ELECTRONIC COMMUNICATIONS POLICY

Purpose:

This Electronic Communications Policy  (the “Policy”) establishes guidelines for PayFiniti, LLC and Genesis Gaming Solutions, Inc. (“PayFiniti” or “Genesis” individually; “Company” collectively) and its clients (the “Account Owner”) regarding the electronic delivery of correspondence and/or dissemination of account-related information.  The Policy includes obtaining consent for the use of the Account Owner’s electronic signature to execute legally binding agreements and transactions.

Scope:

This Policy applies to all Account Owners of PayFiniti’s E-Wallet, to whom Company will deliver correspondence and account-related information via electronic communication methods.

Policies:

1.       Electronic Delivery of Communication

·       Company may deliver correspondence, statements, notices and other important account-related information electronically to each Account Owner, who has consented to electronic delivery (or has failed to opt out of electronic delivery).

·       Electronic delivery methods may include email, secure online portals, mobile applications, screen display, or other electronic means. 

2.       Client Consent for Electronic Delivery

·       Given that PayFiniti’s E-Wallet Account is a virtual product, the Company’s default method of communication with an Account Holder is via electronic delivery.

·       Consent to accept electronic delivery may be obtained through a separate electronic application form that is completed by the Account Owner when initially establishing the account. 

3.       Electronic Signatures

·       Company relies on electronic signatures provided by the Account Owner to formally execute legally binding documents, agreements, and required authorizations. 

·       By providing their signature via electronic means, or any other digital facsimile thereof, the Account Owner acknowledges that in doing so they are, in fact, providing approval as well as legally binding consent.  As an example, a digital signature can be a scanned image of the Account Owner’s wet signature, a computer-generated rendition, or a Personal Identification Number (“PIN”), any of which can be created in a secure environment with property validation. 

·       Any use of a digital signature or PIN by an Account Owner is deemed to be an authentic consent by the Account Owner to authorize a transaction or other legally binding instruction.  Refer to the Terms and Conditions for additional information regarding a PIN.

4.      Electronic Records

·       Company may maintain detailed account information, correspondence, transactional history, account statements, and other pertinent data for each Account Owner in digital format. 

·       Company may share some (or all) of such information with the Account Owner via one of several methods of electronic communication.  The dissemination of information to the Account Owner may be initiated at the Account Owner’s request or as a matter of the Company’s standard business protocol.  Company’s standard protocol may include recurring and/or automated electronic communication (such as transaction confirmations, or periodic statements).   

·       All electronic delivery and signatures must comply with relevant laws and regulations, including those related to data security and privacy. 

·       Company may maintain records of electronic communications, in accordance with its record retention policy and applicable laws. 

5.      Account Owner Responsibilities

·       Each Account Owner is responsible for maintaining the security and confidentiality of their electronic communications, agreements, and transactions.

·       An Account Owner should promptly report any suspected unauthorized access or use of their electronic communications, agreements, or transactions to PayFiniti.  To protect the Account Owner’s privacy, Company may have to cancel the Account Owner’s Mobile Wallet Account (see “Terms and Conditions” for additional information regarding Compromised Accounts). 

6.      Training and Awareness

·       Company will provide online and email assistance and guidance to an Account Owner that inquires about the various methods of electronic communication and/or use of their digital signature. 

·       Upon request, a Company team member will assist an Account Owner in making their selection of preferences with respect to electronic communication methods.

7.       Non-Compliance

·       The failure of an Account Owner to abide by this Policy may result in suspension of electronic delivery or termination of the Account Owner’s PayFiniti E-Wallet Account. 

Policy Review

This Policy will be reviewed annually by Company’s compliance team to ensure compliance with relevant laws and regulations and/or update the procedures as deemed necessary. 

Approval

This Policy is approved by PayFiniti, LLC and Genesis Gaming Solutions, Inc. and was reviewed and is effective as of February 25, 2024.