Privacy Policy

Zenobia Pay Privacy Policy

Last updated: May 1, 2025

1. Who We Are

Zenobia Pay, Inc. ("Company," "we," "us," and/or "our") is a technology service provider for retailers and customers that enables bank transfer payments to reduce fraud chargebacks and fees.

2. What is Covered by this Privacy Policy?

This Privacy Policy describes how Zenobia Pay collects, uses, shares and retains Personal Information. "Personal Information" means any information relating to an identified or identifiable individual that is protected as personal data or personally identifiable information under any applicable data protection laws.

This Privacy Policy applies to our online and offline information gathering and dissemination practices in connection with our website and services, including Personal Information we may receive through our website, software platforms, applications, communications with representatives, third-party tools integrated into our platform, tracking technologies, and information shared during partnerships or events. This Privacy Policy describes the Company's policies and practices regarding its use of your personal data and sets forth your privacy rights.

By accessing or using any of our services, you acknowledge and agree that your Personal Information will be handled as described in this Privacy Policy. Your use of the services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Use, including their applicable limitations of liability and the resolution of disputes. The Zenobia Pay Terms of Use are incorporated by reference into this Privacy Policy.

As a service provider to retailers and customers, we process various forms of data. We do not use this data for any purposes other than those for which it has been provided, and we do not sell this data to third parties.

3. Who is Covered by this Privacy Policy?

This Privacy Policy applies to you if you have arrived by clicking on an authorized link directing you to a site operated by Zenobia Pay. This Privacy Policy does not apply to any website owned or operated by or on behalf of any third party, even if we provide a link to such website.

We do not knowingly attempt to solicit or receive information from minors. Use of our services is strictly limited to persons who are of legal age in the jurisdictions in which they reside. You must be at least eighteen (18) years of age to use our services.

Users have the following rights regarding their Personal Information:

  • access to details of the data we hold
  • corrections to inaccurate or incomplete information
  • deletion of their data where permitted by law
  • limitations on how their data is processed
  • portability of their data in a machine-readable format
  • objection to processing for direct marketing or legitimate interest purposes
  • withdrawal of consent at any time

Users may also file complaints with the relevant data protection authority.

4. Updates to Privacy Policy

We recognize that information privacy is an ongoing responsibility, and we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies. Updates become effective immediately upon posting unless otherwise stated. By your continued use of the services, you consent to the terms of the most recently revised and posted policy.

5. Personal Information We Collect

The following describes the categories of Personal Information we may collect, the sources from which we may collect it, and the business purposes for which we may collect it:

5.1 Information You Provide Directly

If you voluntarily choose to submit or disclose Personal Information to us, that information is governed by this Privacy Policy. The Personal Information we may collect directly from you includes:

  • Name, email address, and phone number
  • Billing information and payment details
  • Business information (business name, EIN, etc.)
  • Account credentials
  • Any other information you choose to provide

5.2 Usage Information

We automatically collect information about your use of our services, such as:

  • IP address and device identifiers
  • Browser type and settings
  • Date and time of access
  • Referring website
  • System activity and usage patterns

5.3 Bank Account Information

When you link your bank account through Plaid Link, we may collect and process the following information:

  • Account numbers and routing numbers
  • Account balances
  • Transaction history
  • Account owner information
  • Financial institution name
  • Account type (checking, savings, etc.)

This information is collected and processed solely for the purpose of facilitating your payments and improving our fraud prevention measures. We use Plaid as a third party service provider to collect this information securely. For more information about how Plaid collects and processes your data, please refer to Plaid's Privacy Policy.

6. How We Use Your Information

At Zenobia Pay, we use the information we collect for the following purposes:

  • Provide Services: Operate, provide, service, process, and maintain our products and services
  • Enhancing Our Platform: To refine and improve our existing services, making them more efficient, reliable, and user-friendly for both merchants and consumers
  • Safeguarding Transactions: To verify identities, detect suspicious patterns, and protect all parties in the payment ecosystem from fraud, unauthorized access, and other security risks
  • Develop New Services: Create new products and services based on user needs and feedback
  • Optimizing User Experience: To analyze transaction data, account connections, and usage patterns to streamline the payment process, reduce friction, expedite fund transfers, and personalize services
  • Delivering Technical Support: To assist merchants, integration partners, and end-users with questions or issues related to our payment platform and connected services
  • Maintaining Service Communications: To provide important updates about our platform, security notifications, and essential service information
  • Investigate Misuse: Investigate any misuse of our services or connected applications, including violations of our policies, criminal activity, or unauthorized access to our services
  • Legal Compliance: Comply with contractual and legal obligations under applicable law and for other legal purposes such as establishing and defending against claims
  • With Your Consent: Process information for other notified purposes with your consent or at your direction

We may also collect, use, and share data that has been aggregated or anonymized in a manner that does not identify you personally for any purpose permitted under applicable law. This includes creating or using aggregated or anonymized data to develop new products or services, to facilitate research, and for analytics purposes to help assess the speed, accuracy, and/or security of our services.

7. Sharing of Information

We may share your information with:

  • Third Party Service providers who perform services on our behalf
  • Financial institutions necessary to process transactions
  • Business partners with your consent
  • Legal authorities when required by law

8. No Sale of Personal Information

We do not sell, trade, or otherwise transfer to third parties for their own use any of your Personal Information. We also do not disclose to third parties any Personal Information about your use of our services.

The term "third parties" does not include our affiliates, website hosting partners, and other third party service providers who assist us in operating our site, conducting our business, or providing services to you, so long as those parties agree to keep this information confidential and not use or further disclose it for their own purposes.

9. Our Use of Cookies and Related Technologies

Cookies/Local Device Storage

Our services will at times place and/or store code or other types of information and/or software on your device or within your browser, such as cookies, locally shared objects, and HTML5 (collectively, "Local Device Storage"). We and third party service providers may independently or in conjunction use Local Device Storage in connection with the services in a way that collects personal information for the purposes described in our respective privacy policies, including without limitation to determine whether you have seen a particular advertisement before on the same or different device and to otherwise control and tailor the display of ads to you based on your perceived preferences, as well as to otherwise administer the services. For example, if you register on any part of the services and are given the option to save your username and password, we may provide this convenience to you via Local Device Storage.

You May Disable Local Device Storage

If you do not want Local Device Storage, your device, browser, or the settings menu within an application may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the services may not function properly.

Tracking Technologies

In addition to Local Device Storage, we and/or our third party service providers may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka "Machine Identification") and similar technologies (collectively, together with Local Device Storage, the "Tracking Technologies") on the services, including in our communications with you, such as within e-mail and text messages, in-application push notifications, videos, and throughout your use of the services. We and our third party service providers may use Tracking Technologies to determine which messages have been opened by recipients, and for all or some of the same lawful purposes described above for use of Local Device Storage.

Do Not Track (DNT)

Your browser setting may allow you to automatically transmit a "Do Not Track" (DNT) signal to websites and online services that you visit. There is no consensus as to what DNT means in this context. As a result, like many websites, we do not alter our practices when the services receive a DNT signal from a visitor's browser. To find out more about DNT, please visit http://allaboutdnt.com.

Global Privacy Control (GPC) and similar privacy preference signals

Where required by applicable local law, we honor user-initiated browser based opt-out preference signals recognized under applicable local law, such as the Global Privacy Control (GPC). To find out more about GPC, please visit https://globalprivacycontrol.org/.

10. Data Security

We implement reasonable security measures to protect your personal information. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

11. Your Rights; Submitting Requests Under Applicable Local Laws

Depending on the jurisdiction in which you live, including if you are a consumer in California, Colorado, Connecticut, or Virginia, you may have the following rights under applicable local law:

  • request information about our processing of your Personal Information (right to know)
  • request a copy of your Personal Information (right to access)
  • rectify, correct, or update the Personal Information we hold about you (collectively right to correct)
  • request deletion of your Personal Information
  • opt-out of "sales" of Personal Information or "sharing" of Personal Information for cross-contextual behavioral advertising purposes (as these terms are defined under applicable law)
  • opt-out of targeted advertising
  • restrict or limit our use of your Personal Information (right to restrict)
  • object to our use of your Personal Information
  • where you have provided consent, withdraw such consent to our processing of your Personal Information at any time
  • ask that we transfer the Personal Information we maintain about you to another organization, or to you, in certain circumstances (right to portability)
  • not be unlawfully discriminated against for exercising your rights
  • lodge a complaint with your local data protection authority

These rights may be limited or denied in some circumstances. For example, we may retain your Personal Information where required or permitted by applicable law.

To exercise your rights under applicable local law or if you are an authorized agent or parent or guardian seeking to exercise rights on behalf of a minor in accordance with applicable local law (specifically, including California, Colorado, Connecticut, and Virginia) please contact us at privacy@zenobiapay.com.

We reserve the right to take reasonable steps to verify your identify before fulfilling your requests to know, correct, or delete. For example, we may seek to establish your identity to a reasonable or a reasonably high degree of certainty by matching information that you submit alongside your request with information that we have in our records. We may ask you or your authorized agent for supplemental information as needed to establish your identity. Authorized agents may also be required to provide a copy of the consumer's signed permission authorizing the agent to submit requests on the consumer's behalf under applicable local law.

You may have a right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please contact us by email at privacy@zenobiapay.com.

12. Opt-Out of Marketing Communications

If you do not wish to receive future marketing or other commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. Note, however, that you may continue to receive certain communications from us that are necessary for the services, such as renewal notifications, invoices, technical notices, updates, security alerts, and support and administrative service bulletins.

13. Children's Privacy

Our services are not intended for children under 18. We do not knowingly collect personal information from children under 18.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

15. Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@zenobiapay.com.