Privacy Policy

1. Information We Collect

a. Personal Information

When you create an account, we collect information including your name, email address, mobile phone number, date of birth, and government-issued identification (for KYC).

b. Financial Information

To enable contributions and payouts, we use Plaid Technologies, Inc. to link your bank account securely, and Checkbook.io, Inc. to process payments. We do not store your full bank login credentials; these are provided directly to Plaid.

c. Identity Verification

We partner with Persona, Inc. to perform identity verification checks. Persona may collect and process information such as a copy of your government-issued ID, biometric identifiers (selfie verification), and other documents to confirm your identity and prevent fraud.

d. Usage Information

We automatically collect data about your interactions with the Services, including IP address, device information, app version, browser type, and log data.

e. Communication Data

We may collect data from SMS, email, or push communications, including message delivery and read receipts.

2. How We Use Information

We use your information to:

1. Verify your identity and comply with legal KYC/AML requirements.
2. Facilitate contributions and payouts within your SUSU group.
3. Send you transactional SMS, email, or push notifications about payments, group updates, and security alerts.
4. Detect, prevent, and address fraudulent activity or misuse.
5. Improve and personalize our Services, including troubleshooting and analytics.
6. Comply with regulatory, legal, and audit requirements.

3. SMS Communication Consent

By providing your mobile number, you consent to receive transactional messages including:

1. One-time passcodes for account verification and login (2FA).
2. Payment contribution reminders and payout confirmations.
3. Security notifications, such as new device logins or suspicious activity.

Message frequency varies by group activity. Message and data rates may apply.

1. To opt out, reply STOP to any message.
2. To get help, reply HELP.

Opting out may limit the ability to use certain features of the Services.

4. How We Share Information

We do not sell or rent your data. We may share information with:

1. Plaid (bank account linking)
2. Checkbook.io (payment processing)
3. Persona (identity verification)
4. Vetted service providers who support hosting, notifications, customer support, and analytics
5. Law enforcement or regulators when legally required
6. Business partners in the event of a merger, acquisition, or sale of assets

5. Data Retention

We retain your personal and financial data only as long as necessary to:

1. Provide the Services
2. Comply with legal and regulatory obligations (e.g., AML record-keeping)
3. Resolve disputes
4. Enforce our agreements

When retention is no longer required, we securely delete or anonymize your data.

6. Data Security

We employ administrative, technical, and physical safeguards, including:

1. Bank-level encryption in transit and at rest
2. Multi-factor authentication for account access
3. Secure audit logging of financial transactions
4. Limited employee access to sensitive information

Despite these efforts, no system is 100% secure. We cannot guarantee the absolute security of your data.

7. Your Rights

You may:

1. Access and review your personal information
2. Request correction of inaccurate data
3. Request deletion of your data, subject to regulatory retention requirements
4. Opt out of SMS or marketing communications

Requests can be made via support@safecirclecapital.com.

8. Children’s Privacy

The Services are not directed to anyone under 18, and we do not knowingly collect personal information from minors.

9. International Use

Safe Circle Capital operates in the United States. If you access the Services from outside the U.S., you consent to having your information processed in the United States under U.S. privacy laws.

10. Changes to this Policy

We may update this Privacy Policy periodically. Material changes will be posted with an updated “Effective Date.”

11. Contact Us

For privacy inquiries, contact us at:

📧 support@safecirclecapital.com
Safe Circle Capital