Legal

Perpay Privacy Policy

This Privacy Policy was updated on 10/28/2026 and is effective immediately for new users, and from 11/13/2026 for existing users. Perpay, Inc. a Delaware corporation, together with its applicable subsidiaries, affiliates, assignees, and successors (collectively, "Perpay", "we", "us" or “our”) are committed to your personal privacy and your security online. This policy describes the ways we collect, use, share and protect your personal information in connection with products and services offered through Perpay (collectively, the “Perpay Services”). You accept this policy by using Perpay Services on our website or by any other means.

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If you have any financial product or service with us, including beginning an application for, or establishing a Perpay Mastercard Credit Card account, as issued by Celtic Bank, Member FDIC (“Celtic”), we will use and share any Non-Public Information (“NPI”) as defined by the Gramm-Leach-Bliley Act (“GLBA”) that we collect from or about you related to your use of that product or service in accordance with our U.S. Consumer Financial Privacy Notice found here: https://perpay.com/legal/privacy-notice.

Furthermore, you acknowledge that the use of the Perpay Mastercard Credit Card account (“Perpay Card”) offered by Celtic, through Perpay is governed by the Cardholder Agreement that is provided to you. Click here to view the Celtic Bank U.S. Consumer Privacy Notice.

If you have any questions about our Perpay’s Privacy Policy or how it applies to specific data, please contact us at hello@perpay.com.

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Information We Collect About You

We collect information about you in three ways:

(I) Information You Provide: When you use Perpay’s website and any services we might provide, you will generally be required to provide personally identifying information, which may include your e-mail address, name, address, telephone number and Social Security Number, as well as financial information, which may include income, employment and bank account information. You may also have to provide certain documents to verify the information you provide.

(II) Information from Third Parties: Third parties, such as credit bureaus or relevant payroll providers, may provide us with information on you. We may combine this information with information we already have about you to evaluate your application for services, to create or offer personalized products and services for you, or for similar purposes.

(III) Information from Your Use of the Website: We may collect additional user behavior information during your use of the website. This may include device information (such as your internet protocol address), log information (such as pages visited), location information, and other information (such as cookies and anonymous identifiers). We will retain your information for as long as needed to provide you services or as necessary to comply with our legal obligations and our backup, archival and audit procedures.

In addition, we partner with Underdog Technologies, Inc., d/b/a Pinwheel ("Pinwheel") to collect information about your payroll account transactions/settings, your income, salary, and wage information, and information from documents such as your paystubs, W-2s, W-4s, and 1099s ("Income Information") and your name, job title, employer name, start date, end date, and other employment details ("Employment Information"). Accordingly, you will be asked to provide your log-in credentials to your employer's payroll provider (such as ADP, Quickbooks, Gusto, or Workday) to Pinwheel. When you link an account through Pinwheel, you acknowledge that (1) Pinwheel will access and transmit your Income Information and Employment Information from your payroll provider to us and (2) pursuant to your instructions, Pinwheel may also change the account that receives your direct deposit. You also acknowledge that we will share certain information with Pinwheel to facilitate those connections (such as your name and payroll provider) and that such information, together with your Income Information and Employment Information, will be collected, used, and disclosed by Pinwheel in accordance with Pinwheel's Privacy Policy (https://www.pinwheelapi.com/terms-and-policies#privacyPolicy).

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Aggregate and De-identified Information

We may collect statistical information about both unregistered and registered users that is not personal information and cannot be tied back to you, your Account or your web browser (“Aggregate and De-identified Information”). Some of this information is derived from personal information. We may use Aggregate and De-identified Information for various business purposes where permissible under applicable laws and regulations, including for analytics or to develop or improve our services and marketing. We may share this Aggregate and De-identified Information with third party service providers for their business purposes. Third party service providers may also share with us non-private, aggregated or otherwise non-personal information about you that they have independently developed or acquired.

We may also use and share Aggregate and De-identified Information for research, which may include research conducted by government entities, non-profit entities, and academic institutions. This may involve publishing findings or combining Aggregate and De-identified Information with other data sets, but such information will not be shared in a way that allows you or any other person to be personally identified.

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How We Use Information We Collect

Information we collect from you may be used in one or more of the following ways:

● To provide you with products and services, including in determining your eligibility for products and services we might provide (e.g., to verify your employment and payment details);
● To verify your identity and age as well as to guard against potential fraud;
● To obtain, with your authorization, third-party data from credit bureaus or others in connection with your application;
● To personalize your experience using the website;
● To provide customer service;
● To enable our service providers to provide you with services, such as funds transfers, billing, payments, and collection activities as needed;
● To send you regular communications, including information and updates pertaining to your account as well as news, updates, and related product or service information;
● To improve our products and services and identify, develop or offer new products and services;
● For our marketing purposes to offer our products and services to you;
● To enforce agreements with you;
● To comply with any court order, law, or legal process, including retaining personal data or responding to any government or regulatory request; and/or
● To fulfill any other purpose for which you provide it or otherwise give your consent.

Information We Share

We may share information with third parties in the course of running our business, including:

● Service providers who assist with parts of our operations including but not limited to, technology providers, payment processing providers, credit bureaus, collections agencies and other service providers;
● Credit bureaus to report account information, as permitted by law;
● As described in our Consumer Financial Privacy Notice, with respect to the information of consumers who apply for a Perpay Mastercard Credit Card;
● Companies that we plan to merge with or be acquired by, or companies we plan to sell, divest or transfer all or a portion of our products and/or services to;
● Law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order or similar legal procedure or we need to do so to comply with law;
● Other third parties where you have provided your consent or directed us to do so (such as payroll providers as described below); and
● Companies that include Perpay as a payment option.
To use the Perpay Services, Perpay may need to send certain of your personal information (e.g., encrypted Social Security Numbers) to payroll providers to validate your employment and payment details. At your direction, this information will be shared with the following payroll providers, which may use your personal information in accordance with their own respective privacy policies and terms of service:
Please note that we do not control how certain third parties who are not our service providers process your data. We encourage you to review the privacy policies and terms of service of any third parties before disclosing your information to such parties or visiting such third-party websites.

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Perpay will not sell or rent any of your personal information to third parties for their marketing purposes and only shares your personal information with third parties as described above. Information that has been made anonymous so that it does not identify a specific user is not considered personal information and we may share aggregated, non-identifiable user information with third parties, such as advertisers and content distributors.

How We Protect Your Information

Perpay is committed to safeguarding your personal information through various industry standard policies and practices.

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We protect your account security by employing session time-outs, which log you out of the website after a specified time period, and by employing secure password practices, including password strength requirements and secure password reset procedures. Your password is not known to any employee or service provider of Perpay.

We protect your data in our care by storing sensitive personal and financial information, such as bank account numbers, in a secure, off-site, hosted environment, which can only be read or written though defined service access points which are password-protected and accessible only to employees and service providers with a permitted need to access such information.

We also protect your information in transit by employing Secure Socket Layer (SSL) certificate technology which encrypts all data entered into our website and ensures the connection is secure. As an additional measure, we also require a 128-bit secure browser for logins and transactions.

While we employ safeguards that are designed to protect the personal information we collect, we cannot guarantee the security of your personal information and you use our website and services at your own risk.

Cookies and Other Technologies

We use various technologies to collect and store non-personally identifiable information when you use the website. This may include sending one or more cookies or anonymous identifiers to your computer or mobile device, including web beacons, clear GIFs, pixel tags and other means. Perpay may use such technologies or similar technologies to obtain non-personal information from you as an online visitor.

Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. Generally, information in your browser's "Help" section of the toolbar, or on the website of the browser designer or vendor, will explain how to turn off or modify your browser's settings regarding cookies. Please note that without cookies, you may not be able to take full advantage of all of the website's features.

We may use cookies, among other things, to keep track of any advertisements we may display or to compile aggregate, non-personally identifiable data about website traffic and website interaction so that we can offer better website experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our website visitors. These service providers are not permitted to use information about or from users collected on our behalf, except to help us conduct and improve our business.

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Your Choices

Opt out of marketing communications. You may opt out of marketing communications by clicking the unsubscribe link at the bottom of the communication. After you opt out, you may continue to receive service-related and other non-marketing emails.

Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our services, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.

Use the following links to learn more about how to control cookies and online tracking through your browser: Firefox; Chrome; Microsoft Edge; Safari

• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

• Using privacy plug-ins or browsers. You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.

• Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:Google, Bing

• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:Digital Advertising Alliance, Network Advertising Initiative.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

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Links to Third-Party Websites

The website may also contain links to websites that are not controlled or operated by us. This policy does not apply to such third-party websites and Perpay is not responsible for the content of such websites or the privacy practices of the third parties controlling or operating such websites. We encourage you to request and review the privacy policies of any third parties before disclosing your information such parties or visiting such third-party websites.

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Product Reviews

If you review a product on our site, this review may be posted on our site or associated social media sites in order to help other customers make informed purchase decisions. By completing a product review, you grant Perpay and its affiliates a nonexclusive, royalty-free, perpetual, irrevocable and fully sublicensable right to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute and display such content in any form and at any location.

Children's Privacy

Our services are not directed to children who are under the age of 13. We do not knowingly collect personal information from children under the age of 13. If we learn that we have collected personal information from a child under the age of 13 without the consent of the child’s parent or guardian as required by law, we will delete that information.

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state charged with overseeing privacy rights for consumers.

Modifications to This Policy

Perpay reserves the right to make changes to this policy at any time and from time to time and by using or accessing the website, you agree that we may modify this policy at any time without prior notice. Any modification is effective immediately upon posting on the website. Your continued use of the website after any modification of this policy indicates your acceptance of the modification and the policy as so modified.

You will know if this privacy policy has been modified since your last visit to the website by referring to the last modified date at the end of this page. Notwithstanding the above, we will seek your consent to future modifications to the extent we are required to do so by applicable law.

How You Can Contact Us

You may email us at hello@perpay.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you have questions or concerns regarding this policy, please contact us by emailing us at hello@perpay.com.

California Privacy Rights:

This section applies to any California residents about whom we have collected personal information from any source, including through your use of our Website(s), products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, for purposes of this section only, “you”). This section explains how Perpay may collect, use, and disclose personal information subject to the California Consumer Privacy Act and California Privacy Rights Act (together, the “CCPA”). It also describes the privacy rights of California residents under the CCPA and how they can exercise those rights.This section applies solely to California residents and supplements any other privacy policies or notices applicable to Perpay’s Website, Services, or products that you visit or use.

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What Personal Information is Covered by the CCPA?

Under the CCPA “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household.  Personal information does not include publicly available information, or lawfully obtained, truthful information that is a matter of public concern, information that has been de-identified, aggregate consumer information, or information that does not fall within the definition of personal information above.

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The CCPA does not apply to certain information that is already regulated by federal or state privacy laws, such as information subject to the Gramm-Leach-Bliley Act (GLBA), the Fair Credit Reporting Act (FCRA), and certain other state or federal privacy laws. For example, this California Privacy Rights section does not apply to information that we collect about individuals who seek, apply for, or obtain our financial products and services for personal, family, or household purposes, which is subject to Perpay’s U.S. Consumer Privacy Notice, or other financial privacy notice applicable to the Perpay Website, Services, or products that you visit or use. As such, most of the personal information about you that we may collect and use is protected by the privacy rules of the GLBA and exempt from the CCPA. Please note that the disclosures below may pertain to information that is regulated by GLBA, FCRA, or other laws, and Perpay does not waive any applicable CCPA exemptions as to that information by including such disclosures in this Privacy Policy.

Similarly, this section does not apply to information we may collect in the context of a person’s role as a job applicant, employee, associate, contractor, or other member of Perpay’s workforce, which is subject to Perpay’s California Employment Information Privacy Statement. For our California Employment Information Privacy Statement, please click here.

Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information, as defined in the CCPA, relating to California residents. The categories of personal information that we collect, use, and disclose about a California resident will depend on our specific relationship or interaction with that individual. The examples provided in each category below include both financial and non-financial information and are for illustrative purposes only.

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Category of Personal Data
Illustrative Examples
Identifiers
Name, address, email address, online identifiers, internet protocol address, or other similar identifiers
Customer records information
Contact or financial information
Protected classifications under California or Federal law
Age, marital status, sex, disability, and veteran or military status
Commercial information
Information about past transactions or purchases
Professional or employment-related information
An individual’s employment status, years of employment, name of employer, paystub or payroll information  
Internet or similar network activity information
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
Audio, electronic, visual, or similar information
Call recordings
Inferences drawn from other personal information  
Certain inferences concerning an individual’s preferences and characteristics
Geolocation data
Device location

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Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.

The personal information of California residents that we collect or use will be retained for the length of time as required by applicable state or federal laws or regulations, or in accordance with an applicable Perpay policy.

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Sensitive Personal Information ‍

Certain of the above personal information is considered “sensitive personal information” under California law.  This includes:

1. Perpay will not retain any information we collect from you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

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Categories of Sources of Personal Information

In the past 12 months, we have collected personal information relating to California residents from the following sources:

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Sources
Illustrative Examples
Directly from you
Marketplace orders, Credit card applications, bank transactions, interactions with our website or mobile apps, employer information, emails to our call center
Service providers
Software providers, fraud prevention services, data analytics providers, data providers
Third parties that you have authorized or directed to share your information with us
Your employer or employer’s payroll provider, payment processors, or other financial institutions
Government or public sources
Public data published by state or federal governments
Business partners
Financial institutions

Purposes for which we use personal information‍

Most of the information we use is in the context of providing financial products and services, and is therefore not subject to the CCPA. We may use personal information relating to California residents for one or more of the following business or commercial purposes:

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2. Disclosure of Personal Information

In the past 12 months, we have disclosed each of the above-listed categories of personal information concerning California residents for the business purposes identified above to one or more of the following categories of third parties and service providers:

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Third Parties or Service Providers
Illustrative Examples
Service providers
Software providers, marketing companies, communication services, fraud prevention services, data analytics providers, data providers
Third parties that you have authorized or directed us to share your information with
Payment processors, payroll providers, entities offering goods or services on the Perpay Marketplace, other financial institutions
Government entities and others, when we share information for legal or necessary purposes
Regulatory and law enforcement agencies

‍In the past 12 months, we have not shared or sold personal information or sensitive personal information relating to California residents in a manner that we consider “sharing” or “selling” as those terms are defined by the CCPA.

Privacy Rights Under the CCPA

If you are a California resident, you have the following rights under California law with respect to the personal information described above, to the extent such information (i) was collected during the 12-month period immediately preceding your request and (ii) is not already subject to privacy and security measures applied under federal law:

Right to Know.  You have the right to request the following information from us about our use of your personal information: (1) the specific pieces of personal information that we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which your personal information was collected; (4) the categories of personal information that we have, shared, sold or disclosed; (5) the categories of third parties to whom we have, shared, sold or disclosed your personal information; and (6) the purpose for collecting, sharing, or selling your personal information.

Right to Correct Inaccurate Personal Information.  You have the right to request the correction of your personal information that is inaccurate.

Right to Delete.  You have the right to submit a request for deletion of personal information under certain circumstances, although there may be legal or other reasons that Perpay will retain your information.

Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale/sharing of your personal information by us, as those terms are defined by the CCPA.  However, as stated above, we do not sell/share your personal information.

Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for Perpay to provide our products and services to you, or for certain other authorized purposes.

Right to Non-Discrimination.  You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

These rights are subject to various exclusions and exceptions under applicable laws and are also subject to our being able to reasonably verify your identity and authority to make a request.

To facilitate this verification, you must provide us with your full legal name and mailing address, and we may need to request further information.  

You may designate an authorized agent to make a CCPA request on your behalf. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. As the Perpay Marketplace and Perpay Card, as issued by Celtic, are intended only for individuals ages 18 or older, we do not intentionally collect information about minors.

If you are a California resident and wish to seek to exercise the California privacy rights set forth above, please contact us at hello@perpay.com and send us the necessary information as identified here.

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Under California Civil Code sections 1798.83-1798.84, California residents are also entitled to ask us for a notice identifying the categories of personal customer information that we share with affiliates and/or third parties for their own direct marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to Perpay Card, Inc., 2400 Market Street, Suite 300, Philadelphia,  PA 19103.

For our California employment information privacy statement, please click here.

We will continue to update our business practices as direct regulatory guidance becomes available.  

We may change or update this California Privacy Rights section in the future. When we do, we will post the revised section on our website. This section was last updated and became effective on the date posted at the top of this page.

How Can I Delete My Account?

If you decide to delete your Account, you can do so by emailing hello@perpay.com or contact Perpay’s Customer Support Team via your Perpay mobile app or dashboard. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. We will continue to store, access, and use information about you and your Account in compliance with this General Privacy Policy and as required by any applicable legal or regulatory obligations.

What Choices Do I Have Regarding My Information?

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3. Children's Privacy

The Perpay Services are not intended for use by children. We do not knowingly collect personal information from children under the age of 13 years. If we become aware that a child under 13 has opened an account or otherwise provided us with Personal Information, we take steps to terminate the child’s account and delete such information.

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state charged with overseeing privacy rights for consumers.

What Happens When There Are Changes to this General Privacy Policy?

We may amend this General Privacy Policy from time to time. If we make changes in the way we collect or use information, we will attempt to notify you by posting an announcement on the Perpay Services or sending you an email; however, any changes to the General Privacy Policy are effective as soon as we post them here.

For more information regarding this General Privacy Policy, or if you have any questions or concerns, please contact us at hello@perpay.com.

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© Perpay Inc., 2026