Privacy Policy

1. Information We Collect

Depending on how you interact with us, we may collect the following categories of information:

• Identifiers and contact details (name, email, phone number, mailing address).
• Government ID data for KYC (e.g., driver's license, passport number).
• Date of birth and residency/address information.
• Transaction information (amounts, assets exchanged, dates, branch location, receipts).
• Compliance information (KYC forms, risk and screening results required by law).
• Device and usage data (IP address, browser type, pages viewed, cookies and similar technologies).
• Geolocation derived from IP (approximate, for security and analytics).
• Audio/visual: video surveillance in our offices; audio recording only with your prior consent.

2. Sources of Information

• Directly from you (forms, documents you provide in person or via our website).
• Automatically from your device when you visit the site (cookies, logs, analytics).
• From service providers that help us operate (IT, security, analytics), under confidentiality.
• From public sources or regulators where legally required.

3. How We Use Information

• To provide and improve our in-person exchange services.
• To comply with the Bank Secrecy Act, FinCEN regulations, and other legal obligations (AML/KYC, recordkeeping, reporting).
• To verify identity, prevent fraud and abuse, ensure security, and protect our customers and business.
• To communicate with you about appointments, receipts, support, and service updates.
• To maintain business continuity, auditing, and legal defense.

4. Cookies and Tracking Technologies

• We use cookies and similar technologies to analyze traffic and improve your experience. By continuing to browse our website, you consent to the use of cookies as described in this Privacy Policy.
• You can manage or withdraw consent at any time through your browser settings. Non-essential cookies are used for analytics and functionality only.

5. Sharing and Disclosure

We do not sell or share personal information for monetary or commercial gain.

We may disclose information to:

• Service providers that process data on our behalf (e.g., IT, security, analytics), under contracts and confidentiality.
• Banks, auditors, advisors, and insurers as reasonably necessary for operations and compliance.
• Law enforcement, courts, or regulators (including FinCEN/OFAC/DFPI) when legally required.
• Parties to a corporate transaction (e.g., merger), subject to appropriate safeguards.

6. Retention

• We retain AML/KYC and transaction records for at least five (5) years as required by the Bank Secrecy Act (31 CFR §1022.410).
• Other records are retained only as long as necessary for the purposes described in this Policy, after which they are securely deleted or anonymized.

7. California Privacy Rights (CCPA/CPRA)

California residents have the right to:

• Know what categories of personal information we collect, use, disclose, or retain.
• Access and obtain a copy of specific pieces of personal information.
• Delete personal information (subject to legal exceptions such as AML/BSA recordkeeping).
• Correct inaccurate personal information.
• Opt out of sale or sharing of personal information (we do not sell or share personal information as defined by CPRA).
• Limit the use and disclosure of sensitive personal information (we use sensitive data only for required compliance purposes).
• Non-discrimination for exercising your privacy rights.

How to exercise your rights: email [email protected]. We will verify your request and respond within the timelines required by California law. Authorized agents may submit requests with valid proof of authorization. A "Do Not Sell or Share My Personal Information" link is available in our website footer.

8. Do Not Track and Global Privacy Control

• Some browsers transmit "Do Not Track" (DNT) signals. There is no industry consensus on how to respond to DNT.
• We honor Global Privacy Control (GPC) signals to the extent required by California law.

9. Children's Privacy

• Our services are intended for individuals 18 years and older. We do not knowingly collect personal information from children under 16.
• If you believe a child has provided us information, contact [email protected] to request deletion.

10. Audio and Video Recording Notice

• For security, compliance, and fraud-prevention purposes, our offices are equipped with video surveillance.
• Audio recording may occur only with your prior consent, which is obtained through our online appointment form.
• By confirming your appointment and visiting our office, you acknowledge and consent to video monitoring and, where applicable, audio recording, in accordance with California law (California Penal Code §632).
• Recordings are used solely for: (i) safety and security; (ii) incident logging and investigation; (iii) legal and regulatory compliance (including AML/KYC inquiries where permitted); and (iv) protection of people and property. We do not use recordings for marketing or profiling.
• Recordings are retained for 90 days unless longer retention is required for an active investigation, legal request, or to comply with law, after which they are securely deleted or anonymized.
• Access is restricted to authorized personnel and vetted service providers (e.g., cloud security vendors) under confidentiality and security obligations.
• We do not place cameras, nor do we record, in areas where recording is prohibited or where a heightened expectation of privacy applies.

11. Security

• We implement administrative, technical, and physical safeguards designed to protect personal information.
• No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. International Transfers

• We generally store and process personal information in the United States.
• If data is transferred outside your state or country, we will take appropriate measures to protect it in accordance with this Policy and applicable law.

13. Changes to This Policy

• We may update this Privacy Policy from time to time. We will post the updated version on this page with a new effective date.
• Your continued use of our website or services after changes are posted indicates your acceptance of the updated Policy.

14. Contact Us

If you have questions or wish to exercise your privacy rights, contact us at:

• Email: [email protected]
• Mail: Easy Peasy Inc., 109 W Wilson Ave, #219, Glendale, CA 91203, USA