Aspire Privacy Policy

AFT US LLC, d/b/a Aspire, respects your privacy and is committed to protecting your personal information. This Privacy Policy outlines how we collect, use, share, and protect personal information in compliance with U.S. regulations and other applicable federal and state laws.

1. Scope and Applicability

This Privacy Policy applies to all personal information collected, processed, or stored by Aspire in connection with Aspire services, including data collected through our website, applications, and any other interactions with end users, business customers, partners, vendors, representatives, visitors and other business contacts. It covers both online and offline data collection methods and applies to current and prospective customers, as well as stakeholders involved in our business operations. 

Throughout this Policy, "you" may refer to:

• End User: An individual whose data is processed in connection with Aspire’s services, including as a customer, cardholder, authorized user or beneficiary.
  
• Representative: An individual acting on behalf of a business (e.g. owner, director, or employee) who engages with Aspire.
  
• Visitor: An individual or business who visits our website, mobile app, or contacts Aspire support without being an Aspire customer.
  
• Business Customer: A company or legal entity that enters into an agreement with Aspire to use our services and may provide personal data of End Users or Representatives.

2. Information We Collect

We collect the following categories of  information to comply with legal obligations, fulfill contractual requirements, and improve our services:

a) Identification and Authentication Information

• Name, business email address, username, password, job title, and company name.
• Government-issued identification, TIN, social security number, and security codes.
• Contact information such as phone numbers, email addresses and physical addresses.

b) Financial and Payment Information

• Bank account details, credit and debit card information, billing address, and transaction history.
• Information collected to verify your identity and facilitate transactions.
• Details of payment methods and transactional data necessary to perform financial operations.

c) Demographic Information

• Date of birth, gender, and marital status, collected only when necessary for legal compliance or internal business processes.
• The processing of this data is based on legal obligations or legitimate business interests.

d) Usage and Device Information

• IP addresses, browser characteristics, device identifiers, operating system versions, geolocation data, and other internet activity information.
• Collected via cookies, web beacons, and similar tracking technologies.

e) Employment and Professional Information

• Details of employment history, qualifications, and professional affiliations where relevant to our business operations or compliance requirements.

f) Preference Information

• Marketing and communication preferences, including opt-in status for promotional communications.
• Preferences related to product and service usage.

g) Information Automatically Collected Through Use of Aspire Services

We automatically collect certain information when you interact with the Aspire Services. This includes:

• Device Information: Such as your device type, operating system, device ID, and browser type.
  
• Usage Information: Including pages viewed, links clicked, time spent, and features used.
  
• Location Data: If enabled, we may collect precise geolocation data from your device or infer location from your IP address.
  
• Log and Analytics Data: Such as access times, error reports, and performance diagnostics.

3. How We Use Your Information

We use personal data for the following purposes:

• To provide and improve our services and maintain customer relationships.
• To comply with regulatory requirements and meet obligations under applicable federal and state law.
• To enhance security, fraud detection, and risk management.
• To conduct analytics and performance monitoring to improve our offerings.
• To send relevant updates and marketing communications, where permitted by law.
• To support internal business processes, such as auditing, compliance monitoring, and data integrity checks.

4. Data Retention and Deletion

We retain your personal information only as long as necessary to fulfill the purposes outlined or as required by applicable laws. Upon termination of the business relationship or at the individual’s request, we will securely delete personal data unless retention is required for for one or more of the following purposes:

• To comply with legal or regulatory obligations (e.g. anti-money laundering, tax, or accounting requirements);
  
• To process transactions initiated prior to the termination of the relationship;
  
• To collect outstanding fees or resolve billing issues;
  
• To detect or prevent fraud, financial crime, or other unlawful activities;
  
• To respond to legal proceedings or requests from law enforcement or regulatory authorities;
  
• To enforce our agreements or defend legal claims;
  
• To fulfill contractual obligations with our ecosystem or financial partners.
  

Specific retention periods may vary depending on the type of data and the applicable legal or operational requirements. When data is no longer needed for the above purposes, it will be securely deleted or irreversibly anonymized in accordance with our data retention and destruction policies.

5. How We Share Your Information

We may share your personal information with:

• Affiliates and Subsidiaries: To support business functions and enhance service delivery.
• Service Providers: For data processing, analytics, and customer support functions.
• Regulatory Authorities: To comply with legal obligations and reporting requirements.
• Law Enforcement Agencies: When required by law or in response to valid legal requests.
• Partners: To support product offerings, collaborations and joint initiatives, where data sharing is necessary.
• Third-Party Auditors and Advisors: To ensure compliance with regulatory and legal standards.

We do not sell personal data to third parties. All data sharing is conducted in line with applicable legal standards and transparency requirements.

6. Data Security and Breach Notification

We implement robust security measures to protect personal data, including encryption, access controls, and regular security assessments. In the event of a data breach, we will promptly notify affected individuals and regulators as required by law. Notifications will be made within the legally mandated timeframes, and affected individuals will be informed of the nature of the breach, the data involved, and the measures taken to mitigate risks.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to personalize your experience and improve our services. A cookie is a small text file placed on your computer or mobile device when you visit a website or use a mobile application. Cookies collect information about users and their visit to the website or use of the mobile application, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or mobile application. We also use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our websites and/or through our mobile application.

If you wish to deny the use and saving of cookies from the Platform on to your computers and/or other electronic devices, you should take the necessary steps within your internet browsers’ security settings to block all cookies from the Platform. You can choose to delete the cookies at any time. However, do note that when you enable blocking of cookies, certain features and functions may be limited in your use of our websites or mobile application. Where legally required, we obtain your consent before setting non-essential cookies. 

8. Your Privacy Rights and Choices

You have the right to the following rights, as applicable:

• Access and receive a copy of your personal data.
• Request correction or deletion of your data.
• Object to or restrict processing of your personal data.
• Opt-out of marketing communications.
• Withdraw consent where it was previously given.

To exercise these rights, please contact us at privacy@aspire.com. We will verify your identity before processing your request to ensure data protection.

9. International Transfers

Your information may be transferred and processed outside your jurisdiction. We ensure that adequate safeguards are in place to protect data during such transfers, including the use of Standard Contractual Clauses where required.

10. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or regulatory requirements. We encourage you to review it regularly. Changes will be posted with a revised effective date and will be made accessible on our website.

11. Contact Information

For questions or concerns about this Privacy Policy, contact us at privacy@aspire.com or mail us at AFT US LLC, 800 North State Street, Suite 304, Dover, Delaware 19901.