Privacy Policy

1. Introduction

Circopay LLC ("Circopay," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (circopay.com) or use our payment processing services.

Please read this Privacy Policy carefully. By accessing or using our website or services, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our website or services.

2. Information We Collect

We collect several types of information from and about users of our website and services, including:

2.1 Personal Information

Personal information is data that can be used to identify you individually. We may collect the following personal information:

• Contact information (name, email address, phone number, business address)
• Business information (business name, business type, tax identification number)
• Financial information (bank account details, processing volume)
• Identity verification information (date of birth, government identification)
• Account credentials (username, password)

2.2 Non-Personal Information

Non-personal information is data that does not identify you individually. We may collect the following non-personal information:

• Usage data (pages visited, time spent on the website, actions taken)
• Device information (IP address, browser type, operating system)
• Location data (general geographic location based on IP address)
• Cookies and similar technologies

3. How We Collect Information

We collect information from you in the following ways:

• Direct collection: Information you provide when you create an account, apply for our services, contact us, or use our website
• Automated collection: Information collected automatically through cookies, web beacons, and other tracking technologies when you use our website
• Third-party sources: Information we receive from business partners, service providers, and other third parties

4. How We Use Your Information

We may use the information we collect for various purposes, including:

• Providing and improving our services
• Processing merchant applications and onboarding
• Facilitating payment transactions
• Fraud detection and prevention
• Risk assessment and management
• Compliance with legal and regulatory requirements
• Communicating with you about your account and our services
• Marketing and promotional purposes (with your consent)
• Analyzing usage patterns and improving our website
• Protecting our rights, property, and safety

5. Disclosure of Your Information

We may disclose your information to the following categories of recipients:

• Service providers and business partners that perform services on our behalf
• Financial institutions and payment processors necessary to process transactions
• Law enforcement, government agencies, and other third parties to comply with legal obligations
• Professional advisors, such as lawyers, auditors, and insurers
• Potential or actual purchasers in connection with a business transaction

We do not sell your personal information to third parties for their marketing purposes.

6. Data Security

We implement appropriate technical and organizational measures to protect your information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption of sensitive data
• Secure network architecture
• Access controls and authentication mechanisms
• Regular security assessments and audits
• Employee training on data security

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

7. Data Retention

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you
• Legal obligations to which we are subject
• Whether retention is advisable in light of our legal position

8. Cookies and Similar Technologies

We use cookies and similar technologies to enhance your experience on our website. Cookies are small text files that are stored on your device when you visit our website. They help us recognize your device and remember certain information about your visit.

We use the following types of cookies:

• Essential cookies: Necessary for the website to function properly
• Analytical/performance cookies: Help us understand how visitors interact with our website
• Functionality cookies: Remember your preferences and settings
• Targeting cookies: Track your browsing habits to deliver tailored advertising

You can control and manage cookies in various ways. Most web browsers allow you to delete cookies, block certain types of cookies, or receive a warning before a cookie is placed on your device. Please note that if you disable cookies, some features of our website may not function properly.

9. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. These rights may include:

• Access: Request access to your personal information
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information
• Restriction: Request restriction of processing of your personal information
• Data portability: Request transfer of your personal information to another service provider
• Objection: Object to processing of your personal information
• Withdrawal of consent: Withdraw your consent at any time

To exercise these rights, please contact us using the information provided in the "Contact Us" section below. Please note that some of these rights may be subject to limitations or exceptions under applicable law.

10. Children's Privacy

Our website and services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately, and we will take steps to delete such information from our systems.

11. International Data Transfers

We are based in the United States and may process, store, and transfer your information in the United States and other countries which may have different data protection laws than those in your country of residence. By providing your information to us, you consent to the transfer of your information to the United States and other countries.

When we transfer your information to other countries, we will take appropriate measures to protect your information in accordance with this Privacy Policy and applicable law.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated Privacy Policy on our website or through other communications. The date the Privacy Policy was last revised is indicated at the top of the page.

We encourage you to review the Privacy Policy whenever you access our website or services to stay informed about our information practices and your choices.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at: