Privacy Policy

Introduction

FS Holdco Inc. d/b/a FS Acquiring, its subsidiaries and affiliated companies ("FSA," "we," "our," "us") collects information about you when you visit, access or use, as applicable, our website, products, or services (collectively, the "Services"). We receive information about you from various sources, including: (i) when you request information regarding the Services from our sales and/or customer support team (whether by telephone, email or text); (ii) if you register for the Services by creating a user account on the Services (your "Account"); (iii) your use of the Services generally; and (iv) from business partners and third party websites and services. This privacy policy (the "Privacy Policy") describes how we may collect, use, or disclose information from users of our Services ("User", "you," "your"); your choices regarding our use of your information; how we safeguard such information; and how you may contact us regarding our privacy practices. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service (fsacquiring.com/terms-conditions).

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications ("Third Party Services") that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

Categories of Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

Information you provide:

We collect information that you provide in relation to the Services, such as when you sign up for an Account, send us an email, or request information. This may include information like your name, email address, phone number, and other contact details. You acknowledge that all this information may be personal to you, and by providing personal information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may retain copies of these communications for business, legal, or support-related purposes.

Transaction Information:

If you make a purchase through our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor ("Processor") on our behalf. We or the Processor may also collect information about the transaction, such as the time and location of the transaction, the payment amounts, and additional details about the transaction, and the devices and payment methods used to complete the transaction. Use and storage of that information by a Processor is governed by the Processor's applicable terms of service and privacy policy.

Records and Financial Information:

In order to provide the Services, we may collect financial information, such as bank account and routing information, payment method information (card number, type, expiration date or other financial information), and transaction information (collectively, "Financial Information"), from you. We may also ask you to provide some of your Financial Information during the account registration process. We also may receive Financial Information from Third Party Services that help us to provide the Services to you.

Usage Information:

To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view and the dates and times of your visits.

Information From Cookies and Other Tracking Technologies:

We may collect certain information automatically through cookies and similar tracking technologies, including IP address, device type, browser, operating system, and referring URLs. When you visit our website, a cookie banner will appear that allows you to review and manage your cookie preferences. By continuing to use our website or clicking "Accept All", you agree to our use of cookies as described in this Privacy Policy. You may also manage or disable cookies through your browser settings. Please note that doing so may limit some functionality of our website.

Information collected from other parties:

We may receive additional information about you from service providers, vendors, or other third parties, such as third parties that facilitate transactions made through the Services, and combine it with other information we have about you. For example, if you interact with a third-party integration (such as a chat tool or scheduling form), that provider may pass data to us. Such interactions are subject to those third parties' terms and privacy policies.

Statistical Information:

We collect statistical information about how Users use the Services ("Aggregate Information"). Statistical information is de-identified, non-personal information and cannot be tied back to you, your Account or your web browser.

How We Use and Process the Information We Collect

We process and use the information we collect to:

• Provide, operate, maintain, and improve our Services;
• Personalize your experience on our Services such as by providing tailored content and recommendations;
• Communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and inquiries, and otherwise provide customer support;
• Monitor and analyze how you use our Services and develop new products, services, features, and functionality;
• Facilitate transactions and payments;
• Facilitate the connection of third-party services or applications;
• Generate anonymized or aggregate data containing only de-identified, non-personal information that we may use for any lawful purposes such as to publish reports;
• Comply with applicable laws and regulations or requests by any judicial process or governmental agency, or for enforcing our Terms of Service or other legal rights;
• Detect and/or prevent fraud or security threats, and respond to trust and safety issues that may arise;
• Fulfill any other purpose disclosed to you at the time of collection or with your consent.

How We Disclose the Information We Collect

We may share information we collect with:

• Our affiliates and subsidiaries;
• Service providers and vendors who assist with providing the Services;
• Parties involved in a business transaction (e.g., a merger, acquisition, reorganization, or asset sale);
• Law enforcement, regulators, or courts when required to do so by applicable law or to protect our rights;
• Other third parties with your permission.

How Long We Store Your Information

We will retain your information as long as needed to provide you with the Services and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

• mandated by law, contract or similar obligations applicable to our business operations;
• for preserving, resolving, defending or enforcing our legal/contractual rights; or
• needed to maintain adequate and accurate business and financial records.

For the avoidance of doubt, if you ask us to delete specific personal information from your Account, we will honor this request only to the extent such information is no longer necessary to provide the Services or required for our legitimate business purposes, like billing for the Services, or legal or contractual record keeping requirements.

Information for California Residents

We are required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act ("CCPA") to provide to California residents an explanation of how we collect, use and disclose their personal information, and of the rights and choices we offer California residents regarding our handling of the personal information. Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, sharing or selling that personal information.
• The categories of personal information about you that we "shared" or sold and the categories of third parties with whom we "shared" or to whom we sold the personal information about you.
• The categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
• The specific pieces of personal information we collected about you, including a copy of such personal information in a portable format (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products or services to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) or other applicable laws.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Sale or Sharing of Personal Information

We do not sell your personal information to any third-party for monetary compensation. Our websites and online services may use analytics and advertising tools that enable us and our analytics and marketing partners to collect and disclose internet or other electronic network activity information based on your activity across our services and sites, including to analyze your usage of our services and to serve you advertisements that are relevant to you (collectively, "cross-context behavioral advertising"). However, please note that we do not knowingly sell or share the personal information of consumers under 16 without consent.

You have the right to opt-out of our sale or sharing of your personal information by submitting a verifiable consumer request to operations@fsacquiring.com.

Collection, Use, and Disclosure of Sensitive Personal Information

We do not collect, use, or disclose "sensitive personal information" beyond the purposes authorized by the applicable law. Accordingly, we only use and disclose sensitive personal information as reasonably necessary and proportionate to: providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use sensitive personal information beyond these purposes.

Right to Request Correction

To the extent that we may maintain inaccurate personal information, you may have the right to request that we correct such inaccurate information taking into account the nature of the personal information and the purposes of the processing of the personal information.

How to Exercise Your Rights

If you are a consumer and wish to make a request pursuant to your rights under the CCPA, please submit a verifiable consumer request to operations@fsacquiring.com. Be sure to use the phrase "Privacy Request" in the subject line. Only you or a person registered with the appropriate regulatory authority that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We attempt to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Vendor Integrations and Features

Our Services may offer features supported by third-party vendors (e.g., embedded forms, chat tools, or scheduling systems). Any information you provide through those tools may be processed by those vendors and subject to their privacy practices.

Additionally, our Services may include third-party content or social features that may collect your data independently of us. We are not responsible for the privacy policies or practices of those third parties.

Children's Privacy

Our Services are intended for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at operations@fsacquiring.com.

How We Store and Protect Your Information

We take reasonable administrative, technical, and physical security measures to protect your information under our control. However, because no system can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Linked Websites

Our Services may contain links to external websites not operated or controlled by FSA. We are not responsible for the content or privacy practices of these third-party sites and encourage you to review their policies before submitting any personal information.

Information for Users Outside the United States

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to access or use our Services from regions outside the United States with laws governing data collection and use that may differ from U.S. law, you acknowledge that you are transferring your personal information outside of those regions to the U.S. for storage and processing.

Revisions

We may update this Privacy Policy periodically. When we do, we will revise the "Effective Date" at the top of this page. Continued use of the Services after changes are posted constitutes your acceptance of the revised policy. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

Contact Information

For questions about this Privacy Policy or you would like to know more about how to exercise your rights, please send us a detailed message to operations@fsacquiring.com. We will provide reasonable and timely assistance to you to resolve your concerns.