Aloha Pay, Inc.

CALIFORNIA CONSUMER PRIVACY ACT NOTICE TO CALIFORNIA RESIDENTS

Last updated August 7, 2020

This Notice to California Residents (“CCPA Notice”), provided by Aloha Pay, Inc. (“Company,” “we,” “us,” or “our”) pursuant to the California Consumer Privacy Act (“CCPA”), supplements our Privacy Policy and applies to natural persons who reside in the State of California (“consumers” or “you”), that visit the Site, use the Services, or otherwise engage or interact with us. Any terms used herein but not defined shall have the meaning assigned in our Privacy Policy, or the CCPA, as applicable.

In the event of any conflict or inconsistency between this CCPA Notice and our Privacy Policy, this CCPA Notice shall control only with respect to the Personal Information (as defined in CCPA) of consumers, their households or devices. If you are located outside of the State of California this CCPA Notice does not apply to you and you should refer to our Privacy Policy.

1. INFORMATION WE COLLECT

In the twelve (12) months preceding the data of the Last Update (the “Last Update”), we have or may have collect and/or received the Categories of Personal Information set forth in THE INFORMATION THAT WE COLLECT section of our Privacy Policy.

2. CATEGORIES OF SOURCES

We collect the Categories of Personal Information from the Categories of Sources set forth in THE INFORMATION THAT WE COLLECT section of our Privacy Policy.

3. USE OF PERSONAL INFORMATION

We may use or disclose the Personal Information we collect for one or more of the Business Purposes described in the HOW WE USE YOUR PERSONAL INFORMATION section of our Privacy Policy.

4. CATEGORIES OF THIRD PARTY RECIPIENTS

We may share your Personal Information for Business Purposes with the Categories of Third Party Recipients set forth in the HOW WE SHARE YOUR PERSONAL INFORMATION section of our Privacy Policy.

5. DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the twelve (12) months preceding the Last Update, we may have disclosed the Categories of Personal Information for a Business Purpose to the Categories of Third Parties set forth in Table I. In the twelve (12) months preceding the Last Update, we have not sold Personal Information.

1. Personal Information Categories

2. Third Parties Categories with Whom We Share this Personal Data for a Business Purpose:

Identifiers

Service Providers, End-Users

Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e)).

Service Providers, End-Users

Protected classification characteristics under California or federal law

Service Providers

Commercial Information

Service Providers, Restaurant Customers

Internet Activity Information

Service Providers, Restaurant Customers

Geolocation Data

Service Providers, Restaurant Customers

Audio and Similar Information

Service Providers

Inferences

Service Providers

Table I

6. YOUR RIGHTS AND CHOICES

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes such rights and explains how to exercise them.

7. RIGHT TO KNOW ABOUT YOUR PERSONAL INFORMATION

You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request):

8. RIGHT TO REQUEST DELETION

You have the right to request that we delete any of Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

9. EXERCISING RIGHT TO KNOW AND/OR REQUEST DELETION

To exercise the rights to know or request deletion described above, please submit a verifiable consumer request to us by submitting a request online to email at privacy@alohapass.co.

You may only make a verifiable consumer request under the right to know twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information related to you. Making a verifiable consumer request does not require you to create an account with us.

10. VERIFICATION PROCESS

To submit a verifiable consumer request, the consumer may be required to provide up to three data points, which may include additional Personal Information, to enable us to verify the consumer’s identity with the degree of certainty required by the CCPA. We will use Personal Information provided in a verifiable consumer request solely for the purpose of verifying the requestor’s identity or authority to make the request. We or a third party on our behalf may follow up with you to determine whether a request is a verifiable consumer request under applicable law. If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we will deny the consumer request in whole or in part and will not to disclose the information requested or, as applicable, will not delete the information requested. We will respond to any such consumer request with a denial, and will also explain why it has no reasonable method by which it can verify the identity of the requestor.

11. RESPONSE TIMING AND FORMAT

We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. If you do not have an account with us, and you do not indicate a preference for delivery, we will use its discretion in choosing the method of delivery of the information. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

12. RIGHT TO OPT-OUT OF THE SALE OF PERSONAL INFORMATION

We do not sell the Personal Information of consumers (including minors under 13 AND 16 years of age). However, if you are 16 years of age or older, you have the right, at any time, to direct us to not sell your Personal Information (the “right to opt-out”) and if you are under 16 years of age you have the right to opt-in to the sale of your Personal Information.

13. RIGHT TO NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties (except for financial incentives permitted by the CCPA, see below), (iii) provide you a different level or quality of products or services, and (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services, as a result or in response to you exercise of any of your CCPA rights.

14. RIGHT TO DESIGNATE AN AUTHORIZED AGENT

If you submit a request to know or delete your Personal Information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.

15. OTHER CALIFORNIA PRIVACY RIGHTS

Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.

To make such a request, please send an email to support@alohapass.co.

16. CHANGES TO OUR CALIFORNIA CONSUMER PRIVACY ACT NOTICE

This CCPA Notice is effective as of the date of the Last Update stated at the top of this CCPA Notice. We may change this CCPA Notice from time to time with or without notice to you. By visiting or accessing the Site or the Services, purchasing products or services from us, or otherwise engaging or interacting with us after we make any such changes to this CCPA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CCPA Notice in current effect. Please refer back to this CCPA Notice on a regular basis.

16. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, or wish to exercise your rights under California law, please do not hesitate to contact us at:

1-888-917-2257

https://alohapass.co

support@alohapass.co,

95-390 Kuahelani Ave Suite 3AC - Unit #5038 Mililani, HI 96789