This policy applies to information we collect:

• On our websites and our services
• In email, text, and other electronic messages between you and us
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy

It does not apply to information collected by:

• Us offline, including our affiliates and subsidiaries; or
• Any third party, including our affiliates and subsidiaries, including through any application or content (including advertising) that may link to or be accessible from this Website

This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our websites and our services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our websites and services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to SureComply. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@surecomply.ai.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We may collect your personal information when you register for or use our services, such as when you create an account, make a payment, send a payout, or make a purchase on a merchant’s website. Here are the kinds of personal information that we may collect when you create an account or use our services:

1. Information that identifies you, for example:

• First and last name
• Address
• Mobile number
• Email
• IP Address
• Device Information
• Information collected from cookies or other tracking technologies

2. Records and financial information, for example:

• Social Security Number
• Employer Identification Number
• Government issued identification
• Bank account and routing numbers
• Credit card information
• Financial information

3. Personal characteristics, for example:

• Age or Date of Birth
• National origin
• Citizenship

4. Internet or network activity, for example:

• Interactions with our services or sites
• Shopping history

5. Geolocation data, for example:

• Global Positioning System (GPS) information when you give us permission through your device settings
• IP-based geolocation

6. Commercial information, for example:

• Online shopping cart information
• Purchase history

7. Audio, electronic, visual, biometric, or similar information, for example:

• Call recordings when you talk to customer service
• Voice identification, when you consent to this biometric method of authentication
• Photo IDs you voluntarily provide to authenticate your account, which we delete immediately upon authentication
• Profile pictures you provide

8. Professional or employment information, for example:

• Business information, contact emails and phone numbers
• Tax IDs

9. Information we infer based on your personal information, for example:

• Fraud and risk assessments
• Personalization preferences

We may collect personal information about you from various sources, for example from:

• Directly from you, when you use SureComply
• Merchants
• Our payment partners, such as card networks and payment processors
• Financial institutions, such as banks
• Service providers, such as companies that help us manage risk and fraud, deliver services to you, and market our services

If you have an account with SureComply, we will associate information from all these sources with your account to improve your experience and for compliance and analytics purposes.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of our websites, or transmitted to other users of our websites or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of our websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on our websites and services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information to:

• Run our sites and provide better services, for example to help you make purchases, show you your account information, verify access to your account, and keep your account and payment information up to date
• Manage and improve our business. For example, we do user research to improve our products’ performance and abilities. We also monitor and analyze our sites to help ensure they work as expected
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
• Comply with laws and enforce our agreements with you and other people who use our services
• To notify you about changes to our websites or any products or services we offer or provide through them
• To provide you with information, products, or services that you request from us
• To fulfill any other purpose for which you provide it
• In any other way we may describe when you provide the information
• For any other purpose with your consent

Disclosure of Your Information

We do not sell your personal information. However, we may disclose aggregated information about our users, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates
• To contractors, service providers, and other third parties we use to support our business
• To 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 SureComply’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SureComply about our users is among the assets transferred
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our websites, we will transmit the contents of that email and your email address to the recipients
• For any other purpose disclosed by us when you provide the information
• With your consent

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SureComply, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our websites may then be inaccessible or not function properly
• Promotional Offers from SureComply. If you do not wish to have your email address or contact information used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy@surecomply.ai. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to SureComply as a result of a product purchase, warranty registration, product service experience or other transactions
• We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to privacy@surecomply.ai. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Accessing and Correcting Your Information

You can review and change your personal information by sending us an email at privacy@surecomply.ai to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from our websites, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users of our websites.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites and services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@surecomply.ai.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our websites and services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our websites and services.

Changes to Our 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 information, we will notify you. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@surecomply.ai.

To register a complaint or concern, please email privacy@surecomply.ai.