Privacy Policy

Your privacy is important to us. This Privacy Policy explains how SplitPay and its subsidiaries and affiliated entities (collectively, "we," "us," or "our") collect, receive, use, process, and disclose information about you when you use or interact with our services (the "User Services"), including when you use SplitPay to facilitate payment or other services at participating restaurants, bars, establishments, or other merchants (each, a "Merchant").

We may revise this Privacy Policy periodically to reflect changes to our use of personal data, our services, applicable laws, or regulatory requirements. We encourage you to review this Privacy Policy from time to time. If we make changes, we will update the effective date shown at the top of this Privacy Policy.

Section 1 — Purpose of this Privacy Policy

This Privacy Policy describes how SplitPay handles personal data that we may collect or receive about you, whether that information is provided directly by you or obtained from third parties. It also explains the purposes for which we process your personal data and the privacy rights that may be available to you.

For purposes of this Privacy Policy, "personal data" means information that relates to an identified or identifiable living individual. A person may be identifiable through information such as their name, identification number, location information, online identifier such as an IP address, or other characteristics or information associated with that individual.

This Privacy Policy is intended to help you understand how your information is handled when you use the User Services. Please read this Privacy Policy carefully and consider it together with our applicable User Terms of Service.

This Privacy Policy applies only to personal data that SplitPay collects, receives, or processes. It does not apply to information collected independently by third parties when you interact with them or use their products or services. For example, if you follow a link to a third-party website that SplitPay does not control, or purchase goods or services directly from a third party, that third party's privacy practices and policies will apply.

Section 2 — About Us and How to Reach Us

The User Services may be provided by different entities affiliated with SplitPay. When this Privacy Policy uses the terms "SplitPay," "we," "us," or "our," those terms may refer to the particular SplitPay entity responsible for providing the applicable product or service.

If you are located in the United States and use the User Services, SplitPay is responsible for collecting and processing your personal data, including where applicable under state privacy laws as the relevant "business" or equivalent entity.

Section 3 — What Personal Data We Receive

We may collect and process different categories of personal data depending on how you interact with the User Services and the purposes for which the information is needed.

Profile and Contact Information

When you create an account, use the User Services, or otherwise interact with SplitPay, we may receive information such as your name, email address, profile picture, telephone number, or other information that you voluntarily provide.

We may associate this information with different devices or accounts that you use to interact with the User Services.

If you choose to receive receipts or other communications by SMS, we may collect your telephone number for that purpose. If you separately consent to receive promotional SMS communications, we may also use your phone number for those communications.

Depending on how you use SplitPay, we may also derive information concerning your dining preferences, transaction patterns, habits, and frequency of visits from your transaction history.

Device Information

When you access or use the User Services, we may collect information about the phones, computers, and other devices you use.

This information may include your IP address, which may be used to determine your general location, device identifiers, cookie identifiers, browser information, network connection information, and other technical or device-related information.

Payment Information

When you use SplitPay to make a payment, we may receive payment information, including tokenized payment card information, from the applicable payment processing provider.

Use of the User Services

We may collect information about your interactions with SplitPay and the User Services, whether or not you are logged into an account.

This may include transaction information, orders or payments made with Merchants, products or services you view, reviews or ratings you submit, and your transaction history.

Settings and Privacy Preferences

We may collect information concerning your account settings, preferences, and privacy choices, as well as information about privacy settings associated with your browser or device.

Communications with SplitPay

When you communicate with SplitPay, we may collect information contained in those communications, including messages and emails.

For example, this may occur when you contact customer support, respond to surveys, participate in promotions, or take part in research activities.

California Residents

For California residents, the categories of personal information we collect may fall within the following categories under the California Consumer Privacy Act ("CCPA"):

• Identifiers, such as name, email address, telephone number, and IP address;
• Commercial information, including transaction and order history;
• Internet or other network activity, including device and usage information; and
• Financial information, such as tokenized payment card information.

We do not intentionally collect sensitive personal information beyond what is reasonably necessary to provide the User Services.

Section 4 — How We Collect and Receive Personal Data

We may obtain personal data through several different methods.

Personal Data You Provide to Us

You may provide personal data directly to SplitPay when you use the User Services, create or manage an account, complete forms on our website, provide feedback, contact customer support, or otherwise communicate with us.

Personal Data Collected Through Cookies and Similar Technologies

When you access or use the User Services, we may automatically collect certain information through cookies and similar technologies.

These technologies may allow us to understand how users interact with the User Services and help us operate, maintain, improve, and personalize our services.

When you use certain payment methods, such as Apple Pay or Google Pay, we may receive your email address if it is associated with the applicable payment method.

Where you have provided the required consent, that email address may also be used for marketing communications described in this Privacy Policy.

Personal Data Received From Third Parties

We may receive personal data about you from third parties. These third parties may include analytics providers, third-party directories, reservation or ordering platforms used by Merchants, and companies that provide technical, payment, or other services that allow us to provide and improve the User Services.

Section 5 — How We Use Your Personal Data

We may use your personal data for the following purposes:

Providing, Improving, and Personalizing the User Services

We use information about you to provide and improve the User Services and create a more personalized experience. This may include displaying your transaction history, providing payment options, recommending products, Merchants, or establishments, and customizing the content or services presented to you.

We may also use information about how you interact with SplitPay and participating Merchants to improve our products and services.

Where permitted and where you choose to participate, we may connect transaction information from different visits or venues to better understand preferences and improve your experience.

If you opt in to applicable features, we may share information such as your visit history, spending patterns, and satisfaction-related information with the Merchant you visit so that the Merchant can provide more personalized hospitality and service.

At your request, we may also send payment receipts to the telephone number you provide.

Product Research and Development

We may use personal data to develop, test, troubleshoot, analyze, and improve the User Services. This may include analyzing how you interact with SplitPay, identifying technical problems, repairing errors, developing new functionality, and improving existing features.

Advertising, Marketing, and Promotions

We may use personal data to market and promote SplitPay and its services, including sending personalized communications, offers, promotions, or advertisements where permitted by law. This may include sending offers or promotions based on your preferences or transaction history ("SplitPay Deals").

You may unsubscribe from promotional communications at any time by using the unsubscribe option included in the applicable communication or by contacting us at splitpayus@gmail.com.

Where a Merchant uses SplitPay's customer relationship management or communication features, SplitPay may also send communications on behalf of that Merchant. These may include thank-you messages, special offers, service recovery communications, or re-engagement campaigns. Such communications may be sent under the Merchant's brand and at the Merchant's direction. You may opt out of these communications at any time.

Communicating With You

We may use your information to communicate with you regarding the User Services, including account information, product updates, policy changes, terms, and other service-related matters. We may also use your information to respond to questions, requests, or customer support inquiries.

Authentication, Integrity, Security, and Safety

We may use your information to authenticate accounts, facilitate secure payments, maintain the security of the User Services, and detect, investigate, and prevent fraudulent, malicious, unsafe, or unlawful activity. This may include addressing security threats, protecting users and Merchants, preventing fraud, and maintaining the quality and safety of the User Services.

Security, Safety, and Dispute Resolution

We may use information to protect the rights, property, and safety of SplitPay, our Merchants, their employees, and our users. This may include assisting Merchants with payment disputes, investigating violations of applicable terms, addressing non-payment, investigating potentially fraudulent transactions, and responding to security incidents or harassment.

Legal and Regulatory Purposes

We may process personal data when necessary to comply with applicable laws, regulations, legal obligations, or valid legal processes. This may include responding to requests from law enforcement or government authorities, participating in litigation or civil discovery, establishing or defending legal claims, and investigating potential violations of our terms or policies.

Marketing Consent

When SplitPay sends marketing communications under the SplitPay brand, SplitPay is responsible for determining the purposes and means of that processing and relies on your consent where consent is required. Marketing communications sent by SplitPay are separate from any authorization you provide for a payment transaction.

You may withdraw your marketing consent or opt out of marketing communications at any time by contacting us at splitpayus@gmail.com.

Communications sent by SplitPay on behalf of a Merchant are different. In those circumstances, the Merchant may be responsible for determining how and why your information is used for its communications.

Aggregated, De-Identified, and Anonymized Information

We may combine, aggregate, de-identify, or anonymize information collected through the User Services so that it can no longer reasonably be associated with you or your device. Information that has been properly aggregated, de-identified, or anonymized is not considered personal data or personal information under applicable privacy laws.

We may use such information for purposes including:

• Operating, maintaining, improving, and developing the User Services;
• Developing, training, and improving algorithms, machine learning models, artificial intelligence systems, and statistical tools;
• Creating market analyses, benchmarking reports, trend analyses, and industry statistics; and
• Providing aggregated or anonymized information to third parties, including commercial partners, for research or analytical purposes.

We do not intend for such information to identify you.

Section 6 — How We Process Your Personal Data on Behalf of Merchants

SplitPay may process personal data while you receive payment, dining, hospitality, or other services from Merchants that use SplitPay.

When SplitPay processes information on behalf of a Merchant, we do so according to the Merchant's instructions. In those circumstances, the Merchant's own terms and privacy policy may apply to its collection and use of your personal information.

This may include sending automated communications on behalf of the Merchant, such as thank-you messages, feedback requests, special offers, re-engagement campaigns, or other marketing communications, when you have opted in to receive communications from that Merchant.

These communications may be delivered through SplitPay's infrastructure but under the Merchant's branding and direction.

For more information about how a particular Merchant collects and uses personal information, you should review that Merchant's privacy policy and terms.

Section 7 — If You Fail to Provide Your Personal Data

If you do not provide personal data that we reasonably require, we may be unable to provide certain products or services to you or process an application to create or register an account.

Information that is required to provide a particular service will generally be identified as required when it is collected.

Section 8 — How We Obtain Your Consent

When applicable law requires us to obtain your consent before using your personal data, you may provide that consent when your information is collected by following the instructions presented to you.

You may also provide or manage consent by contacting us using the information provided in the "How to Contact Us" portion of this Privacy Policy.

Where applicable, you may withdraw consent at any time, although withdrawing consent does not necessarily affect the lawfulness of processing that occurred before the withdrawal.

Section 9 — Third-Party Links

This Privacy Policy applies to personal data processed by SplitPay through your use of the User Services and in connection with our business operations.

Our website or User Services may sometimes contain links to third-party websites, applications, products, or services. SplitPay does not control those third-party websites or services, and this Privacy Policy does not govern your interactions with them.

If you follow a link from our website to another website, use a third-party service, or otherwise interact with a third-party provider, your activities will be governed by that third party's own privacy policy, terms, and practices.

We do not control, monitor, or endorse the privacy practices of third parties. We encourage you to review the privacy policies of any third-party website or service you use and contact the relevant provider with questions regarding its privacy practices.

Section 10 — Sharing Personal Data

In connection with providing and operating the User Services, we may need to disclose personal data to certain third parties. The following list describes common categories of recipients. This list is not exhaustive, and there may be other circumstances in which we disclose information as permitted or required by law.

Third-Party Service Providers

We may share personal data with service providers that assist us in providing the User Services, including companies that provide technical support, hosting, infrastructure, analytics, customer support, or other operational services.

Payment Service Providers

We use third-party payment service providers to process payments. These providers may receive or process payment-related information in accordance with their own privacy policies and applicable legal requirements.

Loyalty Partners

If a participating establishment uses a loyalty program that is integrated or partnered with SplitPay and you have enrolled in that program, we may share information such as your loyalty identifier, telephone number, or email address, together with relevant payment amounts, so that the loyalty provider can properly credit points or benefits to your account.

SplitPay Affiliates and Group Companies

We may share some or all of your personal data with our parent company, subsidiaries, affiliates, or other entities within the SplitPay corporate group where reasonably necessary to operate and provide our services.

Merchants and Partners — Security and Legal Matters

We may share contact information and transaction history with a Merchant when necessary to address a payment dispute, security incident, suspected fraud, or violation of applicable terms at the Merchant's location. This may allow the Merchant to investigate and resolve the matter or take appropriate legal action.

Where you have opted in to a guest-recognition or personalization feature at a particular Merchant, we may also share information such as your name, visit history, dining preferences, and satisfaction-related information to allow that Merchant to provide a more personalized experience.

Analytics and Research Partners

We may provide aggregated and anonymized information to commercial partners or other third parties for purposes such as market analysis, industry benchmarking, research, and statistical analysis. This information is designed not to reasonably identify you and is not intended to constitute personal data under applicable privacy laws.

Merchants — Marketing

Where permitted by law, we may share your email address or telephone number with a Merchant where you have completed a transaction with that Merchant so that the Merchant can send marketing communications on its own behalf.

In that situation, the Merchant is a separate third party that determines its own purposes for processing your information and is responsible for handling that information under its own privacy policy.

Data Storage

SplitPay operates in the United States and may use servers, infrastructure, and service providers located in different countries. As a result, your personal data may be stored or processed in countries where SplitPay or its service providers conduct business.

When personal data is transferred internationally, we will use appropriate safeguards where required by applicable law, including standard contractual clauses or other recognized transfer mechanisms when applicable.

By using the User Services, you acknowledge that your personal data may be transferred to and processed in countries outside the state or country in which you reside.

Do Not Sell or Share My Personal Data

Where permitted by law, SplitPay may share your email address with Merchants with whom you have transacted so that those Merchants may send marketing communications on their own behalf. Under certain California privacy laws, this type of disclosure may be considered a "sale" of personal information.

SplitPay may implement additional mechanisms for exercising these rights, including a "Your Privacy Choices" mechanism and support for Global Privacy Control ("GPC") signals where applicable.

Except for the sharing described above, SplitPay does not sell personal data or share personal data for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA.

For clarity, properly aggregated, de-identified, or anonymized information described in Section 5 is not personal information and its disclosure does not constitute a "sale" or "sharing" under applicable privacy laws.

Section 11 — How Long We Keep Your Personal Data

We retain personal data for as long as reasonably necessary to accomplish the purposes for which it was collected.

We may also retain information when necessary to comply with legal, accounting, reporting, regulatory, or other obligations, establish or defend legal claims, resolve disputes, or satisfy compliance requirements.

If we process your personal data for marketing communications based on your consent, we generally retain the relevant information until you withdraw your consent or opt out. After you opt out, we may retain limited information necessary to ensure that we respect your opt-out request, such as maintaining a suppression or do-not-contact list.

When determining an appropriate retention period, we consider factors including:

• The amount, nature, and sensitivity of the personal data;
• The potential risk of harm from unauthorized access, use, or disclosure;
• The purposes for which the information is processed;
• Whether those purposes can be achieved through other means; and
• Applicable legal and regulatory requirements.

Section 12 — Confidentiality and Security of Your Personal Data

SplitPay is committed to protecting the personal data entrusted to us.

We maintain administrative, technical, and organizational safeguards designed to protect personal data under our control from unauthorized access, improper use, unauthorized disclosure, unauthorized modification, unlawful destruction, and accidental loss.

Our employees, contractors, and data processors who process personal data on our behalf are expected to maintain the confidentiality and security of personal data.

PCI Compliance

To the extent applicable to the User Services, SplitPay seeks to provide payment-related services in a manner consistent with applicable Payment Card Industry Data Security Standard ("PCI-DSS") requirements.

Where applicable, payment security and certification requirements may be satisfied through SplitPay's payment processing partners and service providers.

Section 13 — Recommendation Algorithms

SplitPay may use technology and analytical tools to better understand user preferences and improve the User Services. These tools may allow us to personalize experiences by providing customized recommendations, payment-related suggestions, offers, or other content.

Depending on how you use the User Services, we may analyze information such as transaction history, visit frequency, spending patterns, satisfaction ratings, and preferences.

This information may be used to segment users and provide more relevant communications from SplitPay or participating Merchants, subject to applicable consent and opt-out requirements.

We may also use aggregated and anonymized information that does not reasonably identify individuals to develop, train, test, and improve algorithms, models, and other technologies used to operate and improve the User Services.

Section 14 — Personal Data of Minors

SplitPay does not knowingly collect personal data from individuals under the age of 18.

If we become aware that an individual under 18 has provided personal data to SplitPay, we will take reasonable steps to delete that information as soon as reasonably practicable.

Section 15 — Your Privacy Rights

California Residents — CCPA/CPRA

If you are a California resident, you may have certain rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act. These rights may include:

Right to Know. You may request information about the categories and specific pieces of personal information SplitPay has collected about you, the categories of sources from which that information was obtained, the purposes for which it was collected, and the categories of third parties with whom it has been disclosed or shared.

Right to Delete. You may request that SplitPay delete personal information we have collected about you, subject to certain exceptions permitted by law.

Right to Correct. You may request that SplitPay correct personal information that we maintain about you if you believe it is inaccurate.

Right to Opt Out of Sale or Sharing. As described in Section 10, SplitPay may share contact information with Merchants with whom you have transacted so that they may send marketing communications on their own behalf. Depending on the circumstances, this activity may constitute a "sale" under California law. You may opt out of this activity by contacting splitpayus@gmail.com.

Except for the sharing described above, SplitPay does not sell personal information or share it for cross-context behavioral advertising as defined under applicable California law.

Right to Limit Use of Sensitive Personal Information. To the extent SplitPay collects sensitive personal information covered by applicable California law, you may have the right to request that its use be limited to what is reasonably necessary to provide the requested services or other purposes permitted by law.

Right to Non-Discrimination. SplitPay will not unlawfully discriminate against you because you exercise privacy rights available to you under applicable law.

Exercising Your Rights

We will process and respond to qualifying requests within the period required by applicable law, generally within 45 days where the CCPA requires that timeframe.

We may need to verify your identity before completing certain requests to protect your personal information and prevent unauthorized access.

Other U.S. State Residents

Residents of states with applicable comprehensive privacy laws, including Virginia, Colorado, Connecticut, Texas, and other states, may have privacy rights that include rights to access, correct, delete, or opt out of certain processing of personal data.

If you believe you have privacy rights under applicable state law and wish to exercise them, please contact splitpayus@gmail.com.

The rights available to you may depend on the state in which you reside and the applicable law.

Users Located Outside the United States

If you use SplitPay from outside the United States, additional privacy laws may apply depending on your location.

For example, individuals located in the European Economic Area, the United Kingdom, Switzerland, or other jurisdictions may have additional rights under applicable local privacy laws.

If applicable, SplitPay will provide additional privacy disclosures and rights required by the laws governing your location.

Section 16 — Do Not Track and Opt-Out Preference Signals

Certain browsers and devices may transmit "Do Not Track" ("DNT") signals or Global Privacy Control ("GPC") signals.

SplitPay does not currently respond to DNT signals.

SplitPay does not use advertising pixels or tracking technologies for cross-context behavioral advertising within its guest-facing payment and ordering experience.

As described in Section 10, SplitPay may share contact information with Merchants so those Merchants can conduct their own marketing. Depending on applicable law, this activity may constitute a "sale" of personal information.

SplitPay may support GPC signals as an additional method for exercising applicable opt-out rights as those capabilities become available.

In the meantime, you may exercise applicable opt-out rights by contacting splitpayus@gmail.com.

For more information about Global Privacy Control, you may visit the official Global Privacy Control website.