Privacy Policy
Effective date: [EFFECTIVE DATE]. Meritwave Digital Inc ("we") explains what personal information we collect, why, and your choices. It covers our website, apps (Client Node, Merchant Node, Autonomous Node), the Operations node and our payment services. It applies to clients, merchants and their representatives, and visitors.
1. What we collect.
- Account details: name, email, phone, Base ID (your handle in our system), and for businesses the business details and tax ID.
- Identity data (clients and merchant representatives): photos of the front and back of your ID, your date of birth, and a selfie or profile photo. Our ID reading service ([ID Analyzer]) reads the ID in one pass, including the document number, name, address and expiry date, and compares your selfie to the photo on the ID. We keep the result of the check (pass or fail), the face-match score and the ID expiry date. We do not keep the document number or the reading service's raw answer. We keep the ID photos taken at sign-up and, for clients, the profile photo, as described in section 4. Photos sent for a yearly renewal or a change of representative are used for the check and are not stored. Face data is covered by the Biometric Notice. [VERIFY: the reading service's own retention settings are still being confirmed with the vendor; source: operations-backend PR #267, "What the system does with the images".]
- Verification results: identity-match, sanctions and anti-money-laundering results from our providers.
- Payment data: amounts, times, Lightning invoices and node records; for merchants, bank account details for payouts and debits (entered securely) and equipment orders; card payments are handled by Square.
- Location: if you allow it, the Client Node sends your location while the app is open, so a nearby merchant can find you for Practicle. The app never tracks you in the background, and you can turn location off. Merchants have a fixed store location we create from their address.
- Device and technical data: device type, app version, IP address and logs, and push tokens.
- Autonomous Node: a random Autonomous ID, and a photo only if you choose Practicle. No identity check is required to use the app.
2. Why we use it. To open and run your account, verify identity, meet legal duties such as anti-money-laundering and sanctions rules, process payments and payouts, provide Practicle, prevent fraud, support you, and improve our service. We do not sell personal information and we do not use it for targeted advertising.
3. Who sees it. Service providers that work for us and may use data only for us: identity verification ([ID Analyzer]), banking and payment partners ([BANK PARTNER], Square), push notification services (Google, Apple), and hosting. Merchants see only what a payment needs; with Practicle a nearby merchant can see your current profile photo, without your name, to select you; in a Boost at a merchant, the merchant also sees your profile photo. Regulators and law enforcement where required. A buyer if the business is sold, with notice. [COUNSEL: category-level wording.]
4. How long we keep it. Only as long as needed and as the law requires. Face data follows the Retention and Destruction Policy (client photos are kept while the account is active and the client authorizes the stated purposes, including future Practicle renewal. Practicle expiration alone does not trigger deletion. The photo is deleted upon consent withdrawal or account closure, and the old photo is deleted on replacement. A client renewing after deletion must provide a new photo. Counsel must confirm the retention purposes and any earlier legal deadline). ID photos taken at sign-up are kept [three (3) years after an account closes: a proposal, not a CEO decision; COUNSEL to confirm] [COUNSEL: the ID-photo period is a separate open question]. ID photos sent for a yearly renewal or a change of representative are not stored. Location is kept only briefly to match you to nearby merchants. [FULL RETENTION SCHEDULE - COUNSEL.]
5. Security. We use encryption, access controls and logging. [REQUIREMENT – NOT BUILT: photos are stored as plain image files today, not encrypted; do not publish this sentence until encryption is built.] No system is perfectly secure. If a breach of the security of personal information affects Illinois residents, we will notify them in the most expedient time possible and without unreasonable delay, and the Illinois Attorney General where the law requires (815 ILCS 530).
6. Your choices and rights. Everyone may ask us to access, correct or delete personal information, and to withdraw consents, by emailing [email protected]. Some data we must keep by law. We will not treat you worse for using these rights. Your state may give you more rights:
- Illinois residents: Illinois has no general privacy-rights statute at this time, but we give the rights below to everyone and honor your rights under the Biometric Information Privacy Act, which cannot be waived. Face data is covered by the Biometric Notice and Release and the Retention and Destruction Policy.
- Indiana residents: you may ask us to confirm whether we process your personal data, to give you a copy, to correct it, to delete it, and to opt out of sales, targeted advertising and profiling. We do not sell personal data or use it for targeted advertising. We process sensitive data, including face data and precise location, only with your consent, and you may withdraw it. We answer within 45 days and may extend once by 45 days if we tell you why. If we deny your request you may appeal by emailing [email protected] with the subject "Appeal", and we will answer within [60] days. If we deny your appeal you may contact the Indiana Attorney General at [AG CONTACT LINK]. You can make requests without creating a new account.
- Iowa residents: you may ask us to confirm whether we process your personal data, to access it and get a portable copy, to delete it, and to opt out of the sale of personal data and targeted advertising. We do not sell personal data or use it for targeted advertising. We give you notice before we process sensitive data, including face data and precise location, and you may opt out of that processing by contacting us or by turning off location and Practicle in the app. We answer within [45] days. You may appeal a denial by emailing [email protected] with the subject "Appeal".
- Missouri residents: Missouri has no general privacy-rights statute at this time. We give you, and every user, the rights below anyway.
- Wisconsin residents: Wisconsin has no general privacy-rights statute at this time. We give you, and every user, the rights below anyway.
7. Cookies. See the Cookie Policy for the cookies and browser storage our website and Operations app use. We do not use advertising trackers. [DEVELOPER TO CONFIRM LIST BEFORE LAUNCH]
8. Children. Our service is for people 18 and older. We do not knowingly collect information from anyone younger.
9. Versions, changes and consent. This policy applies only to personal information we collect while this version is in effect, from its effective date until a newer version replaces it. Using our website or apps is not consent to anything that happened before this version, and is not consent to future processing we have not described. We do not treat use of the site as consent to biometric processing: that needs your signed release first (see the Biometric Notice). We give notice in layers: a short notice where we collect information, linked to this full policy. If we make a material change (a new kind of data, a new purpose, a new recipient, or a longer retention period), we tell you before it takes effect and we do not start the new processing for your account until you click to accept the new version. Until you accept, the earlier version keeps governing information collected under it. [COUNSEL: what service we may still provide to a person who does not accept.] We keep each version, with the date range it applied, at [LINK], and we record which version you accepted and when.
10. Contact. [email protected]; [MAILING ADDRESS].