September 3, 2025

SnapPays Mobile, Inc. d/b/a Papaya Payments (Papaya) respects your privacy and is committed to protecting it through compliance with this privacy policy ("Privacy Policy"). The Privacy Policy describes the information we collect about you, how it is used, and with whom it is shared, and it explains the rights and choices you have to control how we handle your Personal Information.

This Privacy Policy describes:

• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• ONE Bill Pay (specifics to this program)
• Cookies, Web Beacons, and Similar Technologies
• Your Choices
• How We Protect Your Personal Information
• Your State Privacy Rights
• Children's Privacy
• How to Contact Us
• Updates to the Privacy Policy

This Privacy Policy governs all Papaya-operated websites (including papayapay.com and ppaya.com), and all Papaya-operated mobile applications, including iOS and Android Applications (the “App” or “Apps”) and Papaya subscriptions (collectively, the “Services”). In this Privacy Policy, “Papaya,” “we,” or “our'' means SnapPays Mobile, Inc. d/b/a Papaya Payments. This Privacy Policy applies to information Papaya collects about you or other communications or services we offer from time to time in connection with any of the foregoing ("Services"). This Privacy Policy does not apply outside of the United States and its territories.

Unless stated otherwise, our Privacy Policy applies to all information Papaya collects that is or reasonably could be associated with you, including your online account information (“Personal Information”). Please read this Privacy Policy before using or accessing the Services. By using our Services, you communicate your understanding and acceptance of this Privacy Policy.

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Personal Information We Collect

Information You Provide to Us

We receive and store any information you provide in connection with our Services. You can choose not to provide certain information, but this may limit your ability to take advantage of some features, promotions, or other Services.

• Contact and Registration Information - such as your name, address, email address, username and password.
• Identification Data - such as your driver’s license number, other government ID number (e.g., SSN), passport number, medical ID number, or employer identification number and date of birth.
• Linked Financial Account Data - such as your financial account number, payment card number, or username and password to an online account.
• Bills - includes any information contained in photographs of bills that you upload to use the Services, including health and wellness data, information on purchases, and account balances.
• Transaction Information - such as information related to your payment transactions.
• Questionnaires, surveys, or contests - includes any information you provide when participating in surveys or contests that Papaya may run from time to time.
• Interactions with Papaya Associates - includes any communications and requests to Papaya associates, such as for customer assistance.
• Content you post to our Websites - such as comments that you post to our Websites, forums, and discussion areas.
• Other information you provide - such as profile data that you upload to your account.

Information We Collect Automatically

We and our service providers may use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer our Websites and improve functionality, and to gather general demographic information about our user base as a whole. For more information about what cookies are and how we use them, please see “Cookies, Web Beacons, and Similar Technologies” below. The information we may collect automatically through such technologies may include:

• Device Information such as your IP address, browser information, and device type.‍
• Usage information such as browsing behavior on our Websites, URL information, clickstream information, telemetry on your interactions with our Services, and date/time stamps.

Information We Receive from Third Parties

We may collect or receive information about you from third parties that perform services and analytics for us. Such companies may include credit bureaus such as TransUnion, Equifax, and/or Experian, data providers, identity theft & fraud detection services and data analytics providers, as well as certain of our Third Party Service Providers and their partners. Such information, which may include your credit history and credit scores, from credit bureaus and other partners to determine your creditworthiness if you are a borrower. By providing your information to the third party, you acknowledge and agree that information accessed, collected, or transmitted by the third party for this purpose will be governed by the privacy policy of the third party.

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How We Use Your Personal Information

We use your Personal Information to provide, support, personalize, and develop our Services. In particular, we may use your Personal Information:

• To Provide Our Services, such as to provide products and services that you request; create and manage your account; and provide and manage the Services.
• To Market and Advertise to You, such as to send you updates, newsletters, promotions, and surveys; personalize notifications and service offerings to you; manage your participation in events and sweepstakes; communicate with you about our products and services; publish customer testimonials or photos; analyze our marketing strategies and trends regarding your use of our website or social media channels; improve the effectiveness of our marketing campaigns; and/or send follow-up communications thanking you for your business or inquiring as to your satisfaction.
• To Improve Our Services, such as engage in analysis, research, and reports regarding use of the Services; track the efficacy of our Websites and/or improve the Website experience; and for troubleshooting and maintenance purposes.
• To Secure our Services and Users, such as protect against error, fraud, unauthorized transactions, claims and other liabilities; manage exposure to risk from unauthorized users; enforce the terms of use on our site; and/or comply with applicable legal mandates, our policies, or industry standards.
• To Provide Customer Service, such as provide customer service when you need help and/or to improve customer experiences; provide status updates on requested transactions; or inform you about product releases or updates.
• Or for any other purpose not listed here, with your consent.

In addition to the above purposes, we may collect and summarize customer and visitor information in aggregated, de-identified form for any purposes, including statistical or research.

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How We Share Your Personal Information

As explained in greater detail below, we may disclose certain categories of Personal Information for the purposes and with the types of entities set forth in this section for business purposes (as defined by applicable law) or as required by applicable law:

At Your Direction

We may share your Personal Information with third parties when you direct us to do so, such as to pay a third party based on a bill you upload to the Services.

Service Providers

We may share your Personal Information with other entities who perform services on our behalf such as payment processing, email distribution, sending marketing communications, servicing products, maintenance of your account, conducting research surveys, verifying and validating information that you have provided to us, and providing customer support services. Such entities are contractually obligated to maintain the confidentiality of your personal information.

Papaya uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Services, you grant Papaya and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

If you subscribe to and use the Papaya Privacy Protection Subscription (“Privacy Protection” or “Privacy Subscription” or “Privacy Service” or “Identity Protection”) service, it is delivered to you by Papaya in partnership with Array US Inc. Information you share with Papaya for the purposes of paying bills or for using any other products offered by Papaya is not shared with Array US Inc.

Sale or Transfer of Business or Assets

Your Personal Information may be transferred or disclosed to a purchaser or prospective purchaser in the event of a sale, assignment, or other transfer of all or a portion of our business or assets.

Legal Disclosure

We may disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect your or our rights or safety, or that of others, or to protect the security or integrity of our Service, including but not limited to by exchanging information with other companies and organizations for anti-fraud/anti-bot and risk reduction purposes.

Links to Third-Parties

Links to third-party websites are provided as a convenience to you. Once you leave our website, we neither control nor have responsibility for third-party sites, their content, or their privacy practices. We encourage you to read the terms and conditions and privacy policy of each third-party service that you access or utilize.

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ONE Bill Pay

Notwithstanding anything to the contrary herein, if you are accessing Papaya through ONE, Papaya will use your data solely to conduct the bill pay services you have requested through ONE.

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Email, SMS and Push Notification Communications

We may communicate with you about our products and services using email, SMS or push notifications. When we communicate with you using email, SMS or push notifications, we may collect information regarding such communications. We use this information to operate and improve Papaya’s customer service and other Papaya Services. If at any time you do not wish to receive the benefit of communications, you can opt out of notifications using the Unsubscribe (email) or STOP (SMS) options. Please note that turning off notifications may impact your Papaya experience.

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Cookies, Web Beacons, and Similar Technologies

We may use cookies and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. For detailed information on the cookies we use, the purposes for which we use them, and how to disable them, see below.

Cookies: We automatically collect information through the use of cookies. Cookies are small text files stored by your Web browser. Cookies allow us to identify and authenticate visitors, track aggregate behavior, and enable site features. For instance, we or authorized third parties may use cookies to help improve the site experience or prevent fraud.

We use session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. We use session cookies to maintain your shopping state as you browse through the site. We also contract with analytics services and third-party advertising companies to collect similar information for specific purposes. The use of cookies by our partners is not covered by this Privacy Policy.

Most browsers will tell you how to manage your cookies, often through the "help" area on your browser's toolbar. Because cookies allow you to have the benefit of our personalized features, we recommend that you leave them turned on. Disabling cookies for our Websites may impact their usability.

Post-Checkout Offerings: If you are presented with a post-checkout offering, the payment details gained during bill payment checkout may be securely retained in your local browser. If you elect to subscribe to any of Papaya’s suite of products (e.g. Papaya Privacy), which includes accepting Papaya’s Terms of Service and Privacy Policy, your payment data is then securely encrypted using RSA public key encryption. If you decline to subscribe, all locally stored data is automatically deleted when the session ends.

Social Media

Our sites include social media features, such as the Facebook "Like" button and widgets, the "share this" widget, or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. If you choose to interact with these features, any information collected in the course of such interactions is governed by the privacy statement of the company providing it. We may post Papaya information on social media sites. Depending on your privacy settings on these platforms, your comments and other reactions may be visible if you respond.

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Your Choices

Accessing, Changing, and Modifying Your Account Information and Settings

We provide a number of choices about the collection, use, and sharing of your Personal Information:

• If you have created an account (optional for Bill Pay service, mandatory for Subscription), you can access, review and manage many changes yourself via the customer dashboard in our App. Within the dashboard, you can do things like update your profile information and change your communication preferences.
• If you have not created an Account (optional only for Bill Pay service), or the information you are seeking is not available within the customer dashboard, you can submit a request using the contact details in the “How to Contact Us” section of this Privacy Policy.
• You may opt out of receiving marketing emails from us at any time by clicking on the Unsubscribe link in our emails. You will continue to receive Service-related emails (e.g., transactional messages).
• We may provide you the opportunity to participate in contests, sweepstakes, surveys and/or other promotions on our Websites or in our Apps. If you participate, we may request Personal Information from you.

Analytics

We use analytics services, such as Mixpanel, to analyze information regarding visits to our websites and mobile applications. Such services use cookies, web beacons, recorded interactions and other tracking mechanisms to collect this information. You may use your browser to control how your information is used.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes, as listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.

Data Retention and Account Closure

We may keep some of your Personal Information for a minimum of five years after you close your account to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to "unsubscribe" from further messages from us. We may retain de-identified information after your account has been closed.

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How We Protect Your Personal Information

Security

We implement a variety of security safeguards designed to protect your Personal Information. However, no method or transmission over the internet or electronic system is completely secure, so there is no guarantee that such data may not be accessed, disclosed, altered, or destroyed in connection with a breach of our physical, technical, organizational, or managerial safeguards.

Choosing a Password

If you elect voluntarily, or if you are required to create an online Account based on Services utilized, you will be prompted to select a personal password. To maximize your level of protection, you should choose a strong and unique password. You are solely responsible for maintaining the secrecy of your password and any account information.

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Your State Privacy Rights

Some state privacy laws provide certain rights to residents of those states. This section of the Privacy Notice applies if you are a natural person who is a resident of California, Colorado, or Virginia. This notice supplements the information in the Privacy Policy with respect to residents of such states.

Information we Collect, Disclose and Use

We collect and disclose for business purposes the following categories of personal information as indicated with a check mark below:

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We collect this personal information from you and from other categories of sources such as: public and publicly available sources; our vendors, data suppliers, and service providers; partners with which we may offer co-branded services or engage in joint event or marketing activities; social networks; and the organization with which you are employed or affiliated.

We disclose this personal information for business purposes with: our service providers; the administrators authorized by your organization (if you access our services through a subscription administered by your organization); and other parties where required by law or to protect our rights.

We collect this information from the sources described in “Personal Information We Collect,” above, and use it for the purposes described in “How We Use Your Personal Information,” above.

Papaya does not “sell” or “share” personal information, or process personal information for targeted advertising purposes, as those terms are described under applicable state privacy laws.

Personal Information Rights

You have the right to request:

• The categories of Personal Information we collect, along with the categories of sources from which we collect such information, the categories of third parties to whom we disclose it, and the business purposes for such disclosure;
• The specific pieces of information we have collected about you;
• Deletion of certain Personal Information we have collected from you; and
• Limit our use of the sensitive Personal Information we have collected about you.

We will not deny, charge different prices for, or provide a different level of quality of services if you choose to exercise these rights. Note that each of these rights is subject to certain restrictions and exceptions under applicable law; for example, we may need to retain certain information for record keeping or legal purposes.

You may exercise these privacy rights by submitting your request via one of the methods in the “How to Contact Us” section. You also have the right to designate an agent to exercise these rights on your behalf.

For security purposes, we will verify your identity – in part by verifying your email account or requesting certain information from you – when you make a request. Once we have verified your identity (and your agent, if applicable), we will respond to your request as appropriate. Consistent with California law, we do not disclose government-issued IDs or financial account numbers.

Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of Personal Information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your Personal Information with third parties for their own direct marketing purposes.

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Children's Privacy

Our Services are designed for and directed at people 13 years of age or older. We do not knowingly collect information from children under 13. If Papaya learns that a child under the age of 13 has submitted personally identifiable information online, it will take reasonable measures to delete such information from its databases and to not use such information (except where necessary to protect the safety of the child or other as required or allowed by law). If you become aware of any Personal Information we have collected from children under 13, please see “How to Contact Us” for details to contact us.

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How to Contact Us

If you have questions about how we collect, store and use Personal Information, please contact us via the Consumer Rights Web form (https://papayapay.com/contact) or email help@ppaya.com.

You have the right to opt out at any time. You may exercise this right by emailing us at the above email address, or writing to the address below. Note that email is the optimum method of communication:

8605 Santa Monica Blvd. #52843

West Hollywood, CA 90069

Phone: 888-850-5196 

Customer Service is available 24/7 Monday through Sunday

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Updates to the Privacy Policy

This Privacy Policy may change from time to time. Papaya will notify you of changes by posting a revised version of the Privacy Policy on its website, and updating the “Effective Date” at the top of the Privacy Policy. You should check this website periodically for updates. If we make material changes to the Privacy Policy, then we will provide notice through our Services or by other means, as legally required. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your Personal Information is subject to the updated Privacy Policy. If you object to any changes, you may close your account and discontinue use of the applicable Services.

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