This Privacy Policy describes your privacy rights regarding Purpl (“we”, “us” or “our”) collection, use, storage, sharing and protection of your personal information. It applies to our Site and all related sites, App, Services and tools regardless of how you access or use them. This Privacy Policy will help you understand how we use your information and what we do with it. This Privacy Policy applies to all information we collect through our Services, even if you have not signed up for a Purpl account or downloaded one of our applications.

All capitalized terms not otherwise defined herein will have the same meaning as those used in the Terms of Use. 

This Privacy Policy does not, however, describe the practices of third parties that may collect information from you when you interact with them, including sellers that use Purpl to accept payment for goods or services.

We encourage you to ask them about their privacy practices before providing any information to them. We may change this Privacy Policy from time to time. If we make changes, we will notify you by posting the updated policy and revising the “Last Updated” date above. We encourage you to review the policy whenever you use our Services to stay informed about our information practices and about the choices available to you. We collect information you provide, such as when you sign up for a Purpl merchant or Purpl customer account, when you provide information as part of our identity verification process, in the course of a transaction, or when you request a digital receipt.

We respect the privacy of our online visitors and registered users (“Users”) as such we will take reasonable steps to protect your information.

• Updates, Modifications & Amendments

We may need to update, modify or amend our privacy policy as our technology evolves. We reserve the right to make changes to this privacy policy at any time by giving notice to Users on this page.

We advise that you check this page often, referring to the date of the last modification on the page. If a User objects to any of the changes to the Privacy Policy, the User must cease using this Site, or terminate the account in the event an account has been created.

• Age Restriction

Our Site and Services are not directed to children under 18. We do not knowingly collect information from children under 18. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through details on this Privacy Policy.

• GDPR Compliant 

The General Data Protection Regulation, or “GDPR” is a European privacy and data protection law. Under the GDPR, residents of the EU may exercise certain rights regarding their personal data.

As a provider of services, Purpl is required to comply with many regulations, including GDPR. To ensure protection of personal data, we have certified our Purpl Materials to remain compliant with European data protection laws.

• Personal Information 

• Identity Verification

To comply with applicable laws and regulations governing e-wallet activity, including anti-money laundering (“AML”) and know-your-customer (“KYC”) requirements, we are required to collect and process certain personal information to verify your identity.

As part of our verification process, we conduct electronic identity checks, including comparing your submitted identification documents with a live “selfie” or biometric data..

The categories of personal data we collect for identity verification may include, but are not limited to:

• Personal Identification Data (e.g., full name, date of birth, nationality)
• Sensitive and Biometric Information (e.g., facial recognition data, live image verification)
• Government Identifiers (e.g., passport, national ID, driver’s license)
• Contact Information (e.g., phone number, email address)

Failure to provide the required personal information may prevent us from opening an account for you or may result in the closure of an existing account.

Our processing of personal data for identity verification is necessary to comply with legal obligations under AML, KYC, and other applicable regulations. This processing is subject to strict security measures to protect your personal data in accordance with relevant data protection laws.

This includes processing information from your identification documents, including photographic images and performing a “liveness check” to verify your identity.

• Collection of Personal Information

To gain full access to our Site and Services, you must register for an account. When you register, we collect certain Personal Information that you voluntarily provide.

Personal Information may include:

• Full name 
• Email address
• Mobile number
• Business name (if applicable)
• Any other information provided to identify you
• Anonymous information linked to you (e.g., IP address)

We also collect personal data when you:

• Fill out any of our online forms to contact our team.
• Engage with our customer support services.

Additionally, we may request personal information from third-party sources, including financial institutions, payment processors, and identity verification services. With your consent, we may also collect additional data through emails, surveys, and other forms of communication. Once you begin using our Services, we will maintain records of your transactions and other activities related to our platform.

• Use of Personal Information

We process your Personal Information to:

• Provide you with our Services.
• Respond to your inquiries or requests.
• Enhance Purpl’s operations and user experience.
• Prevent, detect, and manage fraud and illegal activities.
• Address inappropriate use of our Site and Services.
• Target advertisements, newsletters, and Service updates.
• Verify the information you provide with third-party sources.
• Improve our database, content, and Site layout.
• Resolve disputes that may arise.

• Sharing & Disclosure

We will not share or disclose your Personal Information to third parties without your consent, except where required by law or regulatory obligations

• Information we collect from App Users 

We collect, but are not limited to the following: basic user information, such as your name, email address, mailing address, phone number, photograph, and birth date; financial information, including bank account and payment card numbers; and other historical, contact, and demographic information. We also collect information when you upload or send information to or through the Services about your products and services (including inventory, pricing and other data), participate in contests or promotions offered by Purpl or our partners, respond to our surveys, or otherwise communicate with us. Some of our Services also allow you to connect with people you already know.

• Transaction Information 

When you use our Services to make or accept payments or money transfers, we collect information about when and where the transactions occurred, a description of the transactions, the payment or transfer amounts, billing and shipping information, and information about the devices and payment methods used to complete the transactions.

• Location Information 

When one of our applications is open on your mobile device, we periodically receive information about the location of the device. We may also collect location information about your device if you are near a seller with whom you have auto check-in enabled. For more information and to learn how to disable location information, please see “Your Choices” below.

• Device Information 

We collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device’s interaction with our Services. We may also identify other software running on the device (but will not collect any content from such software) for anti-fraud and malware-prevention purposes.

• Use of Information 

We collect information about how you use our Services, including your access times, browser types and language, and Internet Protocol (“IP”) addresses.

• Information Collected by Cookies 

We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files that are stored on your hard drive or in device memory by a website. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity.

• Information We Collect From Other Sources 

We may also collect information about you from third parties, including but not limited to third-party verification services, credit bureaus, mailing list providers, and publicly available sources. In some circumstances, this information may include your taxpayer identification number.

• Digital Receipts 

If you choose to receive receipts via email or text message, we store the email address or phone number you provide. We use your email address or phone number to send you a receipt for your purchase and to automatically send you digital receipts for future purchases you make from other merchants. Digital receipts may contain additional messages, offers, or links that may be of interest to you.

• Information Sharing

We may share personal information about you as follows:

• With third parties to provide, maintain, and improve our Services, including Service providers who access information about you to perform services on our behalf (e.g., fraud prevention and verification services), and including financial institutions, processors, payment card associations, and other entities that are part of the payment or transfer process; 
• With others who have signed up for Accounts in order to provide our Services;
• With third parties that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services; 
• 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; 
• If we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; to enforce applicable agreements or policies; to protect the security or integrity of our Services; and to protect us, our sellers, end users, or the public from harm or illegal activities; and
• With your consent. 

We may also share aggregated, non-personally identifiable information with third parties.

• Security 

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

We prioritize the security and privacy of your information in every aspect of our system design. To prevent accidental loss, unauthorized access, misuse, alteration, or disclosure of your data, we implement robust security measures.

We use encryption protocols and advanced security software to protect your personal data in transit and while at rest. Additionally, we maintain strict physical, electronic, and procedural safeguards for the collection, storage, and disclosure of your data.

Access to your personal information is strictly limited to employees and authorized third parties who require it for legitimate business purposes.

• Preferences 

You may also email us if you wish to deactivate your account. We may retain archived copies of information about you and your transactions for a period of time that is consistent with applicable law.

• Promotional Communications 

You may opt-out of receiving promotional emails or text messages from Purpl by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

• Information that we collect from Website Visitors 

We do not collect your Personal Information when you visit the Site. However, so we can monitor and improve our Site and Services we may collect non-personally-identifiable information. We will not share or disclose this information with third parties except as a necessary part of providing our Site and Services.

• Cookies

We use cookies to identify you as a User and make your user experience easier, customize our Services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our Site. Cookies allow our servers to remember your account log-in information when you visit our Site, IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities. If your browser or browser add-on permits, you have the choice to disable cookies on our website, however this may limit your ability to use our Site.

• The Personal Data that we Retain

We will retain your information for as long as your account is active or as needed to provide you with our Services, comply with our legal and statutory obligations or verify your information with a financial institution. 

Therefore, even after closing your Account, we retain certain data for 5 years to comply with our regulatory obligations.