ShredPay Privacy Policy
1. Information Collection
We collect data about visitors to our websites and any affiliated blogs, mobile sites, or applications; about Users that access, directly or indirectly, our Services or Apps, or any other Users or Customers that attend events organized or hosted by us; and about our clients, including Platforms, (where these are natural persons) or their employees, agents and representatives (and these individuals about whom we collect data are incorporated into any reference to "you" or “your” in this Privacy Policy). Please refer to the below for further information about the personal information we may collect and how it may be used:
Information You May Provide To Us
Category
Description
Basic Customer Information
Name; Address; Date of birth; Nationality; Country of residence; Phone number; Email Address; Website
Supplemental Identification Information
Government-issued identity document (e.g., passport, driver’s license, or state identification card); Social security number; Employment information (e.g., company name, industry, etc.); Proof of residency; or similar.
Electronic Identification Information (EII)
Biometric information generated based on photos, videos, or similar electronically identifiable biometric data you provide in order for us to verify your identity or location
Financial Information
Bank account number; Payment card numbers; Trading and investment experience; Tax identification number; Income types; net assets/wealth verification; Source of funds; Account balances; or similar.
Crypto or Wallet Information
Wallet addresses; digital transaction information; public and private chain information; and information related to cryptographic integrations
Preferences
User settings and preferences selected on our Website, Apps, or otherwise when using our Services
Transaction Information
Information about the transactions made on our Services, such as: Name of the sender; Name of the recipient; Amount; Currency (fiat and/or digital); Payment method; Date; and/or Timestamp
Additional Information You Submit to Us
Communications such as survey responses or Customer service information (e.g., emails or call recordings provided by you to our customer service teams); any other information you choose to provide
Institutional Information (only for Institutional Customers)
Employer Identification number (or comparable number issued by a government); Legal name; Jurisdiction of formation; Entity type; and Personal identification information for all beneficial owners of your business
Information Which May Be Collected Automatically
Category
Description
Usage Data
IP addresses or other location metadata; device details; operating system and browser you’re using information; other device characteristics or identifiers (e.g., network connection characteristics); data regarding your interaction with our Services.
Product Usage Information
Your viewing history and logs from visiting the websites or using our Apps or Services, including diagnostic information about the performance of websites, Apps, or Services
Information from Cookies and similar technologies
Please see our Cookies Policy for additional information
Information we Obtain from Affiliates or Third Parties
Category
Description
ShredPay Group (“Affiliates”)
We may obtain any and all information about you that is collected by any other ShredPay Group affiliate as part of normal business practices or to adhere to applicable legal and regulatory requirements.
Platform Account Information
We may obtain any and all information about you from the Platform you used to sign up for and access the ShredPay Services.
Public Database Information
We obtain information about you from any and all public databases.
Blockchain Data
We may analyze public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, and wallet addresses.
Information from our Service Provider Partners
We may receive information about you from our service provider partners as part of normal business practices or to adhere to applicable legal and regulatory requirements.
Information from our Marketing and Advertising Partners
We may receive information about you from our marketing partners, potentially including in what content you viewed or the actions you take on our Website or Apps
Retail Merchant Information
If you use your ShredPay account to conduct a transaction with a third party merchant, the merchant may provide us with information about you, including information about your transaction with that merchant.
Research and Survey Information
We may use third party service providers to conduct surveys to better understand our Customers’ or Users’ experience and improve our Services.
2. Use of Information
We may use your personal information for any lawful purpose, including the following: to deliver, personalize, operate, improve, create, and develop our Services, to provide you with a secure, smooth, efficient and safe experience, and to comply with legal and regulatory compliance, theft and loss prevention, and anti-fraud purposes. Below is additional information about how we use your personal information and our legal basis for doing so:
Establish and Administer Your Account and Service Relationship
We will use your information to perform our duties under an applicable ShredPay Group company user agreement (e.g., ShredPay Terms of Service) or similar customer or end-user agreement or other relevant contract with you as set forth below. We may need to suspend or terminate our Services or otherwise close your user account if we cannot process your personal information or similar data for these purposes.
Data used to comply with our legal obligations
Certain uses of our Services may be subject to laws and regulations that require us to collect, use, and store your personal information in certain ways and for specified periods. If you do not provide and continue to provide access to the personal information as required by law, we may have to suspend or close your account.
Platform legal and regulatory obligations
To comply with other Platform legal and regulatory obligations. We may access, read, preserve, and disclose information to the Platform(s) through which you signed up for or access the ShredPay Services when we believe it is reasonably necessary to comply with applicable law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities.
HOW AND WHY WE SHARE YOUR INFORMATION
How We Share Your Information
Personal Information
Category of Personal Information
Information Collected and Disclosed
Categories of Recipients
Personal Identifiers
Basic User Information; Supplemental Identification Information; Institutional Information (as applicable); Financial Information
Platforms; Third party identity verification services; Financial institutions; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Protected personal data classifications under California and federal law, (e.g., gender, age, and citizenship)
Supplemental Identification Information; EII Information
Platforms; Third party identity verification services; Service Providers; ShredPay Group; Law enforcement/Regulators
Commercial information such as records of services purchased, obtained, or considered
Transaction Information
Platforms; Third party identity verification services; Financial institutions; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Internet or other electronic network activity information
Product Usage Information; App, browser, and device information; Information from cookies and similar technologies
Platforms; Third party identity verification services; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Geolocation data
App, browser, and device information
Platforms; Third party identity verification services; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Audio, electronic, visual, or similar information
Additional information You Provide to Us; Information from our Marketing Partners; Information from Analytics and Providers; Research and Survey Information
Platforms; Third party identity verification services; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Professional or employment related information
Basic User Information; Supplemental Identification Information; Institutional Information (as applicable); Financial Information
Platforms; Third party identity verification services; Financial institutions; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Inferences about preferences, characteristics, predispositions, etc.
Preferences; Additional information You Provide to Us; Information from our Marketing Partners; Information from Analytics and Providers; Research and Survey Information
Platforms; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Sensitive Personal Information
Collection and Disclosure of Sensitive Personal Information. We collect and disclose the following categories of sensitive personal information, with the following categories of third parties:
Category of Personal Information
Information Collected and Disclosed
Categories of Recipients
Government identifiers
Supplemental Identification Information; EII Information
Platforms; Third party identity verification services; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Account credentials and financial account details combined with access codes
Basic User Information; Supplemental Identification Information; EII Information
Platforms; Third party identity verification services; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulator
The contents of a consumer’s mail, email, and text messages
Additional information You Provide to Us; Information from our Marketing Partners; Information from Analytics and Providers; Research and Survey Information
Platforms; Third party identity verification services; Service providers; Professional advisors; ShredPay Group; Law enforcement/Regulators
Biometric information (via our service providers)
EII Information
Platforms; Third party identity verification services; ShredPay Group; Law enforcement/Regulators
Why We Share Your Information
We work with third-party service providers who process information on our behalf (such as payment processors, data hosting services, and email service providers, or with our legal or business advisors), third-party partners and other third parties to help us provide our Services, and as a result we need to share certain information with these third parties. We also share identifiers with third party analytics providers or advertising partners, for analytics and advertising purposes.
Affiliates
Personal information that we process and collect may be transferred between ShredPay Group companies, Services, and personnel affiliated with us as a normal part of conducting business and offering our Services to you and to comply with our legal or regulatory obligations. See Section III. for a list of ShredPay Group affiliated companies.
Platform Third Party
Personal information that we process and collect may be transferred between ShredPay and the Platform which you use to sign up for and/or access the ShredPay Services as a normal part of conducting business and offering our Services to you and to comply with our respective legal or regulatory obligations. Please note that when you use the Platform’s other services and products, which are not governed by this Privacy Policy, the Platform's own terms and privacy policies will govern your use of those services and products.
Linked Third Party Websites or Applications
When you utilize certain Services that use third-party services or websites (e.g., AML/KYC services, pay with crypto, withdrawal services, etc.) that are linked through to our Services, the third-party service providers of those services or products may receive information about you that ShredPay, you, or others share with them. Please note that when you use third-party services or websites, which are not governed by this Privacy Policy, their own terms and privacy policies will govern your use of those services and products.
We may also use integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on our Services, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public.
Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.
Professional advisors, industry partners, authorities and regulators
We may share your information described in Section I. with our professional advisors, regulators, tax authorities, law enforcement, government agencies, Platforms, and industry partners to:
respond pursuant to applicable law or regulations, court orders, legal process or government requests;
comply with our reporting and information sharing obligations with industry partners (e.g., Virtual Asset Service Providers (“VASPs”) and regulatory authorities)
detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues; and
protect the rights, property, and safety of our Users, Customers, the ShredPay Group, or others, including to prevent death, imminent bodily harm, or exploitation.
Asset Transfer or Company Acquisition
We may choose to buy or sell assets, and may share and/or transfer information about our Users or Customers in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, merged, reorganized, or if we go out of business, enter bankruptcy, or go through some other change of control or similar event, your personal information could be one of the assets transferred to the acquiring party.
Third-Party Service Providers
We work with third-party service providers to help us provide our Services. When we share information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms and only process as necessary and proper for the limited purpose of the contract. We work with different types of third-party service providers, including:
Why & How We Use Your Information
Information Categories Used
We use Third-Party Electronic ID Verification Service Vendors, including those that process biometric information. For example, we use vendors to complete customer onboarding, transactions, and compliance. The information shared by those vendors will be collected and used as indicated in the privacy policies of those vendors which can be found here: https://astra.com/privacy-policy/ https://plaid.com/legal/#consumers https://www.bridge.xyz/legal/us-privacy-policy/bridge-building-inc https://www.privy.io/privacy-policy https://www.trmlabs.com/policies/privacy-policy?_gl=1j7ohi4_upMQ.._gs*MQ..&gclid=Cj0KCQiAxJXJBhD_ARIsAH_JGji1Wc2QBmckhKdWBUJhqFH32ecaB4gx88Ecd0lm9CEe0yatmsXWFjkaAncqEALw_wcB&gbraid=0AAAAAoLreL5LiDfQxtb2EdscbpUYmeONP https://www.unit21.ai/privacy-policy https://aws.amazon.com/privacy/ https://mailtrap.io/privacy/, https://policies.google.com/privacy
- Basic Customer Information; - Supplemental Identification Information; - EII Information; - Additional information You Provide to Us; Institutional Information (as applicable); - App, browser, and device information and location data; - ShredPay Group Information; - Platform Account Information; - Public Database Information
Vendors for tax reporting Retail merchants (to provide rewards/incentives) Telecommunications technology providers (to send you messages, including SMS messages) AML service providers (for the purposes of transaction monitoring) Data hosting service providers and payment vendors (for off-site data hosting) Security service providers (for investigating fraud and security incidents) Analytics providers (to understand how you use our Services) Payment processing companies (to process transactions on our behalf) Document repository services providers Customer support vendors
- Basic Customer Information; - Supplemental Identification Information; - Financial Information; - Crypto Information; - Transaction Information; - Additional information You Provide to Us; - Institutional Information (as applicable); - App, browser, and device information and location data; - ShredPay Group Information; - Platform Account Information; - Public Database Information; - Blockchain Data
We may share information that has been de-identified or aggregated without limitation.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We retain your information as needed to provide our Services, comply with legal or regulatory obligations, or protect our, your, or others’ vital or necessary interests. We maintain internal retention policies on the basis of how information needs to be used and decide how long we need information on a case-by-case basis.
This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, whether we need it is necessary to protect a vital interest, or if it meets other information preservation requirements. We also keep certain information where necessary to protect the safety, security and integrity of our Services, Platforms, Customers, and Users. Our third-party electronic identity verification providers collect and retain information, which may include biometric information, for the period required for financial regulatory compliance or otherwise as required by applicable law. They retain this information as described in their respective policies.
In line with these considerations, we delete information that is no longer required or needed for the above purposes when you close your account, and delete any other information when permitted pursuant to the above considerations.
CHILDREN'S PERSONAL INFORMATION
The Services are not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. We do not have actual knowledge that we sell or share the personal information of individuals under 18 years of age.
If you are under the age of 18, please do not provide any personal information to any ShredPay Group company. If a User or Customer submitting personal information is suspected of being under 18 years of age, we will require the relevant Customer or User to close the account, and will take all reasonable steps to delete or purge the individual’s information as soon as possible.
HOW TO CONTACT US WITH QUESTIONS
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please reach out to us at [email protected], or by writing to us at the address of your ShredPay service provider, provided in Section XI.
CHANGES TO THIS PRIVACY POLICY
We may change this Privacy Policy from time to time. We post any changes we make to this Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page.
OUR RELATIONSHIP WITH YOU
ShredPay acts as controller with respect to your personal information and has primary responsibility thereto, including with respect to providing you with information and responding to any requests you may make under applicable law.
III. SHREDPAY GROUP AFFILIATED COMPANIES
ShredPay Inc. - 201 California St, Suite 350 San Francisco, CA 94111
ShredPay Markets LLC - 201 California St, Suite 350 San Francisco, CA 94111
ShredPay Liquid LLC - 201 California St, Suite 350 San Francisco, CA 94111
ShredPay Technology LLC - 201 California St, Suite 350 San Francisco, CA 94111
ShredPay Ratings LLC - 201 California St, Suite 350 San Francisco, CA 94111
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