Privacy Policy

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

Table of Contents

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Email Address: Required for account creation and communication.
• Birthday (Optional): Used for loyalty program features such as birthday rewards.
• Payment Data: We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Stripe.
• Third-Party Login Data: We may provide you with the option to register with us using a third party account, like Google, Apple, or Facebook account.
• Receipt Images: When you submit receipts for loyalty point validation, we use AI-powered optical character recognition (OCR) to extract transaction data (merchant name, date, total amount, line items). We do not extract or use your name, phone number, payment card details, or other personal identifiers that may appear on receipts.

Customer vs. Merchant Data

We apply data minimization principles differently based on your role:

• Customers (Pass Holders): We collect only your email address and optionally your birthday. We do not collect or store your name, phone number, or other personal identifiers. This minimizes the data we hold while still enabling loyalty program features.
• Merchants (Business Owners): You may optionally provide your name when creating a business account. This information is used solely for account management purposes and is not required.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and Usage Data: service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services.
• Device Data: information about your computer, phone, tablet, or other device you use to access the Services.
• Location Data: information about your device's location, which can be either precise or imprecise.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To send you marketing and promotional communications if this is in accordance with your marketing preferences.
• To deliver targeted advertising tailored to your interests, location, and more.
• To identify usage trends so we can better understand how our Services are being used.

3. AI and Machine Learning Technologies

In Short: We use AI-powered technologies to validate receipts and enhance your loyalty experience. Your data is processed securely with privacy protections in place.

Receipt Scanning and Validation

BuyPass uses Google's Gemini AI (via the Google Cloud AI Platform) to process receipt images submitted for loyalty point validation. When you upload a receipt:

• The AI extracts transaction data including merchant name, date, total amount, and line items.
• We automatically redact and do not store personally identifiable information (PII) such as customer names, phone numbers, email addresses, or payment card details that may appear on receipts.
• Receipt images are processed in real-time and are not retained after validation is complete.
• The AI determines whether a receipt meets validation criteria based on merchant matching, date range, and minimum purchase thresholds.

AI Decision-Making

Our AI system makes automated decisions regarding receipt validation:

• Auto-Approval: Receipts that clearly match validation criteria are automatically approved for loyalty points.
• Manual Review: Receipts that are unclear, partially damaged, or don't meet automatic thresholds may be flagged for merchant review.
• Rejection: Receipts that appear fraudulent, duplicated, or don't match the merchant are automatically rejected.

You may request human review of any automated decision by contacting the merchant or our support team.

Data Minimization in AI Processing

We apply strict data minimization principles to AI processing:

• Only transaction-relevant data is extracted and stored (amounts, dates, items).
• Personal identifiers are actively filtered out during processing.
• AI models are not trained on your individual receipt data.
• Processing occurs on secure cloud infrastructure with encryption in transit and at rest.

4. Third-Party Service Providers

In Short: We work with trusted third-party providers to deliver our services securely and reliably.

We share data with the following categories of service providers:

Cloud Infrastructure

• DigitalOcean: Hosts our application servers and databases. Data is stored in US-based data centers with enterprise-grade security.
• Amazon Web Services (AWS): Used for image storage (S3) and message queuing. Data is encrypted at rest and in transit.

AI and Analytics

• Google Cloud AI (Gemini): Processes receipt images for validation. Images are processed in real-time and not retained by Google for model training.
• Google Analytics: Collects anonymized usage data to help us improve our services.

Payment Processing

• Stripe: Handles all payment processing for merchant subscriptions. BuyPass does not store credit card numbers or sensitive payment data—this is handled entirely by Stripe in compliance with PCI-DSS standards.

Authentication

• Firebase Authentication: Manages secure login via Google and Apple. We receive only your email address and profile information you authorize.

Digital Wallet Platforms

• Apple Wallet: Delivers passes to iOS devices. Apple does not share your Wallet usage data with us.
• Google Wallet: Delivers passes to Android devices. Google does not share your Wallet usage data with us.

5. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with specific third parties.

We may need to share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Analytics: We may share your information with Google Analytics to track and analyze the use of the Services.

6. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

7. How Do We Handle Your Third-Party Logins?

In Short: If you choose to register or log in to our Services using a third-party account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party account details (like your Google, Apple, or Facebook logins). Where you choose to do this, we will receive certain profile information about you from your provider. The profile information we receive may vary depending on the login provider concerned, but will often include your name, email address, and profile picture, as well as other information you choose to make public on the platform used.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services.

8. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, securely store your personal information and isolate it from any further processing until deletion is possible.

9. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

10. Do We Collect Information from Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

11. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at [email protected].

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Removing Digital Wallet Passes

You can unlink and delete any BuyPass loyalty pass from your device at any time through your mobile wallet application:

• Apple Wallet: Open the Wallet app, select the pass you wish to remove, tap the three-dot menu (...), scroll down, and tap "Remove Pass."
• Google Wallet: Open the Google Wallet app, select the pass, tap the three-dot menu, and select "Remove."

Removing a pass from your wallet does not automatically delete your account or transaction history. To request complete deletion of your data, please contact us.

12. Merchant and Customer Data Ownership

In Short: Merchants own their business data. Customers retain rights over their personal information. We act as a data processor on behalf of merchants.

Merchant Data Ownership

Merchants retain full ownership of their business data, including:

• Pass designs, branding, and loyalty program configurations.
• Aggregated analytics about pass usage, redemptions, and customer engagement.
• Customer lists (limited to email addresses of pass holders who opted in).
• Transaction history and point balances for their loyalty programs.

Merchants can export their data at any time through the dashboard or by contacting support. Upon account termination, merchants may request a complete data export within 30 days.

Customer Data Rights

As a customer (pass holder), you have the following rights regarding data held by merchants through our platform:

• Access: Request a copy of your data held by any merchant.
• Correction: Request correction of inaccurate personal information.
• Deletion: Request deletion of your data from a specific merchant's loyalty program.
• Portability: Your pass and point history can be exported in standard formats.

To exercise these rights, contact the merchant directly or email us at [email protected].

Merchant Access to Customer Data

Merchants can access the following information about their pass holders:

• Email address (required for pass delivery and notifications).
• Pass activity: scans, point accruals, and redemptions.
• Aggregated engagement metrics (not individually identifiable).

Merchants cannot access: your full name (unless you provide it), phone number, physical address, payment information, or data from other merchants' passes.

Data Portability for Merchants

If you switch platforms or close your BuyPass account, you can export:

• Complete customer list with email addresses and point balances.
• Transaction history in CSV or JSON format.
• Pass design assets and configurations.
• Analytics data for your account lifetime.

Export requests are processed within 7 business days. Large data exports may require additional time.

13. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

14. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of the United States, you are granted specific rights regarding access to your personal information.

Categories of personal information we collect

We have collected the following categories of personal information in the past twelve (12) months:

• Category A - Identifiers (Email address): As long as the user has an account with us.
• Category B - Transaction Data (Receipt information: merchant name, date, amounts, line items): Used for loyalty program validation. We do not store customer names, phone numbers, or payment card details from receipts.

We may also collect other personal information outside of these categories in instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels
• Participation in customer surveys or contests
• Facilitation in the delivery of our Services and to respond to your inquiries

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

15. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

16. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at [email protected].

17. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at [email protected].