PRIVACY POLICY

Chargemont UAB

Last updated: 10 March 2026

1. Introduction

Chargemont UAB ("Chargemont", "we", "us", or "our") is a company registered in the Republic of Lithuania. We operate chargemont.com and provide chargeback management, chargeback alerts, dispute representment, and related risk management services (collectively, the "Services").

This Privacy Policy explains how we collect, use, store, share, and protect personal data in connection with our Services, our website, and any communications we have with you. It applies to merchants and their representatives who use our Services, as well as visitors to our website.

We are committed to processing personal data in accordance with the EU General Data Protection Regulation (GDPR) (Regulation (EU)2016/679) and applicable Lithuanian data protection law.

Please read this policy carefully. If you have any questions, contact us at hello@chargemont.com.

2. Who We Are — Data Controller

The data controller responsible for your personal data is:

Chargemont UAB

Registered address: V. Nagevičiaus g. 3, LT-08237 Vilnius, Lithuania

Company registration number: 306442334

VAT number: LT100016443211

Phone: +370 669 41900

Email: hello@chargemont.com

Where we act as a data processor on behalf of a merchant (for example, when processing their customers' transaction data), the merchant is the data controller and we act under their instructions. In such cases, the terms of our Data Processing Agreement govern the processing.

3. What Personal Data We Collect

3.1 Data You Provide Directly

When you register for our Services, contact us, or interact with our platform, we may collect:

•      Full name and job title

•      Business name and registered address

•      Email address and telephone number

•      Payment and billing information

•      Login credentials (username and password)

•      Any information you provide in correspondence with us

3.2 Data We Collect Automatically

When you use our website or platform, we automatically collect:

•      IP address and approximate location

•      Browser type and version

•      Device type and operating system

•      Pages visited, time spent, and navigation paths

•      Referring URLs

•      Cookie and tracking data (see Section 9)

3.3 Transaction and Chargeback Data

To provide our Services, we process transaction and chargeback-related data on behalf of merchants. This may include:

•      Transaction IDs, amounts, dates, and payment processor references

•      Cardholder names and partial card details (as providedby alert networks)

•      Order details, shipping and fulfilment information

•      Customer communication records relevant to dispute resolution

•      Chargeback reason codes and bank reference numbers

This data is processed as a data processor under instruction from merchants. We do not use this data for our own independent purposes.

4. How We Use Your Personal Data

We use personal data for the following purposes and on thefollowing legal bases:

4.1 Providing and Managing Our Services (Contractual Necessity)

•      Creating and managing your account

•      Processing chargeback alerts and dispute responses

•      Communicating with you about your account and our Services

•      Processing payments and billing

•      Providing customer support

4.2 Legal Obligations

•      Complying with applicable laws and regulations

•      Responding to lawful requests from public authorities

•      Maintaining records as required by law

4.3 Legitimate Interests

•      Improving and developing our Services

•      Fraud prevention and security monitoring

•      Analysing usage patterns to improve platform performance

•      Sending service-related updates and notifications

4.4 Consent

•      Sending marketing communications (where you have opted in)

•      Placing non-essential cookies (see Section 9)

You may withdraw consent at any time by contacting hello@chargemont.com or using the unsubscribe link in any marketing email.

5. How We Share Personal Data

We do not sell personal data. We may share data with thefollowing categories of recipients:

5.1 Service Providers and Sub-processors

We work with trusted third-party service providers who process data on our behalf, including:

•      Cloud hosting and infrastructure providers

•      Payment processors and billing platforms

•      CRM and customer support software

•      Analytics and monitoring tools

•      Email and communication platforms

All sub-processors are bound by written data processing agreements and required to maintain appropriate security and confidentiality standards.

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5.2 Chargeback Alert Networks

To provide our alert and prevention services, we sharerelevant transaction data with chargeback alert network providers (such as Ethoca, Verifi/CDRN, and RDR). This is done solely for the purpose of processing alerts on your behalf.

5.3 Legal Requirements

We may disclose personal data if required to do so by law, court order, or in response to a lawful request by a governmental or regulatoryauthority.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred to the acquiring entity. We will notify affected users in advance where required by law.

6. International Data Transfers

Chargemont UAB is established in the European Union (Lithuania) and primarily processes data within the EEA. Some of our third-party service providers may be located outside the EEA.

Where we transfer personal data outside the EEA, we ensurethat appropriate safeguards are in place, including:

•      Standard Contractual Clauses (SCCs) approved by theEuropean Commission

•      Transfers to countries with an EU adequacy decision

•      Other lawful transfer mechanisms as required by GDPR Chapter V

You may request a copy of the relevant safeguards by contacting hello@chargemont.com.

7. Data Retention

We retain personal data only for as long as necessary for thepurposes described in this policy, or as required by law.

•      Account data: retained for the duration of the contract and for 5 years after termination, unless a longer period is required by law

•      Transaction and chargeback data: retained for up to 7 years to meet financial record-keeping obligations

•      Website usage data: retained for up to 13 months

•      Marketing data: retained until you withdraw consent or opt out

When data is no longer required, it is securely deleted or anonymised.

8. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

•      Right of access: to obtain a copy of the personal data we hold about you

•      Right to rectification: to have inaccurate data corrected

•      Right to erasure: to request deletion of your personal data in certain circumstances

•      Right to restriction of processing: to limit how we useyour data in certain circumstances

•      Right to data portability: to receive your data in astructured, machine-readable format

•      Right to object: to object to processing based on legitimate interests or for direct marketing

•      Rights related to automated decision-making: not to besubject to solely automated decisions that significantly affect you

To exercise any of these rights, please contact us at hello@chargemont.com. We will respond within 30 days. There is no charge for submitting a request, unless requests are manifestly unfounded or excessive.

If you are not satisfied with our response, you have the right to lodge a complaint with the State Data Protection Inspectorate of Lithuania (www.ada.lt) or the supervisory authority in your country of residence.

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to improve your experience and analyse usage. Cookies are small text files stored on your device.

9.1 Types of Cookies We Use

•      Strictly necessary cookies: required for the website to function. These cannot be disabled.

•      Analytics cookies: help us understand how visitors useour site (e.g. Google Analytics). These are only placed with your consent.

•      Functional cookies: remember your preferences and settings.

•      Marketing cookies: used to show relevant content andtrack campaign performance. These are only placed with your consent.

9.2 Managing Cookies

You can manage your cookie preferences at any time by clicking"Cookie Settings" in the footer of our website, or by adjusting your browser settings. Please note that disabling certain cookies may affect the Data Securityfunctionality of our site.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or alteration. These measures include:

•      Encryption of data in transit (TLS) and at rest

•      Access controls and role-based permissions

•      Regular security reviews and vulnerability assessments

•      Employee training on data protection and security

•      Incident response procedures

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay, as required by GDPR.

11. Children's Data

Our Services are not directed at individuals under the age of18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately at hello@chargemont.com and we will take steps to delete it.

12. Third-Party Links

Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites and we are not responsible for their privacy practices. We encourage you to read the privacy policy of anywebsite you visit.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.When we make material changes, we will notify you by email or by posting aprominent notice on our website, and update the "Last updated" date at the top of this policy.

We encourage you to review this policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regardingthis Privacy Policy or our data practices, please contact us:

Chargemont UAB

Email: hello@chargemont.com

Website: www.chargemont.com

Registered address: V. Nagevičiaus g. 3, LT-08237 Vilnius, Lithuania

We aim to respond to all enquiries within 5 business days.

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