This Privacy Policy explains how Black Label Solutions (“Black Label Solutions”, “us”, “we” or “our”, NomadPOS) collect, use, disclose, transfer, protect, store and otherwise process your information. It also explains your rights and options around our use of your personal information and how you can exercise these choices. ’Personal information’ means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; For the purposes of this Policy, ‘Customer’, as the term is used here, refers to an individual or an entity that registers to use our Services. Please, do not use Services if you are not ready to accept the Terms of Use and this Privacy Policy.

This Privacy Policy was updated on 1 May 2019.

Scope of privacy policy

Black Label Solutions is committed to protecting the privacy of the individuals on Black Label Solution’s websites, mobile applications, products and services, (collectively, “Services”). By registering for or using Services you acknowledge the collection, transfer, processing, storage, disclosure and other uses of your information, as described in this Privacy Policy.

What information we collect

We collect information about you when you provide it to us, when you use our Services. The ways we collect it can be broadly categorized into the following: INFORMATION YOU DIRECTLY PROVIDE TO US: Account and profile information. We collect following information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services:

• Contact information such as name, email address and country
• Profile information such as business phone number
• Preferences information such as notification and marketing preferences

Operational data. We also store information you upload to or send through our Services, including:

• Information about products and services the Customer sells (including inventory, pricing, sale, transaction, tax, and other data)
• Information about the Customer or the Customer’s business (employees, consumers and suppliers)

Information you provide through our support channels. The Services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, speak to one of our representatives directly or otherwise engage with our support team, we may ask you to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

Payment Information: We collect certain payment and billing information when you subscribe for certain paid Services. For example, we ask you to designate a billing representative, including name and contact information. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.

Other submissions. We ask for and collect personal information from you when you submit web forms on our websites or when you participate in any interactive features of our Services, participate in a survey, promotion, activity or event, request customer support, communicate with us via third party social media sites, or otherwise communicate with us.

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES: Access logs. Like with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our websites and Services. This information includes Internet protocol (IP)

addresses as well as browser type, URLs of referring/exit pages, operating system, language and location preferences, time/date stamp, search history, device identification numbers and system configuration information. Occasionally, we connect personal information to information gathered in our log files as is necessary to improve our Services. If we do this, we would treat the combined information in accordance with this Privacy Policy. Analytics information. We collect analytics information when you use our Services to help us improve our products and services. We are always aiming to make Services a better experience for retailers and customers alike, and your information really helps us to do this! This analytics information consists of the function and feature of the Services being used, and the Customer’s username and IP address of the individual who is using the function or feature (which will include any personal information incorporated into the username), and other information needed to detail the operation of the function and the parts of the Services that are being affected. We use Google Analytics as one of our analytics providers. Refer to Google’s Policies and Principles to find out more about the privacy policy of Google Analytics. To prevent analytics information from being sent to Google Analytics, use the Google Analytics Opt-out Browser Add-on.

Analytics information derived from operational data. Analytics information also consists of data we collect as a result of running queries against Operational Data across our user base for the purposes of generating Usage Data. “Usage Data” is aggregated data about a category or group of features, services, or users that is not of itself personal information. It is also data about our Customers and their business. We may incidentally come across personal information when we compile Usage Data.

Cookies. Cookies are used by Black Label Solutions and our third-party partners (for example, our analytics partners) to collect information. A cookie is a small text file that is stored on your hard drive or in device memory for record keeping purposes. We use cookies to give you a better and more personalised use of the Services, to save you logging in every time and to count the number of visits.

INFORMATION WE RECEIVE FROM OTHER SOURCES

We collect information from other sources, such as our business partners. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

How we use your information

We are continually striving to improve Services. Being able to identify how retailers are using our product plays a big part in helping us to make our software better. We may use information about you for purposes such as:

• Enabling you to access and use our Services
• Displaying historical sale information
• Sending you marketing, advertising, educational content and promotional messages and other information that may be of interest to you, including information about us, our Services, or general promotions for business partner campaigns and services. You can unsubscribe or opt-out from receiving these communications described below under “How You Can Protect Your Information”
• In the case of retail stores, to share the name of the retail store with potential customers to encourage them to use our Services
• Measuring, customising and improving the Services and developing new products
• Sending to you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you
• Investigating and preventing fraudulent transactions, unauthorised access to Services, and other illegal activities
• With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.

Where we need your personal information for any other purposes, it will be obvious from the circumstances as to the purposes for which we require that personal information from you.

Sharing & disclosure of your information

When you use the Services, we may share your information only as described below:

SERVICE PROVIDERS, BUSINESS PARTNERS AND OTHERS

We use and work with third party service providers and our trusted Business Partners to provide application development, hosting, website, infrastructure, maintenance, backup, payment processing, customer relationship management, marketing, accounting, human resources, business intelligence and analytics, data enrichment, customer support and other services for us. These service providers may have access to or process your information for the purpose of providing those services for us. Some of our pages use white-labelling techniques to serve content from our service providers while providing the look and feel of our site. Please note that you are providing your information to these third parties acting on behalf of Black Label Solutions. These third parties may be located in countries which may be outside of your location.

We also share your contact information with select trusted Business Partners, such as our partners who integrate with Services, to enable them to contact you about their services (as they relate to your Services). We also obtain contact information from select Business Partners to better understand your preferences and to deliver you more personalised marketing.

LINKS TO THIRD PARTY SITES
Our Services may contain links to other sites. We have no control over, and take no responsibility for, the privacy practices or content on other sites. You are responsible for checking the privacy policy of any such sites so that you can be informed of how they handle personal information.

SOCIAL MEDIA WIDGETS
Our Services may include social media features, such as the Facebook “Like” button and widgets, and the “Share” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.

COMPLIANCE WITH LAWS AND PROTECTION OF RIGHTS

In certain situations, we may be required to use and disclose your information (including personal information) to a third party if we believe the disclosure is reasonably necessary:

• To comply with any applicable law, legal process (for example, subpoenas and warrants) or governmental request
• To enforce and administer our agreements, policies and terms of use
• To protect the property, rights, and safety of Black Label Solutions, our Customers or the public from harm or illegal activities
• For fraud prevention, risk assessment, investigation, customer support, product development or debugging purposes
• To protect the rights, property or personal safety of Black Label Solutions, its users or members of the public
• To establish or exercise our legal rights or defend ourselves against any third-party claims or allegations

BUSINESS TRANSFERS
If Black Label Solutions undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may transfer or share some or all of our assets, including your personal information. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

NON-IDENTIFYING OR AGGREGATED DATA
We may share aggregated or other non-personal information that does not directly identify you with third parties in order to improve our Services.

Your Privacy Rights
Updating your Personal Information via the Services: You may access, change, or correct information about you by logging into your NomadPOS account at any time or by making a request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information.

ACCOUNT INFORMATION AND DEACTIVATING YOUR ACCOUNT
If you wish to deactivate your NomadPOS account, you may do so by emailing us using the contact details provided below.

OPTING OUT OF PROMOTIONAL COMMUNICATIONS
You may opt out of receiving promotional communications from NomadPOS by using the unsubscribe link within each email or contacting us via our home page or sales team. Even after you opt out from receiving promotional messages

from us, you will continue to receive transactional messages from us regarding Services (e.g., account verification, purchase and billing confirmations and reminders, technical and security notices).

How long we retain your information
We generally retain your information only as long as reasonably necessary to provide you the Services or to comply with applicable law.

However, even after you cancel your account, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of use or other applicable agreements or policies, or to take any other actions consistent with applicable law.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it.

Children’s use of the services
Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at the address listed below.

Security
We have adopted technical, administrative and physical procedures to collect, manage, maintain and store information in a manner designed to help protect your information from loss, misuse, unauthorised access, and alteration. Unfortunately, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

Where data is transferred over the Internet as part of the Services, the data is encrypted using industry standard TLS (HTTPS).

Updates to our privacy policy
Black Label Solutions reserves the right to change this Privacy Policy from time to time, and if we do we will post any changes on this page. If you disagree with these changes, you can cancel your account at any time and/or stop your use of our Services. Your continued use of the Services after any changes to the Privacy Policy constitutes your acceptance of such changes.

General

1. You may not assign your rights or delegate performance of your obligations under these T&Cs without NomadPOS’s prior consent which will not be unreasonably withheld. NomadPOS may, without your consent, assign its agreement with you to any member of H & C Holdings or in connection with any merger or change of control of Black Label Solutions or the sale of all or substantially all of its assets provided that any such successor agrees to fulfil its obligations pursuant to these T&Cs.

2. These T&Cs, together with any Form(s) and Subscription Plan, constitute the entire agreement, and supersede any and all prior agreements between you and NomadPOS in relation to your use and access to the Application.

3. NomadPOS may provide any notice required under these T&Cs by publishing the notice on the Website or emailing any notice to the email address connected to your Account. You must give notice to NomadPOS by emailing: support@nomadpos.com

Do You Have Questions?

If you have any questions about this Privacy Policy or Black Label Solutions privacy practices, please contact us at support@nomadpos.com or at our mailing address below:

Black Label Solutions,

468 St Kilda Rd, Melbourne VIC 3004