PRIVACY POLICY

Version: 10.2025.003

Effective Date: July 3, 2026

Xero Allied Business Advantage, LLC d/b/a Securely (“Securely,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our payment software services (“Services”). This policy applies to users in the United States only and does not apply to individuals under the age of 18.

1. Information We Collect.We collect information you provide directly to us, as well as information generated through your use of our Services.
   1. Information You Provide
      • Account Information: Name, email address, business details, phone number, and payment method details.
      • Identity Verification: Government-issued ID, tax identification number, or other documentation required to verify your identity.
      • Communications: Messages you send to our support team or inquiries submitted through our website.
      • Sensitive Personal Information (SPI): Includes government-issued identification numbers (e.g., SSN, driver’s license), financial account information (e.g., bank routing/account numbers used for payment processing), and any authentication credentials as required by law or for fraud prevention.
   2. Information We Collect Automatically
      • Usage Data: Log data, including IP address, browser type, operating system, access times, and pages viewed.
      • Transaction Data: Payment details, such as transaction amounts, dates, and methods.
      • Cookies and Similar Technologies: Cookies, pixel tags, and similar technologies to improve user experience and analyze website activity.
   3. How We Use Your Information. We use the information we collect to:
      1. Provide, maintain, and improve our Services.
      2. Process payments and facilitate transactions.
      3. Verify your identity and comply with legal obligations.
      4. Communicate with you about your account, transactions, and updates.
      5. Prevent fraud, unauthorized access, and other illegal activities.
      6. Analyze usage trends to enhance user experience.
      7. Use of Sensitive Personal Information: We use sensitive personal information solely for legitimate business purposes such as identity verification, fraud prevention, regulatory compliance (e.g., FCPA, AML), and transaction processing. We do not use sensitive personal information for profiling or advertising.
         • Right to Limit Use of SPI (California Residents): If you are a California resident, you may have the right to request that we limit our use of sensitive personal information to only those uses necessary to provide services or comply with legal obligations. To exercise this right, please contact us at [email protected].
      8. How We Share Your Information.We do not sell your personal information. We may share your information with:
         1. Service Providers: Third-party companies that assist us with payment processing, customer support, and other operational needs.
         2. Compliance and Legal Obligations: Government agencies, regulators, or other parties as required to comply with applicable laws or enforce our terms of service.
         3. Business Transfers: In connection with a merger, sale, or other transfer of
         4. Artificial Intelligence and Machine Learning: Securely does not sell, share, or otherwise provide personal information collected through our platform to third parties for the purpose of training artificial intelligence or machine learning models, including large language models (LLMs). To the extent Securely utilizes AI-assisted tools internally, such tools are subject to our data security standards and are not permitted to use personal information for model training purposes.
      9. Your Privacy Rights.
         1. S. Residents (CCPA/CPRA):If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), including:

1. • • 1. Right to Know: Request details about the personal information we collect, use, and share.
       2. Right to Delete: Request deletion of personal information we hold about you.
       3. Right to Opt-Out: Request that we do not sell your personal information (though we do not sell information). To exercise these rights, please contact us at [email protected]. We will verify your identity before processing your request.

5. Data Security.We implement industry-standard administrative, technical, and physical safeguards to protect your data. However, no system can be guaranteed to be completely secure.
6. Data Retention.We retain your data as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce agreements. When no longer required, we securely delete or anonymize your data.
7. Children’s Privacy.Our Services are not intended for individuals under 18. We do not knowingly collect personal information from children. If discovered, such data, will be promptly deleted.
8. International Use.Our Services are intended for use within the United States only. If you are accessing our Services from outside the U.S., please do not use our platform.
9. Updates to This Privacy Policy.We may update this Privacy Policy from time to time. Changes will be posted on our website with an updated effective date. If changes are significant, we will notify you directly.
10. Contact Us.If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:

Xero Allied Business Advantage, LLC (d/b/a Securely)
Attention: Legal/Chief Operating Officer
P.O. Box 173984
Arlington, TX 76003
Email address for notices: [email protected]