Privacy Policy

Effective Date: January 1, 2026 Last Updated: January 1, 2026

1. Introduction

Qupe, Inc. ("Qupe," "we," "our," or "us") is committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and protect data when you use our website, mobile application, and financial services (collectively, the "Services").

By using our Services, you agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the Services.

2. Information We Collect

2.1 Information You Provide
  • Account information: Full name, email address, phone number, date of birth, and government-issued ID details collected during registration and identity verification.

  • Financial information: Bank account details, card numbers, transaction history, and payment data provided when you use our Services.

  • Communications: Messages, support requests, and feedback you send to us.

2.2 Information We Collect Automatically
  • Usage data: Pages visited, features used, time spent on the Services, and referring URLs.

  • Device data: IP address, browser type, operating system, and device identifiers.

  • Transaction data: Details of every transaction processed through your Qupe account, including amounts, dates, merchant information, and location data where applicable.

  • Cookies and tracking: We use cookies and similar technologies to maintain sessions, remember preferences, and analyze usage. See Section 7 for more detail.

2.3 Information from Third Parties

We may receive information about you from identity verification partners, credit reference agencies, financial institutions, and fraud prevention services as permitted by applicable law.

3. How We Use Your Information

We use the information we collect to:

  • Provide and operate the Services, including processing transactions and managing your account

  • Verify your identity and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements

  • Communicate with you about your account, transactions, and Service updates

  • Personalize your experience, including tailoring product recommendations and spending insights

  • Detect and prevent fraud, unauthorized access, and other harmful activity

  • Comply with legal obligations, including regulatory reporting and tax requirements

  • Improve the Services through analytics, research, and product development

  • Send marketing communications where you have provided consent (you may opt out at any time)

4. Legal Basis for Processing (EU/UK Users)

If you are located in the European Economic Area or the United Kingdom, we process your personal data under the following legal bases:

  • Contract performance: To provide the Services you have requested

  • Legal obligation: To comply with financial regulations and reporting requirements

  • Legitimate interests: To detect fraud, improve our Services, and conduct analytics

  • Consent: For marketing communications and non-essential cookies

5. How We Share Your Information

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

  • Service providers: Third parties who assist us in operating the Services (e.g., cloud hosting, identity verification, payment processing), who are contractually bound to protect your data

  • Financial partners: Banks, payment networks, and other financial institutions necessary to process your transactions

  • Regulatory authorities: Government agencies, law enforcement, and regulators when required by law or to protect legal rights

  • Business transfers: In connection with a merger, acquisition, or sale of assets, in which case we will notify you before your data is transferred

  • With your consent: Any other third party where you have explicitly authorized the disclosure

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Services. We are also required to retain certain financial records for a minimum of five (5) to seven (7) years under applicable financial regulations.

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

7. Cookies and Tracking

We use the following categories of cookies:

Category

Purpose

Can be disabled?

Strictly necessary

Authentication, security, session management

No

Functional

Preferences, language settings

Yes

Analytics

Usage analysis and product improvement

Yes

Marketing

Targeted advertising (where consented)

Yes

You can manage your cookie preferences at any time through your browser settings or our cookie preference center.

8. Data Security

We implement industry-standard security measures to protect your personal information, including:

  • 256-bit TLS encryption for all data in transit

  • AES-256 encryption for data at rest

  • Multi-factor authentication for account access

  • Regular security audits and penetration testing

  • Access controls limiting data access to authorized personnel only

No method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

  • Access: Request a copy of the personal data we hold about you

  • Correction: Request that inaccurate or incomplete data be corrected

  • Deletion: Request deletion of your personal data, subject to legal retention requirements

  • Portability: Receive your data in a structured, machine-readable format

  • Restriction: Request that we restrict processing of your data in certain circumstances

  • Objection: Object to processing based on legitimate interests or for direct marketing

  • Withdraw consent: Where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact us at hello@qupe.com. We will respond within 30 days.

10. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that a minor has provided us with personal data, we will promptly delete it.

11. International Data Transfers

If you are located outside the United States, your information may be transferred to and processed in the United States or other countries where our service providers operate. We ensure that all such transfers are governed by appropriate safeguards, including Standard Contractual Clauses approved by the European Commission where applicable.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by posting a prominent notice in the Services. The updated Policy will be effective as of the date indicated at the top of this page.

13. Contact

If you have questions or concerns about this Privacy Policy or our data practices, please contact our Data Protection Officer:

Qupe, Inc. Attn: Privacy Team 350 Fifth Avenue, New York, NY 10118 Email: hello@qupe.com Phone: +1 (415) 555-0192

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