1. Introduction

Untappd Labs Inc., doing business as Specie (“we,” “us,” “our”), is committed to protecting your privacy and the security of your personal information. This Privacy Policy (“Policy”) explains how we collect, use, disclose, store, and protect information when you use our platform at specie.finance, our web and mobile applications, and all related services (collectively, the “Services”).

This Policy applies to all users of the Services, including business entities and their authorized representatives. 

Specie provides technology and infrastructure that enables businesses to facilitate certain financial and digital asset transactions with regulated financial institutions and service providers. Specie is not a bank, money transmitter, broker-dealer, or custodian of customer funds. Financial services available through the Services may be provided by regulated third-party partners subject to their own terms and privacy policies.

By accessing or using the Services, you acknowledge that you have read, understood, and agree to the practices described in this Policy.

2. Information We Collect

2.1 Information You Provide Directly

• Business information: Legal entity name, registration number, jurisdiction of incorporation, business address, industry, and nature of business activities.

• Identity verification information: Information required for identity verification, sanctions screening, anti-money laundering monitoring, fraud prevention, and other regulatory compliance obligations.

• Authorized representative information: Full name, date of birth, nationality, government-issued identification documents, proof of address, email address, phone number, and role within the business.

• Financial information: Bank account details, payment instructions, source of funds documentation, and transaction history.

• Communications: Correspondence you send to us, including support requests, feedback, and survey responses.

2.2 Information Collected Automatically

• Device and access information: IP address, browser type, operating system, device identifiers, and access timestamps.

• Usage data: Pages visited, features used, transaction patterns, session duration, and referral sources.

• Blockchain data: Wallet addresses, on-chain transaction hashes, and smart contract interactions related to your use of the Services. Transactions conducted on blockchain networks may be publicly recorded on distributed ledgers and may be visible to third parties. Specie does not control the operation of blockchain networks and cannot modify or delete information recorded on a blockchain.

2.3 Information from Third Parties

We may receive information about you from our regulated partners, identity verification providers, sanctions screening databases, credit reporting agencies, publicly available sources, and other third parties, for the purposes of compliance, fraud prevention, and service delivery.

These third parties may include financial institutions, payment processors, blockchain analytics providers, fraud prevention vendors, compliance service providers, and other infrastructure providers that support the operation of the Services.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Service delivery: To create and manage your account, process transactions, facilitate payments, and provide access to platform features.

• Compliance and legal obligations: To conduct KYC/KYB verification, AML and CTF screening, sanctions checks, transaction monitoring, and to fulfill reporting requirements under applicable laws.

• Fraud prevention and security: To detect, prevent, and investigate fraud, unauthorized access, and other illegal activities.

• Platform improvement: To analyze usage patterns, troubleshoot issues, develop new features, and improve the overall user experience.

• Communications: To send you service-related notifications, security alerts, compliance updates, and, where you have opted in, marketing communications.

4. How We Share Your Information

We do not sell your personal information. We may share your information with the following categories of recipients:

• Regulated partners: Partners receive information necessary to provide their respective services. Each partner processes your information under its own privacy policy and applicable regulatory framework.

• Compliance and identity verification providers: Third-party vendors that assist with KYC/KYB verification, sanctions screening, and ongoing compliance monitoring.

• Law enforcement and regulators: When required by law, legal process, or regulatory request, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

• Service providers: Hosting providers, analytics services, customer support tools, and other vendors who process data on our behalf under appropriate contractual safeguards.

• Sub-processors and infrastructure providers: Vendors that support our technology platform, including cloud hosting providers, security monitoring providers, analytics services, and blockchain infrastructure providers.

• Corporate transactions: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the successor entity.

5. International Data Transfers

Your information may be transferred to, stored in, and processed in countries other than your country of residence, including the United States, where our servers and partners are located. These countries may have data protection laws that differ from those in your jurisdiction.

Where required by applicable law, we implement appropriate safeguards for international data transfers, including standard contractual clauses or other mechanisms recognized by relevant authorities. By using the Services, you consent to the transfer of your information as described in this Policy.

6. Data Retention

We retain your personal information for as long as your account is active and as necessary to provide the Services. We also retain information as required to comply with legal and regulatory obligations, including AML record-keeping requirements, which may require us to retain certain data for a minimum of five (5) years after the termination of the business relationship, or longer as required by applicable law.

When retention is no longer necessary, we will securely delete or anonymize your information in accordance with our data retention procedures.

7. Data Security

We implement administrative, technical, and physical security measures designed to protect your information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and use of SOC 2-compliant infrastructure.

However, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee its absolute security.

8. Your Rights

Depending on your jurisdiction of residence and applicable law, you may have certain rights regarding your personal information, including the following:

• Access: Request a copy of the personal information we hold about you.

• Correction: Request correction of inaccurate or incomplete information.

• Deletion: Request deletion of your personal information, subject to legal retention requirements.

• Portability: Request a copy of your data in a structured, commonly used, and machine-readable format.

• Objection and restriction: Object to or request restriction of certain processing activities.

• Withdraw consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact us at privacy@specie.finance. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request.

9. Jurisdiction-Specific Provisions

Depending on your location, you may have additional rights under applicable data protection laws. The following provisions supplement the rights described in Section 8 of this Policy.

9.1 United States 

If you are a resident of certain U.S. states, including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Tennessee, and Indiana, you may have additional rights under applicable state privacy laws.

Depending on your state of residence, these rights may include:

• The right to confirm whether we process your personal information

• The right to access personal information we hold about you

• The right to correct inaccurate personal information

• The right to request deletion of personal information

• The right to obtain a copy of personal information in a portable format

• The right to opt out of certain processing activities, such as targeted advertising or profiling where applicable

• The right to appeal a denial of a privacy rights request where required by law

To exercise any applicable rights, please contact privacy@specie.finance.

We do not sell personal information or share personal information for cross-context behavioral advertising.

9.2 European Economic Area, United Kingdom, and Switzerland

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you may have rights under applicable data protection laws, including the General Data Protection Regulation (GDPR).

These rights may include:

• The right to access your personal data

• The right to correct inaccurate data

• The right to request erasure of personal data

• The right to restrict processing

• The right to object to certain processing activities

• The right to data portability

• The right to lodge a complaint with a supervisory authority

Specie processes personal data based on one or more lawful bases including:

• Performance of a contract

• Compliance with legal obligations

• Legitimate business interests

• Consent, where required by applicable law

If you wish to exercise any of these rights, please contact privacy@specie.finance.

9.3 Latin America

Specie may provide Services to businesses and users located in Latin American jurisdictions. Users located in these jurisdictions may have additional rights under applicable national data protection laws.

9.3.1 Argentina (Ley 25.326)

If you are located in Argentina, you have the right to access, rectify, update, and delete your personal data held in databases.

You may exercise these rights by contacting privacy@specie.finance.

You also have the right to file a complaint with the Agencia de Acceso a la Información Pública (AAIP).

9.3.2 Brazil (Lei Geral de Proteção de Dados – LGPD)

If you are located in Brazil, you have the rights provided under the LGPD, including:

• Confirmation of processing
• Access to personal data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking, or deletion of unnecessary or excessive data
• Data portability
• Information regarding sharing with third parties

You may exercise these rights by contacting privacy@specie.finance.

You may also file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

9.3.3 Mexico (LFPDPPP)

If you are located in Mexico, we process personal data in accordance with the Ley Federal de Protección de Datos Personales en Posesión de los Particulares.

You have the right to exercise ARCO rights, including:

• Access

• Rectification

• Cancellation

• Opposition

To exercise these rights, please submit a request to privacy@specie.finance. 

9.3.4 Colombia (Ley 1581 of 2012)

If you are located in Colombia, you have the right to know, update, rectify, and delete your personal data, and to revoke consent for its processing.

Requests may be submitted to privacy@specie.finance.

You may also file a complaint with the Superintendencia de Industria y Comercio (SIC).

9.3.5 Peru (Ley 29733)

If you are located in Peru, you have the right to access, rectify, cancel, and oppose the processing of your personal data.

Requests may be submitted to privacy@specie.finance.

You may also file a complaint with the Autoridad Nacional de Protección de Datos Personales.

10. Cookies and Tracking Technologies

We use cookies, pixels, and similar technologies to enhance your experience, analyze usage, and support our operations. These technologies may collect information about your device, browsing behavior, and interaction with the Services. You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Services.

11. Children’s Privacy

The Services are intended for use by business entities and their authorized adult representatives. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will take steps to delete it promptly.

We do not direct the Services to children and do not knowingly allow minors to create accounts or submit personal information through the Services.

If you believe a minor has provided us personal information, please contact us at privacy@specie.finance so we can take appropriate action.

12. Third-Party Links and Services

The Services may contain links to third-party websites or integrate with third-party services. This Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you access through our platform, including those of our regulated partners.

When you use third-party services in connection with the Services (including services provided by regulated financial institutions, identity verification providers, blockchain infrastructure providers, and analytics providers), those third parties may independently collect, use, and disclose your information subject to their own terms and privacy policies.

Specie is not responsible for the privacy practices or the content of third-party websites, services, or platforms, and your interactions with such third parties are governed by their applicable terms.

If you connect a third-party account or wallet to the Services, you authorize us to receive information from that third party as permitted by your settings and the third party’s policies.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will update the Effective Date and, where practicable, provide notice through the platform or by email. Your continued use of the Services after a change to this Policy constitutes acceptance of the updated Policy.

14. Contact Information

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

Untappd Labs Inc., DBA Specie

Email: privacy@specie.finance

Website: specie.finance