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Privacy Policy

August 31, 2026

HERE LIMITED ("we", "us", or "our") operates Here, a payments platform available at https://onhere.net/. This Privacy Policy explains how we collect, use, disclose and safeguard your personal data when you use our platform and services, and describes your rights in relation to that data. By creating an account or using Here, you acknowledge that you have read and understood this Privacy Policy.

1. WHO WE ARE
Here is operated by HERE LIMITED, 17 Gresse Street, W1T 1QL London, United Kingdom. Company registration number: 05659314. VAT identification number: —. We are the data controller responsible for your personal data. For any privacy-related question or to exercise your rights, contact us by e-mail at info@onhere.net. We communicate with our users exclusively by e-mail.

2. SCOPE OF THIS POLICY
This Policy applies to personal data we process about account holders (merchants) who register for and use Here, visitors of our website, and individuals whose data we receive in connection with a payment (for example, a customer paying through a hosted checkout page or a payment link). It does not apply to third-party websites or services that we do not control.

3. PERSONAL DATA WE COLLECT
We collect the following categories of personal data:
- Account data: first and last name, e-mail address, telephone number, date of birth, sex, country and postal address, and the password you set (stored only as a secure hash).
- Business data: for business accounts, the company name, legal form, registration number, VAT identification number, industry, registered office address, and the name, role, e-mail and telephone of an authorized representative.
- Verification data: information and documents you submit for identity and company verification, including images of identity documents, a selfie, and official company documents (such as a certificate of incorporation, sole trader certificate or business licence).
- Payment and transaction data: the amount, selected currency, description, status, mode (test or live), reference and time of each transaction, together with related refunds, payouts, rewards, bonuses and delivery-confirmation records. We also process the payout-account details you provide, including account holder, bank name, account country, IBAN where applicable or a local account number, and any routing, clearing, branch or SWIFT/BIC details required for that country. Payment-card data submitted through our payment forms is processed for internal payment processing, security review and transaction records; it is not used for marketing or sold.
- Technical data: IP address, device and browser information, and session and log records generated when you use the platform.
- Communications: the content of e-mails and support requests you send to us.
Payment-card information entered in platform payment forms is processed for payment-processing and security-review functions. Access to those records is limited to authorised operational, security and audit purposes; we do not use payment-card information for marketing or sell it.

4. HOW WE USE YOUR DATA AND OUR LEGAL BASES
We process your personal data to: provide, operate and maintain the platform and your account (performance of a contract); verify your identity and business and comply with applicable financial, anti-money-laundering and know-your-customer obligations (legal obligation and legitimate interests); process payments, calculate our commission, maintain your balance and execute payouts (performance of a contract); detect, prevent and investigate fraud, abuse and security incidents (legitimate interests and legal obligation); communicate with you about your account, transactions and support requests by e-mail; improve and secure the platform (legitimate interests); and comply with legal and regulatory requirements and defend legal claims.

5. PAYMENTS AND FINANCIAL DATA
Here facilitates the processing of payments in currencies enabled in the platform's currency catalogue. EUR and USD are enabled in the standard configuration; availability may vary by feature, transaction and payout account, and additional currencies may be enabled by the platform administrator. Each transaction, balance and payout record retains its selected currency. Unless expressly stated, we do not provide foreign-exchange conversion. We process transaction and payout-account data to operate these services, calculate and deduct platform commission, maintain balances and make payouts to the account you designate.

6. IDENTITY AND BUSINESS VERIFICATION
To meet our legal and risk-management obligations, we and our verification providers process the identity and company information and documents you submit. Verification results and the confirmed data (such as your name, sex and date of birth) may be recorded on your account.

7. HOW WE SHARE YOUR DATA
We do not sell your personal data. We share it only: with service providers that help us operate the platform (for example identity-verification, e-mail delivery, hosting and notification providers), acting on our instructions and bound by confidentiality; with banks, payment institutions and financial partners as necessary to process payments and payouts; where required by law, regulation, court order or a competent authority, or to protect our rights, users or the public; and in connection with a merger, acquisition or reorganization, subject to appropriate safeguards.

8. INTERNATIONAL TRANSFERS
Where personal data is transferred outside your country or the European Economic Area, we take appropriate safeguards required by applicable law (such as standard contractual clauses) to protect it.

9. DATA RETENTION
We retain personal data for as long as your account is active and thereafter for the period required to comply with our legal, accounting, tax and anti-money-laundering obligations, to resolve disputes and to enforce our agreements. When data is no longer needed, we delete or anonymize it.

10. SECURITY
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure or destruction, including encryption of secrets, hashed passwords, access controls and audit logging. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. YOUR RIGHTS
Subject to applicable law, you have the right to access your personal data; to have inaccurate data corrected; to have your data erased; to restrict or object to certain processing; to data portability; and to withdraw consent where processing is based on consent. You also have the right to lodge a complaint with your data-protection authority. To exercise any of these rights, contact us by e-mail at info@onhere.net. We may need to verify your identity before acting on a request.

12. COOKIES
We use strictly necessary cookies and similar technologies to keep you signed in, secure your session and operate the platform. Where optional analytics or third-party technologies such as Google Analytics, reCAPTCHA or Google Fonts are enabled, they may process online identifiers, device or usage data. We provide the notices and obtain consent where required by applicable law.

13. CHILDREN
The platform is not directed to individuals under the age of 18, and we do not knowingly collect their personal data.

14. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The date of the latest revision is shown above. Where changes are material, we will notify you by e-mail. Your continued use of the platform after an update constitutes acceptance of the revised Policy.

15. HOW WE COMMUNICATE
All official communication between you and us takes place by e-mail. Please keep the e-mail address on your account up to date. You can reach us at info@onhere.net.
FEATURE-SPECIFIC PRIVACY NOTICE — CURRENCIES, PAYOUT ACCOUNTS AND OPTIONAL SERVICES
This section supplements and, where inconsistent, updates the descriptions above for the features listed below.

CURRENCIES AND PAYOUT ACCOUNTS
We process the currency selected for a payment, payout or related record. For payout accounts, we process the account holder's name, bank name, account country, account currency, IBAN where applicable or a local account number, and routing, clearing, branch and SWIFT/BIC details where required by the selected country. We use this information to validate, administer and execute payout requests and to meet accounting, fraud-prevention and legal obligations.

CHINESE PRIVATE SELLER PROFILES
For a Chinese private seller profile, we process the required trading name, selected merchant category, business country and business address, together with the account holder's contact and profile data. New registrations in this category do not require a tax/VAT number or company registration number. The selected country is the country supplied by the account holder and is not automatically set to China.

BUSINESS LOANS, SECURITY DEPOSITS AND ESCROW
If you use Business loans, we process eligibility information derived from qualifying successful sales, the application and review record, requested and approved amounts, currency, security-deposit amount and status, linked payout account, payment-link and transaction references, repayment information, disbursement dates and related notifications. If and when an external escrow provider is selected for an arrangement, we may share the minimum data necessary to administer that arrangement, subject to that provider's applicable terms and privacy information.

PHYSICAL-PRODUCT DELIVERY CONFIRMATION
For a physical-product payment, we process the buyer's name and e-mail address, transaction reference and amount, confirmation and release status, timestamps, reminder records and a hashed confirmation-token record. We use this information to send delivery-confirmation messages, administer the holding period and make funds available in accordance with the applicable delivery-confirmation flow.

CONNECTED SIGN-IN AND PASSKEYS
If you choose Google sign-in or link a Google account, we process the Google account identifier, e-mail address and profile name returned through that sign-in flow, and store the provider identifier and e-mail linked to your account. If you register a passkey, the passkey process is performed between your browser or device and the platform. We store the credential identifier, public-key credential record, counter and transport metadata needed to verify sign-ins; we do not receive or store your biometric template or private key.

SERVICE PROVIDERS AND DISCLOSURES
Depending on the services you use and the configuration selected by the platform administrator, we may disclose the minimum personal data needed to: Inilio for identity verification (first name, last name, submitted date of birth, language and callback information, with verification status and extracted identity results returned to us); configured SMTP/e-mail providers for account and transaction communications; Pusher Channels and Pusher Beams for real-time and device notifications; Google for Google OAuth, Google Ads conversion measurement, reCAPTCHA, Analytics or Fonts where those services are enabled; hosting and infrastructure providers; and merchant-selected webhook endpoints for data required by the relevant event. These providers process data under their own applicable terms and privacy information and, where they act for us, under appropriate contractual safeguards.

16. CONTACT
HERE LIMITED
17 Gresse Street, W1T 1QL London, United Kingdom | E-mail: info@onhere.net