NextPay Merchant Services Privacy Policy
The NextPay Commitment to Privacy and Security
(Modified 12/17/2009)

NextPay, LLC is committed to safeguarding the privacy and security of the information NextPay collects. This statement explains the policies
NextPay follows with respect to the handling of customer information collected by NextPay.Information NextPay Collect. NextPay customers
("Merchants") are businesses and other legal entities desiring to accept credit or debit cards or other payment methods, as payment for goods or
services. NextPay does not have direct relationships with, or collect information directly from, individual consumers other than in their capacity as
owners or operators of a commercial enterprise. NextPay does not provide services for consumer, personal, family or household purposes. The
information NextPay receives and collects is strictly related to our business customers and the payment transactions that NextPay assists them in
executing, as well as from prospective or potential business customers who may be interested in learning more about our services. The transaction
information NextPay receives from our Merchants may include personal financial information about their customers (e.g., credit or debit card account
numbers) who may be individual consumers. NextPay understands that such information is sensitive and takes appropriate steps to protect the
confidentiality and security of all information collected by NextPay in accordance with this Privacy Statement.

Policy

Introduction. Protecting your privacy is important to us. NextPay hopes the following statement will help you understand how NextPay collects,
uses and safeguards the personal information you provide to us on our site.

Information that is being collected online. NextPay collects nonpublic, personal information about you only to the extent required to complete
transactions requested by you and protect you against fraudulent uses of this data. The types of information NextPay collects include your name,
address, telephone number, email address and bank account or credit card data. None of this information is collected without you voluntarily
providing it to us. NextPay collects, retains and uses information about you only for specific business purposes and where NextPay reasonably
believes that it will help administer our business or provide products and services to you. The information is used to protect and administer your
records, account, and funds; to comply with certain laws and regulations; and to help us design and enhance our products and services offerings so
that NextPay may provide you with quality products, services, and superior customer support. NextPay does not license, sell, rent or trade any
collected business information, including contact information or specific information about your accounts or other personally identifiable information
unless: (i) you request or authorize it; (ii) information is provided to help complete a transaction initiated by you; (iii) information is provided to a
reputable credit bureau or similar information reporting agency; or (iv) the disclosure otherwise is lawfully permitted or requested.

Customer's Inquiries. When you complete and submit a form on our website, send us an e-mail, send us a fax, or contact us by telephone to solicit
information about our services or the company in general, NextPay may store the inquiries and their contents. Information you submit via an inquiry
is collected only with your knowledge and active participation, and may be used by NextPay to respond to your inquiries, to contact you, to inform
you of services of NextPay or its partners that may be of use to you, and for similar business purposes. Information collected during the course of
an inquiry will not be disclosed to any third party; provided that such information may be shared internally with our affiliated entities for the business
purposes set forth above.

Opening an Account or Using NextPay Services. When you submit an application to obtain a Merchant account and become a Merchant, you will
be required to provide us with certain information about your business, and its owners and officers, which may also act as guarantors of the
Merchant's obligations. NextPay may also obtain and store information about the Merchant, and its officers, owners and guarantors, from consumer
reporting agencies, credit bureaus, relevant financial institutions, and other entities. NextPay may use, retain and disclose this information to (i)
comply with any applicable federal legislation requiring NextPay to obtain, verify, and record information that identifies each entity with which it
establishes a Merchant relationship, (ii) evaluate your eligibility for a Merchant account, which may involve disclosure to consumer reporting
agencies, commercial credit bureaus, and relevant financial institutions. NextPay may also use your information to contact you about other NextPay
offerings and services. If you are, or become a Merchant, NextPay may disclose your information during the course of providing such services to
card associations, banks and other financial institutions that are involved in the course of processing or screening the transaction, and to third parties
that have contracted with NextPay to perform certain functions of our services on our behalf. In addition, NextPay may use, or disclose your
information to third parties for the additional purposes of facilitating and completing merchant-initiated or authorized transactions, complying with
federal, state and local laws, including credit reporting laws and card association rules, assisting in preventing fraud, or informing you about general
company news, product updates and developments, card association rules, and industry trends, offering you products and services that may be of
interest to you, or as otherwise may be permitted or required by applicable law.

Customers of Our Merchants. If you purchase a product or service from a Merchant using a credit or debit card, or any other method of payment for
which NextPay provides the Merchant with transaction processing services, you will likely provide that Merchant with certain personal information
which may include, for example, your name and credit card number. Our Merchants may transmit certain of this information ("Order Information"), to
NextPay for the purpose of processing the transaction. NextPay will use Order Information during the course of providing processing services to
such Merchant. During the course of providing processing services to our Merchants, NextPay may disclose Order Information to banks,
processors, credit and debit card organizations and associations, and other financial institutions that are involved in the course of effecting the
transaction represented by the Order Information. In addition, NextPay may disclose some or all of the information NextPay collects, to our affiliated
companies or to non-affiliated third parties (subject to contractual confidentiality provisions to protect such information) such as a vendor or service
company that NextPay hires to prepare our Merchants' account statements or to provide support or services for one or more of our products.
NextPay will not disclose Order Information to any third party, except to facilitate and complete transactions submitted to us by Merchants, or
otherwise in the course of providing services to our Merchants, or to comply with federal, state and local laws or the rules and regulations of the
respective card organizations or other payment entities (e.g. Visa, MasterCard, American Express, NACHA, etc.).

Cookies. To help make our sites more responsive to the needs of our visitors, NextPay uses a standard feature of browser software, called a
"cookie," to assign each visitor a unique, random number, a sort of user ID, if you will, that resides on your computer. The cookie doesn't actually
identify the visitor, just the computer that a visitor uses to access our site. Unless you voluntarily identify yourself (through registration, for example),
NextPay won't know who you are, even if NextPay assigns a cookie to your computer. The only personal information a cookie can contain is
information you supply. A cookie can't read unrelated data off your hard drive. Our advertisers and the third parties that provide products or services
through our site may also assign their own cookies to your browser, a process that NextPay does not control. NextPay uses cookies to help us
tailor our site to your needs, to deliver a better, more personalized service. In this light cookies are used to retain only information such as address
and billing information that you request us to retain. No information is retained without you initiating the action. Of course, you can set your browser
not to accept cookies, but if you do, you may not be able to take advantage of the personalized features enjoyed by other visitors to our site.

Browser Level Information and IP Addresses. The NextPay web servers automatically collect limited information about your computer configuration
when you visit our site, including the type of browser software you use, the operating system you're running, the resolution of your computer
monitor, the website that referred you, and your IP address. (Your IP address is a numerical address that is used by computers connected to the
Internet to identify your computer so that data (such as the web pages you want to view) can be transmitted to you. NextPay also uses IP address
information for fraud scoring so that your financial data can be better protected. Your IP address does not tell us who you are.) NextPay uses this
information to deliver our web pages to you upon request, to tailor our site and to measure traffic within our site.

Third-Party Web Sites. NextPay may create links to third-party Web sites. In addition, NextPay may authorize third-parties to create links to
NextPay websites. NextPay is not responsible for the content or privacy practices employed by third-party Web sites. Neither does NextPay
control or warrants the utility, merchantability or workmanship of the products or services offered at third-party Web sites.

Online Advertising. NextPay also may use cookies to track advertising leads and campaigns from banner advertisements and third party
advertisement services. NextPay may hire third party companies such as advertising services to track and report performance of advertising and
marketing campaigns to and from NextPay and third party web sites. These companies may also set cookies and use related technology, such as
tracking pixels. These tracking pixels (also known as action tags, web beacons, or transparent GIF files) and other similar tracking technologies
may be used to collect and store information about user visits, such as the user's anonymous cookie ID, page visits and duration, and the specific
ad or link(s) that the user clicked on to visit the site. No personally identifiable information is stored on these cookies or web pixels. This user
activity information is reported to us in aggregate and is anonymous. NextPay uses this information in aggregate to understand, for example, the
effectiveness of our advertising and marketing.
Information Sharing. The information NextPay collects is only used to process the transactions that you either initiate or approve. Email addresses
and other personal information is collected in order to communicate Invoice or other pertinent information to you. None of the information gathered is
ever sold, and is only shared with third parties in order to complete transactions.

Marketing uses of the collected information. None of the information gathered is currently used for marketing purposes. If any information is used for
marketing in the future you will be notified and given the opportunity to opt out of such sharing prior to implementation.

Protection of Cardholder and Customer Data. NextPay has implemented various measures, including appropriate administrative, technical and
physical safeguards, designed to ensure the security and confidentiality of cardholder and customer data, protect against anticipated threats or
hazards to the security or integrity of such information, and protect against unauthorized access to or use of such information. Such measures may
include, among others, encryption, physical access security and other appropriate technologies. NextPay continually reviews and enhances its
security systems, as necessary. NextPay is subject to the detailed rules and regulations of the various credit and debit card organizations and
networks (i.e. VISA, MasterCard, American Express, NYCE, Star, etc.), relating to the security and safeguarding of cardholder information, including
the Payment Card Industry Data Security Standards ("PCI"), VISA U.S.A.'s Cardholder Information Security Program ("CISP") and MasterCard
International's Site Data Protection Program ("SDP"). NextPay endeavors to comply with all such rules at all times. Pursuant to such rules and
regulations, NextPay is required to undergo periodic third-party assessments and periodic network scans to ensure that, among other things,
NextPay has installed and maintains a firewall configuration to protect data; does not use vendor-supplied defaults for system passwords and other
security parameters; protects stored data; encrypts transmission of cardholder data and sensitive information across public networks; uses and
regularly updates anti-virus software; develops and maintains secure systems and applications; restricts access to data to those with a business
need-to-know; tracks and monitors all access to network resources and cardholder data; regularly tests security systems and processes; assigns a
unique ID to each person with computer access; restricts physical access to cardholder data; and maintains a policy that addresses information
security. Additional information regarding the requirements of VISA's CISP and MasterCard's Site Data Protection program (SDP) can be found on the
VISA USA and MasterCard International Web sites.

Merchant's Responsibilities. Merchants are also required to comply with various rules and regulations of the various credit and debit card
organizations and networks relating to the security and safeguarding cardholder information, including PCI, CISP and SDP. Merchants may be
required to undergo periodic third-party data security assessments and periodic network scans to ensure that appropriate security measures are in
place.
Children. NextPay does not solicit or knowingly accept information from persons under the age of eighteen (18). Our web sites are not designed with
the intent to attract or encourage viewing by children.

Enforcement. All NextPay employees are responsible for ensuring that the policy laid down in this document is adhered to. Staff should be aware
that failure to carry out the duties and responsibilities discussed in this policy will be subject to disciplinary action and could result in dismissal.
Modifications to Privacy Policy. NextPay continues to review our policies and procedures to assure that they are effective in meeting our
commitments to our customers. NextPay reserves the right to change this privacy policy without notice at any time and from time to time, including
as needed to comply with the rules and regulations of the various debit and credit card organizations, or to comply with applicable local, state and
federal laws and regulations.
Inquiries

If you have a question or comment regarding this Privacy Statement, please contact,

NextPay, LLC
Attention: Chief Operating Officer
2245 Keller Way, Ste 360
Carrollton, TX 75006
214-234-1122