Privacy

Pay With Spire, Inc.

Privacy Policy

This policy was last updated on December 3rd, 2024.

Pay With Spire, Inc. (“Spire,” “we,” or “us,” or “our”) respects our users,’ customers’, website and mobile app visitors’, and others’ interested in our business (as applicable, “user” “you”, “your” , or “customer”) privacy and protects it through the terms contained in this Privacy Policy (“Privacy Policy”).

Spire, provides ability for customers to use our services and features as a method of payment at enrolled businesses (each a “Merchant”) or third-party networks, and, where applicable, Spire allows customers to receive coupons, marketing messages, or other incentive-based items for Merchants that may be used toward goods and services offered by a participating Merchant or network (collectively, the “Services”). The Services may be offered under Spire’s name or branded with the name of one of our participating Merchants or networks. Among other features, the Services includes a payment settlement network for participating merchants using the Automated Clearing House (ACH) network.

This Privacy Statement describes the types of personal 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, as defined by applicable privacy laws (“Personal Information”), which we may collect, use, or maintain with regard to the Services and any communications between you and us and our practices related to such Personal Information.

BY PROVIDING US WITH YOUR PERSONAL INFORMATION OR BY DOWNLOADING, ACCESSING OR USING THE SERVICES, INCLUDING USE OF OUR (OR OUR MERCHANT’S OR OTHER THIRD PARTY’S) WEBSITE, MOBILE APPLICATIONS OR OTHER PROGRAMS WHERE OUR APIS, SDKS, AND/OR OTHER TECHNOLOGY ARE USED, OR VIA PLASTIC CARD OR OTHER ALTERNATE ID, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SERVICE AND DO NOT PROVIDE US WITH ANY PERSONAL INFORMATION. PLEASE NOTE, HOWEVER, THAT IF YOU CHOOSE TO LIMIT THE INFORMATION THAT YOU PROVIDE TO US WHILE USING THE SERVICES, YOU MAY NOT BE ABLE TO USE OR PARTICIPATE IN THE SERVICES OR CERTAIN FEATURES OF THE SERVICES.

CHANGES OR UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time to reflect how we process your Personal Information, and if we make changes, we will revise the effective date or last modified date at the top of this Privacy Policy. If we make changes that materially affect your privacy rights, we will attempt to provide advanced notice (in nearly contemporaneous disclosures) or otherwise via the app, website, email, or by some other means of contact so that you have a reasonable opportunity to review the changes before you continue to use the Services. If you disagree with a future, modified version of this Privacy Policy, then please stop using the Services at such future time.

PERSONAL INFORMATION WE COLLECT

The Personal Information we receive and collect depends on when and how you interact with us, and what you do within our Services. You may be able to improve your experience when you tell us who you are (e.g., by enrolling in our Services, making inquiries, or requesting further information about our Services). However, you can visit our website or certain parts of the specific application without revealing your identity. When you request information, we will ask you for your Personal Information or obtain such data from third parties. You are free to choose whether to disclose this information to us or not. We may collect Personal Information in the following ways:

2.1. Personal Information collected directly from you. For example, you may submit a request via our website, complete forms to enroll in our Services or provide Personal Information via the use of our Services. This Personal Information may include:

o Enrollment Information, including name, postal address, email address, phone number, PIN and password, driver’s license of state/military identification number, date of birth, bank account information including account and routing numbers.

o Verification Information, including name, postal address, driver’s license of state/military identification number, date of birth, financial information, connections or relations you may have with others who utilize our Service (e.g. same address, bank account, phone), or other documentation you may choose to submit to confirm the information you provided during enrollment.

o Demographic Information, including gender, age, and zip code.

o Transaction Information, including when and where the transactions occurred, a description of the transaction, the payment amount, bank account information, device information, and other information in connection with completing your purchase, including any payments returned by your bank or any repayments, refunds, or credits. This could include information about your location and Geographic Information Systems (“GIS”) data.

o Email Communications. We store all email correspondence between you and us. This may include records and copies of your correspondence (including your email addresses), information if you enter a promotion offered by a Merchant, or when you report a program with our website or application.

o Audio, electronic, visual or similar information – Call recordings when you talk to customer service or sales, voice mails you leave, your response to surveys, chat conversations with us, email correspondence with us.

o Device Information – information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same personal or banking information.

o Sensitive Information. Some Services may provide you the opportunity to provide sensitive Personal Information as a result of enrollment or providing verification checks, including your driver’s license, state identification card, or passport number. We only collect this information as provided by or consented to by you. Such sensitive Personal Information is only shared to provide the Services you request or as consented to and will not be shared or used by us for any other purposes.

2.2. Automatically, when visiting our website or application or using our Services.

o Transaction Information. When you use our Services to make payments, we collect information about when and where the transactions occurred, a description of the transactions, the payment amount, and information about the devices used to complete the transaction. This could include information about your location and Geographic Information Systems (“GIS”) data.

o Internet or Electronic Activity Information. We may use cookies, tags, web pixels, and similar technologies to automatically collect information on our Services. Information within this section describes our use of these technologies and your ability to control the use of these technologies.

- - Cookies. Cookies are small web files that a website or its provider transfers to your device’s hard drive, through your web browser, that enables the site’s or provider’s system to recognize your browser and remember certain information. “First-party cookies” are cookies set by us on the Services. “Third-party cookies” are cookies set by other companies whose functionality is embedded into our Services. Generally, we may use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.

- - Web Pixels. To see how successful our marketing campaigns or other goals of the Services are performing, we may use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page. We may also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.

- - Analytics. We may use third-party service providers to monitor and analyze the use of our Services. Such service providers often have their own separate privacy practices. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g. what features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. We use this data to improve the quality and functionality of our Services; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible. We currently use Azure Application Insights for this purpose. Further information from Microsoft about privacy and Azure can be found at: http://azure.microsoft.com/de-de/support/trust-center/privacy/

- - Java Script. Pages of our Services may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.

- - Other Tracking Technologies. We may also use tracking technologies to collect “clickstream” data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Services, pages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Services for the same purposes.

- - Do Not Track. Some browsers have a “Do Not Track” (DNT) feature that lets you tell websites and online services that you do not want to have your online activities tracked. Such browser features and industry standards are not uniform. As such, we do not monitor or respond to DNT browser requests. If a standard is adopted that we must follow in the future, then we will inform you about that practice in a revised version of this Privacy Statement.

- - Location Information. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information, by changing the relevant preferences and permissions in your device or browser settings.

2.3. Personal Information collected on or via third parties.

o Some of our Services allow you to provide us with Personal Information relating to other parties, such as names, email addresses, postal addresses, or phone numbers (collectively, “Third-Party Data”). If you use any feature of the Services that allows you to submit Third-Party Data, you acknowledge, represent, and agree (a) that you have the authority of the relevant other party for us to access and use the relevant Third-Party Data, and (b) that you have notified these other parties and informed them how their information is collected and used by us to provide the Services. We reserve the right to identify you as the person who has provided the information in any messages that are sent to other parties. We use Third-Party Data to (a) contact such party using the Third-Party Data provided, and/or (b) to provide the Services requested.

o We may also collect information about you from third parties, including but not limited to merchants who use our Services, third-party verification services, credit bureaus, mailing list providers, and publicly available sources. In some circumstances, this includes the information may include your social security or taxpayer identification number.

o We also may obtain Personal Information from other sources, such as through mergers and acquisitions with other companies, as well as through commercial arrangements with third-party providers, business partners, and other sources. Personal Information Spire receives from a third party is subject to your separate agreement with such third party unless you enter into a separate agreement with Spire or otherwise give Spire your permission to use such information. Spire may merge Personal Information Spire receives from third parties with Personal Information Spire has collected or will collect subject to such limitations.

YOUR CHOICES

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies on our Services by taking the steps outlined below.

o First-Party Cookies. You can use the browser with which you are viewing the Services to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access certain secure areas of the Services. Also, if you disable cookies, other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at https://www.allaboutcookies.org .

You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information, by changing the relevant preferences and permissions in your device or browser settings.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

We may process, receive, store and use your Personal Information for the following purposes:

To enroll you in and provide our Services and their contents to you;
For verification purposes related to the Services;
To process and manage Services relating to your purchase of products and services at participating merchants;
To respond to your inquiries and requests;
To create and deliver personalized promotions, including combining your Personal Information with other information, such as the amount and types of purchases you make and benefits you receive;
To communicate with you by mail, telephone, email, mobile alerts, push messages, and SMS messaging, including about your use of the Services;
To notify you about changes to our Services;
To further our business purposes, such as to perform data analysis, audits, fraud monitoring and prevention, to enhance, improve or modify the Services, to identify usage trends, determine effectiveness of promotional campaigns and to operate and expand our business activity;
To better service your requests and/or inquiries, monitor website or application usage and/or performance, improve the customer experience of our website or application, ensure technological compatibility with your computer, phone, or tablet, protect against fraud or identity theft, or conduct aggregate analyses on usage patterns;
To send updates, newsletters and notifications to you relating to the Services, special events, promotions, programs, or contests;
In response to judicial or other governmental subpoenas, warrants and court orders served on us in accordance with their terms, or as otherwise required by applicable law;
To comply with legal, regulatory or administrative requirements of governmental authorities;
To fulfill any reporting requirements to merchants or vendors;
To protect our rights or property, protect our legitimate business interests, to enforce the provisions of our terms or policies, in cases of customer fraud/disputes, and/or to prevent harm to you or others;
To assert, protect or defend us, our affiliates, or our authorized vendor(s) and designees and any of their officers, directors, employees, agents, contractors and partners, in connection with any legal action, claim or dispute;
As disclosed in other applicable policies, terms of use, or other agreements; or
As permitted or required by law or as authorized by you.
To fulfill any of our internal policies;
To fulfill any other purpose for which you provide it;
To fulfill other purposes disclosed at time of collection;
As set forth in a separate agreement between you and us; and
For any other purpose with your consent.

Aggregate Information. We or our affiliated companies, designees, merchants, and/or third-party service providers may also use Personal Information to create aggregated data for analytical purposes. This statistical information does not contain any Personal Information and is used to understand our customer base and to better serve our market. Spire reserves the right to use and share such aggregate data with third parties, such as potential business partners, merchants, advertisers, and funding sources, or in order to describe our business and operations.

HOW WE DISCLOSE THE PERSONAL INFORMATION WE COLLECT

At Spire maintaining your trust and confidence is our top priority. Spire may disclose your Personal Information to third parties from time to time. These types of third parties may include:

o Subsidiaries and Affiliates. We may disclose Personal Information about you to our subsidiaries and affiliates.

o Service Providers & Contractors. To help us provide superior service, your Personal Information may be shared with other companies or individuals as service providers, contractors, and business partners to provide services for us and help support our business. Such third parties may help us with aspects of our business such as transaction processing and payment, fraud prevention, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, plastic card fulfillment, and entry collection, winner selection and prize fulfillment for contests, sweepstakes, and other promotions. Portions of our services may be provided by organizations with which we have a contractual relationship, including subcontractors, and, accordingly, your personal data may be disclosed to them. We also share information with collection agencies in the event of a returned transaction or delinquent payment.

o Merchants & Networks. We may share your Personal Information with Merchants or Networks who use our Services to process payments (or those acting on their behalf), including any Third-party providers of applications utilizing the Spire Services.

o Verification Agencies. We may share your Personal Information with verification services, fraud screening services, and credit bureaus (“Verification Agencies”) to verify the information you provide when you enroll with or participate in our Services. We encourage you to review the privacy policies or notices of third parties (Plaid, Socure, Microbilt, ValidiFI) for information about their practices.

o Analytics Partners. We may share your Personal Information, including, without limitation, your contact information with entities that perform marketing or data aggregation services on our behalf, or with which we or an affiliate or a merchant or network has joint marketing arrangements. We may share Personal Information, including without limitation your device information, location, usage data, and IP address, to analytics-based technologies to assist with personalization, advertising, and marketing. These technologies capture how you interact with our Services through behavioral metrics to improve and market our products and Services.

o Authorized Representatives. If another individual is managing your account with us or your email account, which the Services connect to on your behalf (for example, a manager managing the account of an employee), as authorized by you or as a personal representative under applicable law, that person can view all Personal Information about you on the Services.

o In the Event of a Merger, Sale, Divestiture, or Change of Control. We reserve the right to transfer Personal Information to a buyer or other successor in interest that acquires rights to that information as a result of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of us or substantially all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about you is among the assets transferred.

o With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction.

o Other Disclosures. We may disclose your Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) conform to legal requirements and comply with any court order, law, or legal process, including responding to any government, law enforcement, or regulatory request; (ii) enforce the Terms of Service, other agreements, including between you and us, and any other documents included or referenced therein (all of which are incorporated into and made a part of this Privacy Statement by reference); (iii) fulfill the purpose for which you provide it; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to our, your, or third parties’ rights, property, or safety.

We may share and disclose de-identified and/or aggregate analytics with third-party partners for any legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with Personal Information.

ENROLLMENT PROCESS

By completing the enrollment process, whether through a Spire application or website or a Merchant or third-party application or website you confirm your agreement with the terms of this Privacy Statement and you authorize us to verify your identity, verify your bank account, and confirm you are the owner of the bank account that you would like to use both during enrollment and while you remain active in our system.

THIRD-PARTY LINKS

The Spire Services, Merchant website or app, or third-party app or website may contain links to other websites or services. Spire is not responsible for the privacy practices or the content of those websites or services. Users should be aware of this when they leave our Services, and review the privacy statements of each third-party. This Privacy Statement applies solely to Personal Information collected by Spire via the Service.

EMAIL COMMUNICATIONS & MARKETING

If you create an account and provide your email address, we may send you administrative and marketing emails. All users receive administrative emails. If you wish to opt out of administrative emails, you must delete your account entirely and cease use of the Service.

We may use your Personal Information to provide you with direct marketing information about our products and services of Spire as well as those of our merchants, affiliates and third parties, and we may permit those merchants, affiliates or other third parties to send their own direct marketing to you. Any direct marketing may be by email, post, or such other method(s) as may become relevant. In addition, we may provide direct marketing information and permit others to do that as allowed by our customers’ respective contracts.

We will take steps to seek to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

If you have any questions about opting out of marketing-related emails, you can also contact us as specified in the Contact Us section below. Any request to be removed from marketing communications will be honored. However, please note that even after you are removed from our marketing lists, we may still send you non-promotional communications, such as responding to your support requests and other transactional information.

LOYALTY PROGRAMS, CONTEST, AND SWEEPSTAKES

To participate in our online programs, contests, or sweepstakes, we may require you to register and provide us with Personal Information, such as your name and email address. This Privacy Statement applies to any incentives we may administer online through the website, other social media, or digital platforms. Some incentives we advertise may be administered by third parties who would collect your information, and you should review the privacy policies of the administering party to understand how they use and protect your data. You should carefully review any rules and guidelines associated with any incentive program you participate in, including any option to opt-out of receiving special offers and marketing material by unchecking the appropriate box when registering for any incentives. If you have any questions or concerns, please contact us via the Contact Us section below.

NETWORK OPERATORS.

Use of the Services may involve use of the services of third-party telecommunications carriers and service providers (such as the services of the carrier that provides cellphone service to you). Such carriers and service providers are not Spire’s contractors, and any information that a carrier collects about your use of the Services is not Personal Information and is not subject to this Privacy Statement. Spire is not responsible for the acts or omissions of telecommunications carriers or service providers.

Correcting and Updating account information.

Spire, or its authorized agents, will not modify your Personal Information without your permission, except in the case of correcting an obvious error (such as your zip code). You are responsible for keeping your financial account information with the enrolled bank account current. Please help us keep your data accurate and current by informing us of any changes in Personal Information. You may update, correct, or delete your Personal Information by contacting Customer Service as listed in the terms and conditions of your Enrollment for Spire Services.

SECURITY

We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law. However, no system or online transmission of data is completely secure, and we cannot guarantee that security breaches will not occur. You should always take appropriate security measures to protect your Personal Information, including ensuring you have up-to-date anti-virus software. Spire may assign you a user ID, a password, and/or PIN as part of your participation and access to our Services. Only you may use your user ID, password and/or PIN. You may not share your user ID, password, and/or PIN with anyone else, and you are solely responsible for maintaining and protecting the confidentiality of your user ID, password, and/or PIN. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties.

Suspicious E-Mail. We will never e-mail you to request Personal Information over the Internet or by any other means. Help protect yourself against online fraud – if you suspect that an unsolicited e-mail is fraudulent, please contact us.

CHILDREN.

Our Services are not intended for persons under 18 years of age. If you are under 18 years of age, then please do not use the Services. Spire does not knowingly collect or maintain Personal Information from persons under 16 years of age. If Spire learns that the Personal Information of persons less than 16 years of age has been collected without verifiable parental consent, then Spire will take the appropriate steps to delete this Personal Information. If you believe a child under the age of 16 has provided us with Personal Information, please contact us at privacy@paywithspire.com.

SERVICE

Spire and the Services are located within the United States and are subject to the applicable state and federal laws of the United States. If you choose to access or use the Services, you consent to the use and disclosure of information in accordance with this Privacy Statement and subject to such laws. Of note, the laws in the United States may not provide the same protections for your Personal Information as the jurisdiction in which you are located. Do not provide your Personal Information to us if you do not want this information to be transferred or processed outside of your country or if the laws in your country restrict such transfers.

RETENTION PERIOD

Spire retains Personal Information no longer than necessary to fulfill the purposes set out in this Privacy Statement unless a more extended retention period is required (such as under applicable contracts with clients or business partners) or permitted by law (such as tax, accounting, or other legal requirements).

CUSTOMER SERVICE CORRESPONDENCE

If you send us correspondence, including e-mails and chats, we and/or our authorized agents retain such information in the records of your account. We and/or our authorized agents will also retain customer service correspondence and other correspondence from Spire or its authorized agents to you. Regarding customer service correspondence, we retain these records in order to measure and improve our customer service and investigate potential fraud and violations. We may, over time, delete these records as permitted by law.

CALIFORNIA PRIVACY RIGHTS

This section applies to residents of California and provides residents with certain rights regarding Personal Information (“consumers” or “you”). This section uses certain terms that have the meaning given to them in the CCPA, including Personal Information. The following do not apply to individuals who do not live in these states on a permanent basis.

17.1. Shine the Light

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the CONTACT US section below with a reference to California Disclosure Information.

17.2. CALIFORNIA CONSUMER PRIVACY ACT OF 2018, AS REVISED AND UPDATED BY THE CALIFORNIA PRIVACY RIGHTS ACT (COLLECTIVELY, “CCPA”)

17.2.1. Consumer Privacy Rights

o Under CCPA, consumers have certain rights regarding their Personal Information, as described below.

- - - Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
      - The categories of Personal Information that we collected about you;
      - The categories of sources from which the Personal Information is collected;
      - The business or commercial purpose for collecting or selling Personal Information;
      - The categories of third-parties with whom we share Personal Information;
      - The specific pieces of Personal Information that we have collected about you;
      - The categories of Personal Information that we disclosed about you for a business purpose or sold to third parties; and
      - For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
    - Right of Deletion: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
    - Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration.
    - Right to Opt-In: We do not have actual knowledge that we collect, share, or sell the Personal Information of minors under the age of 16.
    - Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed beyond the scope of the Services and for “the purpose of inferring characteristics about a consumer.” However, we do not collect or process Sensitive Personal Information for this purpose.
    - Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.

If you would like to exercise your California privacy rights, please refer to the Consumer Requests and Verification section below.

17.2.2. CONSUMER REQUESTS AND VERIFICATION

o Right to Non-Discrimination

- - We may not discriminate against you because you exercise any of your rights under CCPA, including, but not limited to:
    - Denying goods or services to you;
    - Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
    - Providing a different level or quality of goods or services to you; or
    - Suggesting that you will receive a different price or rate for goods or services or a different level or quality.

o Verifying Requests

- - You may request to exercise your rights of access, deletion, or correction under CCPA by contacting us as described in the Contact Us section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following:
    - As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
    - We will confirm that you want your information accessed, corrected, and/or deleted.
    - We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.
    - We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
    - In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.

o Authorized Agents

- - You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the Contact Us section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:
    - The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
    - You to verify your identity directly with us; or
    - You to directly confirm with us that you provided the authorized agent permission to submit the request.

CONTACT US

If you have questions or concerns regarding any information in this Privacy Statement, please contact us at privacy@paywithspire.com or write to us at Pay With Spire, Inc., Attn: Customer Service, 3309 Elm Street, Suite 365, Dallas, TX 75226.

info@paywithspire.com