Privacy Policy

Effective Date: 01/29/2026

Last Updated: 01/29/2026

Glacier Payments Inc. (“we” or “us or “our”) is committed to

protecting the privacy of our users. This Privacy Policy outlines what data we process, how we do that, how

it is used, how we safeguard it, and what your rights are. This Privacy Policy applies to the data we

obtain from you when you use the Site and when you use the products, services,

tools, and functionality offered or made available by us, whether online

(including the Site), in person, or when you otherwise interact with us (herein

collectively referred to as the “Services”). The “Site” shall mean all websites, devices, and applications that we

operate, the pages within each such websites, devices and applications, and

equivalent, mirror, replacement, substitute or backup such websites, devices

and applications, and pages that are associated with each such websites,

devices, and applications. By signing up for, accessing, or using our Services

or by accessing our Site, you accept this Privacy Policy and consent to our collection,

use, and disclosure of your Personal Data as described in this Privacy Policy.

This Privacy Policy only covers our data collection, maintenance, and

processing.

What information do we collect?

We collect two types of information from you, Personal Data

and Technical Data (as defined below). Although we do not normally use

Technical Data to identify individuals, sometimes individuals can be recognized

from it, either alone or when combined or linked with Personal Data. In such

situations, Technical Data can also be considered to be Personal Data under

applicable laws, and we will treat the combined data as Personal Data. We may

collect and process, for example, the following Personal Data: (i) name and

contact details; (ii) e-mail address; (iii) phone number; (iv) date of birth

(v) Social Security Number, (vi) invoicing and billing information; (vii)

business and financial data, including but not limited to credit histories,

credit scores, transaction history, and credit rates; and (viii) other Personal

Data that you provide to us. The specific kind of Personal Data collected will

depend on how you use the Services. Some of the Personal Data is received

directly from you during your use of the Site or at the point of registration

for the Services or otherwise at the beginning of and during your use of the

Services, and the rest is based on the data you provide to us that is

processed.

The Services use several web analytics services to compile

Technical Data and reports on visitor usage and to help us improve our Services

(“Technical Data”). Technical Data we gather in connection with the use of our

Services may include, for example, the following data: (a) your IP address; (b)

browser type and version; (c) preferred language; (d) geographic location using

IP address or the GPS, wireless, or Bluetooth technology on your device; (e)

operating system and computer platform; (f) the full Uniform Resource Locator

(URL) clickstream to, through, and from our Services, including date and time;

(g) products or services you viewed or searched for while using our Services;

(h) areas of our Services you have visited; and (i) historical data regarding

your use of our Services.

What do we use your information for?

There are several purposes for our collection, maintenance,

and processing of Personal Data. We collect, maintain, and process Personal

Data to perform our contractual obligations to you and to comply with any legal

obligations. Furthermore, we collect, maintain, and process Personal Data to

run, maintain, and develop our business. We also use or process Personal Data

and Technical Data for some or all of the following purposes:

Quality of Services:

We may process information regarding the use of the Services

to improve the quality of our Services (e.g. by analyzing any trends in the use

of our Services). When possible, we will do this using only aggregated,

non-personally identifiable data. Personal Data may also be used for research

and analysis purposes in order to improve our Services.

Provide Services:

We collect, maintain and process Personal Data in the first

place to be able to offer the Services to you and to run, maintain, and develop

our business, including providing Personal Data to affiliates and third party

providers necessary to provide the Services. In some cases, Personal Data may

be collected, maintained, and processed in order to carry out our contractual

obligations to you. Further, if you contact our customer service, we will use

the information that you provide for answering questions and solving possible

issues.

Communication:

We may collect, maintain and process Personal Data for the

purpose of contacting you regarding our Services and to inform you of changes

in our Services.

Functionality of Services:

Provided the following are done in full compliance with this

Privacy Policy, applicable laws, rules, and regulations, we may (a) process,

analyze, and manage data to provide the Services to you; and (b) use data to

analyze, develop, and improve the Services.

Share Information:

We may share information with third parties that is not

personally identifying, such as aggregated or anonymized data that does not

identify you or our third parties, in our discretion, where not prohibited by

law.

Compliance:

We may share Personal Data in response to a subpoena or

similar investigative demand, court order, requests for cooperation from a law

enforcement agency, self-regulatory body, or other governmental agency to

establish or exercise our legal rights, to defend against legal claims, or as

we reasonably believe is required by law. In such cases, we may raise or waive any legal objection or right

available to us.

Prevent Illegal Activities:

We may share Personal Data when we believe that disclosure

is appropriate in order to investigate, prevent, or take action regarding any

actual or suspected illegal activity or other wrongdoing, to protect and defend

the rights, property, or safety of our business, our users, our employees, or

others or to enforce any of our agreements or policies.

How do we protect your information?

We will take all reasonable and appropriate security

measures to protect the Personal Data we store and process from unauthorized

access or unauthorized alteration, disclosure or destruction. We maintain all

Personal Data collected through industry standard safe mechanisms. We use

administrative, organizational, technical, and physical safeguards to protect

the Personal Data we collect and process. Our security controls are designed to

maintain an appropriate level of data confidentiality, integrity, and availability.

If a security breach occurs despite our security measures that is likely to

have negative effects to your privacy, we will inform you and other affected

parties, as well as relevant authorities when required by applicable data

protection laws, about the breach as soon as reasonably possible. We use

appropriate security measures to keep your Personal Data safe; however, we

cannot guarantee that your Personal Data will always remain secure. We encourage you to disclose any suspected

security vulnerabilities or bugs to us at [email protected]. After

a transaction, your private information (credit cards, social security numbers,

financials, etc.) will be kept on file for more than 60 days in order to comply

with our banking partners’ requirements.

Do we use cookies?

Yes. Cookies are small files that a site or its service

provider transfers to your computers hard drive through your internet browser

(if you allow) that enables the sites or service providers systems to recognize

your browser and capture and remember certain information. We use cookies to understand and save your

preferences for future visits, keep track of advertisements and compile

aggregate data about site traffic and site interaction so that we can offer

better site experiences and tools in the future. Please note that some parts of our Services

may not function properly if use of cookies are refused. If you wish to op-out of cookies, you can use

Clym.io tool located at https://clym.io/blog/introducing-widget-layouts-for-website-compliance.

Further, our Services may not respond to Do-Not-Track requests or headers from

some or all browsers.

Do we disclose any information to outside parties?

We do not share Personal Data with third parties outside of

our organization other than in connection with the performance of the Services,

including, without limitation, with third party providers for the Services,

unless one of the following circumstances applies:

Consent:

We may share Personal Data with third parties outside of our

organization when we have your explicit consent to do so. You have the right to

withdraw this consent at all times.

Necessity:

To the extent that third parties need access to Personal

Data to perform the Services, we have taken appropriate contractual and

organizational measures to ensure that Personal Data is maintained and

processed exclusively for the purposes specified in this Privacy Policy and in

accordance with all applicable laws and regulations.

Service Providers:

We may share Personal Data to authorized service providers

who perform services for us (including data storage, sales, marketing and

customer support services). Our agreements with our service providers include

commitments that the service providers agree to limit their use of Personal

Data and to comply with privacy and security standards at least as stringent as

the terms of this Privacy Policy. Please bear in mind that if you provide

Personal Data directly to a third party, such as through a link on our website,

the processing is typically based on their policies and standards.

Legal:

We may share Personal Data with third parties outside of our

organization if we have a good-faith belief that access to and use of the

Personal Data is reasonably necessary to: (i) meet any applicable law,

regulation, and/or court order; (ii) detect, prevent, or otherwise address

fraud, security or technical issues; and/or (iii) protect the interests,

properties or safety of our customers or the public in accordance with the law.

When possible, we will you about such transfer and processing.

Any Other Legitimate Reason:

If we are involved in a merger, acquisition or asset sale,

we may transfer Personal Data to the third party involved; however, we will

continue to ensure the confidentiality of all Personal Data. We will give

notice to you when your Personal Data is transferred or becomes subject to a

different privacy policy as soon as reasonably possible.

What are your rights concerning your Personal Data?

We will handle your requests and rights in accordance with

applicable law. This means there may be

legal reasons why we cannot fulfill all requests. We may need to request specific information

from you to help confirm your identify and ensure your right to access your

Personal Data (or to exercise any of your other rights). This is a security measure to ensure that

your Personal Data is not disclosed to any person who has no right to receive

it. We may also contact you to ask you

for further information in relation to your request to speed up our response

time.

Withdraw Consent:

In case the collection, maintenance, or processing of

Personal Data is based on your consent, you may withdraw your consent at any

time. Withdrawing your consent may lead to fewer possibilities to use the

Services or the complete termination of our Services.

Correction:

You have the right to have incorrect, imprecise, incomplete,

outdated, or unnecessary Personal Data we have stored about you corrected or

completed.

Objection:

You may object to certain use of Personal Data if such

information is collected, maintained, or processed for other purposes than

purposes necessary for the performance of our Services to you or for compliance

with a legal obligation. You may also object to any further collection,

maintenance, or processing of Personal Data after previously giving consent. If

you object to the further collection, maintenance, or processing of Personal

Data, this may lead to fewer possibilities to use the Services or the complete

termination of our Services.

Access:

We offer you access to your Personal Data that we maintained

or processed. This means that you may contact us, and we will inform you what

Personal Data we maintain and the purposes such Personal Data is used for.

Portability:

You have the right to receive your Personal Data from us in

a structured and commonly used format and to independently transmit that

information to a third party.

Deletion:

You may also ask us to delete your Personal Data from our

systems. We will comply with such request, unless we have a legitimate ground

to not delete the information. We may not immediately be able to delete all

residual copies from our servers and backup systems after the active Personal

Data has been deleted. Such copies shall be deleted as soon as reasonably

possible.

Restriction:

You may request us to restrict certain maintenance or

processing of Personal Data, but this may however lead to fewer possibilities

to use our Services or the complete termination of our Services.

The above-mentioned rights may be used by sending a letter

or an e-mail to us at the addresses set out below, including the following

information: the full name, company name (if applicable), address, e-mail

address, and a phone number. We may request the provision of additional

information necessary to confirm your identity. We may reject requests that are

unreasonably repetitive, excessive, or manifestly unfounded. If you consider

our collection, maintenance, or processing of Personal Data to be inconsistent

with the applicable data protection laws, you may lodge a complaint with the

local supervisory authority for data protection.

California Online Privacy Protection Act Compliance

We are required by the California Consumer Privacy Act of

2018 (“CCPS”) to provide this CCPS Notice to California residents to explain

how we collect, use, and share their Personal Data, and the rights and choices

we offer California residents regarding our handling of their Personal Data. This CCPA Notice applies only to California

residents whose interactions with us are limited to:

1. Visiting

our Site;

2. Signing

up for email alerts;

3. Commenting

on or contributing to our blogs;

4. Establishing

an account that does not include financial products or services; or

5. Applying

for our job openings on our websites (however, note that the CCPA limits some

of the privacy rights for job applicants).

This CCPA Notice does not apply to the Personal Data we

collect, use, or disclose about consumers who initiate or complete the process

of applying for financial products or services. This is because this information is subject is subject to the federal

Gramm-Leach-Billey Act (“GLBA”) and implementing regulations of the California

Financial Information Privacy Act (“FIPA”), or representatives of businesses

that seek to obtain our products or services, or to provide products or

services to us. We do not sell personal

information. As explained in this

Privacy Policy, we use cookies and other tracking technologies to analyze

website traffic and facilitate advertising.

The below provides California residents the right to know

the categories of Personal Data collected and whether we disclosed your

Personal Data for business purposes in the proceeding twelve (12) months:

Privacy Practices:

We do not sell Personal Data. As explained in our Privacy Policy, we use

cookies and other tracking technologies to analyze website traffic and

facilitate advertising. Please note that

we may also disclose Personal Data as described in this Privacy Policy.

Privacy Rights:

The CCPA grants individuals the following rights:

1. Information

and Access. You can request information

about how we have collected, used, and shared your Personal Data during the

past 12 months. You can also request a copy of the Personal Data that we

maintain about you.

2. Deletion. You can ask us to delete the Personal Data

that we collected or maintained about you. Please note that the CCPA limits these rights by, for example,

prohibiting us from providing certain sensitive information in response to an

access request and limiting the circumstances in which we must comply with a

deletion request. We will respond to

requests for information and access only to the extent we are able to associate

with a reasonable effort the information we maintain with the identifying details

you provide in your request. If we deny

your request, we will communicate our decision to you. You are entitled to exercise the rights

described above free from discrimination. To request access to or deletion of Personal Data please contact us at

[email protected].

3. Opt-Out. You may request us to stop sharing your

Personal Data (“op-out”, including via a user-enabled global privacy

control). We cannot share your Personal

Data after we receive your opt-out request unless you later authorize us to do

so again.

4. Non-discrimination. We cannot deny you the Services, charge you a

different price, or provide a different level or quality of the Services just

because you exercised your rights under the CCPA. However, if you refuse to provide your

Personal Data to us or ask us to delete or stop sharing your Personal Data, and

that Personal Data or the sharing of the Personal Data is necessary for us to

provide you with the Services, we may not be able to complete that portion of

the Services or the Services in its entirety.

5. Correction. You have the right to ask us to correct any

inaccurate information that we may have about you.

6. Limit. You can direct us to only use your sensitive

Personal Data (i.e. your social security number, financial account information,

your precise geolocation data, or your genetic data) for limited purposes, such

as providing you with the Services.

7. Identity

verification. The CCPA requires us to

verify the identity of the individual submitting a request to access or delete

Personal Data before providing a substantive response to the request. We will ask you to verify your identity when

you submit a request.

8. Authorized

Agents. California residents can empower

an “authorized agent” to submit a request on their behalf. We will require the authorized agent to have

a written authorization confirming that authority.

Viriginia, Colorado, Connecticut, and Utah

In addition to your rights set forth in this Privacy Policy,

residents of Virginia, Colorado, Connecticut, and Utah have the right to

opt-out of the sharing of Personal Data. Residents of Virginia, Colorado and Connecticut also have the right to

appeal any decision made by us concerning the use of your Personal Data.

Children’s Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA

(Children’s Online Privacy Protection Act), we do not collect any information

from anyone under 13 years of age. Our website, products and services are all

directed to people who are at least 13 years old or older. If we learn we have

collected such information, we will delete such information. To notify us that we might have any

information from or about a person under the age of 18, please contact us at [email protected].

Changes to our Privacy Policy

We reserve the right to modify or amend this Privacy Policy

at any time and for any reason. If we make any changes, we will notify you by

posting it on our Site. We encourage you to frequently check this page for any

changes to stay informed about how we are helping to protect the information we

collect. By using our Services, you

acknowledge and agree that it is your responsibility to review this Privacy

Policy periodically and become aware of any modifications. If there are material changes to this Privacy

Policy, we will notify you more directly by email or means of a notice on the

home page prior to the change becoming effective. We encourage you to review

our Privacy Policy periodically to stay informed about our information

practices and the ways you can help protect your privacy. Your continued access

or use of our website and Services following a change means you consent to the

collection, maintenance, use and disclosure of your Personal Data as set out in

this Privacy Policy.

Contacting Us

If there are any questions regarding this Privacy Policy,

you may contact us at [email protected]