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Privacy Policy

Updated October 20, 2020

XUP, Inc. (“Company“, “we“, “us“, “our“) is committed to respecting your privacy rights and protecting your personal information.

This privacy policy explains what information we collect, how we use it, how it may be shared, how we keep it safe, what rights you have in relation to it, and how you can contact us about our privacy practices. This policy applies to our main website https://xuppay.com (the “Website”, “Sites”), and more generally, with the use of any of our services (the “Services”).

This privacy policy applies to all information collected through our Services as well as, any related services, sales, marketing, or events.

This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third parties carefully.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE USE YOUR INFORMATION?
  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  6. HOW LONG DO WE KEEP YOUR INFORMATION?
  7. HOW DO WE KEEP YOUR INFORMATION SAFE?
  8. DO WE COLLECT INFORMATION FROM MINORS?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. CONTROLS FOR DO-NOT-TRACK FEATURES
  11. DO WE MAKE UPDATES TO THIS POLICY?
  12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short:  We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you use our Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on our Sites or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and our Sites, the choices you make, and the services, products, and features you use. The personal information we collect may include the following:

Information Provided by You 

To provide our Services, we may collect the following information:

About the Business:

  • Legal Business Name
  • DBA Name
  • Tax ID Number (TIN)/ Employer ID Number (EIN)
  • Merchant ID
  • Industry Type
  • Business phone number
  • Business address
  • Business email address
  • Business type
  • Business website
  • Incorporation date
  • Annual revenue
  • Annual card volume

About the Individual:

  • First and Last Name
  • Title
  • Personal Address
  • Personal phone number
  • Personal email address
  • Date of Birth
  • Social Security Number
  • Percentage ownership
  • Bank account information
  • Any additional information you decide to share with us

Information automatically collected

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Sites or use our Services.

We automatically collect certain information when you visit or use our Services or navigate our Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and Services and other technical information. This information is primarily needed to maintain the security and operation of our Sites and Services, and for our internal analytics and reporting purposes.

Like many businesses, we also may collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice.

The information we may collect includes:

  • Log and Usage Data. Log and usage data are service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Sites or Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Sites (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Sites. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Sites. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.


Information collected from other sources

In Short:  We may collect data from third party providers, financial service providers, public databases, marketing partners, social media platforms, and other outside sources.

In order to provide our services as well as enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as third party data providers, financial service providers, public databases, joint marketing partners, affiliate programs, social media platforms, as well as from other third parties. This information may include mailing addresses, business information, risk scores, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles. If you interact with us on a social media platform using your social media account, we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

2. HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services and Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We may use the information we collect or receive:

  • For identity verification. We may use your information to verify your identity and validate the business information.
  • To protect our Services and prevent fraud, illegal or prohibited activities. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
  • To request feedback. We may use your information to request feedback and to contact you about your use of our Services.
  • To manage your accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contracts.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • To investigate fraud, security issues and suspicious activities. We may use your information in the process of investigating fraud, security issues, and other suspicious activities.
  • To deliver and facilitate delivery of services. We may use your information to provide you with the requested service.
  • To improve and maintain our services. We may use your information to improve and maintain our Services.
  • To respond to support inquiries. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
  • To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information see our Cookie Notice.
  • To post testimonials. We may post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your explicit consent to use your name and the content of the testimonial.
  • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, Sites, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information with trusted entities:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
  • Service Providers. We may share your information with our trusted service providers that provide services on our behalf such as identity verification, data analytics, information technology, email delivery, and other related services.

We do not sell your personal information.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short:  We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Website.

The Website may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Website. You should review the policies of such third parties and contact them directly to respond to your questions.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect your personal information through a system of physical, administrative, and technical safeguards.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. No security measures are perfect, and we cannot promise that all information collected from you or about you will remain secure in all circumstances.   If you have any further questions about privacy or security, or have reason to believe your data security has been compromised, please contact us immediately by sending an email to: privacy@xuppay.com.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. Our services are not intended for children under the age of 18.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  If you do not want to receive information about our products or services, please update your preferences (where available) and/or utilize the “unsubscribe” or “opt-out” mechanism within the communications that you receive from us.  

If you have questions or comments about your privacy rights, you may email us at privacy@xuppay.com.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising visit http://www.aboutads.info/choices/. For further information, please see our Cookie Notice.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of our services, to respond to service requests, or for other non-marketing purposes.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy. 

11. DO WE MAKE UPDATES TO THIS POLICY?     

In Short:  Yes, we will update this policy periodically to reflect changes and as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we use and protect your information.

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?     

If you have questions or comments about this policy, you may email us at privacy@xuppay.com or contact us by mail:

XUP, Inc.

1422 S Tryon Street

Charlotte, NC 28203

United States

———–SECTION BELOW IS RESERVED FOR FUTURE USE AND NOT REQURIED AT THIS TIME—————-

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information under the California Consumer Privacy Act (CCPA).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We may collect the following categories of personal information:

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name YES
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history and financial information YES
C. Protected classification characteristics under California or federal law Gender and date of birth YES
D. Commercial information Transaction information, purchase history, financial details and payment information YES
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements YES
G. Geolocation data Device location YES
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities NO
I. Professional or employment-related information Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us YES
J. Education Information Student records and directory information NO
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics NO

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy policy and our Cookie Notice.

You may contact us by email at privacy@xuppay.com.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

XUP, Inc. has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. XUP, Inc. will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data – Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed – Request to know

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell your personal information to third parties;
  • the categories of personal information that we sold or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

  • you may object to the processing of your personal data
  • you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
  • you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

If you are a California resident wishing to exercise these rights, you may contact us by email at privacy@xuppay.com.You will receive a response within 45 days of your request.

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