Privacy

Payelle Privacy Policy

PAYELLE PRIVACY POLICY

Last Updated: December 8, 2025

Payelle, Inc. (“Payelle,” “we,” “us,” or “our”) values your privacy and is committed to protecting your information. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data when you access or use the Payelle mobile application, website, or any related services (collectively, the “Service”).

By using the Service, you consent to this Privacy Policy. If you do not agree, please discontinue use.

1. Description of Our Service

Payelle provides an AI-driven credit card optimization platform. Payelle does not store or access your credit card or bank login credentials. When you connect cards through Apple Wallet, Google Wallet, or similar secure integrations, all credential handling occurs through those trusted third-party systems.

Payelle receives only transaction metadata and card program details necessary to provide recommendations and automations.

2. Information We Collect

2.1 Information You Provide

We may collect the following when voluntarily provided:

• Name
   

• Email address
   

• Account credentials (for your Payelle account only; not bank credentials)
   

• Subscription and billing information (processed via Apple, Google, or payment vendors)
   

• Customer support communications
   

• Any other information you voluntarily submit
   

2.2 Financial Metadata (Strict Data Minimization)

Payelle does not store, access, or process:

• Bank login credentials
   

• Credit card login credentials
   

• Raw financial account access
   

• Full transaction logs pulled directly from financial institutions
   

Payelle may access limited metadata from third-party wallet or API integrations, such as:

• Merchant name
   

• Merchant category code (MCC)
   

• Transaction amount
   

• Time and date
   

• Card program type
   

• Reward eligibility and qualification logic
   

This data is used solely for card optimization and related analytics.

2.3 Device & Technical Data

We may collect:

• Device identifiers
   

• Operating system
   

• App version
   

• IP address
   

• Crash logs
   

• Diagnostic information
   

• Usage metrics and interaction behavior
   

2.4 Location Information

With your explicit consent, we may collect:

• GPS-based location
   

• WiFi/Bluetooth-based merchant proximity
   

• Geofencing signals
   

This information is used only to provide optimized card recommendations and location-based automations. You may disable location at any time in your device settings, though some features may not function properly.

2.5 Cookies, Tracking Technologies, and Analytics

We use cookies, SDKs, and analytics technologies (e.g., Firebase, Mixpanel) to improve performance, measure engagement, and personalize the Service. See Section 13 for the full Cookie Policy.

3. How We Use Your Information

We use collected data to:

• Provide AI-based credit card recommendations and automations
   

• Improve algorithm accuracy and app performance
   

• Diagnose crashes or bugs
   

• Process subscriptions and billing
   

• Communicate updates, support, or promotions
   

• Conduct research using aggregated, anonymized data
   

• Enhance security and prevent fraud
   

Payelle does not sell personal information as defined under applicable law. We may, however, commercialize aggregated, de-identified, or anonymized data as described in Section 5.

4. Legal Basis for Processing (GDPR)

Where applicable, we process personal data under the following legal bases:

• Consent – You authorize processing (e.g., location sharing, certain communications).
   

• Contract – Processing necessary to provide the Service you request.
   

• Legitimate Interest – Security, fraud prevention, analytics, and minimal operational data.
   

You may withdraw consent at any time where legally applicable, without affecting the lawfulness of processing based on consent before its withdrawal.

4.1 Identification of Data Controller

For purposes of the General Data Protection Regulation (“GDPR”), the data controller is:

Payelle, Inc.
Email: support@payelle.ai

4.2 Data Protection Officer & Supervisory Authority

Payelle has designated a contact responsible for privacy and data protection matters:

Data Protection Officer (DPO)
Email: support@payelle.ai

You have the right to lodge a complaint regarding the processing of your personal data with your local Data Protection Authority in the Member State where you habitually reside, work, or where you believe an infringement of data protection law has occurred.

5. Sharing & Disclosure of Information

By accessing or using the Service, you acknowledge and consent that Payelle may collect, receive, and process specific categories of information required to provide the core functionality of the platform. This includes: (i) your device location data when location services are enabled, (ii) card selection information passed through wallet integrations such as Apple Wallet or Google Wallet, and (iii) transaction metadata including merchant category, merchant name, transaction amount, and time. You understand that these data elements are necessary for Payelle to generate accurate reward recommendations and to operate the Service as intended.

By using the Service, you also acknowledge and consent that Payelle may collect, use, share, license, or commercialize aggregated, de-identified, or anonymized information derived from your activity, including location data, card selection data, and transaction metadata, for business, analytical, commercial, or partnership purposes. Payelle will not sell personally identifiable financial credentials or sensitive financial account information.

5.1 Service Providers

We share data with trusted third parties who perform, for example:

• Hosting
   

• Analytics
   

• Customer support
   

• Payment processing
   

• Cloud infrastructure
   

These parties may access data only to perform services on our behalf and are subject to confidentiality and data protection obligations.

5.2 Wallet Providers

When connecting a card via Apple Wallet, Google Wallet, or other secure providers, you authorize those platforms to share limited metadata with Payelle. Payelle never receives or stores your wallet login credentials or underlying bank credentials.

5.3 Legal Requirements & Public Authorities

We may disclose information when required to:

• Comply with law, subpoena, or government request
   

• Satisfy national security or law enforcement requirements
   

• Establish, protect, or exercise legal rights
   

• Investigate potential violations of our terms or policies
   

5.4 Business Transfers

In the event of a merger, acquisition, asset sale, joint venture, bankruptcy, restructuring, or similar transaction, personal information may be transferred as part of business assets. Any acquiring entity will be required to maintain protections that are at least as protective as those described in this Policy.

5.5 Aggregated or Anonymized Information

We may share non-identifiable aggregated insights for analytics, research, or commercial purposes, provided that they cannot reasonably be used to identify you.

5.6 Onward Transfer (GDPR)

Where we disclose personal data to subcontractors or third-party agents (data processors), we obtain contractual assurances that:

• Personal data is transferred only for limited and specified purposes;
   

• Processors provide at least the same level of protection as required by applicable data protection laws;
   

• Processors take reasonable and appropriate steps to effectively process personal data in accordance with those obligations;
   

• Processors will notify us if they determine they can no longer meet their obligations, and will stop or remediate unauthorized processing; and
   

• Processors will, upon request, provide a summary of relevant privacy provisions to competent Supervisory Authorities.
   

6. Data Security

We use encryption, secure transport (HTTPS), access controls, and other commercially reasonable safeguards to protect data. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your Payelle account credentials. You are fully responsible for all activities that occur under your account.

7. Data Retention

Payelle retains personal data only as long as:

• Needed to provide the Service;
   

• Required by law;
   

• Necessary to enforce legal rights; or
   

• Required for internal analytics in aggregated, non-identifiable form.
   

We request only the minimum amount of information required to perform the applicable Services and retain such information only for as long as necessary or for compatible purposes (such as legal compliance or defending our rights). Once no longer needed, data is securely deleted or anonymized.

8. Your Privacy Rights

8.1 California Residents’ Privacy Rights (Shine the Light)

If you are a California resident and have provided personal data to us for personal, family, or household purposes, you may request information about whether we have disclosed your personal information to any third parties for those third parties’ direct marketing purposes. We will provide, upon request and subject to applicable law, a list of such third parties for the preceding calendar year and the categories of personal information disclosed. We are required to respond to a maximum of two such requests per year.

Requests may be sent to support@payelle.ai or by mail to the address provided in Section 17.

8.2 Rights Under the California Consumer Privacy Act (CCPA)

If you are a California resident, you have the following rights (subject to legal limitations):

Right to Know
You may request that we disclose what personal information we collect, use, and disclose, including:

• Categories of personal information collected;
   

• Sources of that information;
   

• Purposes of use;
   

• Categories of third parties to whom we disclose personal information; and
   

• Specific pieces of personal information collected about you.
   

Right to Delete
You may request deletion of personal information that we have collected or maintain, subject to exceptions (for example, where the law requires retention or where data is necessary to provide Services or complete transactions).

Right to Correct
You may request correction of inaccurate personal information we maintain about you.

Right to Non-Discrimination
We will not deny goods or services, charge different prices, or provide a different level of quality because you exercised your rights.

Right to Use an Authorized Agent
You may designate an authorized agent to make a request on your behalf. We will deny requests from agents who do not submit proof of authorization. To verify that an agent is authorized, we may require a copy of a power of attorney or written permission and require that you verify your own identity directly with us.

Verification Requirements & Timelines
To protect your privacy, we must verify your identity before acting on certain requests. You may be asked to provide:

• Full name;
   

• Email address;
   

• Information linking you to the account or transactions.
   

We will confirm receipt of your request within 10 days and aim to respond within 45 days. If more time is needed (up to an additional 45 days), we will notify you of the extension and the reason.

No Sale of Personal Information
Payelle does not sell “personal information” as that term is defined under the CCPA. Because we do not sell personal information, the CCPA right to opt out of the sale of personal information is not applicable. We may sell or license only aggregated, de-identified, or anonymized information that cannot reasonably be linked to you.

8.3 GDPR Rights (European Economic Area Residents)

If GDPR applies, you may exercise the following rights, subject to legal limitations:

• Right of access;
   

• Right to rectification;
   

• Right to erasure;
   

• Right to restrict processing;
   

• Right to data portability;
   

• Right to object to processing based on legitimate interests;
   

• Right to withdraw consent at any time; and
   

• Right to lodge a complaint with a Supervisory Authority where you live, work, or where an alleged infringement occurred.
   

To exercise these rights, contact support@payelle.ai. We will respond without undue delay and in any event within one month of receiving a valid request, extendable as permitted by law.

9. International Data Transfers (GDPR)

Your information may be transferred to and processed in the United States or other countries that may not provide the same level of data protection as your home jurisdiction. By using the Service, you consent to this transfer.

Where required by law, we rely on:

• Standard Contractual Clauses;
   

• Article 49 GDPR derogations (e.g., your explicit consent, contract performance, pre-contractual measures); and
   

• Agreements with processors that include obligations to protect your privacy and data security.
   

Personal data transferred to the United States may be subject to lawful access requests by courts, law enforcement, and national security authorities. Subject to applicable laws, we will use reasonable efforts to ensure appropriate protections are in place.

10. Do Not Track

Our website and app do not currently respond to “Do Not Track” signals. We may collect information about your online activity while you use the Service and may track which website you visited immediately before or after using the Site.

11. Third-Party Websites

The Service may contain links to third-party sites or services that are not owned or controlled by Payelle. This Privacy Policy does not apply to those sites. We are not responsible for the privacy practices of third parties, including advertisers or analytics providers, who may use cookies, tracking pixels, or similar technologies.

12. Social Media Platforms

Any information, communications, or material that you submit to any third-party website or social media platform (including any Payelle-related pages on Instagram, Facebook, TikTok, etc.) is submitted at your own risk and without expectation of privacy. We cannot control the actions of other users or the platforms themselves and are not responsible for content or submissions on those platforms.

13. Cookie Policy

13.1 Types of Cookies Used

Strictly Necessary Cookies
These cookies are essential to enable you to move around the Site and use its features.

Functionality Cookies
These help remember your preferences, device information, and settings to improve your experience.

Analytics Cookies
These help us understand site usage and performance (for example, which pages are visited most frequently).

Advertising / Behavioral Cookies
Used by us or third parties to deliver relevant advertising and measure ad effectiveness.

13.2 Third-Party Cookies

Third-party advertisers, analytics providers, or social platforms may place cookies to collect information about your activities on our Site and elsewhere. They may combine this information with data from other sources to provide interest-based advertising and analytics. Their use of cookies is governed by their privacy policies, not ours.

13.3 How to Opt Out

You may control cookies through:

• Browser settings to block or delete cookies;
   

• Mobile device settings to limit tracking;
   

• Industry opt-out tools such as:
   

  • DAA: http://www.aboutads.info/choices
     

  • NAI: http://www.networkadvertising.org/choices
     

Please note that disabling cookies may affect the functionality of the Service.

14. Children’s Privacy

The Service is not intended for children under 18. We do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will delete it promptly.

If you believe a child under 13 has provided us with personal information, please contact us at support@payelle.ai.

We do not knowingly sell personal information of consumers under 18 years of age.

15. Correcting, Updating, or Deleting Your Information

You may request access, correction, deletion, or export of your data by contacting support@payelle.ai or, where available, through your account settings within the app. We will respond within the timeframes required by law and generally within 30 days of receiving a verified request.

16. Changes to This Privacy Policy

We may update this Policy periodically. Material changes will be communicated via email, in-app notice, or through the Site. The “Last Updated” date at the top indicates when changes were last made. Your continued use of the Service after any changes become effective constitutes your acceptance of the revised Policy.

17. Contact Information

Payelle, Inc.
Email: support@payelle.ai
Website: www.payelle.ai