Privacy Policy

Our Commitment to User Privacy:

This Policy describes how Lithic, Inc., doing business as Privacy.com, protects and manages your personal data, including:

• What data we collect when you sign-up for, use, or engage with any of our applications, products, services or websites (collectively "Services");
• How we manage data from the beginning of your engagement forward;
• The choices you have regarding how data is managed.

This Policy applies to information we collect in connection with your access and use of our Services. Please read this Policy carefully. By continuing to use or access our Services, you are consenting to the practices described in this Policy.

We Limit Use of Your Personal Data:

• Providing, maintaining and improving our Services;
• Verifying your identity;
• Communicating with you about new and existing Services;
• Protect the legal rights, property and safety of our Services and users.

Sharing Personal Data with Merchants:

We may be required to share your data with a merchant if you open a Payment Dispute for a transaction with said merchant.

We Collect and Use Data:

Data We Collect:

Your name, email address, phone number, birth date, government-issued identification number, payment card and bank information as well as other information you may be asked to provide when signing-up for an account, providing identity verification or engaging in a transaction.

Other Data:

• Transaction Data: when, where and how a transaction takes place including, but not limited to, the devices and payment methods used;
• Device Data: hardware model, operating system, unique device identifiers, mobile network data as well as other data generated by a device's interaction with our Services;
• Location Data: to prevent fraudulent use of our Services;
• User Data: browser data, Internet Protocol ("IP") addresses and other data describing user engagement;
• Cookies: small data files we may store on your computer or mobile device memory to help us manage your engagement with our Services, including gathering aggregated data about engagement (discussed below);
• Beacons: small electronic images we may use in our Services and emails to deliver cookies and measure user engagement;
• Information to enhance your experience: you have the option (but are not required) to upload a photograph as a profile picture.

Sources of information:

• We also check that you are using our Services legally and are eligible for the Services you want to use.  We protect the Services from fraudsters who may put you and your money at risk. To do this, we may collect data about you from companies that help us verify your identity, prevent fraud or assess risk.
• We collect (and/or have collected during at least the 12-month period preceding the effective date of this Policy) information about you from the following categories of sources:
• You directly, when you submit information to us or allow us to access information
• Your devices and how you interact with our Services
• Other sources, including:

• Identity Verification. Information from third-party identity verification services and publicly available sources, including your government-issued identification number.
• Eligibility, Compliance, and Fraud. Information about you from third parties for any investigation, eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or transaction-related information with any consumer reporting agency.

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We Share Personal Data Under Controlled Circumstances:

• With third parties who may access data about you to provide you with the Services;
• With third parties who may access data about you to perform functions on our behalf;
• With financial institutions, processors, payment card associations and other entities that are involved in the payment process;
• With government and law enforcement where reasonably necessary to protect user or public safety or comply with applicable law, regulation, legal process, governmental request ;
• With others where reasonably necessary to protect the security or integrity of our Services or user safety;
• In Connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business;
• With your consent.

We may share aggregated and anonymized information that does not specifically identify you or any individual user of our Services.

Security:

We take reasonable measures, including administrative, technical and physical safeguards to help protect your personal data from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction.

We maintain strict security standards and procedures with a view to preventing unauthorized access to your data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your data. Our staff and third parties whenever we hire them to provide support services, are required to observe our privacy standards.

Choices:

• Personal Data: You can change or correct data about yourself through your Privacy.com account at any time or by emailing us at support@privacy.com. You can also email us if you wish to deactivate your account. We may retain data about you for a period of time consistent with applicable law.
• Location Data: Our mobile applications require location data. If you do not grant us access to this data then you cannot use our Services. If you grant access to location data but later revoke this access your mobile device will no longer be able to use our Services. You may also uninstall our Services to stop collection of location data.
• Cookies: You can set your browser to block cookies but our Services may not function properly in this setting (discussed below).
• Marketing: You can opt-out of email or text messages by following instructions in these messages. If you opt-out we may still send you messages regarding transactions and services related to our ongoing business relationship.
• Notifications: Our Services may ask you for permission to send notifications to your device. Our services will still work if you do not grant us permission to send you notifications.
• Website Tracking: Privacy does not track users for advertising purposes. Certain websites you visit may provide options regarding advertisements you receive. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info. Additionally, you can opt out of interest-based advertisements from businesses that are part of the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA); visiting the NAI website and DAA website to learn more. 
• Do Not Track: Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Services do not currently change the way they operate based upon detection of a Do Not Track or similar signal.

Cookies:

We and our partners use cookies or similar technologies to offer an enhanced experience and Services to users who wish to allow them. These technologies help us analyze trends, administer the website, track traffic, and gather information about users. For information on how to block cookies, see below.

We use cookies to track preferences and settings (e.g., so we can remember your preferences, like whether you’ve selected a “do not display install banners” option), for sign in and authentication (e.g., so you don’t have to sign in each time you return to the site, or sign in again whenever you move to a new webpage), and for analytics purposes (e.g., to count page visitors or obtain statistics about our Services’ operations that help us improve our website and Services). We may use cookies from third-party providers.

How to Control Cookies
Some users wish to block cookies. Certain features of Privacy’s Services depend on cookies, so your experience with Privacy’s Services may be negatively affected. Additionally, if you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.

However, we completely understand if you want to block cookies. At a high-level, here’s how you can:

• You can block cookies in your web browser. Your browser can also be set to alert you when cookies are placed on your device. Typically, browser cookie settings can be found in a browser’s settings. To find out how to specifically disable cookies in your browser, search for instructions in your browser’s help documentation.
• If you use Privacy’s Services on a mobile device, you can manage your device’s settings to limit the use of information shared for the purposes of advertising. Look in your device’s settings for “Limit Ad Tracking” (for iOS), “Opt out of Interest-Based Ads” (for Androids), or similar controls.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Third-Party Data:

The Services contain hyperlinks to other websites or locations that we do not control and are operated and controlled by third parties (“Third-Party Websites”). Our Privacy Policy does not apply to these Third-Party Websites and we make no representations regarding the policies or business practices of any such Third-Party Websites.

Changes to this Policy:

We can change this Policy. When the changes impact how we use your data in important ways, we’ll tell you first by email (if you’ve given us your email address).

We may amend this Policy from time to time by posting a revised version and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed. We will provide you with reasonable prior notice of material changes in how we use your information, including by email, if you have provided one. If you disagree with these changes, you may cancel your account at any time. If you keep using our Services, you consent to any amendment of this Policy.

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Last updated: January 30, 2023