Ocuco Privacy Policy

OcuPay

Effective Date: April 1, 2026

This “Privacy Policy” explains how Ocuco (“Company” or “we”) collects, uses, discloses, and otherwise processes personal data on behalf of our customers – typically, merchants (any, a “Merchant”) – in connection with our application, OcuPay, which runs on the Clover Point of Sale system (“Clover POS”). This Privacy Policy does not apply to Company’s privacy practices in any other context.

Company’s processing of personal data in connection with OcuPay is governed by this Privacy Policy and our agreements with Merchants. In the event of any conflict between this Privacy Policy and a customer agreement, the customer agreement will control to the extent permitted by applicable law.

This Privacy Policy is not a substitute for any privacy policy that a Merchant may be required to provide to their customers, personnel, or other individuals.

Information Ocuco Collects

We may collect personal data from or on behalf of Merchants. Merchants determine the scope of the personal data transferred to us or that we collect, and the information we receive may vary by Merchant. Typically, the information we collect on behalf of Merchants includes:

Information collected when a customer makes a payment

When a customer makes a payment via a Clover POS, we collect information about the transaction, which may include personal data. Information about transactions includes:

• The payment card used
• Name associated with the payment card
• The location of the merchant’s store
• Date and time of the transaction
• Transaction amount
• Information about the goods or services purchased in the transaction

Additional information provided through the Clover POS ancillary to a payment

We may collect additional information ancillary to the payment. This information may include:

• Customers’ email address or phone number, such as when the customer chooses to receive an electronic receipt
• Customers’ marketing preferences, such as whether the customer wishes to receive marketing communications or newsletters
• Information about participating customers’ activity in a merchant loyalty program
• Customers’ physical address, where needed for delivery of goods or services
• Other information the customer provides, such as birthdate, interests or preferences, reviews, and feedback

Information collected about personnel of a Merchant

We may collect information about Merchants’ personnel and interactions with the Clover POS, such as clock-in and clock-out time and tips earned.

Additional information that Merchants provide to us

Merchants may provide us with additional information directly, via access they grant to us, or otherwise.

The types of information that merchants may provide to us about their customers include email addresses, phone numbers, and purchase history.

The types of information that merchants may provide to us about their personnel include email addresses, phone numbers, shifts, and sales history.

How We Use the Information We Collect

We use the personal data we collect for or on behalf of Merchants to provide our services and the functionality of OcuPay: personal data is only used in the perimeter of the payment feature managed by OcuPay.

We may also use personal data for related internal purposes, including:

• To provide information about OcuPay, such as important updates or changes to the application and security alerts
• To measure performance of and improve OcuPay
• To respond to inquiries, complaints, and requests for customer support

In addition, Ocuco may use personal data as we believe necessary or appropriate to:

(a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities;

(b) enforce the terms and conditions that govern OcuPay;

(c) protect our rights, privacy, safety or property, and/or that of you or others; and

(d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Information

We may share personal data that we collect with:

• The Merchant from whom or on whose behalf we collected the personal data
• The platform on which OcuPay runs, the Clover POS. You may view Clover’s Privacy Notice here
• With third parties as a Merchant may direct
• With third party service providers that help us manage and improve OcuPay
• With Ocuco subsidiaries and corporate affiliates for the purposes described in this Privacy Policy or in our agreement with a Merchant

Ocuco may disclose personal data to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to:

(a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities;

(b) enforce the terms and conditions that govern OcuPay;

(c) protect our rights, privacy, safety or property, and/or that of you or others; and

(d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Ocuco may sell or transfer some or all of its business or assets, including your personal data, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Rights and Choices

Data Subject Rights

To the extent that applicable law provides individuals with rights pertaining to their personal information, such as to review and request changes to their personal information, individuals should contact the Merchant with any requests pertaining to the Merchant’s use of OcuPay.

To the extent that Clover is responsible for responding to data subject rights requests under applicable law, individuals may contact Clover with applicable requests as explained in Clover’s Privacy Notice at https://www.clover.com/privacy-policy. Ocuco will assist a Merchant, or Clover, as applicable, in responding to such requests subject to our contract with a Merchant or Clover.

Complaints

If you have a complaint about our handling of personal data, you may contact us via the contact information provided below.

Updates

We reserve the right to modify this Privacy Policy at any time. We will notify you of updates by updating the date of this Privacy Policy.

Contact Us

You may contact us with any questions, comments, or complaints about this Privacy Policy or our privacy practices via: info@ocuco.com

Additional Information for Merchants Located in Europe

Controller

Ocuco has appointed a Data Protection Officer (DPO) in accordance with Article 37 of the GDPR. The DPO can be contacted as follows:

Name: Stephen van Beek

Role: Data Protection Officer

Email: dataprotection@ocuco.com

As Ocuco is headquartered in Ireland and is therefore established within the EU, no separate EU Representative under Article 27 GDPR is required.

Ocuco is a data processor acting for and on behalf of the Merchant that has installed OcuPay on their Clover POS. That Merchant is the controller of personal data that we process on its behalf. Clover is also a controller of personal data in some circumstances. Clover’s Privacy Notice is available at https://www.clover.com/privacy-policy.

Legal Basis for Processing

Ocuco processes personal data as directed or permitted by the Merchant that uses OcuPay. The Merchant is responsible for establishing a legal basis for our processing of personal data for or on behalf of the Merchant.

Cross-Border Data Transfer

When we transfer personal data outside of Europe (or the UK) to countries not deemed by the European Commission to provide an adequate level of protection for personal data, we make the transfer pursuant to one of the following transfer mechanisms:

• A contract approved by the European Commission (sometimes called “Model Clauses” or “Standard Contractual Clauses”);
• The recipient’s Binding Corporate Rules;
• The consent of the individual to whom the personal data relates; or
• Other mechanisms or legal grounds as may be permitted under applicable European law.

You may contact us with questions about our transfer mechanism.

Data Retention

Subject to our agreement with a Merchant, Ocuco retains personal data for as long as necessary to:

(a) provide our products and services;

(b) comply with legal obligations;

(c) resolve disputes; and

(d) enforce the terms of any agreement we may have with a Merchant.

You may contact us for additional information about our data retention practices in connection with OcuPay.

Data Subject Rights (EU/EEA and UK)

Under certain circumstances, data subjects in Europe and the UK have certain rights relating to their personal data, which include the rights to request from the Controller:

(a) access to the data subject’s personal data;

(b) correction of incomplete or inaccurate personal data;

(c) erasure of personal data;

(d) restriction of processing concerning the data subject; and

(e) that the controller provide a copy of the data subject’s personal data in a structured, commonly used and machine-readable format.

Data subjects may also object to a controller’s processing of personal data under certain circumstances. Where processing is based on a data subject’s consent, the data subject has the right to withdraw consent at any time; however, the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Data subjects may also file a complaint with a supervisory authority. You may view contact information for supervisory authorities at https://edpb.europa.eu/about-edpb/board/members_en. Data subjects in Europe or the UK should direct any rights request to the appropriate Controller.

Additional Information for Merchants Located in the United Kingdom

For Merchants located in the United Kingdom, this Privacy Policy should be read with reference to the UK General Data Protection Regulation (UK GDPR) as defined in the UK Data Protection Act 2018.

The relevant supervisory authority for UK data subjects is the Information Commissioner’s Office (ICO). UK data subjects may file a complaint with the ICO at https://ico.org.uk.

International transfers of personal data from the UK will be made pursuant to transfer mechanisms recognised under UK law, including the UK International Data Transfer Agreement (IDTA) or equivalent mechanism approved by the UK Secretary of State.

Additional Information for Merchants Located in Canada

For Merchants located in Canada, Ocuco will comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

Ocuco will only collect, use, and disclose personal data with the Merchant’s knowledge and consent, and only for purposes that a reasonable person would consider appropriate in the circumstances.

Individuals in Canada may contact us using the contact details below with any questions about our privacy practices or to exercise applicable rights.

Additional Information for Merchants Located in Australia

For Merchants located in Australia, Ocuco will comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Before disclosing personal data to overseas recipients, Ocuco will take reasonable steps to ensure that the recipient does not breach the APPs in relation to that data.

Individuals in Australia may contact us using the contact details below with any questions about our privacy practices or to exercise applicable rights under the Privacy Act.

Your California Privacy Rights

As a California resident, you have the rights listed below. However, these rights are not absolute, and we may decline your request as permitted by the CCPA.

Information

You can request the following information about how we have collected and used your Personal Information during the past 12 months:

• The categories of Personal Information that we have collected
• The categories of sources from which we collected Personal Information
• The business or commercial purpose for collecting and/or selling Personal Information
• The categories of third parties with whom we share Personal Information
• Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of recipient
• Whether we’ve sold your Personal Information; and, if so, the categories of Personal Information received by each category of recipient

Access

You can request a copy of the Personal Information that we maintain about you.

Deletion

You can ask us to delete the Personal Information that we maintain about you.

Nondiscrimination

You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you goods or services, increasing the price/rate of goods or services, decreasing the service quality, or suggesting that we may penalize you for exercising your rights.

However, the CCPA allows us to charge you a different price or provide a different service quality if that difference is reasonably related to the value of the Personal Information we are unable to use.

How to Exercise Your Rights

Right to Information, Access and Deletion

You can request to exercise your information, access and deletion rights in the following ways:

• Call 1-800-987-0543

Identity Verification. The CCPA requires us to verify the identity of the individual submitting the request before providing a substantive response. A request must be provided with sufficient detail to allow us to understand, evaluate and respond. The requester must provide sufficient information to allow us to reasonably verify that the individual is the person about whom we collected information. A request may also be made on behalf of your child under 13.

Authorized Agents. California residents can empower an “authorized agent” to submit requests on their behalf. We may require the authorized agent to have a written authorization confirming that authority.

Sale of Personal Information

We do not sell, as defined under CCPA, your Personal Information to third parties.

In the preceding twelve (12) months, we have not sold any personal information.

Personal Information That We Collect, Use and Share

The chart below summarises our collection, use and sharing of Personal Information during the last 12 months before the effective date of this Privacy Policy.

Glossary

The following definitions apply to categories of Personal Information referenced in this Privacy Policy:

Contact Information

You may contact Ocuco with any questions, comments, or complaints about this Privacy Policy or our privacy practices at: info@ocuco.com