1. Information We Collect

1.1 Information You Provide

When you create an account or use our Services, you provide us with:

• Identity Information: Full name, date of birth, Social Security Number (for identity verification and tax reporting)
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account numbers, routing numbers, credit/debit card information (card number, expiration date, CVV)
• Authentication Information: Password, security questions, two-factor authentication credentials
• Transaction Information: Payment amounts, recipient information, transaction descriptions

1.2 Information We Collect Automatically

When you use our Services, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Information: Pages visited, features used, time spent on platform, click patterns
• Location Information: Approximate geographic location based on IP address
• Log Data: Access times, error logs, referral URLs

1.3 Information from Third Parties

We receive information from our service providers:

• Authorize.Net: Payment processing confirmations and fraud detection data for credit card deposits
• Circle (USDC): Blockchain transaction confirmations for reserve pool operations
• Google LLC: Profile information if you use Google Sign-In (name, email, profile picture)
• Identity Verification Services: Verification of your identity documents and government records
• Fraud Prevention Services: Risk scores, device fingerprints, fraud indicators

2. How We Use Your Information

2.1 To Provide Services

• Process deposits, payments, and withdrawals
• Maintain your internal ledger account and balance records
• Verify your identity and eligibility
• Manage USDC reserve pool to back all user balances 1:1
• Process manual ACH deposits and credit card transactions
• Send transaction confirmations and receipts

2.2 For Security and Fraud Prevention

• Detect and prevent fraudulent transactions
• Monitor for suspicious account activity
• Verify device identity and location
• Enforce velocity limits and transaction restrictions
• Protect against unauthorized access

2.3 For Compliance and Legal Obligations

• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements
• File Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) as required by law
• Respond to subpoenas, court orders, and law enforcement requests
• Maintain required transaction records
• Report tax information (IRS Form 1099-K for qualifying users)

2.4 For Product Improvement

• Analyze usage patterns to improve our platform
• Develop new features and services
• Troubleshoot technical issues
• Conduct internal research and analytics

2.5 For Communications

• Send service notifications and account updates
• Provide customer support
• Send SMS verification codes for two-factor authentication
• Send security alerts about your account
• Notify you of policy changes

3. How We Share Your Information

3.1 Service Providers

We share information with trusted third-party service providers who help us operate our platform:

Service Provider	Purpose	Data Shared
Authorize.Net (Visa)	Credit card payment processing	Name, card number, expiration date, CVV, billing address
Circle Internet Financial	USDC reserve pool management	Transaction amounts for reserve pool operations
Twilio Inc.	SMS authentication codes	Phone number, verification codes
Google LLC	OAuth authentication (optional)	Email, name, profile picture (if you use Google Sign-In)
Postmark (ActiveCampaign)	Transactional email delivery	Email address, name, email content

3.2 Legal and Regulatory Compliance

We may disclose your information to:

• Government Agencies: FinCEN, IRS, state regulators, law enforcement
• Legal Process: In response to subpoenas, court orders, or legal proceedings
• Safety and Security: To protect against fraud, enforce our Terms, or protect rights and safety

3.3 Business Transfers

If PayGunner is acquired, merged, or sells assets, your information may be transferred to the new entity. We will notify you before your information becomes subject to a different privacy policy.

3.4 With Your Consent

We may share information with other third parties when you explicitly consent or direct us to do so.

3.5 We Do NOT Sell Your Data

Important: We do not sell your personal information to advertisers, data brokers, or other third parties for marketing purposes.

4. Data Security

4.1 Security Measures

We implement industry-standard security practices to protect your information:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.3
• Database Encryption: Sensitive data is encrypted at rest using AES-256 encryption
• Password Security: Passwords are hashed using bcrypt with salt
• Tokenization: Credit card numbers are tokenized and never stored on our servers
• Access Controls: Role-based access restrictions limit employee access to customer data
• Monitoring: 24/7 security monitoring and logging of all system access

4.2 Your Security Responsibilities

You are responsible for:

• Maintaining the confidentiality of your password
• Enabling two-factor authentication (highly recommended)
• Logging out of your account on shared devices
• Notifying us immediately of any unauthorized access

5. Data Retention

We retain your information for as long as necessary to:

• Provide services to you while your account is active
• Comply with legal obligations (typically 5-7 years for financial records)
• Resolve disputes and enforce our agreements
• Maintain records required by anti-money laundering laws

After your account is closed, we will retain transaction records as required by law but will delete or anonymize other personal information within a reasonable timeframe.

6. Your Privacy Rights

6.1 Access and Correction

You have the right to access and correct your personal information through your account settings or by contacting us at privacy@paygunner.com.

6.2 Account Deletion

You may request account deletion by contacting support@paygunner.com. Please note that we must retain certain records for legal compliance.

6.3 Data Portability

You may request a copy of your transaction history and account data in a machine-readable format.

6.4 Marketing Opt-Out

You may opt out of promotional emails by clicking "unsubscribe" in any marketing email. You cannot opt out of essential service communications (transaction confirmations, security alerts, legal notices).

6.5 State-Specific Rights

California Residents (CCPA): You have additional rights under the California Consumer Privacy Act, including the right to know what personal information we collect, the right to request deletion, and the right to opt out of sales (note: we do not sell personal information).

Other States: Residents of Virginia, Colorado, Connecticut, and other states with privacy laws may have similar rights. Contact privacy@paygunner.com to exercise your rights.

7. Cookies and Tracking Technologies

7.1 Cookies We Use

• Essential Cookies: Required for authentication and security (session management)
• Analytics Cookies: Help us understand how users interact with our platform
• Security Cookies: Used for fraud detection and device fingerprinting

7.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling cookies may limit your ability to use certain features.

8. Third-Party Links

Our Services may contain links to third-party websites (such as our payment processors and service providers). We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

9. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we discover we have collected information from a child, we will delete it immediately.

10. International Users

PayGunner operates in the United States. If you are located outside the U.S., your information will be transferred to and processed in the United States, which may have different privacy laws than your jurisdiction.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date at the top
• Sending email notification for significant changes

Your continued use of the Services after changes are posted constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions about this Privacy Policy or how we handle your information, please contact us:

PayGunner, LLC
Email: privacy@paygunner.com
Support: support@paygunner.com
Data Protection Officer: dpo@paygunner.com