This Policy covers the following topics:

• Updates to the Privacy Policy
• Sources of Information About You
• Our Use of Information
• Sharing of Information
• Sharing and Use of Aggregated and Anonymized Information
• Updating of Information
• Children’s Privacy
• Security
• For Nevada Residents
• For Vermont Residents
• For California Residents
• Contact Information

Updates to the Privacy Policy

This Policy was last changed on the date set forth at the top of the Policy. We are constantly trying to improve the Service, so we may need to change this Policy from time to time as well, but we will alert you to changes by placing a notice on a BillGO product/service home page or webpage, within the App, or, when possible, by notifying you by electronic means (such as email, text notification or notification to your Service account). In addition, we will also edit the date at the top of this Policy to reflect the date of the changes. If you use the Services after any changes to the Policy have been posted, you agree to all the changes.

Unless we notify you and get your express consent to the contrary, use and sharing of your personal information, we collect is subject to the Policy in effect at the time such information is collected (meaning – Policy changes will not be retroactive). If we need to use or share your personal information in any manner outside of what is set forth in this Policy, we will notify you in advance and get your express consent.

Sources of Information About You

We obtain information about you from a variety of sources, including you, your interaction with BillGO, and third parties. Such information may include, but is not limited to, your name, postal address, email address, birth date, unique government issued identification number, telephone number, bank account and transaction information, and biller and payment information.

If you use certain Services, you may be required to provide us certain information that includes:

• Information that you provide by filling in forms on our website or to use BillGO Services. This includes information provided at the time of registering to use our Services, subscribing to our Services, posting material or requesting further Services.
• Log-in information and credentials to gain access to BillGO Services.
• Information you provide when you report a problem with our Services.
• Records or copies of correspondence, if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Services. You may be required to provide financial or bank account information in order to use our Services.
• Your search queries on our website or through our Services.

We may collect your usage information about how you use the Services, including your access times, location, browser types and language, and Internet protocol addresses. We may collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device’s interaction with our Services.

When you use our Services to make or accept payments, we collect information about the transactions, including the payment amounts and payment methods used to complete the transactions, bank account information for settlement, other relevant information about the financial institutions you use to conduct business, and basic user information such as your name, email address, mailing address, and phone number.

The information we collect automatically is statistical data and may or may not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve and to deliver better and more personalized Services, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Services.

The technologies we may use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services. Cookies may be used for session management, including the storage of device identifiers.
• Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of the Services or our emails may contain small electronic files know as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit BillGO, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We may also collect information about you from third parties, including but not limited to third-party verification services, credit bureaus, mailing list providers, publicly available sources, and another user that refers you.

Our Use of Information

We use information about you to provide, maintain, personalize and improve our Services and to deliver the information and support you request, including receipts, technical notices, security alerts, and support and administrative messages.

We may use information we collect to send you news and information about our Services and to communicate with you about products, services, contests, promotions, incentives, and rewards offered by us and select partners. You may opt out of receiving promotional emails or texts messages from BillGO by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.

We may also use information about you to:

• To track and analyze trends and usage in connection with our Services.
• To process and deliver contest and promotional entries and rewards.
• To protect our rights or property.
• To compare information for accuracy.
• To verify your identify.
• To investigate and prevent fraud or other illegal activities.
• For any other purpose disclosed to you in connection with our Services.

Additionally, we use information that we collect about you or that you provide to us, including any personal information:

• To provide you with information, products or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration, renewal or change in terms notices.
• To carry out obligation and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Services or any products or services we offer or provide through them.
• In any other way we may describe when you provide the information.
• For any other purpose with your prior consent.

Sharing of Information

We may share personal information about you as follows:

• To our subsidiaries and affiliates.
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• In order to verify the existence and condition or your account and to confirm your authority to use a bank account.
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of service and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of BillGO, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and risk management.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of BillGO’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by BillGO about our users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• With your prior consent or direction.
• For our internal business purposes, such as data analysis, auditing, and legal compliance.

We do not sell any information we collect or that is provided to us by you, including personal information, to third parties. BillGO is not responsible for any practices employed by websites linked to or from our website, nor their information or content. Please remember that when you use a link to go from our website to another website, this Policy is no longer in effect. Your browsing and interaction on any other website is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding. Additionally, some content or applications, including advertisements, on or through the Services are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Services. This information they collect may be associated with our personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Sharing and Use of Aggregated and Anonymized Information

Notwithstanding the foregoing, we may also use and share aggregated, non-personally identifiable information for any purposes (for example, we may publish reports on usage of our Services). For clarity, such information will be in a form that cannot personally identify you.

Updating of Information

You may update or correct information about yourself by accessing your account or portal within the Services.

Children’s Privacy

The Children’s Online Privacy Protection Act was created to protect children under the age of 13 from unsuspecting acts or practices in conjunction with collecting, using, and disclosing any information about them. Our Services are not intended for anyone under the age of 13. If you are under 13, do not use or provide any information on or through our Services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under the age of 13, please contact us so that we can delete the child’s information. The Services will never knowingly accept, collect, maintain or use any information from a child under the age of 13. If a child whom we know to be under the age of 13 sends personal information to us online, we will only use that information to respond directly to that child or notify parents.

Security

We maintain physical, electronic, and operational procedures to safeguard the security of your personal information. We comply with state and federal laws, regulations and standards, are PCI-DSS compliant and have established SOC2 Type2 protocols and internal controls to secure information provided to us. When you provide personal information we take appropriate steps to safeguard access (e.g. encryption). While we have taken commercially appropriate and required efforts to guard your personal information, we cannot guarantee that your personal information may not be accessed or disclosed accidentally or wrongfully. You acknowledge and agree that any personal information you provide or store through the Services is at your own risk. If you have reason to believe that your interaction with us is no longer secure (e.g. if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us as detailed below.

For Nevada Residents

WE ARE PROVIDING YOU THIS NOTICE UNDER NEVADA STATE LAW. YOU MAY BE PLACED ON OUR INTERNAL DO NOT CALL LIST BY EMAILING US AT Privacy@billgo.com, OR WRITING US AT BillGO, Inc., P.O. Box 272390, Fort Collins, CO 80527 (ATTN: Privacy).

Special Notice to Vermont Residents

Pursuant to Vermont Regulation B-2018-01, BillGO MT, Inc. does not share information it collects about Vermont residents outside of our subsidiaries and affiliated companies unless legally permitted. For example, with your consent, we may share Vermont resident information to maintain your account or pursuant to joint marketing agreements with financial institutions with which we have executed agreements. Additionally, with your consent, we may share information about your creditworthiness with our subsidiaries and affiliated companies; however, we may share information about your transactions or our experiences with you with our subsidiaries and affiliated companies without your consent.

For California Residents

UNDER CALIFORNIA CIVIL CODE SECTIONS 1798.83-1798.83, CALIFORNIA RESIDENTS ARE ENTITLED TO ASK US, ONCE PER YEAR, FOR A NOTICE IDENTIFYING THE CATEGORIES OF INFORMATION WHICH WE SHARE WITH OUR AFFILIATES AND/OR THIRD PARTIES FOR MARKETING PURPOSES, AND PROVIDING CONTACT INFORMATION FOR SUCH AFFILIATES AND/OR THIRD PARTIES. REQUESTS WILL APPLY TO INFORMATION PROVIDED DURING THE PREVIOUS CALENDAR YEAR (FOR EXAMPLE, IF YOU REQUEST INFORMATION IN 2019, YOU WILL RECEIVE INFORMATION REGARDING 2018). IF YOU ARE A CALIFORNIA RESIDENT AND WOULD LIKE A COPY OF THIS NOTICE, PLEASE SUBMIT A WRITTEN REQUEST TO: Privacy@billgo.com (SUBJECT HEADING: “CALIFORNIA CIVIL CODE COPY OF NOTICE REQUEST") OR BILLGO, INC, P.O. Box 272390, Fort Collins, CO 80527 (ATTN: PRIVACY).

THIS CALIFORNIA PRIVACY RIGHTS NOTICE IS PART OF THIS PRIVACY POLICY. PLEASE REVIEW THE REST OF THIS POLICY TO LEARN MORE ABOUTOUR PRIVACY PRACTICES.

Contact Information

Please contact us with any questions or concerns regarding our Policy or the Services provided at Privacy@billgo.com or BillGO, Inc, P. O. Box 272390, Fort Collins, CO 80527.