legal

Privacy Policy.

INKPAY Privacy Policy. Effective September 24, 2026.

INKPAY App takes your privacy seriously and is committed to protecting the privacy and security of the personal information we collect. This Privacy Policy (“Privacy Policy”) describes how INKPAY, LLC. (“INKPAY App,” “INKPAY,” “we,” “our,” or “us”) collects, uses, discloses, and retains personal information in connection with (i) our websites, mobile applications, and other online services that link to or display this Privacy Policy (collectively, the “Platform”); (ii) our interactions with you through the Platform or related communications, such as customer support, service notifications, and optional marketing messages; and (iii) any other interactions you have with us in connection with the services we provide (collectively, the “Services”). This Policy does not cover job applicants, employees, or contractors.

Contents

Notice at Collection (What We Collect and Why)

We may collect the following categories of personal information listed in the table below.

Personal Identifiers

such as your name, address, telephone number, and email address

Purpose: To verify identity; assist with identifying users; determine eligibility for features; send important notices; personalize and improve services; support account setup and subscription management.
Disclosed to: Affiliates, Service providers (identity verification, hosting, support, comms, fraud), Analytics partners, Advertising partners, Research partners, Government authorities, Other parties at your direction/consent.
Sold or shared for targeted ads: Yes

Protected Classification characteristics under California or Federal Law

such as age, sex, race, ethnicity, physical, or mental handicap

Purpose: To verify age/eligibility where legally required; not used to determine access to features or for marketing.
Disclosed to: Service providers, Governmental and public authorities, Affiliates.
Sold or shared for targeted ads: No

Commercial Information

such as information about products or services purchased, obtained, or considered, or other purchasing or consuming (e.g., Subscription tier, purchases, payout history, referral/reward records)

Purpose: To process subscriptions, rewards, and payouts; to generate dashboards; to identify usage trends and improve features; to personalize the experience (where enabled).
Disclosed to: Affiliates, Service providers, Analytics partners, Advertising partners, Research partners, Business partners, Third parties involved in business transactions.
Sold or shared for targeted ads: Yes

Financial & Payment Info

such as Payment method token, last 4 digits, billing address (via processor); payout method details; Payout Card data (via issuer)

Purpose: To process subscription payments and facilitate payouts; to verify identity and meet banking/card network requirements; to send important billing notices; send payouts; operate Payout Card program.
Disclosed to: Service providers, Affiliates, Governmental and public authorities.
Sold or shared for targeted ads: No

Government Identifiers

such as government ID (e.g., driver’s license), sanctions screening results (where required)

Purpose: To verify identity, age, and residency; to conduct required KYC/AML and sanctions screening; fraud prevention, to determine eligibility for payouts/financial features.
Disclosed to: Service providers, Governmental and public authorities, Affiliates.
Sold or shared for targeted ads: No

Device, Internet and Network Activity Information and Online Identifiers

such as internet browsing history, search history, and information regarding interactions with the Platform and advertisements

Purpose: To operate, secure, and improve the platform; to power analytics and AI tools; to identify usage trends; to engage in interest-based advertising (where applicable and permitted); to personalize experience (where enabled); customer support.
Disclosed to: Service providers, Analytics partners, Advertising partners, Research partners, Affiliates.
Sold or shared for targeted ads: Yes

General Geolocation Information

such as location information from your device or based on your IP Address

Purpose: To provide relevant features and content (e.g., ZIP-code based rewards); to secure accounts; to comply with territory-based requirements; to improve platform experience.
Disclosed to: Service providers, Analytics partners, Advertising partners, Research partners, Affiliates, Governmental and public authorities.
Sold or shared for targeted ads: Yes

User Content & Social Signals

such as Profile data you submit, connected social handles (if you choose), comments/feedback

Purpose: To operate profile features; to provide analytics/attribution; to improve services; to communicate with you.
Disclosed to: Other users of the platform, Service providers, Affiliates, Advertising partners, Research partners, Other parties at your direction/consent.
Sold or shared for targeted ads: Yes

Inferences

such as inferences drawn from any of the information in the categories listed in this chart to identify consumer preferences, characteristics, behavior, attitudes, abilities, and aptitudes

Purpose: To provide dashboards/insights and non-determinative recommendations; to personalize experience (where enabled); to improve AI functionality over time.
Disclosed to: Analytics partners, Service providers, Affiliates, Research partners, Advertising partners.
Sold or shared for targeted ads: Yes

Audio/electronic/visual data

such as phone call recordings to customer service

Purpose: To provide and improve support; to monitor quality and training; to investigate and prevent fraud or abuse.
Disclosed to: Service providers, Affiliates, Governmental and public authorities.
Sold or shared for targeted ads: No

Sensitive personal data

such as Log-in information in combination with passwords and information concerning individuals’ health

Purpose: To authenticate access; to secure accounts; not used for marketing or to make recommendations; any health information only for support or compliance where applicable.
Disclosed to: Service providers, Affiliates, Governmental and public authorities.
Sold or shared for targeted ads: No

Communications

such as Support tickets, chat logs, email/SMS notices, opt-in marketing

Purpose: To send important notices and transactional messages; to respond to inquiries; to send marketing/promotional communications (where permitted); to measure engagement and respect opt-out.
Disclosed to: Service providers, Affiliates, Analytics partners, Governmental and public authorities, Other parties at your direction/consent.
Sold or shared for targeted ads: No

We may also create aggregated or deidentified data for analytics, benchmarking, and Service improvement. We do not reidentify deidentified data.

As further described in the “How We Use Personal Information” section below, we generally collect and use the above-listed categories of personal information to provide and manage the Platform and the Services, to process and fulfill your requests, and as otherwise necessary to support and market our business.

As noted in the table above, we “sell” or “share” (as these terms are defined in the CCPA) certain categories of personal information, and you may exercise your right to opt out of such disclosures by clicking “Do Not Sell or Share My Personal Information” in the footer of our website and following the instructions on the window that pops up. Alternatively, where available, you may choose to enable an online tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). When detected, we will process such a signal as a request to opt out.

We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in this Notice, including to satisfy legal or reporting requirements.

More information about our information handling and privacy practices and a description of your legal rights can be found in the “California Privacy Rights” section below.

How We Collect Personal Information

We collect personal information in several ways, including directly from you, automatically through your use of the Platform, and from third parties.

Information You Provide Directly to Us

Account, subscription, and platform information: personal information you choose to provide when you register for an account, subscribe to a Super Pass tier, participate in referral or reward programs, request payouts, or otherwise use features and tools available through the Platform.

Communications and participation information: information you provide when you sign up to receive communications from us, participate in promotions, sweepstakes, surveys, pilot programs, or other initiatives we may offer, or when you submit feedback or contact our support team.

Interactive and engagement information: personal information you provide when you interact with our AI-powered tools, analytics dashboards, assessments, or other interactive features, or when you engage with our social media pages, attend events, or participate in other in-person or virtual interactions hosted or sponsored by INKPAY.

Information Collected Automatically

Device, usage, and activity information: information automatically collected when you access or use the Platform, including details about your device, browser, operating system, IP address, general location derived from IP address, and how you navigate and interact with the Platform, such as pages viewed, features used, links clicked, and the time and duration of your visits.

Cookie and tracking technology information: information collected through cookies, SDKs, pixel tags, and similar technologies used by us and our service providers to operate and secure the Platform, understand usage patterns, improve performance, personalize certain features, measure the effectiveness of content and promotions, and support analytics and fraud prevention, which may include information collected across devices or over time.

Information From Third Parties

Partner and service provider information: personal information received from third-party sources such as business partners, analytics and advertising providers, payment processors, identity verification services, fraud prevention vendors, and social media or third-party platforms that you choose to connect to the Platform, subject to their privacy practices and your settings on those platforms.

Referral and supplemental information: information received from other individuals, such as when someone refers you to INKPAY or provides information about you in connection with a referral, promotion, or invitation, as well as information from data providers used to supplement or validate existing information, consistent with applicable law.

Combining Information

Combined and cross-source information: personal information combined from different sources and devices, including information you provide directly, information collected automatically, and information received from third parties, which is used to operate, improve, secure, and protect the Services and is treated as personal information in accordance with this Privacy Policy.

How We Use Personal Information

We use personal information to:

To provide and manage the platform and services: to create and administer user accounts, operate platform features and AI tools, manage subscriptions and access levels, provide customer support, enforce our Terms of Use, and operate our business.
To process subscriptions, rewards, and payouts: to process Super Pass subscriptions and recurring billing, calculate referral activity and reward amounts, administer upgrades or cancellations, facilitate payouts through approved partners, and maintain transaction, accounting, tax, and compliance records.
To power analytics, AI tools, and network insights: to generate dashboards, KPIs, referral analytics, and AI-driven guidance based on usage and engagement data, improve AI functionality over time, and provide informational insights without using sensitive personal data.
To identify usage trends and improve the platform: to understand how users interact with INKPAY, test and refine features, diagnose technical or performance issues, enhance system reliability, and improve overall user experience using aggregated or deidentified data where feasible.
To personalize the user experience (where enabled): to tailor dashboards, insights, recommendations, or notifications based on user activity and opt-in personalization settings, with the ability for users to disable personalized recommendations.
To communicate with you: to send transactional and service-related messages, respond to inquiries and support requests, provide updates about your account or subscriptions, notify you of policy or feature changes, and invite participation in surveys or permitted promotions.
To determine eligibility and verify identity: to verify age, identity, and residency; conduct required KYC, AML, and sanctions screening; confirm eligibility for subscriptions, payouts, or financial features; and meet legal, banking, and card-network requirements.
To send marketing and promotional communications: to inform users about new features, subscription tiers, or platform updates through permitted channels, measure engagement with those communications, honor opt-out preferences, and avoid using sensitive personal data for marketing or upselling.
To conduct research and analytics: to perform internal research, reporting, and analysis to measure engagement, assess feature effectiveness, and support product and business planning, generally using aggregated or deidentified data.
To engage in interest-based advertising (where applicable): to deliver relevant advertising on or off the platform using permitted tracking technologies and third-party partners, subject to user choices and controls described elsewhere in this Privacy Policy.
To maintain security and prevent fraud: to monitor and protect the platform and users, detect and prevent fraud or unauthorized activity, investigate policy violations, and safeguard systems, accounts, and transactions.
To satisfy legal and regulatory obligations: to comply with applicable laws and regulations, respond to lawful requests from courts or authorities, maintain required records, and support audits, reporting, and dispute resolution.
To carry out corporate or business transactions: to evaluate, negotiate, or complete mergers, acquisitions, financings, restructurings, or asset transfers, and to transfer personal information as permitted and protected by law in connection with such transactions.
As otherwise permitted, necessary, or with your consent: to use personal information as described at the time of collection, at your direction or with your consent, or as necessary to protect our rights, safety, property, operations, and those of our users and partners.

How We Disclose Personal Information

We may disclose personal information to:

Our affiliates: to companies that are part of the INKPAY corporate group for purposes consistent with this Privacy Policy, including business operations, platform support, compliance, analytics, and internal administration.
Other users of the platform: to other individuals who access or interact with the Platform when you choose to share information publicly or through platform features, such as information you post, submit, or make visible in connection with referrals, promotions, or other interactive features like your profile picture and INK ID.
Our service providers: to third-party vendors and service providers that perform services on our behalf, such as payment processors, identity verification providers, cloud hosting providers, analytics vendors, communications providers, customer support tools, and fraud prevention services, all of whom are contractually restricted from using personal information for purposes other than providing services to INKPAY.
Our business partners: to companies with whom we partner to offer or support products, services, promotions, or other related activities, such as co-sponsored features, events, or promotions, or where a partner’s offering may be integrated with or complementary to the Platform.
Our research partners: to third parties that assist us with research initiatives, surveys, usability testing, or studies conducted in partnership with or on behalf of INKPAY, subject to appropriate confidentiality and data-use restrictions.
Our analytics partners: to third-party providers that help us measure usage, engagement, and effectiveness of platform features, content, and marketing efforts, including analytics and measurement tools.
Our advertising partners: to third parties that assist with advertising, marketing, or promotional activities, including social media platforms and advertising networks, where permitted by law and subject to user choices and controls described in this Privacy Policy.
Third-party data providers: to data providers, such as data aggregators or enrichment providers, where permitted by law, to help validate, supplement, or better understand user information and platform engagement, consistent with applicable privacy requirements.
Third parties involved in business transactions: to relevant third parties and their advisors in connection with a merger, acquisition, financing, joint venture, restructuring, reorganization, bankruptcy, or sale of all or a portion of INKPAY’s business or assets, where personal information may be transferred as part of such a transaction and subject to appropriate safeguards.
Governmental and public authorities: to courts, law enforcement, regulators, or other governmental or public authorities where required or permitted by law, including in response to subpoenas, court orders, regulatory requests, or other legal processes.
Other parties at your direction or as permitted by law: to third parties when you direct us to do so, provide consent, or participate in sweepstakes or contests that require disclosure (such as winner lists), or where we believe disclosure is necessary or appropriate to comply with law, protect our operations or affiliates, prevent fraud, protect rights, safety, or property, or pursue or limit legal claims.
Other disclosed purposes: for additional purposes that are described to you at the time of collection or prior to disclosure, consistent with applicable law.
Aggregated or deidentified information: to third parties using information that has been aggregated or deidentified so it can no longer reasonably be used to identify you, for purposes consistent with those described in this Privacy Policy.
Mobile Information Sharing & Consent: We value your privacy. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Use of Artificial Intelligence

INKPAY uses AI and analytics to run and improve features such as network insights, dashboards, recommendations, and guidance. We primarily rely on aggregated and behavior-based data and do not use sensitive personal data (e.g., precise financial status, protected characteristics) to drive recommendations. Our AI supports both chat and voice interactions and is designed to assist with product and service information, as well as to make personalized suggestions. In the future, the AI may also be able to answer cardholder-related questions in accordance with applicable policies and procedures.

If your inquiry requires additional attention, such as with disputes, payouts, or escalations, the AI will facilitate a transfer to human support for further assistance. All AI outputs are informational only and do not guarantee earnings or outcomes. The AI does not make binding or solely automated decisions regarding user entitlements, payouts, or dispute outcomes. You may opt out of personalized recommendations in settings where available. We do not use solely automated decision-making that produces legal or similarly significant effects.

Cookies, Ads, Measurement & Global Privacy Control (GPC)

We automatically collect certain usage and device information when you visit or interact with the Platform, open or interact with emails sent by us or on our behalf, or otherwise engage with our content (including advertisements, where applicable).

We and our service providers use cookies (small text files stored on your device), pixel tags (web beacons), SDKs, and similar tracking technologies to collect this information. These technologies may collect information such as your IP address, browser type, device type, operating system, unique device identifiers, general location derived from IP address, date and time of access, referring and exit pages, and information about how you interact with the Platform and our content (for example, pages viewed, features used, frequency of access, and interactions with emails or links).

We use this information to operate, secure, and maintain the Platform; remember user preferences and login status; understand and analyze usage patterns; improve performance and functionality; support analytics and fraud prevention; and enhance the overall user experience. Where personalization is offered, it is subject to user controls and applicable law.

Your browser or device settings may allow you to control or reject cookies or similar technologies. Because these controls are browser and device-specific, you must manage your preferences separately for each browser and device you use. Additional information about cookies and how to manage them is available at www.allaboutcookies.org.

Global Privacy Control (GPC) and Browser Signals. Where required by applicable law, INKPAY recognizes and honors browser-based opt-out preference signals, such as the Global Privacy Control (GPC), as a valid request to opt out of the sale or sharing of personal information or the use of personal information for targeted advertising. When we receive a valid GPC signal, we apply it in accordance with applicable legal requirements.

Do Not Track (DNT). Some browsers transmit “Do Not Track” signals. At this time, the Platform does not respond to DNT signals. Users should instead use the cookie controls, advertising opt-out tools, and rights request mechanisms described in this Privacy Policy to manage their preferences.

Interest-Based Advertising

Where permitted by law, INKPAY may engage in limited interest-based advertising to provide relevant information about our Platform and services. We may also allow certain third-party advertising or social media partners to collect information about your interactions with the Platform over time using cookies or similar technologies so that advertisements may be displayed to you on third-party services or across devices.

The information used for interest-based advertising is typically collected through cookies or similar technologies and may include device identifiers or online activity information. In some cases, we may share limited identifiers (such as a hashed email address or user ID) with advertising partners to support ad delivery, reporting, attribution, or analytics. We do not use sensitive personal information for interest-based advertising.

You can control interest-based advertising through the following options:

Web browser opt-out:
- Network Advertising Initiative (NAI): www.networkadvertising.org/choices
- Digital Advertising Alliance (DAA): https://optout.aboutads.info
Mobile device controls:
- Your mobile operating system may allow you to limit or opt out of interest-based advertising through device settings.
- The DAA’s AppChoices tool is available at www.aboutads.info/appchoices

Opt-out choices apply only to the specific browser or device used. If you clear cookies, reset identifiers, change browsers, or use a new device, you may need to reapply your preferences. Even if you opt out, you may still see advertisements, but they may be less relevant.

Depending on your U.S. state of residence, the use or disclosure of information for interest-based advertising may constitute “targeted advertising,” “sharing,” or a “sale” of personal information under applicable law. Information about how to exercise your rights is provided in the “Your Privacy Rights” section below.

Google Analytics and Advertising

INKPAY uses Google Analytics to understand how users interact with the Platform and to improve functionality and performance. Google Analytics uses cookies and similar technologies to collect information about use of the Platform and reports that information to us in aggregated form.

For information about how Google handles data collected through Google Analytics, please visit: www.google.com/policies/privacy/partners/. You may opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-On available at https://tools.google.com/dlpage/gaoptout/.

We may also use certain Google Analytics advertising features, such as remarketing or demographic and interest reporting, which rely on a combination of first-party and third-party cookies to help measure advertising effectiveness and improve relevance. You can manage or opt out of certain Google advertising features through the Google Ads Preferences Manager at https://ads.google.com?subid=xs-ip-gemini-adlc or through the opt-out tools described above.

Children’s Privacy

Our content and services are intended for individuals who are eighteen (18) years of age or older. We do not knowingly collect, use, or disclose personal information from individuals under the age of 18 without prior verified parental or legal guardian consent. If an underage individual seeks to participate in limited platform activities, such participation and data collection must occur exclusively through a verified parent or legal guardian in accordance with our Terms of Use. If we learn we have collected personal information from a user under 18 without guardian consent, we will delete that information.

International Data Transfers

The Platform is directed only to U.S. consumers. The Platform is not directed to consumers outside of the U.S. We will transfer and/or store personal information under our control in the United States and/or other countries where we have facilities or in which we engage service providers. As a result, your personal information may be transferred to other countries or regions.

If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. When we transfer your personal information outside of your country of residence, we do so in accordance with applicable law and take appropriate steps to ensure your information is protected. However, please note that while outside of the jurisdiction in which you reside, your personal information will be subject to applicable local laws (including those of the United States), which may not provide the same level of protections for personal information as those in your own country.

Security

We value the security of our users' Personal Information and incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, we cannot guarantee that any data transmission over the Internet, wireless transmission, or electronic storage of information is 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.

Retention

We will retain your personal information as long as necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required or allowed under law.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of the personal information; the purposes for which we use the personal information; whether we can achieve the purposes through other means; and the applicable legal requirements.

If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.

Links to Third-Party Services

The Platform may contain links to third-party sites, plug-ins, applications, or other online services. If you click on a link to a third-party service, you will be taken to a service we do not control and that is not governed by this Privacy Policy. We are not responsible for third parties’ privacy practices. We suggest that you read the privacy notices of every service with which you interact carefully.

Your Privacy Choices

You have certain rights with respect to Personal Information under certain U.S. state privacy laws. Under the California Consumer Privacy Act (CCPA), these rights have been extended to Personal Information collected, used, and shared between businesses (B2B), however, these rights have not been extended in any other state. As a result, these rights are limited to consumers and not applicable to individuals in their capacity as employees of businesses that are exchanging Personal Information between one another. For purposes of this subsection, the terms “consumer”, “Personal Information”, “business purpose”, “third party”, “sell”, and “share” have the meanings ascribed to them respectively in the applicable state law.

California (CCPA/CPRA)

Notice of collection: See Sections 2-3 for categories, purposes, and sources.

Rights: Access, correction, deletion, portability, opt-out of sale/sharing, limit use of sensitive personal information (we only use SPI for limited, allowable purposes such as KYC/AML, fraud prevention, and compliance). No discrimination for exercising rights.

How to exercise/opt-out: See How to Submit a Request below and our “Do Not Sell or Share” link.

GPC: We process browser-based opt-out signals where required.

No Financial Incentives. We do not offer any programs that would be considered a “financial incentive” under U.S. state privacy laws.

California Shine the Light. If you are a California resident, you have the right to ask us one time each year if we have shared Personal Information with third parties for their direct marketing purposes. To make a request, please send us an e-mail, or write to us at the address listed in the Contact Us section with “Shine the Light” in the subject line of your communication.

California Sensitive Personal Information Disclosure. We collect certain categories of sensitive Personal Information as defined by California law, including government-issued identifiers, account and financial credentials, health-related information, and precise geolocation. This information is used only for permitted purposes such as providing services, processing transactions, complying with legal obligations, and operating our business, and in accordance with Section 1798.121 of the California Privacy Rights Act. We do not sell or share sensitive Personal Information for cross-context behavioral advertising, though we may disclose it to third parties at your direction, subject to their privacy practices.

Other U.S. State Privacy Rights

To the extent provided for under the applicable laws, you may have the right to:

Access and Disclosure. You can request, up to two times every 12 months, that we disclose to you the categories of Personal Information we collected about you, the categories of sources from which we collected the Personal Information, the categories of Personal Information we sold or disclosed, the business or commercial purposes for collecting, selling, or sharing your Personal Information, the categories of third parties with whom we shared the Personal Information, and the specific pieces of Personal Information we collected about you. You also have the right to request a portable copy of your Personal Information.

List of Third-Party Recipients. If you live in Oregon or Minnesota, you have the right to request a list of specific third parties to which we disclosed Personal Information. If you live in Delaware or Maryland, you have the right to request a list of the categories of third parties to which we disclosed Personal Information. You can find the categories of third parties in the Notice at Collection table above in Section 1.

Correction and Deletion. You can request that INKPAY correct or delete Personal Information that we have about you, subject to certain exceptions allowed under applicable law.

Do Not Sell or Share My Personal Information (Opt-out of Targeted Advertising). Under certain U.S. State Privacy Laws, you may be able to request that we not sell, or share for targeted behavioral advertising, your Personal Information. We may sell, share, and use for targeted advertising the following categories of Personal Information to companies that provide marketing and advertising services to us, as well as advertisers that place advertisements on the Site: Demographic Information, Device, Internet, and Network Activity Information and Online Identifiers, General Location Information, and Inferences. You can request that we not sell or share your Personal Information by sending an email to support@inkpayapp.com with your request following the instructions in the “Contact Us” section. Please note that any opt-outs through these tools are specific to the device and browser you are using, so you should opt-out for each web browser and on each device you use. Your opt-out preferences will be deleted any time you clear your web browser’s cookie cache. We recognize Global Privacy Control (GPC) signals broadcast from web browsers as a valid opt-out request where required by applicable law. Please note that the GPC will apply only to the browser you are currently using. We do not respond to “Do Not Track” signals. If your GPC signal conflicts with an advertising preference you have selected directly on our website, your explicit selection will take precedence. We do not recognize the “Do Not Track Signal.”

Opt-out Preference Signals/Global Privacy Control. You have the right to submit a request to opt-out of the selling and sharing of Personal Information through an opt-out preference signal. If you use an opt-out preference signal we will apply the opt-out to the device or browser which sends the opt-out preference signal and to any consumer profile associated with that browser or device, including pseudonymous profiles. You can use an opt-out preference signal by downloading a supported browser or extension. If known, we will also treat the opt-out preference signal as a valid request to opt-out of sale/sharing for the user. Some browsers allow you to send a Do Not Track signal, an older request to block tracking of users by third parties. We may not honor these older signals.

Right to Opt-out of Profiling. Under certain U.S. State Privacy Laws, you have the right to opt out of Profiling, as applicable, in furtherance of decisions that produce legal or similarly significant effects. We do not Profile in a manner that would result in legal or similarly significant effects and as such do not offer this right.

How to Submit a Request

You may exercise these rights by emailing us at support@inkpayapp.com or following the instructions in the “Contact Us” section. Please note that we may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

How We Verify Your Identity

Whether you submit a request directly on your own behalf, or through an authorized agent, we will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the Personal Information.

In response to verified requests to access, disclose, correct, and delete, we will confirm receipt of this request within 10 business days of receipt of the request where required by law.

In response to verified requests for access and disclosure or a portable copy of your Personal Information, we will disclose and deliver the required information to you free of charge within 45 days after receiving the verifiable consumer request. We may extend this time period to deliver information once by an additional 45 days when reasonably necessary. We will provide notice of the extension within the first 45-day period.

Following verification of your request to delete, we may require you to separately confirm that you want your Personal Information to be deleted. We will delete the information within 45 days of receiving a verifiable consumer request (subject to certain exceptions). We may extend this time period once by an additional 45 days when reasonably necessary. We will provide notice of the extension within the first 45-day period.

Following verification of your request to correct, we may require you to provide documentation, if necessary, to rebut our own documentation that the Personal Information is accurate. If we determine, based on the totality of the circumstances, that the information is not accurate, we will respond to the request by correcting the information, deleting the information (if deletion of the information does not negatively impact you), or providing you with the name of the source from which we have received the alleged inaccurate information (if we are not the source). We will correct the information within 45 days of receiving a verifiable consumer request. We may extend this time period once by an additional 45 days when reasonably necessary. We will provide notice of the extension within the first 45-day period.

Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, for requests to know, delete, and correct we will require written proof of the agent’s permission to do so and we will need to verify your identity directly. If you would like to designate an authorized agent to submit a request to know, delete, or correct Personal Information on your behalf, please email us at support@inkpayapp.com to verify your identity and provide written proof of permission. Once verified, your authorized agent may act on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/themselves as an authorized agent.

Appeals

You may have a right to appeal decisions concerning your ability to exercise your consumer rights. Please contact us at support@inkpayapp.com to request an appeal concerning decisions on your consumer request.

Users Under 18

Note that INKPAY is not intended for independent use by users under the age of 18. We do not knowingly sell Personal Information from anyone under the age of 18. Please see our section on Children's Privacy above for more information.

No Discrimination

INKPAY will not discriminate against you because you made any of these requests. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

Financial Partners & Payout Cards

If you opt into a Payout Card (defined in our Terms of Use), the issuing bank and program partners will receive and process certain data (identifiers, KYC/AML results, card profile, transaction metadata) solely to verify identity, issue and service the card, process transactions, manage risk, comply with law, and provide support. Card use is governed by the Cardholder Agreement presented at enrollment. See our Terms of Use for more details.

Marketing Communications & Texts

You can opt out of receiving marketing and promotional communications from us at any time. Note that even if you opt out of receiving marketing and promotional communications from us, you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries. To opt out of receiving our marketing and promotional communications, you can:

Send us an email at support@inkpayapp.com
Write to us at: INKPAY Legal, 30767 Gateway Pl. Suite 160, Rancho Mission Viejo, CA 92694
Follow the instructions included in any promotional emails or text messages that you receive from us

Changes to this Policy

This Privacy Policy reflects our current practices and is subject to change and update from time to time. When we post changes to this Privacy Policy, we will modify the “Effective Date” at the top of this Privacy Policy to indicate when such changes have come into effect.

Contact Us

If you have any questions about this Privacy Policy, the practices of our website, or your dealings with our website, you can contact us using the information below:

Email: support@inkpayapp.com

Your Consent to This Policy