Privacy is an important issue. We provide this policy as required by law to explain our information practices. Please read and retain this policy to learn how we collect and use information about you and your rights to limit the sharing and use of information.

How do we protect information?

Global Technology Partners LLC (GTP) and its subsidiaries, including Maritime Payment Solutions LLC (MPS) and Atlas Payment Solutions LLC (APS), does not share customer information about you, except as permitted by law. GTP has strict standards and procedures designed to prevent unauthorized access to information. We apply these standards and procedures to our facilities and online services. Our safeguards meet or exceed federal standards for protecting consumer information. We permit only authorized employees, who have been trained in the proper handling of information, to have access to that information. If an employee were to violate GTP’s privacy procedures, he or she would be subject to disciplinary action.

This policy applies to individuals who inquire about and/or obtain products or services from GTP for personal, family and household purposes. This policy describes information practices across GTP. However, departments within GTP may have more restrictive information sharing practices.

This policy supersedes all previous notices or statements about practices described in this policy. You should retain a copy of this policy for your records. If we materially change our policy, we will prominently place a notification on our website. You may request a current copy of the policy at any time by visiting our website at https://gtpprepaid.com.

COLLECTING INFORMATION

We collect nonpublic personal information about you from the following sources:

• Information you give us on applications or other forms;
• Information about your transactions with us; and
• Information about your transactions with other parties

You have the right to access this information (personal data) and to correct, amend or delete such personal data if it is inaccurate or has been processed in violation of the Privacy Shield Principles. (An exception to this is when the burden or expense of providing access, correction, amendment or deletion would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated.)

SHARING AND USING INFORMATION

GTP reserves the right to share and/or use all information we collect as this policy describes. We do not share information about you with third parties outside of GTP except as permitted by law and then subject to appropriate confidentiality and security measures, including compliance with this privacy policy. When GTP does disclose information about you to third parties under the limited legal exceptions, the third parties are required to treat the information about you they receive in strict confidence; to use it only for the purpose for which it was shared; and not to use the information for their own marketing purposes. GTP remains liable under this Privacy Policy if these third parties process your personal data in a manner inconsistent with the principles unless we can prove that we are not responsible for the event giving rise to any damage. We restrict access to information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect this information.

LEGAL EXCEPTIONS FOR SHARING OF INFORMATION

It is important to understand that, according to the law, GTP may share or use information about you for the following purposes:

• In response to lawful requests by public authorities, including to meet national security or law enforcement requirements
• To perform services (e.g., printing statements, bill payment, email services and mail house services)
• To process your account
• To protect the rights, property or safety of GTP, our customers or others (e.g., to protect against fraud)
• To comply with a legal requirement or process (e.g., subpoena or court order)
• To comply with your request or authorization to share information
• To furnish information to consumer reporting agencies

You have the opportunity to choose whether to have your personal data used or disclosed. GTP provides you the means and opportunity to opt out of such usage or disclosure if:

• Your personal data is to be used for a new purpose materially different from that which was originally authorized
• Your personal data is to be disclosed to a non-agent third party

You can invoke your choice to opt out via these mechanisms:

• Electronic mail to compliance@gtplimited.com
• S. mail (or alternate postal services) at

Global Technology Partners

5001 E. 68^th Street, Suite 500, Tulsa, Oklahoma 74136

FORMER CUSTOMERS
If you terminate your relationship with GTP, we will still apply the practices in our policy to information about you that we maintain.

ONLINE INFORMATION PRACTICES

GTP uses technology that encrypts (scrambles) online information so it transfers privately between you and GTP’s network. Your unique user ID and password help protect information online. While we strive to protect personally identifiable information, we cannot warrant the security of the personally identifiable information transmitted to or received by us. GTP joins with certain third parties to deliver online products and services. GTP and these outside parties may keep some information you provide in order to deliver these services, such as online applications, online surveys, email and cookies.

• We may keep information from online tools, online applications and forms, online service subscriptions or business conducted online through Internet or wireless devices.
• Online surveys – This information is used solely for research to help us improve our customer service and develop a superior website. We may maintain this information in a form that does not identify you.
• Email – If you send us an email, we may keep the content of your email. Please be careful about the information you email to us, because email to any public website can sometimes be intercepted. If you agree to receive emails from GTP, we keep the information you give us and may use it to send you email messages regarding your account or for other customer service purposes.
• Cookies – A cookie tells us our site was visited by you before and which pages were viewed. Cookies are also used for security purposes when you conduct business online. GTP may use cookie files to enhance the use of our site and redesign of our site, as necessary. Accepting a cookie does not give us access to your computer or any personal information about you. Outside parties, other than vendors who assist us with our website and who are under strict confidentiality requirements by contract, are not given access to our cookie files. GTP uses cookies that do not transmit any personal information about you.

CLIENT IDENTIFICATION NOTICE

Information Collection Procedures for Opening Accounts

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify and record information that identifies each customer who opens an account. Therefore, all new and existing customers are subject to the identity verification requirements.

When you open an account, we will ask for your name, address and identification number, and, in the case of an individual, your date of birth. For business accounts, we may also obtain this information for individuals associated with the business. We may also request to see a valid driver’s license or other approved identifying documents. In all cases, GTP is committed to protecting your privacy and identity.

COMPLAINT RESOLUTION
Please contact our Compliance department at compliance@gtplimited.com if you have a general question about how GTP protects your Personal Data, if you wish to exercise your rights in relation to your Personal Data, or if you wish to make a complaint about GTP use of your Personal Data.