Privacy Policy

1. Introduction

Swipe Savvy, Inc. ("Swipe Savvy," "we," "us," or "our") operates the swipesavvy.com website, mobile applications, point-of-sale systems, rewards wallet, customer data platform, and related services (collectively, the "Services").

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Services. Please read this policy carefully. If you do not agree with the terms, please do not access the Services.

2. Information We Collect

2.1 Information You Provide

Category	Examples	Purpose
Account Information	Name, email, phone number, business name	Account creation and management
Payment Information	Credit card details, billing address	Processing transactions
Business Information	Tax ID, industry type, locations	Merchant onboarding
Transaction Data	Purchase history, rewards earned	Rewards program administration
Communications	Support tickets, feedback	Customer service

2.2 Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, features used, time spent, clickstream data
• Location Data: General location based on IP address (precise location only with consent)
• Log Data: Access times, error logs, referring URLs

2.3 Information from Third Parties

• Payment processors (transaction confirmations)
• Identity verification services
• Analytics providers
• Advertising partners (with your consent)

3. How We Use Your Information

We use the information we collect to:

• Provide Services: Process transactions, manage accounts, deliver rewards
• Improve Experience: Personalize content, develop new features, optimize performance
• Communications: Send service updates, marketing (with consent), support responses
• Security: Detect fraud, protect against unauthorized access, ensure compliance
• Analytics: Understand usage patterns, measure effectiveness, generate reports
• Legal Compliance: Meet regulatory requirements, respond to legal requests

4. Data Sharing & Disclosure

We may share your information with:

4.1 Service Providers

Third-party vendors who assist us in operating the Services, including:

• Cloud hosting providers (AWS)
• Payment processors
• Email service providers
• Analytics services
• Customer support platforms

4.2 Business Partners

For merchants and rewards partners, we may share:

• Transaction data necessary for reward fulfillment
• Aggregated, anonymized analytics
• Customer preferences (with consent)

4.3 Legal Requirements

We may disclose information when required by law, court order, or to protect our rights, property, or safety.

4.4 Business Transfers

In connection with a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

5. Data Retention

We retain your information for as long as necessary to provide the Services and fulfill the purposes described in this policy. Retention periods are determined based on:

• Active account status
• Legal and regulatory requirements
• Business necessity
• Dispute resolution needs

Upon account deletion, we will remove or anonymize your personal data within 90 days, except where retention is required by law.

6. Data Security

We implement industry-standard security measures to protect your information:

• Encryption: TLS 1.3 for data in transit, AES-256 for data at rest
• Access Controls: Role-based access, multi-factor authentication
• Compliance: PCI-DSS Level 1 for payment data
• Monitoring: 24/7 security monitoring and incident response
• Audits: Regular security assessments and penetration testing

While we strive to protect your information, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

7. Your Privacy Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of your personal data
• Correction: Update inaccurate information
• Deletion: Request deletion of your data
• Portability: Receive your data in a portable format
• Opt-Out: Unsubscribe from marketing communications
• Restriction: Limit how we use your data
• Objection: Object to certain processing activities

To exercise these rights, contact us at privacy@swipesavvy.com.

8. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: What personal information we collect and how it's used
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt out of the sale of personal information (we do not sell data)
• Right to Non-Discrimination: Equal service regardless of privacy choices

To submit a CCPA request, email privacy@swipesavvy.com with subject line "CCPA Request."

9. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

• All rights listed in Section 7 above
• Lawful Basis: We process data based on consent, contract performance, legitimate interests, or legal obligations
• Data Protection Officer: Contact our DPO at dpo@swipesavvy.com
• Supervisory Authority: You have the right to lodge a complaint with your local data protection authority

10. Cookies & Tracking Technologies

We use cookies and similar technologies to:

• Essential Cookies: Enable core functionality (authentication, security)
• Analytics Cookies: Understand how users interact with our Services
• Preference Cookies: Remember your settings and preferences
• Marketing Cookies: Deliver relevant advertisements (with consent)

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect functionality.

11. Children's Privacy

Our Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we learn we have collected such information, we will delete it promptly.

12. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (EU-approved)
• Data Processing Agreements with all vendors
• Compliance with applicable data transfer frameworks

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• Sending email notification for significant changes

We encourage you to review this policy periodically.

14. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

• Privacy Team: privacy@swipesavvy.com
• Data Protection Officer: dpo@swipesavvy.com
• General Support: support@swipesavvy.com
• Phone: 1-800-505-8769
• Mail: Swipe Savvy, Inc., Attn: Privacy Team, 123 Commerce Street, Suite 400, Wilmington, DE 19801