Privacy Policy – Clink Pay, Inc.
LAST UPDATE: February 27, 2025
Clink Pay, Inc. (“Clink Pay”) operates Clink, a mobile-based platform (together with all related domains and sub-domains, the “Platform”). We are committed to protecting your privacy and ensuring transparency in how we handle your personal information. The following privacy policy (“Privacy Policy”) explains how we collect, use, share, and protect the data you provide as part of our partnership with Cybrid, a federally registered money services business. Cybrid offers financial services to its customers and has engaged Clink Pay to solicit potential customers for these services. As a partner promoting Cybrid’s services, we comply with all applicable laws and regulations to safeguard your information and build trust. Please read this Privacy Policy to understand your rights and how we work to protect your privacy. This Privacy Policy applies to Clink Pay’s mobile application, website, products, and services on or in which it is posted, linked, or referenced.
By using the Services, you accept the terms of this Privacy Policy and our Terms of Service (the “Terms of Service”) and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. If you have not done so already, please also review our Terms of Service. Capitalized terms undefined herein shall have the meanings ascribed to them in the Terms of Service. The Terms of Service contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.
Clink Pay, Inc.
12505 78th Ln NE
Kirkland, WA 98034
privacy@clinkpay.net
Clink Pay collects non-personally identifying information that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Clink Pay’s primary purpose in collecting non-personally identifying information is to better understand how its visitors use its Platform and enhance its functionality. Clink Pay also collects potentially personally identifying information for logged-in users. Clink Pay only discloses logged-in user information under the same circumstances that it uses and discloses personally identifying information as described below. Clink Pay may collect and use Internet Protocol (“IP”) addresses solely to block malicious activities, such as Denial of Service or Distributed Denial of Service attacks, to protect the security and integrity of our systems.
This Platform may collect various types of personal data, either directly or through third parties, including:
Personal data may be provided voluntarily by the user or, in the case of usage data, collected automatically when using this Platform. Unless specified otherwise, all data is mandatory, and failure to provide this data may prevent the Platform from delivering its services. If this Platform specifically states that specific data is optional, users may choose not to provide it without affecting the service availability or functionality. If you are unsure which data is mandatory, please contact us at privacy@clickpay.net.
We may automatically record certain information about how you use our Platform (we refer to this information as “Log Data“). Log Data may include information such as a user’s IP address, device and browser type, operating system, the pages or features of our Platform to which a user browsed and the time spent on those pages or features, the frequency with which a user uses the Platform, search terms, the links on our Platform that a user clicked on or used, and other statistics. We use this information to administer the Service and analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
Although not currently in use, we may use technologies to analyze trends, administer the Platform, track users’ movements around the website, and gather demographic information about our user base as a whole.
All users are responsible for ensuring that any third-party personal data they provide, publish, or share through this Platform is obtained and shared in compliance with applicable privacy laws.
Information we will never collect. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction. The data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In some cases, the data may be accessible to certain types of persons in charge or involved with the operation of this Platform (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed as data processors by Clink Pay. The list of these parties may be requested from Clink Pay at privacy@clinkpay.net.
The data is processed at Clink Pay’s operating offices and other places where the parties are located. Depending on the user’s location, data transfers may involve transferring their data to a country other than their own. To find out more about where such transferred data is processed, users can check the section containing details about the processing of personal data.
Unless specified otherwise in this document, personal data shall be processed and stored for as long as required by the purpose for which it was collected. It may be retained longer due to applicable legal obligations or based on the user’s consent.
In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service. The data collected about the user is also used to enable us to provide the requested service, comply with legal obligations, respond to enforcement requests, protect our rights and interests (or those of its users or third parties), protect, investigate, detect and deter against any malicious, fraudulent, unauthorized, or illegal activity, as well as those of users or third parties, and detect and prevent malicious or fraudulent activity. Additionally, the data is used for purposes such as user database management, access to third-party accounts, displaying content from external platforms, hosting and backend infrastructure, managing contacts and sending messages, contacting users, registration and authentication, traffic optimization and distribution to send information, including (without limitation) confirmations, technical notices, updates, security alerts, support and administrative messages. We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us.
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Platform, you instruct us to take a specific action with respect to your personal information, or you opt into third-party marketing communications.
The user may refer to the “Detailed Information on the Processing of Personal Data” section for specific information about the personal data used for each purpose.
Personal data is collected for the following purposes and using the following services:
User Database Management
These services allow the owner to create user profiles using information the user provides (e.g., email address, name). Personal data may be matched with publicly available information to build profiles to improve the application. Some services also enable automated messages, such as emails triggered by user actions.
Personal data processed: email addresses, usage data, and various data types specified in the service’s privacy policy.
Place of processing: United States.
Access to Third-Party Accounts
These services allow this application to access data from a user’s account on third-party platforms and perform actions. Activation requires explicit user authorization and is not automatic.
Personal data processed: various types of data are processed as specified in the service’s privacy policy.
Place of processing: United States.
Displaying Content from External Platforms
These services allow content hosted on external platforms to be viewed and interacted with directly from this application. Even if users do not engage with the content, these services may collect web traffic data for the pages where they are installed.
Hosting and Backend Infrastructure
These services host data and files required for this application to operate, distribute, and support specific features or functionalities. Some use geographically distributed servers, which may make it challenging to determine the exact location of stored personal data.
Personal data processed: usage data; various data types as specified in the service’s privacy policy.
Place of processing: United States.
Managing Contacts and Sending Messages
This type of service allows you to manage a database of email contacts, phone contacts, or any other contact information to communicate with the user.
These services may also collect data concerning the date and time when the user viewed the message and when the user interacted with it, such as by clicking on links included in the message.
Personal data processed: email address.
Place of processing: United States.
Contacting the User
Mailing List or Newsletter (This Application)
By registering on the mailing list or for the newsletter, the user’s email address will be added to the contact list of those who may receive email messages containing information of a commercial or promotional nature concerning this Platform. Your email address might also be added to this list when you sign up for this Website or after making a purchase.
Personal data processed: email address; first name.
Registration and Authentication
By registering or authenticating, users allow this Platform to identify them and give them access to dedicated services. Third parties may provide registration and authentication services depending on what is described below. In this case, this Platform can access some data stored by these third-party services for registration or identification purposes.
Personal data processed: email address, first name, and last name.
Traffic Optimization and Distribution
These services enable this application to distribute content via servers in multiple locations, optimizing performance. The personal data processed depends on the service’s implementation and functionality, typically filtering communications between the application and the user’s browser. While the services are hosted in the United States, the distribution of content may involve the transfer of personal information across various servers, which could make it difficult to pinpoint the exact locations where content containing user data is transmitted.
Personal data processed: various data types specified in the service’s privacy policy.
Place of processing: United States.
We do not share or sell the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. Our app uses Plaid to securely connect your bank account and Persona to verify your identity. During this process, your photo is directly passed to Persona for verification. By using these services, you agree to allow us to share your data with Persona and Plaid in accordance with their respective privacy policies. You can review Persona’s Privacy Policy and Plaid’s Privacy Policy. Additionally, we may share certain data with Cybrid to facilitate the KYC process, and you can review Cybrid’s Privacy Policy.
We disclose personal information to third parties under the following circumstances:
Affiliates. We may disclose your personal information to subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.
Third Parties. We may share your information with a third party if you specifically authorize it or if it is required in order to complete a transaction, service, or activity that you initiated or requested. Note: In such cases, the collection and processing of your personal information may be subject to the privacy policy of such third parties.
Business Transfers. We may share personal information when we enter into or negotiate a business deal involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Compliance with Laws and Law Enforcement; Protection and Safety. We may share personal information for legal, protection, and safety purposes.
Professional Advisors and Service Providers. We may share information with those who need it to do work for us. These recipients may include third-party companies and individuals to administer and provide the Service on our behalf (such as customer support, hosting, data analytics, marketing, email delivery, and database management services), as well as lawyers, bankers, auditors, insurers and any contractors, service providers or other this parties we use to support the provision of the Services. For operation and maintenance purposes, this Platform and any third-party services may collect files that record interaction with this application (system logs) or use other personal data (such as the IP Address).
Other. We may share your information for any other purpose disclosed by us when you provide the information. You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities.
Some employees, contractors, and affiliated organizations may be outside your home country. By using Clink Pay’s Platform, you consent to the transfer of such information to these parties. Outside of the parties mentioned above, Clink Pay discloses potentially PII only when required to do so by law or when Clink Pay believes in good faith that disclosure is reasonably necessary to protect its property or rights, the rights of third parties, or the public at large, as well as to prevent fraud, or comply with legal proceedings, if you are a registered user of Clink Pay’s Platform and have supplied your email address, Clink Pay may occasionally send you emails about new features, request feedback, or provide updates about Clink Pay and its services. If you submit a request to Clink Pay, the company reserves the right to publish the request to clarify or respond to it and support other users.
Although not currently in use, we may also share aggregated and/or anonymized data with third parties for their own purposes in the future.
Legal action. Your data may be used for legal purposes by Clink Pay in court or the stages leading to possible legal action arising from improper use of the Platform or the related services.
By using the Platform, you declare that you are aware that Clink Pay may be required to reveal personal data upon request of public authorities.
Information Not Contained in This Policy
More details concerning the collection or processing of personal data may be requested at any time. Please see the contact information at the end of this privacy policy.
Unless stated otherwise in this Privacy Policy, personal data is processed and stored for as long as necessary to fulfill the purpose for which it was collected. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Contractual Purposes: personal data collected to fulfill a contract between the owner and the user will be retained until the contract has been entirely performed.
Legitimate Interests: data collected for the owner’s legitimate interests will be retained as long as necessary to achieve those purposes. Specific details about these interests can be found in relevant sections of this document or by contacting the owner.
Sometimes, personal data may be retained longer if the user consents, provided the consent is not withdrawn. Additionally, the owner may be required to keep personal data for an extended period to comply with legal obligations or by order of an authority.
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you. We employ industry-standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID, or other form of authentication involved in obtaining access to password-protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services without notice, pending an investigation, if any security breach is suspected.
As a Clink Pay user, you may access information that you have voluntarily provided through your account on the Services and to review, correct, or, in some instances, request the deletion of your data, subject to legal requirements. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.
You can opt out of marketing communications or certain tracking technologies by following instructions or adjusting your device settings. Where applicable, you may request your data in a portable format or ask us to restrict how your data is processed. To exercise these rights or for further assistance, please contact us at privacy@clinkpay.net.
You can opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account.
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described below. If you have questions about the legal bases under which we process your personal information, or if you would like to exercise your rights, contact us at privacy@clickpay.net.
We use the information we collect about you to pursue the following purposes, which are necessary for the performance of the contract between us to provide you with the products or services you requested or which we consider in our legitimate interests:
Based on your voluntary consent, we may use your personal information (which may be combined with third-party data) to send you personalized emails and push notifications tailored to you and your interests.
In order to comply with our legal obligations, we may also use some of your personal information to perform KYC checks, detect and prevent illegal uses, abuse, spam, fraud, security incidents and other harmful activity or government or court orders.
If you have any questions about the Privacy Policy, please email us at privacy@clinkpay.net.
