MasterCard International Inc.:
Start Path Privacy Notice

MasterCard International Inc. respects your concerns about privacy. This Privacy Notice applies to the MasterCard Start Path website (the “Site”). It describes the types of personal data we collect in connection with the Site, the purposes for which we collect such personal data, the other parties with whom we may share it and the measures we take to protect the security of the data. It also tells you about your rights with respect to your personal data, how you can reach us to update your information or get answers to questions you may have about our privacy practices.

1. Personal Data We Collect

In connection with your use of the Site, we may collect certain personal data such as: your name, telephone number, email address, user name, password, answers to our security questions and the materials contained in your application submission.

We collect personal data about you from the following sources:

· Personal data we receive about you and your business directly from you upon applying through the Site; and

· Personal data we receive about you and your business from the Services if you submit an application for a Start Path program through the Services;

· Preferences data or transaction data that is processed through the Site.

2. How Do We Use Personal Data We Collect

We may use the personal data we obtain about you to:

· Create and manage your online account, provide the Site services, and to respond to your inquiries;

· Communicate with you about the Site;

· Evaluate your application submission;

· If you have consented, provide marketing and related communications to you;

· Monitor the use of and improve our interactive assets;

· Perform data analyses (including anonymization of personal information) to determine, among other measurements, business performance, number of registrants and site performance;

· Enforce our Terms of Use;

· Comply with applicable legal requirements and industry standards and our policies; and

· Perform auditing, research and analysis in order to maintain, protect and improve our services.

3. Personal Data We Share

We do not sell or otherwise disclose personal data we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected.

We share personal data to perform the services requested through the Site. We may share the personal data we collect with members of the selection committee who will be evaluating submissions for the different Start Path programs. We may share the personal data we collect with our affiliates, financial institutions that issue payment cards or process payment card transactions, entities that assist with payment card fraud prevention, and merchants. We may share aggregated, de-identified and other non-personally identifiable information with participating financial institutions and their customers. For example, we may share data to show trends about the general use of the Site.

We also may share data with our service providers who perform services on our behalf. We do not authorize these service providers to use or disclose such data except as necessary to perform certain services on our behalf or comply with legal requirements. We require these service providers by contract to appropriately safeguard the privacy and security of personal data they process on our behalf.

We also may disclose personal data about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with this Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

4. Your Rights and Choices

You may have certain rights regarding the personal data we maintain about you. We offer you certain choices about what personal data we collect from you, how we use that information, and how we communicate with you. To learn more about your rights and choices, please check MasterCard’s Global Privacy Notice.

If you are located in the European Economic Area or Switzerland, we use your personal data only for the purposes indicated in this policy unless we have a legal basis, such as consent, to use it for other purposes. Where required by law, MasterCard obtains your prior opt-in consent at the time of collection for the processing of (i) personal data for marketing purposes and (ii) personal data deemed sensitive pursuant to applicable law. Subject to applicable law, you may have the right to request access to and receive information about the personal data we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate. The right to access personal data may be limited in some circumstances by local law requirements. To update your preferences, ask us to remove your personal data from our mailing lists or submit an access request, please contact us as specified below.

5. How We Protect Personal Data

We restrict access to personal data about you to those employees who need to know that information to provide products or services to you. We maintain reasonable administrative, technical and physical safeguards that comply with state and federal regulations to protect the personal data we have about you. We also take measures to destroy or permanently de-identify personal information when there is no longer a business need to keep the information. The types of measures we take vary with the type of information, and how it is collected and stored. Unfortunately, no data transmission can be guaranteed to be 100% secure. Thus, while we strive to protect your personal data, we cannot ensure or warrant the security of any data transmission.

6. Data Transfers

We may transfer the personal data collect about you to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the data. When we transfer your data to other countries, we will protect that data as described in this Privacy Notice. MasterCard is certified under the Safe Harbor privacy framework as set forth by the U.S. Department of Commerce, European Commission and Switzerland regarding the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area or Switzerland to the U.S. Click here to view our Safe Harbor Privacy Policy.

7. Updates to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. We may also supplement the notice on the website with changes made directly to the Privacy Notice in the Site. Your continued use of the Site subsequent to any changes to the Privacy Notice (as notified on our website) constitutes your acceptance of the changes. Please review our Privacy Notice on our websites periodically to ensure that you are aware of any changes or updates.

8. How to Contact Us

Subject to applicable law, you may have the right to request access to and receive information about the personal data we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate. The right to access personal data may be limited in some circumstances by local law requirements. To ask us to remove your data from our mailing lists, please click here to opt-out from receiving marketing communications. To update your preferences or submit an access request, please contact us as specified below. If you have any questions or comments about this Privacy Notice or if you would like us to update the data we have about you or your preferences, please click here. You may also contact us by writing to:

Global Privacy & Data Usage Officer

MasterCard Worldwide

2000 Purchase Street

Purchase, New York 10577

USA

If you are located in the European Economic Area or Switzerland, MasterCard Europe sprl may be the entity responsible for the processing of your personal information. To exercise your rights of access, rectifications, blocking, or deletion or to object to the processing of your personal information, contact us by email at info@startpath.com or writing to us at:

Global Privacy & Data Usage Officer

MasterCard Europe sprl

Chausee de Tervuren 198A

B-1410, Waterloo

Belgium

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