Privacy Policy

Introduction

Parlay Protocol Inc. dba Parlay Finance ("we," "us," or "our") wants you to be familiar with how we collect, use, and disclose personal information that we collect online. In general, this Privacy Policy describes our practices in connection with information that we collect through:

• Web application operated by us from which you are accessing this Privacy Policy; and
• HTML-formatted email messages that we send to you that link to this Privacy Policy.

Collectively, we refer to the website and emails as the "Services."

Nonetheless, note that we provide certain products and services to financial institutions (e.g., banks). This Privacy Policy does not address our handling of personal information that we collect online on behalf of our financial institution clients. Instead, when we collect personal information online on behalf of a financial institution client, our handling of that information is governed by our contracts with our client. If you have any questions about how your financial institution handles information relating to you, please review their privacy policy or contact them directly.

Personal Information

"Personal Information" is information that identifies you as an individual or relates to an identifiable individual. We collect Personal Information through, or in connection with, the Services, such as:

• Name
• Telephone number
• Email address
• IP address (we may also derive your approximate location from your IP address)

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services.
  • We collect Personal Information through the Services, such as when you create an account or contact customer service.
• From Other Sources.
  • We receive your Personal Information from other sources, such as referral or joint marketing sources.

We need to collect Personal Information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.
  • To provide the Services' functionality to you, such as arranging access to your account.
  • To provide you with customer service.
  • To respond to your inquiries and fulfill your requests.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.
• Accomplishing our business purposes.
  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  • For fraud prevention and security monitoring purposes, including to detect and prevent cyberattacks or attempts to commit identity theft;
  • For developing new products and services;
  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
  • For operating and expanding our business activities.
• Analyzing Personal Information for business reporting and providing personalized services.
  • To analyze use of the Services.
• Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as the information no longer identifies you or any other individual.

Disclosure of Personal Information

We disclose Personal Information:

• To our third-party service providers, to facilitate services they provide to us.
  • These can include providers of such services as website hosting, data analysis, fraud prevention, information technology and related infrastructure provision, customer service, email delivery, and auditing.

Other Uses and Disclosures

We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, and for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety, or property, and/or that of you or others. We may use, disclose, or transfer Personal Information to a third party in connection with any proposed or actual reorganization, bankruptcy, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock.

Other Information

"Other Information" is information that does not reveal your specific identity or directly relate to an identifiable individual. We and our service providers may collect and use Other Information in a variety of ways, including:

• Your browser or device.
  • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Services function properly.
• Cookies.
  • Cookies are pieces of information stored directly on your computer. Cookies allow us to collect such information as browser type, time spent on the Services, pages visited, language preferences, and traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting particular cookies from a particular website. You may also wish to refer to allaboutcookies.org. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information, as detailed in this Privacy Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Security

We seek to use reasonable organizational, technical, and administrative measures that are designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact Us" section below.

Third-Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating a website or service to which the Services link. The inclusion of a link on the Services does not imply our endorsement of the linked site or service.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our application.

Use of the Services by Minors

The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics) on or through the Services or otherwise to us.

Updates to this Privacy Policy

The "LAST UPDATED" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

Contact Us

If you have any questions about this Privacy Policy, please contact us at legal@parlay.finance. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.