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Last updated: February 1, 2024

Thank you for choosing to be part of our community at Switch Pay LLC, doing business as Switch (“Switch”, “we”, “us”, “our”). We are committed to protecting your Personal Information and your right to privacy.

This Privacy Policy (“Policy”) describes our current policies regarding collection, use, distribution, and protection of Personal Information you share with us on our website (the “Website”) any of our services (the “Switch Services” and together with the Website, the “Services”), as well as any related services, sales, marketing, or events where we interact with you. We appreciate that you trust us with your Personal Information.

We take your privacy very seriously. In this Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to your Personal Information. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of our Services immediately.

This Policy does not apply to websites, software, or applications run by third-parties that Switch may link to, reference, or otherwise contract with, so please reference the respective third-party privacy policy for information on how they collect and use your information.

If you have any questions or concerns about this Policy, or our practices with regards to your Personal Information, please contact us at

















  1. WHAT INFORMATION DO WE COLLECT?In Short: We collect Personal Information that you provide to us, and any information automatically collected when you visit our Website.

    We collect Personal Information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Switch Services, when you participate in activities on the Website, or otherwise when you contact us.

    The Personal Information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. This includes information we may collect from you or you may voluntarily provide us with certain information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you, your household, or your device used to access the Website (the “Personally

    Identifiable Information” or “PII”) and any information from which your identity is not readily ascertainable but collected automatically through your use of the Website or the Switch Services (“Non-PII”) (collectively, “Personal Information”).

    PII may include real names; phone numbers; email addresses; mailing addresses; usernames; passwords; contact or authentication data; billing data; billing addresses; debit/credit card numbers; and other similar information. All PII that you provide to us must be true, complete and accurate, and you must notify us promptly of any changes to such PII.

    Non-PII may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

    Like many businesses, we also collect information through cookies and similar technologies.

    The information we collect includes:

    • Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity on the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
    • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include informationsuch as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
    • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note, however, if you choose to opt out, you may not be able to use certain aspects of the Services.
  2. HOW DO WE USE YOUR INFORMATION?In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

    We use Personal Information collected via our Website for the business purposes described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

    We use the information we collect or receive:

    • To facilitate account creation and log-on process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those thirdparties to facilitate account creation and logon process for the performance of the contract.
    • To post testimonials. We post testimonials on our Website that may contain Personal Information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at and be sure to include your name, testimonial location, and contact information.

    • Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
    • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
    • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
    • To send administrative information to you. We may use your PII to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
    • To protect our Switch Services. We may use your Personal Information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
    • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract with you.
    • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
    • To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
    • To administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
    • To deliver and facilitate delivery of Services to you. We may use your information to provide you with the requested Service.
    • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Switch Services.
    • To send you marketing and promotional communications with your consent. We and/or our third-party marketing partners may use the Personal Information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect Personal Information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).
    • To deliver targeted advertising to you with your consent. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
    • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include PII. We will not use PII without your consent.
    • Depending on your location, you may have a right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
  3. LEGAL BASES FOR PROCESSING YOUR PERSONAL INFORMATION AND WHO WE SHARE IT WITHIn Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

    The laws in some jurisdictions require us to tell you about the legal ground that we use or disclose your Personal Information. To the extent those laws apply, our legal grounds for processing your Personal Information are as follows:

    • Consent: Where required by law, and in some other cases, we handle your Personal Information if you have given us specific consent to use your Personal Information for a specific purpose. Where legally required, this is explicit consent.
    • Legitimate Interests: In most cases, we handle your Personal Information on the ground that it is reasonably necessary to achieve our legitimate business interests and is not overridden by your interests or fundamental rights and freedoms:
      • Protecting our business, personnel, and property.
      • Providing cybersecurity, including for the protection of your Personal Information.
      • Customer service and improving our business practices.
      • Marketing.
      • Managing legal issues.
    • Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract or to take steps at your request in anticipation of entering into a contract with you.
    • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
    • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.We may also process your Personal Information for the same legitimate interests of our customers and business partners. More specifically, we may need to process your data or share your Personal Information in the following situations:
    • With service providers acting on our behalf.
    • With other participants in the payment ecosystem, including financial institutions, and merchants.
    • With third parties for fraud monitoring and prevention purposes, or other purposes required by law.
    • In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  4. DO WE USE COOKIES, AUTOMATED DATA COLLECTION, AND OTHER TRACKING TECHNOLOGIES?In Short: We may use cookies and other tracking technologies to collect and store your information.

    We may use automated means such as cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice below.

    Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website.

  5. CONTROLS FOR DO-NOT-TRACK FEATURESMost web browsers and some mobile operating systems and mobile applications include a Do-NotTrack (“DNT”) feature or setting you can activate to signal your

    privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

  6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?In Short: We may transfer, store, and process your information in countries other than your own.

    Our servers are located in the United States. If you are accessing our Website from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your Personal Information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in the United States, and other countries. We will comply with applicable legal requirements when transferring your Personal Information to countries other than the country where you are located.

    If you are located in the European Economic Area (EEA), we will transfer your Personal Information in accordance with adequacy decisions (see list of countries for which the European Commission has issued an adequacy decision here), Binding Corporate Rules, standard contractual clauses (discussed further below), and other data transfer mechanisms.

    If you are not a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all reasonable measures to protect your Personal Information in accordance with this Policy and applicable law of your country of residence.

    European Commission’s Standard Contractual Clauses:

    We have implemented measures to protect your Personal Information, including by using the European Commission’s Standard Contractual Clauses for transfers of Personal Information between our group companies and between us and our

    third-party providers. These clauses require all recipients to protect all Personal Information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

  7. HOW LONG DO WE KEEP YOUR INFORMATION?In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

    We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Policy will require us keeping your Personal Information for longer than the period of time in which users have an account with us.

    When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

  8. HOW DO WE KEEP YOUR INFORMATION SAFE?In Short: We aim to protect your Personal Information through a system of organizational and technical security measures.

    We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information we process or that you provide to us. However, despite our safeguards and efforts to secure your information,

    no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our Website is at your own risk. You should only access the Website within a secure environment.

  9. DO WE COLLECT INFORMATION FROM MINORS?In Short: We do not knowingly collect data from or market to children under 18 years of age.

    Our Services are not intended for children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that Personal Information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at and we will take steps to remove that information promptly.

  10. WHAT ARE YOUR PRIVACY RIGHTS?In Short: Your rights may be determined by where you live and the laws that apply to your Personal Information.

    Under applicable law, in some regions (like the EEA and UK), you have rights that allow you greater access to and control over your Personal Information. You may contact us as described below to make these requests.

    You may review, change, or terminate your account at any time. Your rights may include the right to:

    • Request access and obtain a copy of your Personal Information;
    • Request correction, supplementation, anonymization, blocking, or erasure of your Personal Information that is inaccurate, incomplete, outdated, unnecessary, excessive, or processed in non-compliance with applicable requirements;
    • Restrict the processing of your Personal Information; and
    • Request to receive a copy of the Personal Information you provided to us in a portable form or that we transmit it to a third party.In certain circumstances, you may also have the right to object to the processing of your Personal Information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

      If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

      If you are a resident in the EEA or UK and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:

      If you are a resident in Switzerland, the contact details for the data protection authorities are available here:

      Rights Relating to your Account Information

      If you would at any time like to review or change the information in your account or terminate your account, you can:

    • Contact us using the contact information provided.Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

      To opt-out of interest-based advertising by advertisers on our Website visit

      Opting out of email marketing

      You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

    • Contact us using the contact information provided.

      Opting out of targeted advertising

      When you use our online services, we (and our vendors) may collect information about your activities so that we can provide you with advertising tailored to your interests.

      You can opt out of targeted advertising by visiting the Digital Advertising Alliance website or the Network Advertising Initiative website . If you choose to opt out, you will continue to receive advertisements but they will not be tailored to your interests.

      If you have questions or comments about your privacy rights, you may email us at

  11. PRIVACY RIGHTS RELATED TO CALIFORNIA RESIDENTSIn Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your Personal Information.

    The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), permits California residents who use our website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, or if you have any questions or concerns about your California privacy rights, our Privacy Policy, or our use of your personal information, please send an email to

    For all California residents, any such inquiries shall be responded to within forty-five

    (45) days. We must verify your identity with respect to such inquiries. Depending on the nature of the Personal Information at issue, we may require additional measures or information from you as part of that verification.

    For California residents under age 18 who have publicly posted content or information, you may request and obtain removal of such content or information pursuant to California Business and Professions Code Section 22581, provided you are a registered user of any website where this Policy is posted. To make such a request, please send an email with a detailed description of the specific content or information to

    CCPA Privacy Notice

    The categories of Personal Information we may have collected and disclosed is described in Sections 1 and 11 of this Policy. During the 12 months leading up to the effective date of this Policy, we made the following disclosures of Personal Information about Californians for business purposes:



    Colle cted

    A. Identifiers

    Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name


    B. Personal Information categories listed in the California Customer Records statute

    Name, contact information, education, employment, employment history and financial information


    C. Protected classification characteristics under California or federal law

    Gender and date of birth


    D. Commercial information

    Transaction information, purchase history, financial details and payment information


    E. Biometric information

    Fingerprints and voiceprints


    F. Internet or other similar network activity

    Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements


    G. Geolocation data

    Device location


    H. Audio, electronic, visual, thermal, olfactory, or similar information

    Images and audio, video or call recordings created in connection with our business activities


    I. Professional or employment-related information

    Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us


    J. Education Information

    Student records and directory information


    K. Inferences drawn from other Personal Information

    Inferences drawn from any of the collected Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics


    Will your Personal Information be shared with anyone else?

    We also have shared all categories of Personal Information we collect as set forth in Sections 1 and 11, including with governmental entities for legal purposes and our affiliates and service providers. Each service provider is a for-profit entity that processes the information on our behalf.

    We may use your Personal Information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

    Switch Pay LLC has not disclosed or sold any Personal Information to third parties for a business or commercial purpose in the preceding 12 months as traditionally understood. Switch Pay LLC will not sell Personal Information in the future belonging to website visitors, users and other consumers.

    Notice of Privacy Rights for California Residents

    Right to request deletion of the data – Request to delete

    You can ask for the deletion of your Personal Information. If you ask us to delete your Personal Information, we will respect your request and delete your Personal Information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

    Right to be informed – Request to know

    Depending on the circumstances, you have a right to know:

    • whether we collect and use your Personal Information;
      • the categories of Personal Information that we collected in the last twelve months;
      • the purposes for which the collected Personal Information is used;
      • whether we sell your Personal Information to third parties;
      • the categories of Personal Information that we sold or disclosed for a business purpose;
      • the categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
      • the business or commercial purpose for collecting or selling Personal Information.

    In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

    Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights.

    Right to Limit Sensitive Personal Information Use

    You may request that we limit our use of sensitive information (e.g. information relating to your government ID or geolocation) to specifically permitted purposes.

    Right to Opt-Out

    You can request that we stop any sharing of your Personal Information. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

    Verification process

    Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

    We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting

    additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

    If you are an agent making a request on behalf of a consumer, we reserve the right to take steps to verify that you are authorized to make that request, which may include requiring you to provide us with written proof such as a notarized authentication letter or a power of attorney. We also may require the consumer to verify their identity directly with us. Because opt-out requests for sales made through cookies and related technology must be performed from each browser that is used to access our Services, it is easiest for the consumer to perform such opt-outs themselves. However, if a consumer wishes for an agent to perform browser-based requests on their behalf, the consumer may arrange for the agent to use the consumer’s browser to make such requests. We are not responsible for the security risks of this or any other arrangements that a consumer may have with an agent. For clarity, this is not permission for any user to share their login credentials with an agent or any third party. Such sharing is prohibited and is not required for an agent to make requests under this Privacy Policy. For security and legal reasons, however, we reserve the right not to accept requests that require us to access third-party websites or services.

    To exercise these rights, you can contact us by email at, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

  12. RESIDENTS OF COLORADO, CONNECTICUT, UTAH, AND VIRGINIAWe treat collected information of persons residing in any jurisdiction with the utmost care and in accordance with applicable law.

    Colorado – we adhere to the consumers’ privacy rights and company personal data collection duties set forth in Colorado’s comprehensive data privacy law known as the Colorado Privacy Act (CPA), or Colo. Rev. State. § 6-1-1301 et seq., which comports with the Colorado Consumer Protection Act.

    Connecticut – we do and will abide by Connecticut’s primary data privacy law known as Personal Data Privacy and online Monitoring, or 2022 S.B. 6 or Public Act No. 22-15 effectual on July 1, 2023, which gives Connecticut residents the right to request a copy

    of their personal data, correct any inaccuracies, and opt out of personal data processing. Moreover, we comply with Conn. Gen. Stat. § 42-471, which mandates that we safeguard personal information from being misused by third parties and erase it upon disposal.

    Utah – we observe the requirements of Utah’s 2022 S.B 227, known as the Utah Consumer Privacy Act (UCPA) effectual as of December 31, 2022, which gives consumers the right to know:

  13. RESIDENTS OF OTHER U.S STATES AND COMPLIANCE WITH FEDERAL LAWWe reiterate that we treat collected information of persons residing in any jurisdiction with the utmost care and in accordance. Thus, for purposes of clarity, we pronounce our adherence to the following laws of these U.S. States:
  14. DO WE MAKE UPDATES TO THIS NOTICE?In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

    We may update this Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

  15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?Based on the applicable laws of your country, you may have the right to request access to the Personal Information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your Personal Information, email

If you have questions or comments about this Policy, you may contact us by email at