SpotPay (“SpotPay,” “we,” “our,” or “us”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the SpotPay mobile application, website, card services, and related products (collectively, the “Services”).

1. Scope of This Policy

This Privacy Policy applies to information we collect when you:

• Create or use a SpotPay account
• Verify your identity (KYC)
• Add, send, receive, or withdraw funds
• Use your SpotPay card for purchases or ATM withdrawals
• Contact customer support
• Visit our website or interact with us online

2. Information We Collect

Personal Information

• Name
• Date of birth
• Email address
• Phone number
• Residential address

Identity Verification Information

• Government-issued ID
• Selfies or biometric verification
• Taxpayer identification (where required)

Financial Information

• Bank account details
• Debit card details
• Funding sources
• Transaction history

Technical Information

• Device identifiers
• IP address
• Browser type
• Operating system
• App usage data

3. How We Use Your Information

• Provide and maintain our Services
• Process transactions
• Verify your identity
• Prevent fraud and abuse
• Comply with AML, KYC, sanctions, and legal obligations
• Communicate with you
• Improve and personalize the product
• Send updates and promotions

4. How We Share Information

We may share information with:

• Banking and card issuing partners
• Identity verification providers
• Fraud prevention and compliance vendors
• Payment processors and blockchain infrastructure partners
• Government or law enforcement where required

5. Data Retention

We retain your information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements. Financial and compliance records may be retained for longer periods as required by law.

6. Security

We implement technical, administrative, and physical safeguards designed to protect your information. However, no system is completely secure, and we cannot guarantee absolute security.

7. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access your personal data
• Correct inaccurate information
• Delete certain information
• Restrict or object to processing
• Request data portability

8. California Privacy Rights

California residents may have additional rights under applicable law, including the right to know what data we collect, request deletion, and opt out of certain data sharing practices.

9. International Transfers

Your information may be transferred to and processed in countries outside your home jurisdiction. By using the Services, you consent to such transfers.

10. Children’s Privacy

SpotPay is not intended for individuals under 18. We do not knowingly collect information from children.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted here with a revised “Last Updated” date.

12. Contact Us

If you have questions about this Privacy Policy, contact us at support@spotpay.ai