Privacy Policy

Privacy Policy

Equb Pay LLC Effective Date: June 1, 2026 Last Updated: June 1, 2026

Contact: hello@myequbpay.com | Equb Pay LLC, Colorado

1. Introduction

Equb Pay LLC ("Equb Pay," "we," "us," or "our") operates the Equb Pay mobile application and website at myequbpay.com (collectively, the "Platform"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Platform.

By using the Platform, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the Platform.

2. Information We Collect

2.1 Information You Provide Directly

  • Account information: Name, email address, phone number, and password when you create an account.
  • Identity verification information: Government-issued ID information collected through our identity verification provider for compliance with applicable financial regulations.
  • Financial information: Bank account information collected through Plaid, our third-party bank linking provider. We do not store your bank login credentials. We receive and store only the tokenized account information necessary to initiate ACH transfers.
  • Circle information: Information about savings circles you create or join, including circle name, contribution amounts, payout schedule, and member information.
  • Communications: Messages or inquiries you send to us directly.
  • Waitlist information: Name, email address, city, and community affiliation provided when joining our waitlist.

2.2 Information Collected Automatically

  • Usage data: Pages visited, features used, time spent on the Platform, and actions taken.
  • Device information: Device type, operating system, browser type, and IP address.
  • Log data: Server logs including access times, pages viewed, and error reports.
  • Cookies and similar technologies: We use cookies and similar tracking technologies to maintain session state, remember preferences, and analyze usage patterns. You may disable cookies in your browser settings, though some Platform features may not function properly as a result.

2.3 Information from Third Parties

  • Plaid: When you link your bank account, Plaid provides us with tokenized account identifiers, account type, and routing information necessary to process ACH transfers. Plaid's privacy policy governs their collection and use of your information. We do not receive your bank login credentials.
  • Identity verification providers: Verification status and risk signals from identity verification services we use to comply with applicable regulations.
  • Analytics providers: Aggregated usage data from Google Analytics and similar services.

3. How We Use Your Information

We use the information we collect to:

  • Provide and operate the Platform: Process contributions and payouts, maintain circle records, and facilitate member communications.
  • Verify your identity: Comply with applicable financial regulations and prevent fraud.
  • Process transactions: Initiate ACH bank transfers for contributions and payouts on your behalf.
  • Send communications: Transaction confirmations, payment reminders, platform updates, and responses to your inquiries. You may opt out of non-transactional communications at any time.
  • Improve the Platform: Analyze usage patterns, diagnose technical issues, and develop new features.
  • Comply with legal obligations: Meet requirements under applicable federal and state financial regulations, including Bank Secrecy Act (BSA) obligations, anti-money laundering (AML) requirements, and FinCEN reporting requirements.
  • Protect against fraud and abuse: Monitor for suspicious activity and take action to protect our users and the Platform.
  • Respond to legal requests: Comply with court orders, subpoenas, or other legal process as required by law.

4. How We Share Your Information

We do not sell your personal information to third parties. We share your information only in the following circumstances:

4.1 Within Your Circle

Circle members can see the names and payment status of other members in circles they have joined. This visibility is fundamental to the trust and accountability that rotating savings circles require. You consent to this visibility when you join or create a circle.

4.2 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

  • Plaid: Bank account linking and ACH transfer facilitation
  • Unit.co (Phase 2): Banking-as-a-Service infrastructure for payment processing
  • Identity verification providers: KYC and identity verification
  • Cloud infrastructure providers: Data storage and processing (AWS)
  • Communication providers: Email and notification delivery (Firebase, Resend)
  • Analytics providers: Usage analytics (Google Analytics)

These providers are contractually obligated to use your information only as directed by us and in accordance with this Privacy Policy.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid legal process, including:

  • Court orders, subpoenas, or other legal process
  • Requests from law enforcement or government agencies
  • Currency Transaction Reports (CTRs) for transactions over $10,000 as required by federal law
  • Suspicious Activity Reports (SARs) as required by the Bank Secrecy Act

4.4 Business Transfers

If Equb Pay is acquired, merges with another company, or transfers its assets, your information may be transferred as part of that transaction. We will notify you of any such change and your options.

4.5 With Your Consent

We may share your information for other purposes with your explicit consent.

5. Data Retention

We retain your personal information for as long as necessary to provide the Platform and comply with our legal obligations. Specifically:

  • Account information: Retained for the duration of your account and for a minimum of 5 years after account closure, as required by applicable financial regulations.
  • Transaction records: Retained for a minimum of 5 years as required by the Bank Secrecy Act and applicable state financial regulations.
  • Identity verification records: Retained for a minimum of 5 years from the date of verification.
  • Waitlist information: Retained until you request deletion or until the Platform launches in your city, whichever comes first.

6. Data Security

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

  • TLS 1.3 encryption for all data in transit
  • AES-256 encryption for sensitive data at rest
  • Access controls limiting employee access to personal information on a need-to-know basis
  • Regular security assessments and vulnerability testing

No method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we are committed to protecting your information using commercially reasonable means.

7. Your Rights and Choices

7.1 Access and Correction

You may access and update your account information at any time through the Platform. For information we hold that is not accessible through the Platform, contact us at hello@myequbpay.com.

7.2 Deletion

You may request deletion of your account and personal information by contacting us at hello@myequbpay.com. Note that we are required to retain certain transaction and identity records for a minimum of 5 years under applicable financial regulations. We will inform you of any information we are legally required to retain.

7.3 Opt-Out of Marketing Communications

You may opt out of marketing emails at any time by clicking "unsubscribe" in any marketing email or by contacting us at hello@myequbpay.com. You cannot opt out of transactional communications (such as payment confirmations and security alerts) while your account is active.

7.4 California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale of personal information. We do not sell personal information. To exercise your CCPA rights, contact us at hello@myequbpay.com.

7.5 Colorado Residents

If you are a Colorado resident, you may have additional rights under the Colorado Privacy Act (CPA), including the right to access, correct, delete, and obtain a copy of your personal data. To exercise your CPA rights, contact us at hello@myequbpay.com.

8. Children's Privacy

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe we have collected information from a child under 18, please contact us at hello@myequbpay.com.

9. Third-Party Links

The Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party services you access through our Platform.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Platform and updating the "Last Updated" date above. For significant changes, we will provide additional notice, such as an email notification. Your continued use of the Platform after any changes constitutes your acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Equb Pay LLC Email: hello@myequbpay.com Website: myequbpay.com

For privacy-related complaints that we have not resolved to your satisfaction, you may contact your state attorney general's office or applicable consumer protection agency.

This Privacy Policy was drafted for Equb Pay LLC and should be reviewed by a qualified attorney before final publication. Last reviewed: June 2026.