Privacy Policy

Castle Pay offers payment solutions for regulated and other emerging markets. This Privacy Policy is designed to help you understand how we collect, use, and share your personal information, and to help you understand and exercise your privacy rights.

Note: The information we collect from you, what we use it for, and to whom we disclose it depends on whether you are an individual consumer who uses Castle Pay to make purchases (a "Customer"), or a merchant customer who uses Castle Pay to process payments (a "Merchant"). We refer to the term "you" in this policy where our data collection practices apply equally to both Customers and Merchants.

1. SCOPE
2. CHANGES TO OUR PRIVACY POLICY
3. PERSONAL INFORMATION WE COLLECT
4. HOW WE USE YOUR INFORMATION
5. HOW WE DISCLOSE YOUR INFORMATION
6. YOUR PRIVACY CHOICES AND RIGHTS
7. SECURITY OF YOUR INFORMATION
8. INTERNATIONAL DATA TRANSFERS
9. RETENTION OF PERSONAL INFORMATION
10. CHILDREN'S INFORMATION
11. THIRD-PARTY WEBSITES/APPLICATIONS
12. CONTACT US
    • CONSUMER PRIVACY NOTICE
    • SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
    • SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

1. SCOPE

This Privacy Policy applies to personal information processed by us, including on our website at https://www.castlepay.us/, the Castle Pay mobile applications available at UPCS_App.com, and other online or offline offerings. Collectively, these are referred to as the "Services."

An Important Note: This Privacy Policy does not apply to any of the personal information that our Merchants may collect, use, process, and disclose using Castle Pay's Services ("Merchant-Owned Data"). Our Merchants' privacy policies govern the collection and use of Merchant-Owned Data. If you are a Customer accessing our Services via a Merchant's service, please carefully review the applicable Merchant's privacy policy. Any questions or requests relating to Merchant-Owned Data should be directed to the Merchant you transact with.

2. CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

3. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law.

A. Information You Provide to Us Directly

• Account Creation:
  • Customers: To create an account, we may collect your name, email address, a valid driver's license or state identification card, checking and savings account information, phone number, birthday, address, last 4 digits of your social security number or other government-issued identification number, security questions and answers, loyalty card number, and a unique PIN.
  • Merchants: To create an account, you must provide your contact name, email address, phone number, title, business and legal entity names/addresses, legal entity's federal tax identification number, corporate contact name and info, the state in which you do business, average monthly revenue and ticket sales, POS provider, cannabis business license details (if applicable), banking details (institution name, contact person name/email, routing number, and account number), and underwriting documentation (driver's licenses, voided checks, bank statements, legal entity documents, bank letters, and other business licenses).
• Purchases: We may collect personal information and details associated with the purchases Customers make using our Services.
• Your Communications with Us: When you request information, register for our newsletter, request customer/technical support, apply for a job, or otherwise communicate with us, we collect information you choose to provide, such as your email, phone number, name, employer, and/or mailing address.
• Share Content with Friends or Colleagues: Our referral services allow Customers to share content or invite friends via email. If you suggest a business to us, we may ask for the name, email address, and phone number of the referred business' representative.
• Surveys: If you participate in voluntary surveys, you may be asked to provide certain personal information.
• Sweepstakes, Contests, or Games of Skill: We collect personal information provided for these activities. In some jurisdictions, we are required to publicly share the information of winners.
• Conferences, Trade Shows, and Other Events: We may collect personal information from individuals when we attend these events.

B. Information Collected Automatically

• Automatic Data Collection: We may collect your IP address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser/device info, general location data (derived from IP), and internet service provider. We also track your usage details, such as pages visited before, during, and after using our Services, links clicked, content interactions, and the frequency/duration of activities.
• Geolocation: If a Customer uses a location-enabled device, we may collect precise geographical location data via sensor data, GPS, Wi-Fi, or cell site triangulation to protect against fraud and enhance Services. Some features may not function properly if location collection is disabled via your device controls.
• Cookies, Pixel Tags/Web Beacons, and Other Technologies:
  • Cookies: Small text files placed in device browsers to store preferences and enhance your experience.
  • Pixel Tags/Web Beacons: Embedded code that collects engagement data (e.g., verifying if a web page was visited or an email was opened/forwarded).
• Analytics Partners: We use third-party tools to process analytics, including:
  • Google Analytics: Review the Google Analytics Privacy Policy to learn about opt-out options.
  • Twitter Analytics: For more info, visit Twitter's help page.
• Social Media Platforms: Our Services include buttons/widgets (like Twitter, Facebook, LinkedIn) that may collect your IP address and pages visited, and set cookies. Interactions are governed by the respective platform's privacy policy.

C. Information We Collect from Others

We may obtain information about you from other sources, including referrals and third-party services/organizations who verify your information and assess your eligibility to use our Services.

4. HOW WE USE YOUR INFORMATION

We use your information for various business purposes:

A. Provide Our Services

• Managing your info and accounts.
• Providing access to specific areas, functionalities, and features.
• Answering customer or technical support requests.
• Communicating about your account, activities, and policy changes.
• Processing financial transactions and payment methods.
• Processing job applications and registering you for events.
• Sending transactional text messages (purchase receipts, verification codes) to Customers (standard rates apply).
• Using precise location data to protect against fraud and offer targeted discounts.

B. Administrative Purposes

• Pursuing legitimate interests (direct marketing, R&D, network/information security, and fraud prevention).
• Detecting security incidents, protecting against malicious/illegal activity, and prosecuting those responsible.
• Measuring engagement, improving/upgrading Services, and developing new products.
• Ensuring internal quality control, safety, and identity verification.
• Debugging errors, auditing transactions, enforcing agreements, and complying with legal obligations.

C. Marketing and Advertising

• Tailoring content, email campaigns, custom audience advertising, and "interest-based" or "personalized advertising" across devices, as permitted by law. Contact us to opt out.

D. Other Purposes

• Consent: For any other purpose clearly disclosed at the time of collection.
• Automated Decision Making: We use algorithms to automatically prevent purchases if fraud is suspected. Processing will not affect legal rights solely based on automated decisions unless necessary for a contract, allowed by law, or backed by explicit consent.
• De-identified & Aggregated Info: Creating non-identifiable demographic or location analyses.

5. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for the following business purposes:

• To Merchants: We share Customer names and Castle Pay-specific identifiers with Merchants to facilitate loyalty programs and advertising.
• Service Providers: We share data with third parties providing IT, hosting, payment processing, and customer service. Customer account details are shared with verification service providers using public records to verify identities.
• Business Partners & Affiliates: To deliver jointly offered products/services or share within our corporate affiliates.
• Advertising Partners: Third-party ad networks may set tracking tools on our Services to collect device/activity data to deliver personalized ads across their networks.
• APIs/SDKs: We use third-party Application Program Interfaces and software development kits for functionality.
• Legal & Protection: We may disclose information if required in good faith by law enforcement, national security requests, subpoenas, court orders, or to protect rights, property, safety, or investigate illegal activity.
• Asset Transfers: In the event of a merger, acquisition, financing, bankruptcy, or sale of corporate assets, customer data may be transferred as permitted by law/contract.

6. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices

• Email & Texts: Unsubscribe from promotional emails using the link at the bottom. You will continue to receive necessary transactional or policy update messages.
• Mobile Devices: Turn off push notifications and precise location tracking within your mobile device settings.
• "Do Not Track": We do not currently respond to or honor browser-transmitted DNT signals.
• Cookies & Ad Opt-Outs: Restrict cookies via browser settings (though some Services may stop working). For mobile apps, follow Android or iOS specific instructions to limit tracking. You can also opt out of targeted ad programs via the Network Advertising Initiative, Digital Advertising Alliance, European Digital Advertising Alliance, and Digital Advertising Alliance of Canada (must be done on each browser/device individually).

Your Privacy Rights

Where provided under applicable law, you may have the right to:

• Access Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the "right of data portability");
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion of your personal information;
• Request Restriction of or Object to our processing of your personal information; and
• Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.

7. Security of Your Information

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

8. International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

9. Retention of Personal Information

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes (such as combating fraud), enforce our agreements, and comply with applicable laws.

10. Children's Information

The Services are not directed to children under 18, and we do not knowingly collect personal information from children, other than with the parent's consent (in the case of a parent creating a sub-account for their minor child). If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child's account as applicable.

11. Third-Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage you to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

12. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

UPCS ("Castle Pay's")
4839 Union Rd. Buffalo, NY 14225
Email: support@UPCS.us
Phone: 888-555-5555

Consumer Privacy Notice

Reasons we can share your personal information

To Limit our sharing

• Call 888-555-5555 – our menu will prompt you through your choice(s)
• Email us at support@CastlePay.us, or
• Mail the form below

Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions? Call 888-555-5555 or email us support@CastlePay.us.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Castle Pay's has collected about them, and whether Castle Pay's disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.

Information Collected. The categories of personal information collected by Castle Pay's in the preceding 12 months is described in Section 2 of the Privacy Notice above..

Information Disclosed. The categories of personal information shared by Castle Pay's in the preceding 12 months are described below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in Section 2 of the Privacy Notice above.

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, Castle Pay's does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in Section 12 of the Privacy Notice above, and provide written confirmation via a scanned document containing your signature and the name of your authorized agent.

Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to verify information you have given us to set up your account, or to provide details regarding recent transactions.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in Section 12 of the Privacy Notice above. We will process such requests in accordance with applicable laws.

Financial Incentives.

• Personalized discounts. We may offer personalized discounts and financial incentives to Customers based on information we retain regarding Customers’ individual spending habits. Customers may opt out of receiving these personalized discounts at any time by adjusting their account settings. These programs allow us to deliver additional value to Customers and generate additional profit from our arrangements with the Merchants who provide the discounts. The value of each Customer’s data varies depending on the Merchant providing the promotion and the details of each promotion, and said value will be reflected in the discount offered to each Customer.
• Refer-a-friend programs. As described above in Information You Provide to Us Directly (“Share Content with Friends or Colleagues”), we may offer incentives to you such as discounts or promotional credit in connection with programs that we may run, wherein you provide personal information regarding their friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These referral programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of the referred party’s data to us depends on whether the referred party ultimately becomes a Customer or Merchant and uses our Services. Said value will be reflected in the incentive offered for each referral. Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at Support@UPCS.us with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.