Privacy Policy

CoverPay Inc. ("CoverPay," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our BNPL aggregation platform and related services.

2.1 Information You Provide

• Identity Information: Name, date of birth, Social Security Number (last 4 digits or full, as required), government-issued ID
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account details, payment card information, income and employment data
• Transaction Information: Purchase amounts, merchant details, payment history

2.2 Information Collected Automatically

• Device Information: Device type, operating system, unique device identifiers
• Usage Data: Pages visited, features used, session duration, click patterns
• Location Data: Approximate location derived from IP address
• Log Data: IP address, browser type, access times, referring URLs

2.3 Information from Third Parties

• Credit Bureaus: Credit reports and scores (with your authorization)
• BNPL Providers: Approval status, plan details, payment history
• Identity Verification Services: KYC/AML verification results
• Partner Applications: Data shared by merchant partners through which you access CoverPay

We use your information to:

• Provide, maintain, and improve the Services
• Process BNPL transactions and route to providers
• Assess creditworthiness and manage risk
• Verify your identity and prevent fraud
• Comply with legal and regulatory obligations
• Communicate with you about your account and transactions
• Develop and improve our routing algorithms
• Provide customer support

We may share your information with:

• BNPL Providers: To process your financing applications (Klarna, Affirm, Afterpay, PayPal, etc.)
• Hedge Liquidity Services: Our affiliated settlement and infrastructure provider
• Merchant Partners: Transaction confirmations and payment status
• Credit Bureaus: As required by law or financing agreements
• Service Providers: Cloud hosting, analytics, customer support vendors under contractual obligations
• Law Enforcement: When required by law, subpoena, or court order
• Business Transfers: In connection with a merger, acquisition, or sale of assets

We do not sell your personal information to third parties for marketing purposes.

We implement industry-standard security measures including:

• AES-256 encryption for data at rest
• TLS 1.3 encryption for data in transit
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• SOC 2 Type II compliance (in progress)
• PCI DSS compliance for payment data

We retain your personal information for as long as your account is active or as needed to provide the Services. We also retain information as necessary to comply with legal obligations, resolve disputes, and enforce agreements. Financial records are retained for a minimum of 7 years as required by law.

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

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your information (subject to legal requirements)
• Opt out of certain data processing activities
• Data portability (receive your data in a structured format)
• Withdraw consent where processing is based on consent

To exercise these rights, contact us at privacy@coverpayme.com.

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected, the right to delete, and the right to opt out of the sale of personal information. We do not sell personal information.

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

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through the Services. The "Last updated" date at the top of this policy indicates when it was last revised.

CoverPay Inc.
Privacy Team
Email: privacy@coverpayme.com
Website: https://coverpayme.com