Compliance

Privacy Policy

Last modified: January 2026

SnapPays Mobile, Inc. dba Papaya Pays (“Papaya,” “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit and use of the Company’s platform and related program materials (the “Platform”), your participation in the commission/referral program for Company’s data privacy tool (the “Program”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform and Program. By accessing or using this Platform and Program, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Platform and Program after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Important Note About Your End Users

When we process personal information on behalf of a Partner, our Partner controls that data and is responsible for providing notices and obtaining any required consent from a Partner’s employee or end user.  In that situation, we act as a service provider/processor and handle the data under our agreement with the Partner.

Information We Collect About You and How We Collect It

The information we collect depends on how you interact with the Service.

1. Information You Provide to Us

• Account and Profile Information (e.g., name, business email, phone number, company name, job title, login credentials).
• Communications (e.g., messages sent through forms, email, chat, or support tickets).
• Payment information (e.g., bank name, ACH transfer information, if applicable; typically processed by a payment processor).

1. Information We Collect Through Automatic Data Collection Technologies  

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Device and Usage Data (e.g., IP address, operating system, and browser type, pages viewed, timestamps, referring URLs, interactions with features).
• Cookies and similar technologies

How We Use Your Information

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

1. To Provide and Operate the Service

• To create accounts and authenticate users.
• To present our Platform and its contents to you.
• Process transactions and send service-related notices.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and payments.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

1. For Security, Integrity, and Safety

• Monitor for suspicious activity, fraud, and abuse.
• Protect our systems, users, and customers.
• Debug, maintain, and improve the Service.

1. To Improve the Service

• Analyze usage and performance.
• Develop new features and refine the user experience.

Disclosure of Your Information

We may disclose aggregated and anonymous information about our users, and any information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• 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.
• 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 Papaya's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Papaya about our Platform users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• 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.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Papaya, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Accessing and Correcting Your Information

You may also send us an email at Partners@papayapay.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your State Privacy Rights

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
  • targeted advertising (excluding Iowa);
  • sales; or
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please send an email to Partners@papayapay.com. To appeal a decision regarding a consumer rights request Partners@papayapay.com.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to Partners@papayapay.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

Geographic Restrictions

The Services are based in the state of California in the United States and provided for access and use only by persons located in the United States. You acknowledge that you may not be able to access all or some of the Services outside of the United States and that access thereto may not be legal by certain persons or in certain countries.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Partners@papayapay.com