Privacy Policy

Terms effective as of 1 June 2023

Overview

This Privacy Policy is designed to help you understand how Bead Pay, LLC ("Bead Pay", "we", "us", "our") collects, stores, uses and protects information. Bead Pay's services include merchant payment facilitation services, websites, products, and any other features, technologies or functionalities, including merchant and consumer support ("Services") we offer.

This Policy applies to www.beadpay.com and all other Bead Pay and Bead Pay partner sites on which it appears ("Sites"). If you use any Services provided by us or you provide voluntarily any personal data to us then you specifically represent to us that you have read, understood and consented to the collection, use and storage of your personal data.

We may process information from the following types of users:

• Sites Visitors;

• Merchants who sign up for our Services (“Merchants” means any business that uses our Services to process payments, including non-profits that use our Services to accept donations and “Channel Partners” that use our Services as a payment services platform for their own Merchants);

• Consumers (“Consumers” means individuals who pay a Bead Pay invoice during checkout with a Bead Pay Merchant, when requesting a refund from a Merchant on a previously paid Bead Pay invoice, or when making a donation via the Bead Pay Widget)

Information We May Collect

The information we collect depends on the type of user interacting with us. We collect information you choose to provide to us when interacting with our Services. We may also collect information automatically from your devices. The following sections provide you with some more information.

Type of User	Information We May Collect
Sites Visitors	We may collect the following from visitors of our Sites: Technical information, including IP address, browser type, and language Identifiers associated with the device(s) you use to access our Sites; pages you visit and features you use; access dates and times; and addresses of websites you navigate to or from, before or after interacting with our Sites Email address (e.g., when you opt in to receive other marketing materials, provide information via a contact form, etc.) Phone number (e.g., when you contact our sales team) Full name (e.g., when you submit a support request) Country We may also collect information about a visitor’s device(s) for purposes including fraud prevention. Information we collect may be collected automatically using cookies or similar technologies.
Merchants	During the onboarding process, we may collect the following information from beneficial owner(s) (UBOs). In the case of Channel Partners, we may collect the information of that Channel Partners’ Merchants. The information we collect depends on our compliance analysis and your risk profile: Full name of beneficial owner(s) Full names of authorized users Email address of authorized users Physical business address Business phone number ID of beneficial owner(s) Tax ID (if applicable in specific country) Proof of business (e.g. articles of incorporation) Proof of address, if not evident in above documents Bank account details
Consumers	We may collect information when a Consumer indirectly interfaces with Bead Pay to pay the invoice of a Merchant, request a refund and/or make donations. When paying a Bead Pay invoice or making a donation, we may collect: Full Name Address Email address and/or phone number Date of birth Crypto wallet address Goods and/or services purchased and price(s) as presented to us by the Merchant Technical information, including IP address, browser type, and language Identifiers associated with the device(s) you use to access our Sites; pages you visit and features you use; access dates and times; and addresses of websites you navigate to or from, before or after interacting with our Sites When requesting a refund, we may collect: Amount Currency Email address and/or phone number Crypto wallet address Invoice ID We may collect this information either from the Merchant or directly from the Consumer. This information supports our ability to create a streamlined payment experience for both the Merchant and Consumer. For example, we use this information to email Consumers directly to issue receipts and to issue refund instructions and access PIN (including in the event of an irregular payment, such as underpayment, overpayment, etc.).
Additional Information	In our commitment to combat fraud and illegal activity, as well as comply with laws and regulations, Bead Pay may collect information related to the integrity and accuracy of our communications, including email. Examples may include: Knowing if you interact with a link in an email that we send to you Information from other third parties about you that is relevant to the use of our Sites or Services Information about current, former or prospective vendors and customers (“Partners”), including limited personal information (e.g. professional contact info) about employees and/or agents of such Partners throughout the course of Partner relationships

How We Use Cookies

We may automatically collect information using cookies, web beacons (also known as “tracking gifs,” “pixel tags” and “tracking pixels”) and other tracking technologies (which we individually and collectively refer to as cookies) to, among other things, improve our Services and your experience, monitor user activity, count visits, understand usage and campaign effectiveness, and tell if an email has been opened and acted upon. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our services.

We may allow the use of cookies on our sites by third parties. The information collected by cookies may be collected by us or third parties on our behalf, and the information may be shared with and used by us or by third parties subject to their own privacy policies.

Why Personal Information is Collected

Information we collect is used to provide our Services, to operate our business, to provide you with an efficient, streamlined and personalized experience and for other purposes as required or permitted by law. Specifically, we may use your information to:

• Provide our Services;

• Provide customer support (to Merchants, Consumers and Partners)

• Facilitate the processing of payments and send information about your payments;

• Resolve disputes, collect fees, and troubleshoot problems;

• Send communications to you about our business and Services, and inform you of important matters related to your account and/or use of our Services or Sites. We may also use your personal information to respond to any questions, comments or requests you submitted to us, including complaints;

• Comply with applicable laws and regulations;

• Support legal claims, including to establish, exercise and defend;

• Monitor and report compliance issues;

• Measure our business to customize and improve the Services, our Sites and applications (including new products and services, our communications, sales processes, marketing, advertising, product metrics, network and information security, accounting/auditing and invoicing systems, reconciliation/collection procedures, and customer service);

• Analyze data related to our Services and business systems;

• Deliver personalized marketing based on your communication preferences, such as notices and promotional offers. We will request your consent to send you emails for marketing purposes where it is required by law. You will always have the option to opt out of receiving our marketing communications via unsubscribe links in newsletters or by contacting us;

• Manage risk by comparing information for accuracy and verifying with third parties to identify, prevent or protect against fraud and other prohibited or illegal activity, claims and other liabilities;

• Enhance safety and security of our products and Services; and

• enforce our Terms of Use and other usage policies.

Personal Information Quality

It is our goal to ensure that your personal information is correct, accurate, relevant, timely and secure. For us to meet this goal, if there is any change to any of the details you have provided to us, we request that you promptly advise us so that we can continue to provide the Services. Further, if it comes to your attention that we possess certain information about you that is not correct, accurate, complete, or up to date, contact and we will use all reasonable efforts to correct your personal information within our systems at your request. We reserve the right to only correct such information once we have verified that the new information is correct and we have verified that it is you who have asked for the correction.

Personal Information Security

We undertake to use our best endeavors to keep secure your Personal Data and we further undertake to take all reasonable precautions to protect that information against any unauthorized loss, misuse, or alteration.

Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure.

The Services that we provide uses industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and debit and credit card numbers that is transmitted between you and us.

We retain data as required or permitted by law. As such, we may retain identification for 5 years or more after an account has been closed or become dormant.

Authorized Access to Personal Information

Upon request, we will provide you access to personal information we hold about you in a timely manner after we are able to verify that such access has been requested by you.

Unauthorized Access to Personal Information

In the event of unauthorized access to your personal information, including a data breach, we will without undue delay after becoming aware such breach, notify in writing of the data breach within 72 hours.

Information We May Share with Third Parties

We may share the information we collect with our affiliates and third parties, such as:

• Partners and other service providers who support our business operations, and to deliver our Services, such as cloud-based infrastructure providers; ID-verification, and other due diligence, solutions providers; customer service solutions providers; website analytics providers; and marketing automation platform providers;

• Law enforcement, government officials, regulatory agencies, our settlement and banking partners, and other third parties pursuant to other legal processes; or when we believe, in our sole discretion, that the disclosure of information is necessary to report suspected illegal or fraudulent activity or to investigate violations of our Terms of Use;

• Our Merchants, to whom we may share certain Consumer information in cases of suspected fraud or in connection with ongoing investigations; and

• If we get involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after a closing transaction.

Sale and Disclosure of Personal Information

Bead Pay does not disclose personal information of individuals to third parties for monetary or other valuable consideration.

Jurisdiction-specific Provisions

Canada

As used in this Policy, “applicable law” includes the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) and “Personal Data” includes “personal information” as defined under PIPEDA.

United States - California

If you are a California resident, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA. For such residents, the provisions of this CCPA Addendum prevail over any conflicting provisions in our Privacy Policy.

We have collected the following categories of California Personal Information within the past 12 months:

Category	Examples
Identifiers	Real name, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
Information under the California Customer Records statute	Personal information described in subdivision (e) of Section 1798.80 (California Customer Records statute). This means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, social security number, address, telephone number, passport number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or any other financial information
Commercial information	Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies on our site
Internet or similar network activity	Information regarding a consumer’s interaction with an Internet website, application, or advertisement
Geolocation data	Geolocation data

For each of the above categories, we obtain California Personal Information from a variety of sources, including: you (both online and offline interactions with us or our service providers); other entities with whom you transact; devices you use to access our Sites, applications, and the Services; ID-verification and fraud prevention services; marketing and analytics providers; and public databases and social media platforms

For more information, please see the “Why Personal Information is Collected” section of this Policy.

For each of these categories, we may share personal information with a variety of third parties, including: service providers; marketing, advertising and analytics providers; law enforcement, government officials, regulatory agencies, our settlement and banking partners, and other third parties pursuant to other legal processes; and merchants in cases of suspected fraud or in connection with an ongoing investigation.

California Personal Information We May Use

We may use the California Personal Information we collect for business purposes, including:

• Auditing and reporting for transactions and interactions, including online interactions, you have with us or others on our behalf;

• Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;

• Debugging to identify, troubleshoot and repair errors in our systems;

• Transient use, including the customization of our Services, marketing, advertising or Sites;

• Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services; and

• Conducting internal research to develop, enhance and demonstrate technology, including the quality or safety of services or devices which we may own, control or provide.

We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.

Your Rights as a California Resident

As a California consumer and subject to certain limitations under the CCPA, you have rights regarding our use and disclosure of your personal information, including:

• Right to know: You have a right to request additional information about the categories of personal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.

• Right to opt-out from a sale: We do not sell “Personal Information” as defined by the CCPA and have not done so in the past 12 months.

• Right to limit the use or sharing of Sensitive Personal Information: we do not sell or share Sensitive Personal Information as defined by the CCPA and have not done so in the past 12 months.

• Right to opt-out of sharing of cross-context behavioral advertising

• Right to Delete: You have the right to request that we delete California Personal Information about you which we have collected from you.

• Verification: As required under applicable law, we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information to verify your identity in response to exercising requests of the above type, including name and account information. We may limit our response to your exercise of the above rights as permitted under applicable law.

• Nondiscrimination: Subject to applicable law, we may not discriminate against you if you choose to exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:

  • Denying you goods or services;

  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

  • Providing you a different level or quality of goods or services; or

  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

To submit a request to exercise any of the rights described above, please contact us using instructions in the Contact Us section below. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your identity, including name, address, transaction history, photo identification, and other information associated with your account.

Changes to Our Privacy Policy

We may amend our Privacy Policy at any time by posting a revised version on our website. Any revised version will take effect at the time it is posted. You are responsible for periodically reviewing this Policy.

Contact Us

You may contact us with questions or concerns about our privacy policies or practices at [e-mail].