AutoCorr And Autogen Privacy Policy

Privacy Policy specifically for MMA AutoCorr and AutoGen users.

Last updated: June 22, 2023

This Privacy Policy includes important information about your personal data, and we encourage you to read it
carefully.

This Privacy Policy (“Policy”) describes the “Personal Data” that we collect about you, how we use it, how we share it,
your rights, and how you can contact us about our privacy practices. This Policy also outlines your data subject rights, including the right to object to some uses of your Personal Data by us.

“Personal Data” means any information that relates to an identified or identifiable individual, and can include
information that you provide to us and that we collect about you, such as when you engage with our Services (e.g.
device information, IP address).

“Services” means the products and services that MMA provides and are covered by this Policy, which may include
MMA -provided devices and apps. Our “Business Services” are Services provided by MMA to entities (“Business
Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business
Users’ own business and activities. Our “End User Services” are those Services which MMA provides directly to
people (rather than entities) for their own use.

“Sites” means mma.ie and the other websites, apps and online services that MMA indicates are covered by this
Policy. Collectively, we refer to Sites, Business Services and End User Services as “Services”.

When you directly use an End User Service for your personal use (such as when you sign up for Link or make a
payment to MMA in your personal capacity), we refer to you as an “End User.”

When you do business with, or otherwise transact with, a Business User but are not directly doing business with
MMA, we refer to you as an “End Customer.”

When you are acting on behalf of an existing or potential Business User (e.g. you are a company, administer an
account for a merchant who is a Business User, or receive an employee credit card from a Business User, we refer to
you as a “Representative.”

When you visit a Site without being logged into an MMA account or otherwise communicate with MMA, we refer to
you as a “Visitor.”

Depending on the activity, MMA acts as a “data controller” and/or “data processor.

1. Personal Data that we collect and how we use and share it
2. Legal bases for processing data
3. Security and retention
4. Contact us

1. Personal Data that we collect and how we use and share it.

Our collection and use of Personal Data changes depending on whether you are acting as End User, End Customer,
Representative or Visitor and our different Services. For example, if you are the sole owner of a business (i.e., sole
proprietorship), we may collect Personal Data to onboard your business, but you may also be an End Customer that
purchased goods from another Business User that uses MMA Services for payment processing.

“Transaction Data” as used in this Privacy Policy includes Personal Data, and may include the following: your name,
email address, billing address, receiving address, payment method information (such as , bank account information ),purchase amount, date of purchase, and in some cases, some information about what you have purchased and your
phone number and past purchases.

1.1 End Users

We provide End User Services where we do not act as a service provider or processor to Businesses but instead
provide the Services directly to you for your personal use.

a. Personal Data that we collect about End Users

Using your Bank Account details. MMA offers you the opportunity to store your payment methods with MMA. When
you commit to a transaction, you agree to let us store your Personal Data such as your payment method so that you
can more readily make purchases through our accounts department with Business Users of our payment processing
Business Services (e.g. name, contact information, payment method details If you choose to share bank account information with us, MMA will periodically collect and process your account information (e.g. bank account owner information, account balances, account number and details, account transactions and, in some cases, credentials). With your separate permission, we will share this Personal Data with Business Users that you choose. You can ask us to stop collecting and sharing this information.

With your separate permission, we will share contact information (e.g. receiving address, billing address and phone
number) with Business Users that you do business with.

1.2 End Customers

MMA offers Business Services to our Business Users (e.g., payment processing through in-person or online checkout,
or processing pay-outs for those Business Users). When we are acting as a Business User’s service provider (also
known as a data processor), we will process Personal Data in accordance with the terms of our agreement with the
Business User and the Business User’s lawful instructions.

Business Users are responsible for making sure that their End Customers’ privacy rights are respected, including
ensuring appropriate disclosures about data collection and use that happens in connection with their products and
services. If you are an End Customer, please refer to the privacy policy or notice of the Business User you choose to
do business with for information regarding their privacy practices, choices, and controls.

a. Personal Data that we collect about End Customers

Transaction Data. If you are an End Customer, when you make payments to, get refunds from, begin a purchase, or
otherwise transact with a Business User that uses us to provide payment processing Business Services, we will
receive Transaction Data. We may also receive your transaction history with the Business User.

Identity/Verification Information

Payments and Accounting. We use your Transaction Data to provide our Payments related Business Services to
Business Users, including to process online payment transactions, to calculate applicable sales tax, to invoice and bill, and to help them calculate their revenue, pay their bills, and perform accounting tasks. We may also use Personal Data to provide and improve our Business Services.

For payment transactions, your Personal Data is shared with several parties in connection with your transaction.
Because we act as a service provider or processor, we share Personal Data to enable the transaction. For example,
when you choose to use a payment method for the transaction, your payment method will receive the Transaction
Data that may include your Personal Data.

1.3 Representatives

To provide Business Services, we collect, use and share Personal Information from Representatives of Business Users (e.g. a business owner)

a. Personal Data that we collect about Representatives.

Registration and Contact Information. If you register for an MMA product for a Business User (including incorporation of a Business), we collect your name and account log-in credentials. information. If you are a Representative or Representative of a potential Business User, we receive your Personal Data from third parties.

b. How we use and share Personal Data of Representatives

We generally use Personal Data of Representatives to provide the Business Services to the associated Business Users,
as well as for the purposes described below.

Business Services. We use and share Personal Data of Representatives with Business Users to provide the Services
you (or the Business User you are associated with) have requested.

In some cases, our Business Service will require us to submit your Personal Data to a government entity (e.g.,
incorporating a business, or paying applicable sales tax). For our tax Business Services, we may use your Personal
Data to file taxes on behalf of your associated Business User.

The use of Personal Data by a Business User’s authorized third party is subject to the third party’s privacy policy.

1.4 Visitors

We collect, use, and share Personal Data of Visitors (who are not End Users, End Customers or Representatives).

a. Visitor Personal Data that we collect.

When you visit our Sites, we will receive your Personal Data either from you providing it to us or through
technologies.

Forms.

When you choose to fill in a form on the Site or on third party websites, we will collect the information included in
the form (e.g., your contact information and other information about your question related to our Services). We may
also associate a location with your visit.

b. How we use and share visitor Personal Data

In addition to the ways we collect, use, and share Personal Data we also process your Personal Data as follows:

a. Personal Data Collection

Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services,
we will collect information about:

Devices and browsers across our Sites and third-party websites, apps and other online services (“Third-Party Sites”),
Usage data associated with those devices and browsers and how you’ve engaged with our Services, including IP
address, plug-ins, language used, time spent on Sites and Third-Party Sites, pages visited, links clicked, payment
methods used, and the pages that led or referred you to Sites and Third-Party Sites.

Financial Partners. “Financial Partners” are financial institutions that we partner with to transact our services.

2. Legal bases for processing data

For the purposes of the General Data Protection Regulation, we rely upon several legal bases to enable our
processing of your Personal Data.

Contractual and Pre-Contractual Business Relationships. We process Personal Data for the purpose of entering
business relationships with prospective Business Users and End Users and to perform the respective contractual
obligations with them.

3. Security and retention

We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of
your Personal Data. We maintain organizational, technical, and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration, or misuse.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
We retain your Personal Data if we are providing the Services to you or our Business Users (as applicable) or for a
period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your MMA account or complete a
transaction with a Business User, we may retain your Personal Data:

to comply with our legal and regulatory obligations.
to comply with our tax, accounting, and financial reporting obligations where required by our contractual commitments to our financial partners (and where data retention is mandated by the payment methods you used).

In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention
obligations that are imposed by applicable law.

4. Contact us

If you have any questions or complaints about this Policy, please contact us at dpo@mma.ie