Privacy Policy
1. Introduction
Justified Payments ("Justified Payments," "we," "us," or "our") provides technology-driven payment processing and related financial services to businesses and their customers. This Privacy Policy explains how we collect, use, share, and protect personal data when you use our website, applications, and services (collectively, the "Services"), and describes the privacy rights available to you depending on where you are located.
Justified Payments is headquartered in Texas, United States. This Policy is designed to address applicable data protection laws in the United States, the European Union, the United Kingdom, and Canada, including the General Data Protection Regulation ("GDPR"), the UK GDPR and Data Protection Act 2018, the Personal Information Protection and Electronic Documents Act ("PIPEDA"), and applicable U.S. state privacy laws.
2. Who This Policy Applies To
This Policy applies to:
- Visitors to our website and marketing pages;
- Users who register for or use the Justified Payments platform ("Users");
- Representatives of businesses that use our payment processing services ("Business Clients"); and
- Individuals whose information is submitted to us by a Business Client in connection with a transaction (for example, a Business Client's customer making a payment).
Where a Business Client submits personal data to us in order to receive our Services, we generally act as a "service provider" or "processor" on the Business Client’s behalf, and the Business Client (acting as the "controller" or "business") determines the purposes and means of processing that data. Where you interact with us directly — such as by creating an account or visiting our website — we act as the "controller" or "business" with respect to that personal data.
3. Information We Collect
We collect personal data in the following ways:
- Directly: from you directly, when you create an account, complete identity verification, submit a payment, contact our support team, or otherwise interact with our Services;
- From Business Clients: from our Business Clients, who may submit your information to us so that we can process a transaction or provide our Services;
- Automatically: through cookies, pixels, and similar tracking technologies when you use our website or applications; and
- From Third Parties: from identity verification providers, fraud prevention services, credit bureaus, and publicly available sources, used to verify your identity and comply with legal obligations.
The categories of personal data we may collect include:
- Identification Data: name, date of birth, government-issued ID number, and similar identifiers.
- Contact Data: mailing address, email address, and phone number.
- Financial Data: payment card numbers, bank account and routing numbers, IBAN, transaction history, and billing information.
- Technical Data: IP address, device identifiers, browser type, operating system, and other online identifiers.
- Verification Data: information collected for Know Your Customer (KYC) and anti-money laundering (AML) checks, which may include identification documents and biometric data used for identity verification.
- Usage Data: information about how you interact with our website and Services.
4. How We Use Your Information
We use personal data to:
- provide, operate, and maintain the Services, including processing payments and transactions;
- verify your identity and comply with KYC, AML, and sanctions-screening obligations;
- detect, investigate, and prevent fraud and other illegal activity;
- communicate with you about your account, transactions, or our Services;
- comply with applicable laws, regulations, and legal process;
- improve and develop our Services; and
- market our Services, where permitted by law and subject to the choices described below.
We process personal data on the following legal bases, where applicable: performance of a contract with you or your Business Client, compliance with a legal obligation, our legitimate interests (such as fraud prevention and service improvement), and, where required, your consent.
5. How We Share Your Information
We do not sell or rent your personal data. We share personal data with:
- Service Providers: service providers and processors who perform services on our behalf, such as cloud hosting, identity verification, fraud and AML screening, card network processing, and customer support tooling;
- Business Clients: Business Clients, when the data relates to a transaction conducted through their use of our Services;
- Financial Partners: payment networks, card issuers, and financial institutions, as necessary to process transactions;
- Regulators/Law Enforcement: regulators and law enforcement, where required by law or to protect our rights, property, or the safety of our users; and
- Corporate Transactions: professional advisors and successors, in connection with a merger, acquisition, financing, or sale of assets.
Categories of service providers we use include cloud infrastructure and hosting providers, database providers, identity verification providers, fraud and anti-money-laundering screening providers, and card payment processors.
6. International Data Transfers
Because Justified Payments operates across the United States, the European Union, the United Kingdom, and Canada, personal data may be transferred to, stored in, and processed in countries other than the country in which it was originally collected, including the United States. Where we transfer personal data from the EEA or UK to a country that has not been deemed to provide an adequate level of protection, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses or the UK's International Data Transfer Addendum, and we require our service providers to maintain appropriate technical and organizational measures to protect your data.
7. Cookies and Tracking Technologies
We and our service providers use cookies, web beacons, and similar technologies to operate our website, remember your preferences, analyze usage, and support marketing. You can manage non-essential cookies through our cookie management tool or your browser settings. Disabling certain cookies may affect the functionality of our Services.
8. Do Not Sell or Share My Personal Information
Justified Payments does not sell personal data for monetary consideration, and we do not "share" personal data for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act ("CCPA") and similar U.S. state privacy laws.
To the extent any of our limited advertising or analytics activities are ever interpreted to constitute a "sale" or "share" of personal data under applicable law, you have the right to opt out. You can exercise this right by:
- submitting a request to privacy@justifiedpayments.com with the subject line "Do Not Sell or Share My Personal Information";
- enabling a Global Privacy Control (GPC) signal in your browser, which we will honor as a valid opt-out request where required by law; or
- using the cookie management tool on our website to disable non-essential advertising and analytics cookies.
Authorized Agents
You may designate an authorized agent to submit a do-not-sell or do-not-share request on your behalf. We may require the agent to provide proof of authorization and may also require you to verify your own identity directly with us.
We will not discriminate against you for exercising your right to opt out, including by denying you Services, charging you a different price, or providing a different level of quality.
9. Data Retention
We retain personal data for as long as necessary to provide the Services, comply with our legal obligations (including recordkeeping obligations under anti-money-laundering and financial services laws), resolve disputes, and enforce our agreements. Retention periods vary depending on the type of data and the purpose for which it was collected.
10. Data Security
We implement administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, loss, misuse, or alteration, consistent with industry standards applicable to payment service providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
11. Your Privacy Rights
Your rights depend on where you live. To exercise any of the rights below, contact us at privacy@justifiedpayments.com. We may need to verify your identity before fulfilling your request, and certain rights are subject to exceptions, including where we need to retain data to complete a transaction, comply with a legal obligation, detect or prevent fraud, or exercise our own legal rights.
United States
Depending on your state of residence, you may have rights under applicable state privacy laws (including, among others, California, Colorado, Connecticut, Texas, and Virginia), such as the right to:
- know what personal data we collect, use, and disclose about you;
- access a copy of your personal data;
- correct inaccurate personal data;
- delete personal data, subject to certain exceptions;
- opt out of the sale or “sharing” of personal data and of targeted advertising; and
- not be discriminated against for exercising these rights.
We do not sell personal data for monetary consideration. To the extent any sharing of data for advertising purposes is deemed a "sale" or "share" under applicable law, you may opt out by contacting us.
European Union / European Economic Area
If you are located in the EEA, you have rights under the GDPR, including the right to:
- access your personal data and receive information about how it is processed;
- rectify inaccurate personal data;
- erase your personal data, in certain circumstances;
- restrict or object to processing;
- data portability; and
- withdraw consent at any time, where processing is based on consent.
You also have the right to lodge a complaint with your local data protection authority.
United Kingdom
If you are located in the UK, you have similar rights under the UK GDPR and the Data Protection Act 2018, and you may lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.
Canada
If you are located in Canada, you have rights under PIPEDA and applicable provincial privacy laws, including the right to access and request correction of your personal information, and to withdraw consent to its collection, use, or disclosure, subject to legal or contractual restrictions. You may direct questions or complaints to the Office of the Privacy Commissioner of Canada.
12. Children's Privacy
Our Services are not directed to, and we do not knowingly collect personal data from, individuals under the age of 18 (or the age of majority in their jurisdiction). If we learn that we have collected personal data from a child without appropriate consent, we will take steps to delete that information.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the updated Policy with a revised "Last Updated" date, and your continued use of the Services after such changes constitutes your acceptance of the updated Policy.
14. Contact Us
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:
Justified Payments
Texas, United States
Email: privacy@justifiedpayments.com