federal Consumer Privacy Notice is not subject to this CCPA Notice.

To the extent of any conflict between this CCPA Notice and the rest of our Privacy Policy, this CCPA Notice shall control only with respect to California Consumers and their personal information.

Information collected, sources, business uses and disclosures.

We collect personal information from the sources and for the business uses and disclose it as described in Collection and Use of Information, Location Information, and Disclosure of Personal Information sections above.

Selling and Sharing Personal Information

We do not sell your information for monetary or any other valuable consideration. We do not share personal information with third parties for their use for cross-context behavioral marketing purposes.

Sensitive Personal Information

Sensitive personal information includes your social security, driver's license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, genetic data, biometric information, health, sex life or sexual orientation. The CCPA allows us to use and disclose this type of information for specific purposes that allow us to operate our business. We only use or disclose this type of information for those permitted purposes.

Your CCPA Rights and How to Exercise Them

Verified California residents have the right to:

• Request and receive disclosure of our personal information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information.
• Request and receive a copy of the personal information we have collected about them during the prior 12 months.
• Request and receive disclosure of our information disclosure practices during the prior 12 months, including a list of the categories of personal information sold with the category of third-party recipients and a list of the categories of personal information that we disclosed for a business purpose.
• Request that we not sell personal information about them. (We do not sell your information.)
• Request that we not share personal information for cross-context behavioral marketing purpose. (We do not share your information for these purposes.)
• Request that we correct information that is inaccurate.
• Request that we not process or disclose sensitive personal information except as permitted by the CCPA (We only process or disclose sensitive personal information as permitted by the CCPA).
• Request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.

In order to make a request for disclosure, California residents may contact us by either calling 1-800-622-1367 or emailing us at Help@spectrum-gps.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request. If we require more time (up to an additional forty-five days), we will notify you of our need for additional time. Please understand that we cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

You may make a request for disclosure of our information collection practices, the information we collected about you, or our disclosure practices up to twice within a 12-month period. You may make a request that we correct or delete your information at any time. You do not need to opt out of selling or sharing your information or to limit our processing or disclosing your sensitive personal information because we do not engage in these activities.

For requests for a copy of the personal information, we have collected during the 12 months prior to your request, we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account (if you have registered an account with us).

For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records); and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.

You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California; (2) you provide the authorized agent with signed written permission to make a request; (3) you verify directly with us that you have authorized the person to make the request on your behalf; (4) you verify your own identity directly with us; and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

We will not discriminate against you as a result of your exercise of any of these rights.

If you have questions about your rights or how to exercise them, please contact us using the information below.
Website www.spectrum-gps.com/ccpa/ccpa_request.aspx

Revisions to Privacy Policy

We reserve the right to amend or modify this Privacy Policy at any time. As our business grows and the Services evolve, we may from time to time amend this Privacy Policy. If we make material changes, we will post the revised Privacy Policy on this page with an updated effective date so that you will know when it was last updated. We may endeavor to notify you electronically of any material changes to this Privacy Policy in accordance with the Terms and Conditions. Your use of our Site or the Services following an update to this Privacy Policy means that you accept the updated Privacy Policy. If your relationship with us becomes inactive or is terminated, we will continue to adhere to the policies and practices described in this Privacy Policy, unless you consent to the change or it is legally permitted.

Contacting Us

If you have any questions regarding privacy while using our Site or the Services, or have questions about our practices, you can send a message using our Contact Us page, write to us at 2200 Post Oak Blvd., Suite 2150, Houston, TX 77056, call us at 1-800-622-1367, or email us at help@spectrum-gps.com.

Federal Consumer Privacy Notice

This Federal Consumer Privacy Notice is provided to consumers and customers (as those terms are defined in the Gramm Leach Bliley Act) of Spectrum.