‍Privacy Policy

Last Updated: Nov 13 2024                                             

This Privacy Policy contains an overview about the collection, use and disclosure of your personal data. Please check the Levro Terms of Use for the meaning of defined words (those with capital letters).

Please read this Privacy Policy carefully as it applies when you use our Services or visit our Website or use our App. We take privacy and protection of data seriously and are committed to handling the personal information of those we engage with, whether customers, suppliers or colleagues, responsibly and in a way that meets the legal requirements of the countries in which we operate.

Please note that we use information that we collect from or about our customers in accordance with our Consumer Privacy Notice, which provides choices about our sharing and use of information.

1. Who We Are

Levro, Inc. (“Levro”, “us”, “we”, “our”) is responsible for the collection, use, and disclosure of your personal information. If you have any questions about how we protect or use your data, please email us at [email protected].

2. Data We Collect About You

2.1 Information You Give Us
You may give us information, including personal information, about yourself when you sign up to use our Services, such as your name and email address. This also includes information you provide through your continued use of our Services, and when you report a problem with our Services. The information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, social security number, personal description, and photograph.
We may also need additional commercial and/or identification information from you (e.g., if you send or receive certain high-value or high-volume transactions or as needed to comply with our anti-money laundering obligations under applicable law).
In providing the personal information of any individual (other than yourself) that, for example, may receive payments from us as part of your use of our Services, you promise that you have obtained consent from such individual to disclose their personal data to us, as well as their consent to our collection, use, and disclosure of such personal information, for the purposes set out in this Privacy Policy.

2.2 Information We Collect About You
With regard to your use of our Services, we may automatically collect the following information, some of which may include personal information:

• Details of the transactions you carry out when using our Services, including the geographic location from which the transaction originates.
• Technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through, and from our Website or app (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our Customer Support number.

2.3 Information We Receive from Other Sources
We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. For example:

• The banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details.
• Business partners may provide us with your name and address, as well as financial information, such as card payment information.
• Advertising networks, analytics providers, and search information providers may provide us with pseudonymized information about you, such as confirming how you found our website.
• Credit reference agencies do not provide us with any personal information about yourself but may be used to corroborate the information you have provided to us.

2.4 Children’s Data
Our products and services are directed at adults 18 years and over and not intended for children. We do not knowingly collect information from this age group. Part of the verification process prevents Levro from collecting such data. If any information is collected from a child without verification of parental consent, it will be deleted.

3. How We Protect Your Personal Information

3.1 We seek to protect your personal information from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of personal information and how we are processing that data.

3.2 We use a secure server to store your personal information. All information you provide to us is stored on our secure servers. Any payment transaction information will be encrypted using Transport Layer Security (TLS) technology.

3.3 You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. More details about our security program can be found at Security at Levro. If you have reason to believe that your data or someone else’s data is no longer secure, please contact [email protected].

3.4 In the event of a security breach, we will take necessary measures to ensure the continued safety of data and contact affected parties and relevant regulators within a reasonable amount of time about the scope and scale of the unauthorized disclosure, as required by applicable laws.

4. Disclosure of Personal Information

We may disclose your personal information to the following categories of recipients:

• Service Providers
  These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology, and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Payment processors.
• Advertising Partners
  These parties help us market our services and provide you with other offers that may be of interest to you. They include:
  • Ad networks.
  • Data brokers.
  • Marketing providers.
• Analytics Partners
  These parties provide analytics on web traffic or usage of the Services. They include:
  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.
• Business Partners
  These parties partner with us in offering various services. They include:
  • Businesses that you have a relationship with.
  • Companies that we partner with to offer joint promotional offers or opportunities.
• Parties You Authorize, Access, or Authenticate
  • Third parties you access through the services.
  • Social media services.
  • Other users.

In addition, we may disclose information about you for the following purposes:

• Legal Obligations
  We may share any personal data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section below.
• Business Transfers
  All of your personal data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
• Data That is Not Personal Data
  We may create aggregated, de-identified, or anonymized data from the personal data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

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5. Our Commercial or Business Purposes for Collecting or Disclosing Personal Information
This section describes how we may use your Personal Data:

5.1 Providing, Customizing, and Improving the Service

• To carry out our obligations relating to your contract with us and to provide you with the information, products, and services.
• To notify you about changes to our Services.
• To customize our Services and the information we provide to you, and to address your needs (e.g., country of address and transaction history). For example, if you frequently send funds from one currency to another, we may use this information to inform you of new product updates or features that may be useful for you.
• As part of our efforts to keep our Services safe and secure.
• To administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To improve our Services and ensure that they are presented in the most effective manner.
• To measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you.
• To allow you to participate in interactive features of our Services, when you choose to do so.
• To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.
• To combine information we receive from other sources with the information you give to us and information we collect about you. This combined information may be used for the purposes outlined above (depending on the types of information received).
• Carrying out other business purposes as stated when collecting your personal data or as set forth in applicable data privacy laws, such as the California Consumer Privacy Act (CCPA).

5.2 Marketing the Services

• Marketing and selling the Services and similar goods and services we offer.
• Showing you advertisements, including interest-based or online behavioral advertising.

5.3 Corresponding with You

• Responding to correspondence we receive from you, contacting you when necessary or requested, and sending you information about Levro or our Services.
• Sending emails and other communications according to your preferences or with content that we think will interest you.

5.4 Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order, or other legal processes, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property, or safety of you, Levro, or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of personal data or use the collected data for materially different, unrelated, or incompatible purposes without providing you notice.

6. Personal Data Use and Processing Grounds (EEA Users)
This section outlines our lawful bases for processing your personal data. The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your personal data.
We will only process your personal data if we have a lawful basis, which may include consent, contractual necessity, or “legitimate interests” of us or others, as further described below.

Contractual Necessity:
We process the following categories of personal data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. Failure to provide such personal data may prevent you from using some or all portions of the Services that require such data.

• Certain Profile or Contact Data
• Certain Device/IP Data
• Certain Financial Data

Legitimate Interest:
We process the following categories of personal data when it furthers the legitimate interests of us or third parties:

• Certain Profile or Contact Data
• Web Analytics
• Professional or Employment-Related Data
• Geolocation Data
• Sensory Data
• Other Identifying Information that You Voluntarily Provide

Examples of legitimate interests include:

• Providing, customizing, and improving the Services.
• Marketing the Services.
• Corresponding with you.
• Meeting legal requirements and enforcing legal terms.
• Completing corporate transactions.

Consent:
In some cases, we process personal data based on your express consent. This will be clearly indicated at the point and time of collection.

Other Processing Grounds:
From time to time, we may also need to process personal data to comply with legal obligations, to protect vital interests, or to carry out tasks in the public interest.

7. Disclosure of Your Information

7.1 We may share your information with selected third parties, including:

• Affiliates, business partners, suppliers, and subcontractors for the performance of any contract with them or you.
• Advertisers and advertising networks to serve relevant adverts.
• Analytics and search engine providers to assist in website improvement and optimization.

7.2 We may disclose your personal information to third parties in the following situations:

• Affiliates, business partners, suppliers, and subcontractors for contract performance.
• In the event of a business or asset sale or purchase, we may disclose your data to the prospective seller or buyer.
• To comply with legal obligations, enforce agreements, or protect the rights, property, or safety of Levro, customers, or others. This includes fraud protection and credit risk reduction.
• For fraud investigations, crime prevention, or in response to legal orders.
• To assess financial and insurance risks and protect our operations or those of affiliates.
• To pursue remedies or limit damages sustained.
• To recover debt or in cases related to your insolvency.
• To develop customer relationships, services, and systems.

7.3 List of Third Parties
We do not publish a list of third parties with whom we share your data, as this depends on your use of our Services. However, for further information or a specific list, contact [email protected].

8. Sharing and Storing Your Personal Data
The data we collect from you may be transferred to, and stored at, a location outside the United States. It may also be processed by staff outside the US working for us or suppliers. By submitting your personal information, you agree to this transfer and processing. We will ensure that your data is treated securely and per this Privacy Policy.

9. Tracking Tools and Opt-Out
We use cookies and similar technologies to recognize your browser, tell us how and when you use our Services, analyze trends, and operate and improve our Services.

• Essential Cookies: Necessary for website functionality.
• Analytic Cookies: Used to measure and improve website performance.
• Functional Cookies: Enhance functionality and personalization.
• Advertising Cookies: Manage and display advertisements based on your online activities.

You can manage cookies through browser settings. For more information on managing cookies, visit www.allaboutcookies.org.

10. Retention of Your Information
Levro is legally required to store some personal and transactional data beyond account closure. We retain data for as long as necessary for the purposes stated in this Privacy Policy, unless a longer retention period is required by law. Retention periods vary depending on services and products and are based on criteria such as:

• Service and product provision.
• Auditing and policy enforcement.
• Legal compliance and troubleshooting.

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11. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that differ from the laws of your country. Specifically, our Website servers are located in the United States, and our third-party service providers and partners operate globally, although data is stored in the United States. The Services are hosted and operated in the United States (“U.S.”) by Levro and its service providers. If you do not reside in the U.S., the laws in the U.S. may differ from those in your country of residence.

By using the Services, you acknowledge that any Personal Data about you, whether provided by you or obtained from a third party, is being provided to Levro in the U.S. and will be hosted on U.S. servers. You authorize Levro to transfer, store, and process your information in the U.S. and possibly other countries. In some cases, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

12. California-Related Rights

12.1 California Consumer Privacy Act Notice

This section addresses the disclosure requirements under the California Consumer Privacy Act of 2018 (the CCPA) for California residents. This notice should be read together with our Privacy Policy and applies to all California residents who visit our Website or use our Services. These terms do not address or apply to our handling of personal information that is exempt under the CCPA.

Please note, this section does not apply to information we collect from job applicants, employees, or contractors. If you are a job applicant, employee, or contractor, please contact [email protected] for more information about your privacy rights.

12.2 California Consumer Privacy Act

Our processing of personal information varies based on our relationship and interactions with you. Below, we describe the categories of personal information (as defined by the CCPA) that we may collect about California residents and the categories of third parties to whom we may disclose that information for business or commercial purposes.

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Consumer Privacy Rights

• Access: You have the right to request twice in a 12-month period that Levro disclose the personal information we have collected about you in the past 12 months. This may include:
  • The categories of sources of the consumer’s personal information
  • The business or commercial purpose for collecting or selling the consumer’s personal information
  • The categories of any third parties with whom we share the consumer’s personal information or to whom personal information is sold
  • The specific pieces of personal information collected about the consumer
• Correction: You have the right to request that we correct certain personal information we have collected. If you make a correction request, we may correct or delete information as allowed by law. This right is subject to certain exceptions under CCPA.
• Deletion: You have the right to request that we delete certain personal information we have collected from you, subject to exceptions.
• No Discrimination: You will not be discriminated against for exercising your CCPA rights.
• Personal Data Selling/Sharing Opt-Out: Under CCPA, you have certain rights when a business discloses personal information for purposes such as cross-contextual behavioral advertising. We have not knowingly “sold” or “shared” personal information from anyone under 16.
• Limit the Use of My Sensitive Personal Information: We use Sensitive Personal Information solely for essential business purposes and do not offer a separate option to limit its use.

Authorized Agents

Consumers may designate an agent to make CCPA requests on their behalf. We will verify both the consumer’s identity and the agent’s authorization.

"Shine the Light"

Under California Civil Code Sections 1798.83-1798.84 (“Shine the Light”), California residents may request a list of third parties with whom we have shared personal information and the categories of information shared.

To exercise your rights to know, delete, and/or correct, please submit your request in writing to:

Levro, Inc.
Attention: Legal and Compliance Team
660 4th Street #509
San Francisco, CA 94107

Or by email at [email protected].

13. Third-Party Links

Our Services may include links to websites of our partner networks, advertisers, and affiliates. Please review their privacy policies before submitting any personal data to these websites.

14. European Union, United Kingdom, and Swiss Data Subject Rights

You have the following data protection rights:

• Access, correct, update, or request deletion
  If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to Contact Us” section below.
• Object to processing, restrict processing, or request portability
  If you are a resident of the EU, UK, or Switzerland, you can object to the processing of your personal information, ask us to restrict its processing, or request portability of your personal information. You can exercise these rights by contacting us using the contact details provided under the “How to Contact Us” section below.
• Opt-out
  You have the right to opt-out of marketing communications we send you at any time. You can do so by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “How to Contact Us” section below.
• Withdraw consent
  If we have collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of any processing conducted prior to your withdrawal, nor will it affect processing conducted on lawful grounds other than consent.
• Right to complain
  You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

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15. Changes to Our Privacy Policy

15.1 To keep up with best practices, new legislation, and changes in how we collect and use personal information, we may modify this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will post the revised policy on the website and update the “Last Updated” date. Your continued use of our services after these changes means that you accept the revised Privacy Policy.

If you would like to review the version of the Privacy Policy effective immediately prior to this revision, please contact us at [email protected].

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16. How to Contact Us

16.1 Questions, comments, and requests regarding this Privacy Policy are welcomed and should be addressed to our global privacy team at [email protected], or you can write to us at the following address:

Levro, Inc.
Attention: Legal and Compliance Team
660 4th Street #509
San Francisco, CA 94107

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