LEGAL

Privacy Policy

Effective date: October 27, 2026

1. Introduction

VeloSync, Inc. (“VeloSync”, “we”, “us”, “our”) is a Delaware corporation operating from Salt Lake City, Utah. We provide payment facilitation infrastructure, related payment and settlement services, and enterprise landing services to business customers.

This Privacy Policy describes the personal information we collect through velosync.io (the “Site”) and in connection with our services (the “Services”), how we use and share that information, and the rights and choices available to individuals. It also explains the different roles we take when handling personal information: for some activities we determine why and how personal information is processed, and for others we process personal information only on behalf of, and under the instructions of, our business customers and financial partners.

If you are an individual who transacts with one of our business customers (for example, a buyer paying a merchant that uses our Services), that business customer is responsible for its own privacy practices. Please refer to its privacy policy for how it handles your information; this Policy covers the information we receive and process in providing the Services to it.

2. Definitions

- Personal Information means information that identifies, relates to, or could reasonably be linked to an identified or identifiable individual. - Merchant means a business that has been approved to use our payment facilitation and settlement Services under a written agreement with us. - Representative means an individual acting on behalf of an existing or prospective business customer, such as an owner, beneficial owner, officer, director, administrator, or authorized employee. - End Customer means an individual whose personal information we receive in order to provide the Services to a Merchant, such as a payer, payee, or refund recipient. - Visitor means an individual who visits the Site or contacts us without an account relationship. - Financial Partners means banks, card networks, payment processors, payout providers, and other financial institutions and service providers that work with us, directly or indirectly, to provide the Services. - Transaction Data means data relating to a payment, payout, refund, or other transaction processed through the Services, including amount, date and time, payment method token, transaction status, and refund or chargeback information.

3. Personal information we collect

The categories of personal information we collect depend on how you interact with us.

Contact and communications information. Name, business email address, phone number, company name, and the content of inquiries and communications you send us through the Site’s forms, by email, or through our support channels.

Business and onboarding information. Information provided during application, underwriting, and onboarding, including business registration details, business address, tax identifiers, bank account details, ownership structure, and — for Representatives and beneficial owners — name, date of birth, residential address, government-issued identification, and other know-your-business (KYB), know-your-customer (KYC), and sanctions-screening information. We are required to collect much of this information by law and by the requirements of our Financial Partners and the card networks.

Transaction Data. When we process payments, payouts, refunds, and settlements for Merchants, we receive Transaction Data relating to End Customers and Merchants. Raw payment card numbers are processed by PCI DSS compliant processors and are not stored on VeloSync systems; we receive and store tokens and truncated card details (such as card brand and last four digits) needed to operate, reconcile, and support transactions.

Technical and usage information. IP address, browser and device type, operating system, referring pages, and Site usage and security logs, collected when you visit the Site or use the Services.

Information from third parties. We receive information from identity-verification and fraud-prevention providers, sanctions and watchlist databases, credit and business information services, and our Financial Partners, for use in underwriting, verification, and risk monitoring.

4. How we use personal information

We use personal information for the following purposes:

- Providing the Services: operating payment facilitation, settlement, payout, and enterprise landing services; opening and administering accounts; and providing support. - Application review and compliance: evaluating applications; performing KYB/KYC verification and sanctions screening; meeting our legal obligations and the requirements of our Financial Partners and the card networks. - Transaction processing and risk management: processing transactions; monitoring for fraud and financial crime; preventing losses to Merchants, End Customers, Financial Partners, and us; and managing disputes, refunds, and chargebacks. - Communications: responding to inquiries, sending service and administrative notices, and providing information about the Services to existing and prospective business customers. - Security and operations: protecting the security and integrity of the Site and the Services, debugging, auditing, and improving our systems. - Legal and enforcement: complying with applicable law, regulation, and legal process, and establishing, exercising, or defending legal claims and enforcing our agreements.

5. How we share personal information

We share personal information only as described in this Policy:

- Financial Partners: banks, card networks, payment processors, and payout providers, to process transactions, settle funds, and meet network and regulatory requirements. - Verification and risk providers: identity-verification, sanctions-screening, and fraud-prevention providers, to verify identity, screen applicants, and assess transaction risk. We may share information about attempted transactions with Merchants and Financial Partners so they can assess fraud or loss risk. - Professional advisers and service providers: lawyers, auditors, accountants, insurers, and providers of IT, cloud hosting, communications, and customer-support services, under contractual obligations to use the information only as directed and to protect its confidentiality. - Authorities and legal process: regulators, law enforcement, and courts, when we are required or permitted to do so by law, regulation, subpoena, or other legal process, or to protect our rights, property, or safety or that of others. - Business transfers: in connection with a merger, acquisition, financing, or sale of all or part of our business or assets, information may be disclosed to the prospective counterparty and its advisers and transferred to the successor entity, subject to this Policy.

We do not sell personal information, and we do not share personal information for third-party advertising.

If we process personal information as a service provider on behalf of a Merchant, we disclose it in accordance with our agreement with that Merchant and its lawful instructions.

6. Cookies and similar technologies

The Site uses a limited set of cookies and similar technologies that are necessary for the Site to function, to maintain security, and to understand aggregate Site usage. You can control cookies through your browser settings; disabling certain cookies may affect Site functionality. We do not use cookies to sell or share personal information for advertising purposes.

7. Transfers to other countries

We operate from the United States, and our Financial Partners and service providers may be located in other countries. Personal information may therefore be transferred to, and processed in, countries whose data protection laws differ from those of your jurisdiction. Where required, we use contractual and other safeguards designed to protect personal information in transit and at the recipient.

8. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, and alteration, consistent with payment-industry practice. These include access controls limited to personnel and providers with a business need, encryption of data in transit, network monitoring, and — for card data — processing exclusively through PCI DSS compliant processors, with no raw card numbers stored on VeloSync systems. No system is completely secure, and we cannot guarantee absolute security.

9. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy and to meet our legal, regulatory, accounting, and contractual obligations. In particular, we may retain information after an account is closed or a relationship ends:

- to complete transactions initiated before closure; - to comply with anti-money laundering, sanctions, tax, accounting, and financial reporting requirements, including AML record-keeping obligations; - to detect and prevent fraud and other financial crime; - to respond to legal process and regulatory requests; - to collect amounts owed under our agreements; - to meet our contractual commitments to Financial Partners; and - to resolve disputes and enforce our agreements.

When a retention period has passed, we delete personal information or de-identify it so that it can no longer be associated with an individual.

10. Your rights and choices

Depending on your jurisdiction, you may have the following rights regarding your personal information, subject to exceptions under applicable law:

- Access and information: to confirm whether we process your personal information and to obtain a copy of it, together with information about the categories of information collected, their sources, the purposes of processing, and the categories of recipients. - Correction: to request that inaccurate or incomplete personal information be corrected. - Deletion: to request deletion of your personal information. We may decline where retention is required by law, by our Financial Partners’ or the card networks’ rules, or for the other purposes described in Section 9. - Portability: to receive certain personal information in a portable format, where technically feasible. - Objection and restriction: to object to, or request restriction of, certain processing. - Non-discrimination: to exercise these rights without discriminatory treatment.

If we process your personal information on behalf of a Merchant (for example, Transaction Data of an End Customer), please direct your request to that Merchant; we will support the Merchant in responding as required by our agreement with it.

To exercise a right, contact us at admin@velosync.io. We may request additional information to verify your identity and authority before acting on a request. You may use an authorized agent where permitted by law; we may require evidence of the agent’s authority and verify your identity directly. We respond to verified requests within the period required by applicable law.

11. Children’s information

The Site and the Services are intended for businesses and their Representatives. They are not directed to individuals under 18, and we do not knowingly collect personal information from children. Identification information relating to a minor is collected only where it arises in a business onboarding context (for example, a minor beneficial owner), and only as required for verification.

12. Changes to this Policy

We may update this Policy from time to time. The current version will be posted on this page with its effective date, and material changes will be notified through the Site or by email where appropriate. Continued use of the Site or the Services after an update takes effect constitutes acknowledgment of the updated Policy.

13. Contact us

Questions, requests, or complaints about this Policy or our handling of personal information can be addressed to:

VeloSync, Inc. 3443 S. State Street, Suite 17, Salt Lake City, UT 84115, USA admin@velosync.io

If you have a complaint, you may also contact the data protection or consumer protection authority in your jurisdiction.