PRIVACY POLICY

SOFT PAY LLC
FinCEN Registration Number: 31000307011822

Effective Date: 09/15/2025
Last Updated: 09/15/2025

1. INTRODUCTION

SOFT PAY LLC ("Company," "we," "us," or "our") is a Money Services Business (MSB) registered with the Financial Crimes Enforcement Network (FinCEN) under registration number 31000307011822. We are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our money services business services.

By using our services, you consent to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our services.

2. INFORMATION WE COLLECT

2.1 Personal Information

We collect personal information that you provide directly to us, including but not limited to:

  • Identity Information: Full name, date of birth, Social Security number, government-issued identification numbers

  • Contact Information: Physical address, mailing address, telephone numbers, email addresses

  • Financial Information: Bank account information, credit/debit card information, transaction history, source of funds

  • Employment Information: Occupation, employer name and address, income information

  • Verification Information: Documentation used to verify your identity and eligibility for our services

2.2 Transaction Information

We collect information related to your transactions, including:

  • Transaction amounts, dates, and frequencies

  • Beneficiary information for money transfers

  • Purpose of transactions

  • Geographic location of transactions

2.3 Automatically Collected Information

We may automatically collect certain information about your device and usage, including:

  • IP addresses and device identifiers

  • Browser type and operating system

  • Website usage patterns and preferences

  • Location data (with your consent)

2.4 Information from Third Parties

We may obtain information about you from third-party sources, including:

  • Identity verification services

  • Credit reporting agencies

  • Government databases and watchlists

  • Other financial institutions

3. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

3.1 Service Provision

  • Process and complete your financial transactions

  • Verify your identity and eligibility for services

  • Maintain your account and provide customer service

  • Communicate with you about your transactions and account

3.2 Legal and Regulatory Compliance

  • Comply with federal and state laws and regulations

  • Meet Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) requirements

  • File required reports with FinCEN and other regulatory agencies

  • Respond to legal process and government requests

  • Prevent fraud, money laundering, and other illegal activities

3.3 Business Operations

  • Improve and develop our services

  • Conduct risk management and internal audits

  • Analyze transaction patterns and customer behavior

  • Marketing and promotional activities (with your consent)

4. HOW WE SHARE YOUR INFORMATION

We may share your personal information in the following circumstances:

4.1 Regulatory and Legal Requirements

  • With FinCEN, federal and state regulatory agencies

  • With law enforcement agencies as required by law

  • In response to court orders, subpoenas, or legal process

  • To prevent fraud or comply with anti-money laundering laws

4.2 Service Providers and Business Partners

  • With third-party service providers who assist in our operations

  • With correspondent banks and financial institutions

  • With identity verification and fraud prevention services

  • With payment processors and technology providers

4.3 Business Transactions

  • In connection with mergers, acquisitions, or sale of assets

  • To successors in interest in the event of business transfer

4.4 Other Disclosures

  • With your explicit consent

  • To protect our rights, property, or safety

  • To protect the rights, property, or safety of others

  • As otherwise permitted or required by law

5. DATA SECURITY

We implement appropriate technical, administrative, and physical safeguards to protect your personal information against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

  • Encryption of sensitive data in transit and at rest

  • Multi-factor authentication systems

  • Regular security assessments and audits

  • Employee training on data protection

  • Secure data centers and network infrastructure

  • Access controls and monitoring systems

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security.

6. DATA RETENTION

We retain your personal information for as long as necessary to:

  • Provide you with our services

  • Comply with legal and regulatory requirements

  • Resolve disputes and enforce agreements

  • Meet our business needs

Generally, we retain customer information for at least five (5) years after account closure or last transaction, as required by federal regulations. Some information may be retained longer as required by law or for legitimate business purposes.

7. YOUR PRIVACY RIGHTS

Depending on your location and applicable laws, you may have certain rights regarding your personal information:

7.1 Access and Correction

  • Request access to your personal information

  • Request correction of inaccurate information

  • Request updates to your contact information

7.2 Data Portability and Deletion

  • Request a copy of your personal information in a portable format

  • Request deletion of your personal information (subject to legal and regulatory requirements)

7.3 Communication Preferences

  • Opt out of marketing communications

  • Choose your preferred method of communication

To exercise these rights, please contact us using the information provided in Section 11.

8. COOKIES AND TRACKING TECHNOLOGIES

We may use cookies, web beacons, and similar tracking technologies to:

  • Remember your preferences and settings

  • Analyze website usage and performance

  • Provide targeted content and advertisements

  • Enhance security and prevent fraud

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of our services.

9. THIRD-PARTY LINKS AND SERVICES

Our website or services may contain links to third-party websites or services. This Privacy Policy does not apply to information collected by third parties. We encourage you to review the privacy policies of any third-party sites or services you visit.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

  • Posting the updated policy on our website

  • Sending you an email notification

  • Providing notice through our services

The "Last Updated" date at the top of this policy indicates when it was most recently revised. Your continued use of our services after any changes constitutes your acceptance of the updated Privacy Policy.

11. CONTACT INFORMATION

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

SOFT PAY LLC
1001 S MAIN ST STE 600
KALISPELL 59901 – MONTANA (USA)
Phone: +1 917 352 84 27
Email: info@thesoftpay.com
Website: www.thesoftpay.com

Privacy Officer:
Sara Simon legal@thesoftpay.com

Customer Service Hours:
Mo-Fr 9am to 6pm EST

12. REGULATORY INFORMATION

SOFT PAY LLC is registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN) under registration number 31000307011822. We are subject to federal and state regulations governing money services businesses, including but not limited to:

  • Bank Secrecy Act (BSA)

  • USA PATRIOT Act

  • Anti-Money Laundering (AML) regulations

  • State money transmitter licensing requirements

For questions about our regulatory compliance or to file a complaint, you may also contact:

FinCEN
Financial Crimes Enforcement Network
P.O. Box 39
Vienna, VA 22183
Website: www.fincen.gov

13. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA). For information about your California privacy rights, please contact us using the information provided above.

14. CHILDREN'S PRIVACY

Our services are not intended for 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 such information promptly.

This Privacy Policy is effective as of the date listed above and supersedes all previous versions.