Privacy Policy

Last Updated: [November 10th, 2021]

JALS, LLC (“Nespy”) provides consumers with a platform that digitizes transactions at the point of sale, providing consumers with the ability to pay for a product or service in cash and then receive change for that transaction in a digital form.

This Privacy Policy describes how Nespy (“we”, “us”, or “our”) collects, uses, discloses and otherwise processes personal information from consumers and merchants in connection with our websites, mobile application, and API (collectively, “the Services”), and explains the rights and choices available to individuals with respect to their personal information.

INFORMATION WE COLLECT

Information Collected From Consumers

Information you provide us with. Personal information that consumers may provide to us through the Services or otherwise includes:

  • Contact details, such as your name, email address, and phone number.
  • Payment data needed to complete your orders on or through the Service (including name, payment card information, bank account number, billing information), and your purchase history. This information is processed directly by our payment service providers: Dwolla and Plaid. For more information, see the “Payment Processors” section below.
  • Point of sale transaction data, such as a consumer’s Nespy identifier and transaction information, collected via the API to process giving change and receiving payments via Nespy.
  • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
  • Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with those communications.

Information Collected From Merchants

Information you provide us with. Personal information that employees of our merchants may provide to us through the Services or otherwise includes:

  • Business contact information, such as your name, work email address, and phone number.
  • Identification information, such as your driver’s license.
  • Payment data needed to complete your orders on or through the Service (including name, payment card information, bank account number, billing information), and your purchase history. This information is processed directly by our payment service providers: Dwolla and Plaid. For more information, see the “Payment Processors” section below.
  • Point of sale transaction data, such as a merchant’s Nespy identifier and transaction information, collected via the API to process giving change and receiving payments via Nespy.
  • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
  • Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with those communications.

Automatic Data Collection

We may automatically log information about your interactions with our Services and communications, such as:

  • Device data, such as computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
  • Online activity data, such as pages or screens viewed, how long you spend on a page or screen, the website you visited before browsing to our website, navigation paths between pages or screens, information about activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on the device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

OUR USE OF PERSONAL INFORMATION

We use your personal information for the following purposes:

Service delivery, including to:

  • Provide, operate, and improve our Services and our business;
  • Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
  • Understand your needs and interests, and personalize your experience with the Services and our communications; and
  • Provide support, and respond to requests, questions, and feedback.

Research and development, including to:

  • Develop new features, products, and services; and
  • Create aggregated, de-identified, or other anonymous data or analytics

Marketing. We may collect and use your personal information for marketing purposes, including:

  • Direct marketing. We may send you direct marketing communications about our Services as permitted by law, including, but not limited to, notifying you of special promotions, offers, and events via email, text message, and other means. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.

Compliance and protection, including to:

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern our Services; and
  • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

PERSONAL INFORMATION SHARING

We may share your personal information with:

Merchants. Companies and other proprietors that use our Services. We will only share a consumer’s information – specifically, their transaction data and Nespy identifier – with those merchants from whom the consumer purchases goods and services.

Point of sales platforms. Platforms on which our application runs, such as the Clover Point of Sale system.

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email and text message delivery, and website analytics services).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, JALS, LLC or our affiliates (including in connection with a bankruptcy or similar proceedings).

Privacy Choices

Access to information. To keep your information accurate, current, and complete, please update your information via the settings on the mobile application or web portal, or contact us as specified below. We will take reasonable steps to update or correct information in our possession that you have previously submitted via the Services.

Opt out of marketing communications. You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communications you receive from us, or via the settings on the mobile application or web portal. You may continue to receive service-related and other non-marketing emails.

Online tracking opt-out. There are a number of ways to limit online tracking, 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 www.allaboutcookies.org.
  • Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

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.

Please note that 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 www.allaboutdnt.com.

Processing Personal Information in the US

We are headquartered in the United States. To provide our services and operate our website, it is necessary for us to process personal information in the United States.

If we transfer personal information across borders such that we are required to apply appropriate safeguards to personal information under applicable data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Payment Processors

For online payments, we use the services of Dwolla (https://www.dwolla.com), and Plaid (https://www.plaid.com).

When you make a transaction, you direct us to share certain information with these payment processors, and you will provide other information—such as your credit card or bank account information—directly to them. We do not record or maintain this financial information.

For more information on how payments are handled, or to understand the data security and privacy practices of our payment processors, please refer to their privacy notices.

Other Sites and Services

The Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Information Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of personal information.

Children

Our Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through our Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will provide a notification by updating the date of this Privacy Policy and posting it on the website.

How to Contact Us

You can reach us by email at support@nespy.com or at the following mailing address:

JALS, LLC
8550 Leesburg Pike
Vienna, VA 22182