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Privacy Policy

Last Updated on December 31, 2022

This Privacy Policy (this “Privacy Policy”) describes how Kickfin, Inc. (“Kickfin,” “we,” “us,” or “our”) handles personal information when you access or use our websites, including, any applications we provide, any communications between you and us, or any other products and services provided or otherwise made available by or through Kickfin (collectively, the “Services”).

This Privacy Policy is primarily directed at users of the Services, including:

  • Any merchant or any representative of any merchant that accesses or uses Kickfin’s platform or the Services for any purpose, including for disbursing tips or other payments to employees or independent contractors of merchants, or otherwise expresses interest in using the Services;
  • Any employee or independent contractor of a merchant who accesses or uses the Services or otherwise expresses interest in using the Services;
  • Any customer of a merchant who accesses or uses the Services to make tips or other payments to an employee or an independent contractor of the merchant; and
  • Any other individual who visits our websites or any applications we provide, interacts with our emails or other communications, or accesses or uses the Services.

By agreeing to or accepting the applicable agreement or terms of use or otherwise accessing or using the Services, you are confirming that you have carefully read this Privacy Policy, that you understand the terms of this Privacy Policy, and that you accept and consent to the terms of this Privacy Policy.

  1. Information We Collect and How We Collect It

When you access or use the Services, we may collect the following types of information about you:

  • Customer payments: Customers that use the Services to pay tips or other payments to an employee or independent contractor of a merchant provide their name, contact information, and payment card information (as further described below).
  • Registration and account information: The Services may provide you with the opportunity to, or may require you to, create a Kickfin account. When you create a Kickfin account, we collect your name and contact information, the login credentials you will use to access the Services, and any account settings and preferences you provide to us.
  • Information provided by employers: To enable employees or independent contractors to register for the Services and receive disbursements, and otherwise in connection with their use of the Services, employers provide us with information about their employees and independent contractors, including names, contact information, employment status and details, place of employment, hours of employment, entitlement to disbursements, disbursement information, and any other information provided by employers in connection with use of the Services.
  • Payment card information: The Services enable you to provide payment card information to facilitate transactions. For example, a customer of a merchant can provide payment card information to make a tip or other payment to an employee or independent contractor of the merchant. If you are an employee or independent contractor of a merchant that accesses or uses the Services to receive disbursements from your employer on a payment card you own, then the Services enable you to provide your payment card information. Please note that we do not collect or retain your payment card information; it is directly collected and held by our third-party services providers and business partners.
  • Transaction history: If you use the Services to initiate or receive transactions, then we store records of such transactions. For example, if you make a tip or other payment to an employee or independent contractor of a merchant through the Services, then we retain a record of such tip or other payment. Similarly, if your employer uses the Services to initiate disbursements or you work for a merchant that sends you disbursements via the Services, then we retain records of such disbursements. You can access your transaction history in your Kickfin account.
  • Information collected automatically: When you use the Services, Kickfin automatically collects information about your device and web browser, such as your IP address, and may collect information about how you use the Services. Please note that Kickfin may monitor how you use the Services, and use this information, as well as share it with third parties, for any purpose described in this Privacy Policy. For further details, see Section 6 below.
  • Information collected by cookies: Our website may use cookies, pixels, or similar technologies. When you use our website, these technologies may collect information about your device, browser, and activity on our website.
  • Communications with you: We may retain records of any communications between Kickfin and you. Similarly, we may conduct surveys or customer or user inquiries in which you may elect to participate. 
  • Information required for compliance: We may collect additional information about you as part of conducting activities that may be required by law, such as screenings, identity verification, or other checks, or as otherwise required under our policies or the policies of our third-party service providers or business partners or as a matter of sound business practices. We may collect this information directly from you or from third-party service providers.

We may collect the above-described information directly from you, from your device, from our third-party service providers and vendors, from other third-party businesses, and from publicly-available sources.

  1. How We Use Information We Collect

We may use the information described above to:

  • Provide the Services to you and/or your business, or determine your eligibility to use the Services;
  • Determine the terms under which we are willing to contract with you or perform the Services for you, and perform, administer, and otherwise process information in relation to any contract we have with you;
  • Operate, evaluate, and improve our business (including analyzing and improving the Services, developing new services, customizing your experience, learning about our users, performing data analyses and planning, and facilitating the functionality of the Services);
  • Perform any screenings, identity verification, fraud prevention checks, or other procedures that we believe are required by law, our policies, our agreements with third-party service providers or business partners, or sound business practices;
  • Coordinate the Services with undertakings by your employer to us or to you or third parties;
  • Communicate with you via any lawful channel, including email, SMS, telephone, chat, or other methods of communication, deliver information to you, provide customer support, or receive, process, and respond to any inquiries or requests;
  • Market to you regarding products or services that may be of interest to you;
  • Help promote the safety of the Services, troubleshoot issues, and detect and prevent errors, fraudulent activity, financial loss, or other potentially wrongful, harmful, or illegal activity;
  • Enforce this Privacy Policy or the agreement or terms of use that govern your access to and use of the Services;
  • Comply with, make claims relating to, or enforce legal obligations, legal process, our policies, or prudent security or business practices; or
  • As otherwise permitted, authorized, or required by applicable law.

We also may use information we collect for any other purpose notified to you or to which you consent, or to perform any actions requested by you.   

  1. Sharing of Information We Collect

We may share information with third parties for any purpose described in Section 2 above (“How We Use Information We Collect”), for any other purpose that has been notified to you or to which you have consented, and as otherwise permitted, authorized, required by applicable law.  This includes sharing information as follows:  

  • We may share information with our affiliates for the purposes described in this Privacy Policy.
  • We may share information with third-party service providers and business partners who provide services to us, or otherwise help us operate our business or provide or otherwise make available the Services, including security providers, marketing partners, analytics or research companies, identity verification or fraud prevention companies, financial institutions, payment processors, payment card associations, payment networks, and professional service providers, such as attorneys, accountants, and auditors.
  • If you are a customer who uses the Services to make a tip or other payment to an employee or independent contractor of a merchant, then we may share information about you and your payment with the merchant. The merchant also may enable its employees and independent contractors to know information about you or your payment. 
  • If you are an employee or independent contractor, we may share information about you with your employer, such as whether you have elected to use the Services, or the amounts of disbursements received by you. We may also contact your employer to confirm you are entitled to use the Services. If you are a business using the Services, then we will contact your employees and/or independent contractors to determine if they wish to use the Services and to enable them to register for the Services.
  • We may share information (a) in connection with complying with, making claims relating to, or enforcing legal obligations, legal process, prudent security or business practices, or legal claims; or (b) as we deem reasonably necessary to comply with applicable law, and to protect us, the Services, and the public from fraud, harm, security breaches, and other potentially harmful, wrongful, or illegal activity. This may include disclosures to law enforcement offices or other governmental or regulatory authorities, third-party rights owners, or others, as well as disclosures to protect our rights, property, interests, or personal safety or those of our customers, users, or the general public. 
  • We may share or transfer information with another business in connection with an actual or contemplated sale, merger, transfer, or exchange of all or any portion of our business or assets.
  1. Minors

The Services are intended solely for use by persons that are the age of majority under the laws of the applicable jurisdiction.  If you are under the age of majority under the laws of your jurisdiction, you may not access or use the Services or contribute any information to us.  If you believe we may have inadvertently collected information about a person under the age of majority under the laws of the applicable jurisdiction, please contact us as set forth in Section 11 below.

  1. Security

We have implemented measures designed to provide security for information collected in connection with the Services.  However, please note that due to the inherent open nature of the Internet and the nature of the Services, we cannot guarantee that communications sent between you and us, or your access to or use of the Services are or will be secure.        

  1. Monitoring the Services

We reserve the right to, but do not have the obligation to, monitor and retain records of your access to and use of the Services.  We also may share records of your access to and use of the Services with our third-party service providers, or enable such third-party service providers to collect such records as part of providing services to us.  By accessing or using the Services, you acknowledge and consent to the monitoring of your access to and use of the Services by us and our third-party service providers.

  1. Marketing

As permitted by law, we may send marketing communications to you regarding products or services offered by us or by partners.  You can stop these communications from any time by clicking on the “unsubscribe” link included in marketing emails.  You also can unsubscribe by contacting us as set forth Section 11 below. 

We also may partner with third parties to provide you with advertisements based on your interests that you see on other websites. These parties may use data technologies to collect information about your online activities over time and across websites to provide you targeted advertising based upon your interests, such as cookies, clear gifs, web beacons, or similar technologies. This data collection may take place both on our website and on third-party websites that participate in ad networks or use similar third-party providers. To opt-out of certain of these technologies and for other information, please visit the Digital Advertising Alliance and the Network Advertising Initiative.

  1. Links to other Websites

The Services may provide links to other websites or platforms for your convenience and information. These websites operate independently from us, and their privacy practices are subject to their own privacy notices or policies, which we encourage you to review. We are not responsible for the content of the linked websites, any use of these sites, or the privacy practices of these sites.

  1. Your California Privacy Rights

If you are a California resident, California law permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (if any such disclosures occur). To make such a request, please send an email to 

  1. Changes to this Privacy Policy

We may modify, supplement, or replace this Privacy Policy from time to time and will post any modified, supplemented, or replaced Privacy Policy on this website.  We will indicate at the top of the Privacy Policy the last date on which this Privacy Policy was modified, supplemented, or replaced. By using the Services after we have posted a revised Privacy Policy, you accept and consent to the terms of the revised Privacy Policy. 

  1. Do Not Track

As of the “Last Updated” date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, this website is not designed to respond to Do Not Track signals. 

  1. Contact Us

If you have questions about this Privacy Policy or personal information, please contact us by email at