Information that RiftPay Collects

Types of Information Collected

Personal Data

“Personal Data” is information by which you may be personally identified. RiftPay may collect the following Personal Data from you:

• Name;
• Username;
• Email;
• Mailing Address;
• Birthdate;
• Profile Photo;
• Phone Number; and
• Payment Information (collected and processed by third party vendor).

Non-Personal Data

Non-personal data includes any data that cannot be used on its own to identify, trace, or identify a person. We may collect your IP Address, device information, or location information.

When non-Personal Data you give to us is combined with Personal Data we collect about you, it will be treated as Personal Data and we will only use it in accordance with this Privacy Policy.

Howwe collect information.

We collect information about you in two ways:

(1) when you provide it do us directly through an interaction with us; for example, when you register for the service, when you contact us for service request, surveys, or during live chats;

(2) through automated collection methods like cookies or log files; and

(3) when we obtain the information through a third party, including third party data verification and marketing services.

Why we collect and how we use your information.  (Legal Basis)

We collect and use your Personal Data when we have a legitimate purpose to do so, including the following reasons:

• when it is necessary for the general functioning of the Services, including to facilitate payments or to contact you;
• when it is necessary in connection with any contract you have entered into with us (including our terms of service) or to take steps prior to entering into a contract with us;
• when we have obtained your prior consent to the use, including to send information to you about our service offerings or features;
• when we have a legitimate interest in processing your information for the purpose of providing or improving our Services;
• when have a legitimate interest in using the information for the purpose of contacting you, subject to compliance with applicable law; or
• when we have a legitimate interest in using the information for the purpose of detecting, and protecting against, breaches of our policies and applicable laws.

We may use aggregated (anonymized) information about our Users, and information that does not identify any individual, without restriction.

Information Collected from Third Parties

Information from our service providers: We may receive information about you from third-party service providers that we engage for marketing our products and services.

Accessing and Controlling Your Information

If you would like to prevent us from collecting your information completely, you should cease use of our Services. You can also control certain data via these other methods:

Opt-out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe' function included in all such messages. However, you will continue to receive notices and essential transactional emails.

Optional information: You can always choose not to fill in non-mandatory fields when you submit any form linked to our services.

If you are a California resident, you also have the rights disclosed below.

Data Rights for California Users

If you are a California resident, you have the following rights with respect to information that we hold about you. We attempt to provide you the same rights no matter where you choose to live.

Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared.

Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.

Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.

Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.

Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.

Exercise Your Data Rights for California Users

We acknowledge your right to request access, amendment, or deletion of your data. We also recognize that you have the right to prohibit sale of your data, but we do not sell data.

You can exercise the rights described above, by sending an email or mail to the addresses listed in the Contact section below. Only you, or an agent authorized to make a request on your behalf, may make a request related to your personal information.

We cannot respond to your request if, (i) we cannot verify your identity; or (ii) your request lacks sufficient details to help us handle the request. Any information we provide will only cover the 12-month period preceding the request's receipt.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We are not obligated to provide responses to your data requests more than twice in a 12-month period.

How Long do we Store Personal Data?

We will only retain your Personal Data for as long as is necessary to fulfil the purposes for which it is collected. This length of time may vary according to the nature of your relationship with us.  ^[a]

Automated Data Collection Methods

Cookies

A cookie is a small file placed on the hard drive of your computer. Cookies are used to help us manage and report on your interaction with the Services. Through cookies, we are able to collect information that we use to improve the Services, keep count of return visits to our website, session times, click stream data, manage multiple instances of the Site in a single browser, and keep track of usernames and passwords. If you turn off cookies, your experience on the Services may be impaired.

Log Files

We use means through the Services to collect IP addresses, browser types, access times, physical location, operating system, and device information. Occasionally, we use the information to improve our Services.

Users under the age of 16

Our Services are not intended for anyone under 16 and we do not knowingly collect Personal Data from children under 16. If you are under 16, do not use or register on the Services, make any purchases, use any of the interactive or public comment features, or provide any information about yourself to us. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address listed below.

Do Not Track Settings

We do not track our Users over time and across third party websites to provide targeted advertising and do not specifically respond to Do Not Track (“DNT”) signals.

Who We Share Data With

We may use aggregated (anonymized) information about our Users, and information that does not identify any individual, without restriction.

We do not sell or otherwise disclose Personal Data specific personal or transactional information to anyone except as described below.

Other Users

We may share your public profile information so that other users may find you to send or request funds from you, invite you to a Circle, or for an instant-share transaction. You may manage the people your profile is shared with within the Services.

Affiliates and Subsidiaries

We may, for our legitimate interests, share your information with entities under common ownership or control with us who will process your information in a manner consistent with this Privacy Policy and subject to appropriate safeguards. Such parent companies, affiliates, or subsidiaries may be located in the United States.

Successors in Interest.

We may, for our legitimate interests, share your information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Data about our Users is among the assets transferred. You will be notified of any such change by a prominent notice displayed on our Services or by email. Any successor in interest to this Privacy Policy will be bound to the Privacy Policy at the time of transfer.

Law enforcement and other governmental agencies.

We may share your information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

Service Providers.

We may, for our legitimate interests, share certain information with contractors, service providers, third party authenticators, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.Some of the functions that our service providers provide are as follows:

• Host server infrastructure and storage;
• Business analytics services;
• Payment processing;
• Marketing, sales, and service management; and
• Email management services.

Some of our current service providers include Amazon Web Services, Dwolla, Google Analytics, Hotjar, Marqueta, and Trulioo.

Third-Party Services and Websites

RiftPay is not responsible for the privacy policies or other practices employed by websites linked to, or from, our Services nor the information or content contained therein, and we encourage you to read the privacy statements of any linked third party.

Data Storage and How RiftPay Protects Your Information

RiftPay stores User data on our servers including name and email address. Payment information is processed and stored by our partners or service providers. Personal Data about Users is stored within the United States. Our Services are not intended for use outside of the United States and are unavailable outside the United States. By providing your Personal Data, you consent to any transfer and processing in accordance with this Privacy Policy.

RiftPay employs physical, electronic, and managerial control procedures to safeguard and help prevent unauthorized access to your information.  We use data encryption and we choose safeguards based on the sensitivity of the information that we collect, process and store and the current state of technology. Our outsourced service providers who support our operations are also vetted to ensure that they too have the appropriate organizational and technical measures in place to protect your information^[b]

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your information transmitted to the Services. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. In the event that there is breach in the information that we hold; we shall notify of such breach via email or via notice on the Services.

Changes to the Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our Users’ Personal Data, we will notify you by email to the primary email address specified in your account or through a prominent notice on our Site. Such changes will be effective when posted. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of our Services following the posting of any modification to this Privacy Policy shall constitute your acceptance of the amendments to this Privacy Policy. You can choose to discontinue use of the Service if you do not accept any modified version of this Privacy Policy.

Questions and Comments

If you have any questions or comments about this Privacy Policy, or if you would like to file a request about the data we hold or file a deletion request, please contact us at Support@RiftPay.io.

California Consumer Privacy Act (CCPA) Summary of Information Collected

This chart is a summary of data collected and data disclosed in accordance with our privacy policy above.

Categories of Personal Information

Collection

Disclosure

Sale

Do we collect?

Collected in past 12 months

For a business purpose

For a business purpose in past 12 months

Do we sell?

Sold in past 12 months

Identifiers:

IP addresses; cookies, beacons, pixel tags, mobile ad identifiers, customer numbers, unique pseudonyms, user aliases, and telephone numbers.

YES

YES

YES

YES

NO

NO

Categories of PI described in Section 1798.80(e) of the CCPA (including name, email, and screen name).

YES

YES

YES

YES

NO

NO

Commercial information

NO

NO

NO

NO

NO

NO

Geolocation data

YES

YES

YES

YES

NO

NO

Internet or other electronic network activity information

NO

NO

NO

NO

NO

NO

Inferences drawn from other personal information to create a profile about a consumer.

NO

NO

NO

NO

NO

NO

Characteristics of protected classNameifications under California or federal law

NO

NO

NO

NO

NO

NO

Biometric information

NO

NO

NO

NO

NO

NO

Audio, visual or similar information

YES

YES

YES

YES

NO

NO

Professional or employment related information

YES

YES

YES

YES

NO

NO

Non-public education information (per the Family Educational Rights and Privacy Act)

NO

NO

NO

NO

NO

NO