Easy Labs Inc. Privacy Policy

Last Updated: January 6, 2025

Easy Labs Inc. ("Easy," "we," "us," or "Company") is a technology services provider offering programmable, non-custodial software and infrastructure solutions to help businesses streamline their payments and simplify their financial infrastructure. This document explains how we collect, use, disclose, and safeguard your personal information when you use our software, services, and other offerings (collectively, the "Services" or "Platform"). It also describes certain rights and choices you may have regarding your information.

If you do not agree with any part of this Privacy Policy, do not access or use our Services. By continuing to interact with our Platform, you agree to the practices described herein.

1. Introduction and Scope

Applicability. This Privacy Policy applies to personal information that Easy collects or receives when you register for an Easy account ("Easy Account"), use our Services, or otherwise engage with us.

Separation from Terms. This Privacy Policy is not a combined agreement with our Terms of Service. Please review our Terms of Service separately for obligations governing your use of the Platform's functionalities.

2. Information We Collect

We collect different types of information to provide and improve the Services, including:

Personal Information You Provide

  • Account Registration: Information such as your name, email address, phone number, mailing address, and business details.
  • KYC/KYB Verification: Documents and data for anti-money laundering ("AML") and counter-terrorism financing ("CTF") compliance, which may include government-issued IDs, proof of address, etc.
  • Customer Support: Details you provide when contacting our support channels (e.g., email inquiries).

Payment and Transaction Data

  • Payment Details: When you process transactions, we may collect or receive payment card/bank details—tokenized by our secure third-party providers (e.g., Basis Theory, Finix).
  • Transaction Records: Data about the payments you initiate or receive (e.g., amounts, dates, currencies, statuses).

Automatic Data Collection

  • Log Data: IP address, browser type, device identifiers, pages viewed, referral URLs, etc.
  • Cookies & Tracking: We may use cookies or similar technologies to remember your preferences and gather usage statistics.

Information from Third Parties

Affiliates & Service Providers: We may receive additional info (e.g., from credit bureaus, compliance vendors) for identity verification or fraud detection.

3. How We Use Your Information

We use the personal information we collect for the following general purposes:

Service Provision

  • Account Creation & Management: To register and maintain your Easy Account.
  • Transaction Processing: To process payments, schedule automated transactions, or facilitate digital asset management.

Compliance & Security

  • Regulatory Requirements: To satisfy legal obligations (e.g., AML, CTF, sanctions).
  • Fraud & Risk Mitigation: To detect, investigate, and prevent fraud, suspicious activity, or policy violations.
  • PCI DSS & Data Protection: Where applicable, we adhere to relevant data security standards.

Service Improvements & Analytics

  • Performance Monitoring: To analyze usage trends and improve our features, workflows, and user experience.
  • Aggregated Insights: We may produce anonymized analytics that do not identify you personally, to guide product development.

Communications

  • Support: To address your inquiries and provide troubleshooting.
  • Service Notifications: To inform you of material changes, updates, security alerts, or regulatory compliance requests.

Optional Marketing

Promotions: With your consent or as allowed by law, we may send marketing communications, which you can opt out of at any time.

4. Disclosure of Your Information

We may share or disclose your personal information under these circumstances:

Affiliates and Service Providers

  • Third-Party Processors: We partner with entities such as Finix (payment processing), Basis Theory (tokenization), Brale (stablecoin/cashback solutions), DFNS (wallet infrastructure), etc. They process your data strictly per our instructions and in accordance with this Policy.
  • Corporate Affiliates: We may share data with parent companies or subsidiaries to support Platform functions.

Legal or Compliance Requirements

  • Regulatory Obligations: We may disclose data to comply with laws, regulations, or enforceable requests from government authorities.
  • Fraud & Security: We may share data to address suspected fraud or security threats.

Business Transfers

Merger or Acquisition: In the event of a sale, merger, or reorganization, your data may be transferred to the succeeding entity.

Consent

We may share data in any other ways you expressly agree to.

5. Data Security

Technical Measures

We implement administrative, technical, and physical safeguards (e.g., encryption, tokenization, firewalls) to protect your information from unauthorized access.

Sensitive data (e.g., card details) is primarily handled by third-party processors with their own certified security protocols.

User Responsibilities

You are responsible for maintaining the confidentiality of any credentials or keys used to access the Platform.

We are not liable for losses resulting from compromised credentials due to negligence or failure to follow recommended security practices.

6. Data Retention

Retention Duration

We retain personal information only as long as necessary for the purposes described in this Policy or as required by law (e.g., AML obligations).

Disposition

When no longer needed, we securely delete or anonymize your data in accordance with industry standards and legal requirements.

7. International Data Transfers

Because Easy is available to users in the United States and Canada, your personal information may be transferred to or processed in countries outside your own. By using our Services, you acknowledge and consent to such cross-border data transfers under applicable laws.

8. Your Rights and Choices

Depending on your jurisdiction, you may have rights such as:

  • Access/Rectification: Request a copy of your personal data or ask us to correct inaccuracies.
  • Deletion: Seek deletion of certain data, subject to legal or contractual restrictions.
  • Objection/Restriction: In certain scenarios, object to our processing activities or request limits on them.
  • Withdrawal of Consent: If processing is based on consent, withdraw your consent at any time.

To exercise any of these rights, contact us at [email protected]. We may verify your identity before completing certain requests.

9. California Privacy Rights

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

  • Right to Know: You can request that we disclose what personal information we collect, use, or disclose about you.
  • Right to Delete: You may ask us to delete your personal information, subject to exceptions (e.g., legal requirements).
  • Right to Correct: You can request correction of inaccurate personal information we maintain about you.
  • No Retaliation: We will not discriminate against you for exercising any CCPA/CPRA rights (e.g., denying services, varying pricing).

To exercise these rights, please email us at [email protected] with "California Privacy Request" in the subject line. We may ask you to verify your identity. If you use an authorized agent, we may require proof of that relationship. We will respond to valid requests in accordance with California law.

10. Government and Law Enforcement Requests

We may disclose your personal information to government authorities or law enforcement if required by applicable law, subpoena, or other valid legal process. Where permitted, we may attempt to notify you if your data is subject to such a request. Additionally, we reserve the right to disclose information in good faith if necessary to:

  • Protect Our Rights: Prevent or address fraud, policy violations, or illegal activity.
  • Ensure Safety: Protect the rights, property, or safety of Easy, our users, or the public.

11. Children's Privacy

We do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected such information, contact us at [email protected], and we will promptly delete it.

12. Updates to this Privacy Policy

We may revise this Privacy Policy from time to time. The "Last Updated" date at the top indicates the latest revision. If we make material changes, we will provide notice (e.g., via email or on our website). Your continued use of our Services after any changes are posted constitutes your acceptance of those changes.

13. Contact Us

If you have questions about this Privacy Policy or wish to submit a request about your personal data, please contact us at:

Email: [email protected]

Business Correspondence:

Easy Labs Inc.
9 East Loockerman St,
Suite 311, Dover, DE, 19901
United States

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