Effective Date: March 20th, 2025

This Privacy Notice outlines the data collection, usage, and disclosure practices of EPM Mobile Inc. (“StarPOS,” “we,” “us,” or “our”), headquartered at 413 Commonwealth Ave, Catonsville, MD 21228, along with its subsidiaries. “Personal data” refers to any information that can identify or be reasonably linked to an individual.

If your country of residence is:

• The United States, Canada, or any other regions where StarPOS operates, your data controller is EPM Mobile Inc.

This Notice applies to all users of StarPOS services, including merchants, their customers, and personnel. Additional notices may apply to specific services.

TABLE OF CONTENTS

1. Personal Data We Collect
2. How We Use Your Personal Data
3. Parties With Whom We Share Your Data
4. Your Rights and Choices
5. International Transfers
6. Data Security
7. Links to Other Websites
8. Data Retention
9. Additional Information for EU/UK Users
10. Information for California Residents
11. Information for Virginia Residents
12. Changes to This Notice
13. Contact Us

1. PERSONAL DATA WE COLLECT

We collect data from various sources, including:

A. Customers Using StarPOS Services

• Transaction Data: Payment details, merchant location, transaction time/amount, and purchased goods/services.
• Optional Data: Email/phone for receipts, loyalty program participation, or preferences (e.g., birthdate).
• App Data: Name, email, password, and location (with consent) via StarPOS apps.

B. Merchants and Their Personnel

• Business Data: Contact details, account credentials, government IDs (e.g., SSN), transaction history, and marketing preferences.
• Employee Data: Clock-in/out times, tips, and job-related information.

C. Third-Party Apps

• Data from applications installed on StarPOS devices (e.g., cloud storage integrations).

D. Job Applicants

• Resume details, professional history, and references.

E. Public/Private Sources

• Government sanctions lists, credit agencies, and social media platforms.

F. Automated Collection

• Device identifiers, IP addresses, browsing activity, and location via cookies (see Cookie Notice).

G. Sensitive Data

• Biometric data (e.g., fingerprints for authentication) or health data (e.g., pharmacy transactions) as permitted by law.

2. HOW WE USE YOUR DATA

• Providing Services: Process payments, manage accounts, deliver receipts, and support merchants.
• Research & Development: Improve products, analyze trends, and develop analytics.
• Marketing: Send merchant promotions (with consent) and tailored offers.
• Compliance: Fraud prevention, legal obligations, and risk management.
• Employment: Process job applications and recruitment.
• Anonymization: Create aggregated insights for business purposes.

3. SHARING YOUR DATA

We share personal data with:

• EPM Mobile Affiliates: For operational purposes.
• Service Providers: Payment processors, IT support, and fraud detection agencies.
• Merchants: To fulfill orders (e.g., food delivery details).
• Legal Authorities: In response to subpoenas, fraud prevention, or safety concerns.
• Business Transfers: In cases of mergers, acquisitions, or bankruptcy.

4. YOUR RIGHTS AND CHOICES

• Marketing Opt-Out: Unsubscribe via email links or contact us.
• Targeted Ads: Opt out via DAA or device settings.
• Access/Delete Data: Submit requests at www.starposregister.com/privacyrequests.
• Do Not Track: We do not respond to DNT signals.

5. INTERNATIONAL TRANSFERS

Your data may be transferred to the U.S. or other countries. We use safeguards such as Standard Contractual Clauses for EU/UK transfers.

6. DATA SECURITY

We implement PCI DSS compliance, encryption, and access controls. Report breaches to eosei@epmmobileinc.com.

7. LINKS TO OTHER SITES

Third-party sites (e.g., social media) have separate privacy policies. We are not responsible for their practices.

8. DATA RETENTION

We retain data as long as necessary for legal, compliance, or business needs (e.g., fraud prevention).

9. ADDITIONAL INFORMATION FOR EU/UK USERS

• Controller: EPM Mobile Inc.
• Legal Bases: Contractual necessity, consent, legitimate interests, and legal compliance.
• GDPR Rights: Access, correct, delete, restrict, or port data. Contact eosei@epmmobileinc.com.

10. INFORMATION FOR CALIFORNIA RESIDENTS (CCPA)

• Opt-Out of Sales/Sharing: Use our Opt-Out Tool or Global Privacy Control.
• Collected Categories: Identifiers, transaction history, geolocation.
• Submit Requests: Privacy Portal or call 443-519-8788.

11. INFORMATION FOR VIRGINIA RESIDENTS (VCDPA)

• Exercise rights to access, correct, or delete data via the methods above.

12. CHANGES TO THIS NOTICE

• Updates will be posted at www.starposregister.com/privacy. Material changes will be notified via email or app alerts.

13. CONTACT US

EPM Mobile Inc.
413 Commonwealth Ave, Catonsville, MD 21228
📞 443-519-8788 | eosei@epmmobileinc.com
Data Protection Officer: eosei@epmmobileinc.com

24/7 Privacy Hotline: 443-519-8788 (Report suspected breaches or urgent concerns).

[END OF PRIVACY NOTICE]
For the latest version, visit www.starposregister.com/privacy.

Glossary & Additional Details

• Sensitive Data: Includes biometrics, health, or financial information.
• Everyday Business Purposes: Fraud detection, customer service, and compliance.
• Third-Party Apps: Review app privacy policies before installation.