Privacy Notice

Last Modified: May 11, 2026

Introduction

Aylo Billing US Corp and Aylo Billing Limited (hereinafter "we", "us", or "our") operates the website www.probiller.com (hereinafter "Probiller" or the "Website") and is the controller of the information collected or provided via this Website.

Please read this Privacy Notice carefully, as your access to and use of our Website signifies that you have read and understand all terms within this Privacy Notice. We respect your privacy and are committed to protecting your personal data.

If you have any questions about our privacy practices, please see the section "Contact Information" below for information on how to contact us.

Scope

For the purposes of this Privacy Notice, "process", "processed" or "processing" means any operation or set of operations performed on personal data or on sets of personal data (excluding disclosure thereof), whether by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure, or destruction. Information on disclosure of personal data or of sets of personal data may be found in the "Disclosure of Your Personal Information" section below.

This Privacy Notice applies to information we process:

• on this Website,
• on your communications with Probiller via email, online support chats, virtual assistant, phoneline support or otherwise,
• when you interact with a website that uses Probiller for billing or checkout purposes.

Our Policy Towards Minors

Our Website prohibits minors from accessing or using its platform in any way. Our Website is forbidden to persons under the age of eighteen (18) or the applicable age of majority in the jurisdiction from which this Website is accessed. We do not knowingly collect Personal Information from minors. If you become aware that a minor has provided us with Personal Information in any way, inadvertently, fraudulently or erroneously attempted to provide us such information with the intent to access our Website, please contact us at support@probiller.com, so that we may remove such information immediately.

The Data We Collect About You

"Personal Data", or "Personal Information", means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include data that has been anonymized or aggregated.

We may process different kinds of Personal Data about you, which we have grouped together as follows:

• Identity Data. We process your first and last name.
• Contact Data. We process your billing address (country, city, state/province, zip/postal code), and your email address.
• Financial Data. We process your bank account and payment card details. Specifically, we process your card's number, your bank account, your card's expiration month, year and cvv2 (Card Verification Value 2), and tokenized card hash.
• Transaction Data. We process your payment details. Specifically, we process the rebill amount, the frequency and start delay in days. Moreover, we process the transaction amount, id and type, the processor transaction id and the membership/subscription id.
• Technical Data. We process your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
• Usage Data. We process information about how you use our Website, products and services.
• Online Forms and Communication Data. We process Contact Data and/or Transaction Data and other information that you submit through online forms provided on Probiller or information sent to us via email, online support chats or such as information provided in the context of support requests or any other inquiries, the content reporting and moderation of content, and our internal complaint handling system.

We may process aggregated information that does not directly or indirectly identify you and is not associated with you.

The Sources from Which We Process Personal Information

We collect your Personal Data through:

• Direct interactions. Information that you provide when reporting a problem with our Website, or during your communication with us.
• Third parties. We may receive Personal Data about you from various third parties, for example, other websites controlled by us or members of our corporate group, our business partners or other third parties that utilize our platform.
• Support Chatbot. We may collect Personal Data during your interactions with the chatbot, which is intended to assist you and provide you with support services.

Purposes for Which We Use Your Personal Information

In general, we use your Personal Information for the following purposes:

• Provision of services. To present our Website and its contents to provide you with information, products or services that you request from us.
• Customer management. To manage end users' transactional information, to provide customer support and notices to such user, including expiration and renewal notices, and notices about changes to our Website or any products or services we may offer or provide through it from time to time.
• Analytics. To determine whether users of this Website are unique, or whether the same user is using this Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns.
• Functionality and security. To diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
• Compliance. To enforce our Terms and Conditions and to comply with our legal obligations.
• Communication and handling of requests. We process Online Forms and Communications Data and other information necessary to respond to and resolve any of your requests.
• Other purposes. We will process Contact Data and end users' submitted Personal Information in any other way we may describe when you provide the information; or for any other purpose with your consent provided separately from this Privacy Notice.

Our Legal Bases under Canadian and European Union (EU) Privacy Law

To the extent required by applicable laws, we process your Personal Data only when:

• You provide your consent for a specific purpose: for example, when you allow us to process your Personal Data to provide you assistance and support services or to send you e-mail marketing. You may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.
• It is necessary to perform our contractual obligations as per our Terms and Conditions, for example, to provide you with our services;
• It satisfies a legitimate interest which is not overridden by your data protection interests, for example, to keep our Website safe and secure from fraud and illegal activities;
• It is necessary to comply with legal obligations, for example, we may be required to collect, use, or disclose your information in connection with civil, criminal, corporate, taxation, regulatory matters, or litigation.

Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (EEA), Switzerland or the United Kingdom ("UK"), the legal bases on which we rely may differ from those listed above.

Disclosure of Your Personal Information

We disclose your Personal Information when necessary to perform the services or for other purposes set out in this Privacy Notice. When we disclose your Personal Information, we usually rely on the performance of our contract with you, our legal obligation to do so, our legitimate interest (e.g., operating our Website), so long as it doesn't outweigh your interests, except when expressly stated otherwise below in the paragraph "To comply with the law or protect our rights or the rights of third parties". Disclosure of your Personal Information may also involve transfers of your Personal Information outside the EEA. To the extent that we need to transfer Personal Information outside the EEA, we will do so according to the section "Transfers of Your Personal Information to Other Countries" or when necessary for the performance of the contract between us. The parties to whom we may disclose your personal information include:

• Within our Corporate group. We may disclose any of the categories of Personal Information that we collect to members of our corporate group to the extent this is necessary for the purposes described in this Privacy Notice, and generally to operate our business, which includes: transaction monitoring, payment processing and customer support. You acknowledge that in some cases, members of our corporate group might be established or run their services outside the EEA.
• Our contractors and/or employees. To provide our services to you, our employees and/or contractors may receive access to your personal data only on a need-to-know basis. Such employees and contractors abide by confidentiality obligation.
• Service providers. We disclose the categories of Personal Information we process to our authorized service providers that perform certain services on our behalf. These services may include payment processing and fulfilling orders, identity and document authenticity verification including risk and fraud detection and mitigation, customer service, marketing, analytics, security, or hosting our Website or supporting our Website's functionality. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. Where required under applicable laws, we entered into data processing agreements with such service providers to ensure that Personal Information is only processed securely within our instructions.
• Legal successors. We may disclose all of the categories of Personal Information we process to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding. Such transactions may be in our legitimate interest, particularly our interest in making decisions that enable our business to develop.
• To comply with the law or protect our rights or the rights of third parties. We access, preserve and share your Personal Information with regulators, law enforcement, out-of-court dispute settlement bodies or others where we reasonably believe such disclosure is needed to:
  1. satisfy any applicable law, regulation, legal process, or governmental request;
  2. enforce applicable Terms and Conditions, including investigation of potential violations thereof;
  3. detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues;
  4. protect against harm to the rights, property or safety of our company, our users, our employees, or others; or
  5. maintain and protect the security and integrity of our Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose your information to third parties for the above purposes where necessary to comply with our legal obligations, to perform a task in the public interest (where the public interest is laid down by applicable law), or under our legitimate interests and the interests of the public, including as part of investigations or regulatory enquiries to detect, investigate and prosecute illegal activity.

Cookies and Automatic Data Collection Technologies

As you navigate through and interact with our Website, we use automatic data collection technologies to collect website activity data. The technologies we use for automatically collect data may include the use of cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.

We currently use essential cookies, which are set by our Website. These are cookies necessary for the functioning of our Website and cannot be switched off in our systems as they enable core Website functionality. These include, for example, cookies that enable a user to log in to our Website and to check if a user is allowed access to a particular service or content.

Financial Information

Financial information (including Personal Information) that you have provided to us will only be shared with our third-party service providers, who act as our processors, in order to initiate and complete any orders placed on your account. All credit card transactions are processed with industry standard encryption by our third-party service providers who will use your financial information only for that purpose. All the financial data and the related Personal Information will be shared with our third-party service providers only upon your authorization or when necessary to carry out any transaction requested by you. Such transactions are subject to the rules, terms, conditions, and policies established by the respective third-party service providers.

Transfers of Your Personal Information to Other Countries

We may share the information we collect globally, across our corporate group and with our service providers and other third parties. Transfers are necessary for a variety of reasons, including our operation and provision of the services stated in our Terms and Conditions and this Privacy Notice to fix, analyze, and improve our products and services. Whenever we transfer Personal Information to countries outside the EEA and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Notice, as permitted by the applicable laws and based on appropriate mechanisms.

Where applicable, we rely on decisions of the European Commission, known as "adequacy decisions," recognizing that certain countries offer a level of protection of Personal Data that is essentially equivalent to the EEA.

In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

Retention of Personal Information

We will only retain your Personal Data for as long as necessary to fulfill the purposes we process it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider several factors, including what Personal Data we are processing, the risk of harm from any unauthorized disclosure, why we are processing your Personal Data and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Notice, we will delete your Personal Information from our systems.

For more information on data retention periods, please see the section "Contact Information" below on how to contact us.

Where permissible, we will also delete your Personal Information upon your request as explained in the section "Your Rights Related to Your Personal Information".

Your Rights Related to Your Personal Information

Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your Personal Data:

• Right of access. You have the right to receive information on the Personal Data we hold about you and how such Personal Data is used, as well as a copy of your Personal Data;
• Right to rectification. You have the right to rectify inaccurate Personal Data concerning you;
• Right to be forgotten. You have the right to delete/erase your Personal Data;
• Right to data portability. You have the right to receive the Personal Data provided by you in a structured, commonly used and machine-readable format and to transmit this Personal Data to another data controller;
• Right to object. You have the right to object to the use of your Personal Data where such use is based on our legitimate interests or on public interests;
• Right to restriction of processing. You have the right in some cases, to restrict our use of your Personal Data; and
• Right to file a complaint. If you are in the EEA or the UK, you also have a right to file a complaint with your local data protection authority.

If we ask for your consent to process your Personal Data, you have the right to withdraw your consent at any time with effect for the future. However, please note that, in such cases, you may no longer be able to use or access one or several functionalities on our Website.

You may exercise your above-mentioned rights by sending us an e-mail at support@probiller.com. Please note that we have one (1) month to respond to your initial request.

Prior to processing a request for access or deletion of your data, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it or delete it in an unauthorized way.

Please note that if we do not have sufficient information to identify you, we will not be able to respond to your request. To adequately verify your identity or your authorization to make the request, we may require you to provide additional information.

California Rights and Choices

The California Consumer Privacy Act of 2018 ("CCPA") provides California residents ("Consumer(s)") certain rights with respect to their Personal Information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, such Consumers have the right to:

• Opt-out of the sale of their Personal Information, should we sell their Personal Information;
• Be informed of certain information concerning our collection and use of their Personal Information;
• Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
• Not be subject to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.

You can exercise your rights, by sending us an email us at support@probiller.com with the subject line "CCPA Request." If you need assistance regarding the exercise of your rights, you can also send an e-mail at support@probiller.com to help you with the process.

Resident's Rights -- Jurisdictions in the United States, Where Applicable

We do not sell, trade, or exchange your Personal Information with anyone for money.

Changes to Our Privacy Policy

We keep our Privacy Notice under regular review. The purpose is to address any new legal requirements, technical developments or to add more clarifications, as needed.

Although we may attempt to notify you when major changes are made to this Privacy Notice, you are expected to periodically review the most up-to-date version found at this location, so you are aware of any changes, as they are binding on you. If we change anything in our Privacy Notice, the date of change will be reflected in the "Last Modified" date mentioned in the header of this Privacy Notice.

Notice to Law Enforcement

The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:

• The document(s) is/are uploaded, and all required fields have been filed out adequately on our platform for Legal Service Process located at: https://legalservice.aylo.com/legal/datarequest;
• The document(s) you are serving is correctly issued by a valid court of law or equivalent legal or administrative authority to us (See Websites' footer to find our operating entity);
• The document(s) is/are also sent by mail at the following address: 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540.

We reserve the right to refuse online service through our Website, namely in cases where the above requirements are not met and require formal legal service at the above address. In such an event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.

Contact Information

If you have any questions about this Privacy Notice or our information-handling practices, please contact us at privacy@probiller.com.

You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.

Our Data Protection Officer can be contacted at the following email address: dpo@probiller.com.

Manage Your Private Data

Request a Copy of my Data

Request Deletion of my Data

AYLO BILLING US CORP, 610 BRAZOS STREET - SUITE 500, AUSTIN, TEXAS 78701, USA
AYLO BILLING LIMITED, 195-197 OLD NICOSIA-LIMASSOL ROAD, DALI INDUSTRIAL ZONE 2540, BLOCK 1, CYPRUS