TClub, Inc., a Delaware corporation, doing business as Abound (“Abound,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy explains how Abound collects, uses, discloses, retains, and protects personal information when you access or use the Abound Platform (including www.joinabound.com and the Abound mobile application), or any Abound Service that links to this Privacy Policy. It also applies, as described below, when Abound receives or processes personal information in connection with a Platform Partner Service, including a Remittance Transfer or Virtual Asset Transfer.
THIS PRIVACY POLICY DESCRIBES YOUR PRIVACY CHOICES AND RIGHTS. IT IS A NOTICE OF ABOUND'S DATA PRACTICES; IT DOES NOT REPLACE ANY POINT-OF-USE NOTICE, CONSENT, AUTHORIZATION, PLATFORM PARTNER PRIVACY POLICY, OR OTHER PRIVACY DISCLOSURE THAT APPLIES TO A PARTICULAR FEATURE.
ABOUND PROVIDES ABOUND SERVICES. PLATFORM PARTNERS INDEPENDENTLY PROVIDE PLATFORM PARTNER SERVICES UNDER THEIR OWN PLATFORM PARTNER TERMS AND PRIVACY POLICIES. SERVICE PROVIDERS PROCESS PERSONAL INFORMATION FOR ABOUND OR A PLATFORM PARTNER AND DO NOT NECESSARILY PROVIDE A SERVICE DIRECTLY TO YOU OR ENTER INTO A DIRECT CONTRACT WITH YOU. FOR A PARTICULAR FEATURE OR TRANSACTION, ANY APPLICABLE POINT-OF-USE PRIVACY NOTICE, CONSENT, AUTHORIZATION, PLATFORM PARTNER PRIVACY POLICY, OR OTHER LEGALLY REQUIRED PRIVACY DISCLOSURE CONTROLS TO THE EXTENT OF A CONFLICT WITH THIS PRIVACY POLICY.
Definitions. Capitalized terms not defined in this Privacy Policy have the meanings given in the Abound User Agreement and Terms of Service (“User Agreement”). In addition to the capitalized terms given in the User Agreement, in this Privacy Policy, “Sensitive Personal Information” means information given heightened protection under an applicable state privacy law, including Social Security or government-identification numbers, financial-account credentials, precise geolocation, biometric or health information, and similar categories identified by Applicable Law; and “Notice of Financial Incentive” means the point-of-use disclosure Abound or a Platform Partner provides before enrollment in a Rewards, loyalty, or similar program that is treated as a financial incentive under Applicable Law.
1.1.Inclusions. This Privacy Policy applies to personal information that Abound collects or receives:
1.1.1.directly from you or from another person who is authorized to provide information about you, including a Recipient or referral contact;
1.1.2.automatically when you access or use the Abound Platform or an Abound Service;
1.1.3.from Platform Partners, Service Providers, merchants, financial institutions, rewards networks, analytics providers, advertising partners, affiliates, and other third parties; and
1.1.4.from public sources, public blockchains, sanctions and watchlist databases, fraud-prevention tools, consumer reporting sources where permitted, and other legal or compliance sources.
1.2.Exclusions. This Privacy Policy does not govern:
1.2.1.the independent data practices of a Platform Partner, third-party website, application, or service that is not controlled by Abound. Such parties process personal information in accordance with their own privacy policies, notices, and applicable terms as have been agreed between you and the relevant Platform Partner or Service Provider. Where a Platform Partner or Service Provider acts as an independent data controller with respect to the Services, its applicable privacy policy and terms govern and control that processing. To the extent of any inconsistency between this Privacy Policy and the applicable privacy policy or terms of that Platform Partner or Service Provider with respect to such processing, the applicable third-party privacy policy and terms will control the relationship between you and such party;
1.2.2.personal information governed by a separate privacy notice for a specific product, program, employment or applicant relationship, or other context, to the extent that separate notice applies.
1.3.Financial privacy laws. Certain personal information processed in connection with a Platform Partner Service may be processed by Abound as a service provider to a regulated financial institution. If a separate financial privacy notice provided by the applicable financial institution or otherwise applicable to the relevant financial service applies, that notice supplements this Privacy Policy and controls for the covered nonpublic personal information. Legal exemptions are data- and activity-specific; other personal information may remain subject to applicable state privacy law.
1.4.Supplemental and point-of-use notices. Abound or a Platform Partner may provide a shorter notice at or before collection, including a bank-linking, biometric, AI, cookie, state-specific, or Transaction-specific notice. A more specific notice supplements this Privacy Policy and controls for the data practice it describes to the extent of a conflict. Such notices may also describe additional purposes, disclosures, choices, consents, or rights applicable to the relevant processing activity. Any changes to a Platform Partner’s or a Service Provider’s privacy policy or terms will be governed by the applicable terms and policies accepted by you.
2.1.
| Category | Examples | Typical Sources | Main Purposes |
|---|---|---|---|
| Identifiers and contact information | Name, username, email address, telephone number, postal address, date of birth, Account identifier | You; a Recipient, referral contact, or other person you authorize; support interactions; Platform Partners and Service Providers | Account creation; eligibility; support; service communications; security; fraud prevention |
| Government, identity, and biometric verification data | Driver’s license, passport, tax identification number, Social Security number, identification images, selfie or liveness information, biometric identifiers or templates, verification results | You; Platform Partners and Service Providers, including identity-verification providers; verification and public databases | Onboarding; identity and age verification; KYC/AML and sanctions screening; fraud prevention; Account security |
| Financial, payment, and account-linking data | Bank and routing information, card information or tokens, linked-account and balance information, ACH authorizations, Payment Instrument identifiers | You; banks; card networks; Platform Partners and Service Providers, including bank-linking and payment providers | Account linking and verification; transmitting payment instructions; subscription billing; refunds; fraud prevention. Abound may receive tokenized or limited data rather than full credentials |
| Transaction, Recipient, and remittance data | Transfer amount, Fees, FX Rate, destination, Recipient identity and bank information, payment purpose, Transaction status, cancellation, error, refund, and complaint information | You; Recipients; Cybrid and other Platform Partners; banks and payout providers | Orchestrating Transactions; displaying status; providing support; routing remittance notices and complaints; compliance and recordkeeping |
| Virtual Asset and public blockchain data | Wallet addresses, asset or stablecoin type, network selection, Transaction hash, public-ledger data, conversion and payout information | You; public blockchains; Platform Partners; blockchain analytics and other Service Providers | Orchestrating Virtual Asset Transfers; security; fraud and sanctions screening; support; compliance; analytics |
| Rewards, Abound Wallet, referral, promotion, subscription, and commercial information | Rewards and cashback activity, Abound Wallet display information, offers viewed or activated, referral codes and participation, merchant interactions, subscription status and billing history, contest or promotion entries, survey or poll responses, and commercial preferences, | You; merchants; rewards and card networks; Platform Partners; app marketplaces; promotion sponsors and Service Providers | Administering Rewards, offers, contests, surveys, promotions, referrals, subscriptions, billing, eligibility, analytics, campaign measurement and abuse prevention |
| Social-media and third-party integration data | Social-account identifier, public profile information, email address, profile photograph, and other information you authorize a social platform to provide, only to the extent social-media login capability is enabled by Abound and authorized by you | Social-media platforms; social login providers; embedded-content, GIF, media, or sharing providers; your device; and your interactions with the applicable integration | Authenticating your Account and providing social-media login functionality, only to the extent you enable or authorize that capability |
| Internet, device, usage, and advertising data | IP address, device identifier, browser, operating system, app version, carrier, logs, cookies, SDK data, session and usage events, referral URL, advertising interactions | Your device; Abound Platform; analytics, security, advertising, and measurement Service Providers | Platform operation; authentication; security; analytics; personalization; advertising and attribution; product improvement |
| Device permissions, files, media, and contacts | Metadata and content from files stored on your device, such as photos, media and you select for upload, camera or microphone content, and contacts or address-book information, when you grant or enable the relevant device permission or affirmatively select the information for use with an Abound feature | You; your device; device operating-system permissions; and Service Providers that support the applicable feature | To provide the feature you request; upload or process selected content; verify identity; provide support, and communications |
| Location data | Approximate location derived from IP address; device-based or precise location if you enable it | Your device; network data; Platform Partners and Service Providers | Fraud prevention; eligibility; localization; security; requested location-based functionality |
| Communications and support data | Emails, chats, support tickets, call recordings, survey responses, feedback, disputes, complaints, and security reports | You; Recipients; Platform Partners; customer-support and communications Service Providers | Support; quality assurance; training; dispute and complaint handling; security; fraud prevention; legal compliance |
| AI Input, Output, and related data | Prompts, files, instructions, generated Output, feedback, safety signals, usage metadata, and derived information | You; the AI Service; AI Service Providers or Platform Partners | Generating Output; operating, securing, supporting, evaluating, and improving AI Services and the Abound Platform; preventing abuse |
| Inferences, risk signals, and consumer-report data | Fraud scores, verification results, risk indicators, service preferences, eligibility indicators, and consumer report or credit information where separately authorized and permitted | Internal analysis; Platform Partners; Service Providers; fraud and consumer reporting sources where permitted | Security; fraud prevention; compliance; risk assessment; eligibility; service optimization |
2.2.Sensitive Personal Information. We may collect Sensitive Personal Information only where reasonably necessary and permitted by Applicable Law, including Social Security or tax identification numbers, government identification information, financial-account credentials, precise geolocation if enabled, biometric or liveness information, and the contents of communications. We use this information primarily for identity verification, account security, fraud prevention, legal and compliance obligations, Transaction orchestration, and the Abound Services or Platform Partner Services you request. We do not use Sensitive Personal Information to infer characteristics about you except as permitted by law and disclosed to you. If we use or disclose Sensitive Personal Information for a purpose that gives you a right to limit that use or disclosure, we will provide the required notice and method to exercise that right.
2.3.Biometric and identity-verification information. A Platform Partner or Service Provider may collect identification images, selfies, liveness information, or biometric identifiers or templates. The applicable flow will identify the collecting entity and present any notice, consent, and retention information required by Applicable Law. Abound may receive a verification result or risk signal rather than the underlying biometric template.
3.1.We collect personal information in the following ways:
3.1.1.Directly from you and people you authorize. We collect information when you create an Account, complete onboarding, link a Payment Instrument, submit identity information, initiate a Transaction, use an Abound Wallet display or Virtual Asset feature, activate or redeem an offer, enroll in a subscription, participate in a referral or Rewards program or any other survey, poll, contest, sweepstakes or promotional program offered by Abound, use an AI Service, upload any media or other content, contact support, or otherwise interact with the Abound Platform. If you provide personal information about a Recipient, referral contact, or another person, you should provide only information that you are authorized to provide and which is reasonably necessary for the applicable feature. Information you submit through the Abound Platform may be collected by or transmitted to a Platform Partner for Platform Partner Services. In those cases, the Platform Partner, not Abound, provides the applicable services, and its privacy policy and terms govern and control its collection and use of that information.
3.1.2.Automatically from the Abound Platform. We collect device, usage, advertising, and technical information through cookies, pixels, software development kits (“SDKs”), logs, application programming interfaces (“APIs”), and similar technologies.
3.1.3.From Platform Partners, Service Providers, and other third parties. We may receive personal information from:
3.1.4.identity-verification, biometric, compliance, and fraud-prevention providers;
3.1.5.banks, payment processors, card networks, ACH originators, and app marketplaces;
3.1.6.bank-linking and account-verification providers;
3.1.7.remittance, payout, on-ramp, off-ramp, Virtual Asset, and other Platform Partners;
3.1.8.public blockchains, wallet infrastructure providers, and blockchain analytics providers;
3.1.9.merchants, rewards networks, advertising partners, and referral sources;
3.1.10.analytics, communications, customer-support, AI, security, and other Service Providers;
3.1.11.affiliates and corporate group companies;
3.1.12.social media platforms and plug-in providers, where applicable, to the extent the relevant capability is enabled by Abound and authorized or used by you; and
3.1.13.public records, sanctions databases, consumer reporting sources where permitted, and legal or compliance sources.
4.1.Using personal information. We use personal information only for disclosed purposes that are reasonably necessary and proportionate to the context in which the information was collected, including the following:
4.1.1.Provide the Abound Services. We use personal information to create and maintain your Account; operate the Abound Platform; provide interfaces, instruction routing, status displays, support, Rewards, offers and promotions, subscriptions, surveys, polls, contests, sweepstakes, and Abound-provided AI functionality; and provide other Abound Services you request.
4.1.2.Facilitate Platform Partner Services and Transactions. We use personal information to transmit your instructions and related information to Platform Partners and Service Providers, support onboarding and verification, display Transaction status, communicate pricing and disclosures, and otherwise orchestrate a requested Platform Partner Service. The applicable Platform Partner, not Abound, performs the underlying Financial Service, including any remittance, money-transmission, payment, acquisition, custody, conversion, settlement, off-ramp or payout service. The applicable Platform Partner’s privacy policy and terms govern and control its collection, use, and processing of personal information in connection with such Financial Services. Abound does not itself collect, hold, move, exchange, convert, settle, redeem, take custody of, or pay out funds or Virtual Assets, except to the extent expressly stated in the User Agreement or required by Applicable Law.
4.1.3.Verify identity, eligibility, and compliance. We use personal information to verify identity and Payment Instruments, prevent duplicate Accounts, determine eligibility, conduct sanctions, anti-money-laundering, fraud, and risk checks, and comply with legal, regulatory, or Platform Partner requirements. A consumer report, credit report, or credit score may be obtained or used only where the requesting party has a permissible purpose and provides any separate notice or obtains any authorization required by Applicable Law.
4.1.4.Protect the Abound Platform and prevent misuse. We monitor Transaction activity, device signals, behavioral patterns, and information received from Platform Partners and Service Providers to identify suspicious activity, Account compromise, promotion abuse, payment fraud, sanctions risk, security incidents, and other unlawful or prohibited conduct.
4.1.5.Communicate, support, and route requests. We send verification codes, receipts, confirmations, reminders, security alerts, policy updates, and support responses; investigate disputes concerning the Abound Platform or Abound Services; and provide customer support. Except where Abound is expressly designated as the Platform Partner’s agent for the relevant communication, use of an Abound support channel does not constitute legally effective notice to the Platform Partner, extend any statutory or contractual deadline, or obligate Abound to investigate, decide, respond to, or provide a remedy in respect of a Platform Partner Service. You remain responsible for using the legally operative contact method identified in the applicable disclosure.
4.1.6.Administer Rewards, offers, referrals, and subscriptions. We use personal information and, where authorized, linked Transaction data to determine eligibility, validate qualifying activity, prevent abuse, post or reverse Rewards, administer subscription billing and benefits, and communicate applicable terms. We may also use personal information to administer surveys, polls, contests, sweepstakes, and promotional programs, including to verify eligibility and measure program performance.
4.1.7.Analyze, personalize, and advertise. We use device, usage, commercial, and analytics information to troubleshoot, test, measure performance, improve functionality, optimize user flows, develop features, personalize content and offers, attribute campaigns, and conduct advertising or measurement, subject to your choices and Applicable Law.
4.1.8.Provide and improve AI Services. We process Input, Output, feedback, safety signals, and related metadata to generate Output; operate, secure, support, evaluate, and improve AI Services and the Abound Platform; prevent abuse; and provide support. An AI Service may be supported by a Service Provider or, where disclosed, provided directly by a Platform Partner.
4.1.9.Protect rights and enforce agreements. We use personal information to investigate violations, resolve disputes, recover amounts owed, preserve evidence, enforce the User Agreement and applicable offer terms, and protect the rights, safety, and property of Abound, Users, Platform Partners, Service Providers, and others.
4.1.10.Comply with law and conduct business operations. We use personal information for legal, compliance, audit, reporting, recordkeeping, tax, insurance, law-enforcement, and regulatory purposes, and in connection with financing, due diligence, reorganizations, mergers, acquisitions, sales of assets, or similar corporate transactions.
4.1.11.Create aggregated or de-identified information. We may aggregate, anonymize, or de-identify personal information and use it for analytics, benchmarking, security, product development, reporting, and other lawful purposes. Where required by Applicable Law, we will maintain de-identified information in de-identified form and will not attempt to reidentify it.
4.1.12.Purpose compatibility and data minimization. We will not collect materially different categories of personal information or use personal information for a materially incompatible purpose without providing any notice and obtaining any consent required by Applicable Law.
5.1.Disclosing personal information. We may disclose personal information to the following categories of recipients for the purposes described below:
| Recipient Category | Examples | Why We Disclose |
|---|---|---|
| Platform Partners and regulated financial providers | The direct provider identified in the applicable point-of-use flow or in the relevant schedule of the User Agreement, which may include Cybrid, Coinbase, Saber, or another Platform Partner | To provide Platform Partner Services, including Remittance Transfers, Virtual Asset services, onboarding, conversion, settlement, payout, and related compliance |
| Service Providers and operational vendors | Cloud hosting, security, customer support, communications, analytics, AI, fraud-prevention, and software providers, including providers supporting embedded-content, media, or promotion-related functionality | To operate, secure, support, analyze, and improve the Abound Platform and Abound Services and to provide the applicable feature or request |
| Bank-linking, identity, and verification providers | Plaid, Persona, and similar providers, acting as a Service Provider or Platform Partner as identified in the applicable point-of-use flow | To link and verify accounts, authenticate Payment Instruments, verify identity, conduct liveness or fraud checks, and support onboarding |
| Banks, payment processors, card networks, ACH participants, and app marketplaces | Financial institutions, card networks, payment processors, ACH originators, Apple App Store, and Google Play | To support payments, subscriptions, refunds, Transaction funding, network processing, and billing |
| Merchants, rewards and card networks, referral, advertising, analytics, and measurement partners | Cashback and merchant networks, card-linked offer providers, advertisers, and campaign-measurement providers | To validate qualifying activity, administer Rewards, surveys, contests, sweepstakes, promotional programs and referrals, personalize offers, measure campaigns, and conduct advertising subject to your choices |
| Affiliates and corporate family | Parent, subsidiary, and affiliated entities | For internal administration, support, analytics, security, compliance, and product or marketing operations |
| Professional advisers, auditors, insurers, and financing sources | External counsel, auditors, accountants, consultants, insurers, lenders, and investors | For legal advice, audit, insurance, financing, diligence, risk management, and corporate administration |
| Authorities and legal recipients | Regulators, law enforcement, courts, sanctions authorities, and other governmental bodies | To comply with Applicable Law, legal process, reporting obligations, and requests from competent authorities; and to protect rights and safety of Users, the Abound Platform, the Abound Services, Platform Partners or Service Providers |
| Corporate transaction counterparties | Prospective or actual buyers, sellers, investors, lenders, merger counterparties, and advisers | For due diligence, financing, reorganization, merger, acquisition, asset sale, or similar transaction administration |
| Other recipients at your direction or as permitted by law | Persons you direct us to contact or disclose to; recipients of information you intentionally make public; other legally permitted recipients | To follow your instructions, provide requested functionality, protect rights and safety, or comply with Applicable Law |
5.2.Other disclosures. We may also disclose personal information:
5.2.1.at your direction or with your consent;
5.2.2.when you intentionally make information available through a public or external channel;
5.2.3.as otherwise permitted or required by Applicable Law, including to protect rights, safety, and security or respond to legal process.
5.3.Platform Partner and Service Provider Context. The relevant schedules of the User Agreement specifies the current Platform Partners and relevant Service Providers. The entity, classification, documents, and data practices identified in the applicable point-of-use flow control. Depending on the feature you use, Abound may disclose personal information to or receive it from the following parties for the roles described in the applicable flow:
5.3.1.Cybrid Technology Inc. for Remittance Transfers, onboarding and identity verification, ACH and payment infrastructure, Virtual Asset conversion, settlement, payout support, and remittance complaint routing, where enabled;
5.3.2.Coinbase, Inc. for digital-asset on-ramp, stablecoin acquisition, conversion, guest-checkout, or related functionality, where enabled;
5.3.3.Saber Money Canada Inc. for where enabled;
5.3.4.Plaid Inc. for bank-account linking, account verification, balance and Transaction information, and related payment support, where enabled;
5.3.5.Jasnah, Inc. (NEAR AI) and other AI providers for AI-assisted tools, support, rate alerts, transfer-planning features, summaries, or automation support, where enabled;
5.3.6.Sumsub Inc. which provides identity-document collection, liveness verification, KYC/AML screening, fraud prevention, and related compliance support, where enabled;
5.3.7.Tazapay Canada Corp which provides services in relation to transmission of User Funds to the Recipient; and
5.3.8.merchants, rewards and card networks, app marketplaces, advertising and measurement partners, communications providers, and other Platform Partners or Service Providers used for the applicable feature.
5.4.Platform Partner and Service Provider roles. When a Platform Partner directly provides a Platform Partner Service, it may collect, use, retain, and disclose personal information under its own privacy policy, which, together with its applicable terms as have been agreed between you and the relevant Platform Partner, governs and controls its processing of personal information in connection with that service. A Service Provider generally processes personal information for Abound or a Platform Partner under contractual restrictions, although a Service Provider may separately act as a Platform Partner where the applicable flow expressly identifies a direct relationship.
5.5.Sale, sharing, and targeted advertising. We do not sell personal information for money. We may disclose identifiers, internet or device activity, usage information, and commercial information including Rewards or offer-interaction information, to advertising, analytics, social media, affiliate, and measurement partners in ways that may be treated as a “sale,” “sharing,” or “targeted advertising” under certain state privacy laws. We do not use government identification information, financial-account credentials, precise geolocation, or biometric verification data for cross-context behavioral advertising, and we do not knowingly sell or share the personal information of anyone under 16 years of age. You may request to opt-out of any “sale”, “sharing”, or “targeted advertising” by e-mailing us at support@joinabound.com. An opt-out does not restrict disclosures that are necessary to provide an Abound Service or Platform Partner Service, comply with law, or disclose information to a Service Provider under an applicable legal exception.
5.6.Rewards and financial incentives. Rewards, cashback, referral benefits, subscription benefits, discounts, or other programs may qualify as a financial incentive or price or service difference under certain state privacy laws. Where required, Abound will provide a separate Notice of Financial Incentive or applicable offer terms before enrollment describing the material terms, the categories of personal information implicated, how the benefit is reasonably related to the value of the information, and how to opt in or withdraw. Participation is voluntary. You may withdraw from an applicable program as described in the offer terms. Withdrawal may end eligibility for future benefits but will not affect a non-waivable privacy right or treatment of a vested Reward except as permitted by the applicable terms and Applicable Law.
6.1.Usage of Cookies. Abound and its Service Providers may use cookies, SDKs, tags, pixels, APIs, local storage, and similar technologies to:
6.1.1.remember your preferences, maintain sessions, and provide requested functionality;
6.1.2.secure your Account and detect suspicious or abusive activity;
6.1.3.measure the performance of the Abound Platform and communications;
6.1.4.understand use of and improve the Abound Platform and Abound Services;
6.1.5.personalize content, advertising, Rewards, and offers, subject to your choices; and
6.1.6.attribute referrals, advertising, or marketing campaigns.
6.2.Data collected. These technologies may collect information such as IP address, device identifier, browser type, operating system, application version, session information, usage events, referral URLs, and advertising interactions.
6.3.Managing cookie preferences. You may manage certain technologies through, browser or device settings, and the privacy choices described in Section 12. Essential technologies may be required for security, authentication, fraud prevention, or core functionality, and some features may not operate properly if they are disabled.
6.4.Do Not Track signals. The Abound Platform may not respond uniformly to traditional “Do Not Track” signals.
7.1.Communications. Abound may send or cause the following communications to be sent:
7.1.1.transactional or service communications, including verification codes, receipts, Transaction or Account notices, security alerts, policy updates, support messages, and legally required notices; and
7.1.2.marketing communications, including promotions, offers, surveys, and product announcements, where permitted by Applicable Law and consistent with any separate consent you provide.
7.2.Opt-out. You may opt out of marketing emails through the unsubscribe link in the message and opt out of marketing text messages by replying STOP, where supported. Marketing consent is not a condition of purchasing or using an Abound Service or Platform Partner Service, and you may revoke consent through any reasonable method identified in the applicable communication or enrollment terms. Opting out of marketing does not affect transactional or service-related communications. Message and data rates may apply.
7.3.Recording related consents. We may record calls or retain chat transcripts, support messages, and related metadata for support, quality assurance, training of personnel or systems, fraud prevention, security, and dispute handling. We will provide notice or obtain consent before recording where required by Applicable Law.
8.1.Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. For instance, user bank login credentials are not stored on Abound servers, and Abound uses Transport Layer Security (“TLS”) to help protect personal information transmitted to Abound.
8.2.Data security risks. No security program can eliminate all risk, and we cannot guarantee absolute security. Platform Partners and third-party services, including Service Providers and those providing any plug-in capacities, maintain their own security practices and are responsible for their systems and for the personal information they process in connection with their services, subject to their applicable privacy policies and terms. You are also responsible for protecting your credentials, devices, one-time passcodes, PINs, biometric authentication, email account, telephone number, and other Account access methods as described in the User Agreement.
9.1.Retention criteria. We retain personal information only for as long as reasonably necessary for the disclosed purposes, taking into account the following criteria:
9.1.1.Account, identifier, and contact information is generally retained while your Account is active and thereafter as needed for support, fraud prevention, legal obligations, and dispute resolution;
9.1.2.identity-verification, Transaction, payment, Remittance Transfer, Virtual Asset, and compliance records are retained for the period required by Applicable Law, Platform Partner obligations, audit, fraud, sanctions, tax, and dispute needs; certain records may be retained for at least five years where an applicable legal or regulatory requirement so provides;
9.1.3.Rewards, offer, referral, subscription, and communications records are retained as needed to administer the applicable program, reconcile activity, provide support, address disputes, and satisfy tax or accounting requirements;
9.1.4.device, cookie, advertising, analytics, and AI-related information is retained according to the applicable feature, cookie setting, vendor configuration, security need, and disclosed purpose;
9.1.5.information subject to a legal hold, security incident, investigation, claim, audit, or enforcement matter is retained for as long as reasonably necessary to address that matter.
9.2.Retention period by Platform Partners, Service Providers, and Abound. Platform Partners, Service Providers and other third-parties determine their own retention periods under their respective privacy policies, platform terms including Platform Partner Terms, and legal obligations. Abound does not retain personal information for longer than is reasonably necessary for a disclosed purpose, subject to legal, security, fraud-prevention, dispute, backup, and recordkeeping requirements.
9.3.Deletion, archiving, and de-identification. When personal information is no longer required, we may delete it, securely archive it where continued retention is permitted or required, or de-identify or anonymize it. Where Applicable Law requires, we maintain de-identified information in de-identified form and do not attempt to reidentify it.
10.1.International processing. Abound is based in the United States and may process or store personal information in the United States, India, and other countries where Abound, its affiliates, Platform Partners, or Service Providers operate.
10.2.Cross-border transfers. Personal information may therefore be transferred to and processed in jurisdictions with privacy laws that differ from those in your place of residence. Where required, Abound uses measures designed to protect personal information in connection with cross-border processing. Platform Partners are responsible for transfers they independently conduct under their privacy policies and applicable Platform Partner Terms.
11.1.Age eligibility. The Abound Platform and Abound Services are intended only for individuals who are at least 18 years old and are not directed to children.
11.2.Information about minors. We do not knowingly collect personal information from an individual under 18 in connection with the Abound Platform. If we learn that we collected personal information from a person under 18 in violation of our eligibility requirements, we will take reasonable steps to delete or otherwise handle the information as required by Applicable Law, subject to any legal obligation to retain it.
11.3.Reporting information about minors. If you believe that a person under 18 has provided personal information to Abound, contact us using the information in Section 15.
12.1. General choices. Depending on the feature, you may be able to:
12.1.1.access and update certain Account information through the Abound Platform;
12.1.2.unlink a Payment Instrument or bank connection, subject to pending Transactions, separate authorizations, Platform Partner Terms or requirements, and legal retention needs;
12.1.3.opt out of marketing communications;
12.1.4.manage device permissions, including location, camera, microphone, and notifications;
12.1.5.manage cookies, advertising choices, and other privacy preferences through available browser, device, application, or consent controls.
12.2.State privacy rights. Depending on where you reside, the nature of the personal information, and applicable exemptions, including exemptions for certain information subject, you may have some or all of the following rights:
12.2.1.the right to confirm whether we process personal information and to know or access categories and specific pieces of personal information;
12.2.2.the right to correct inaccurate personal information;
12.2.3.the right to delete personal information;
12.2.4.the right to obtain a portable copy of certain personal information;
12.2.5.the right to opt out of sale, sharing, or targeted advertising;
12.2.6.the right to limit certain uses or disclosures of Sensitive Personal Information, or to opt out of certain profiling or automated decision-making that produces legal or similarly significant effects, where applicable;
12.2.7.the right to appeal the denial of a privacy request, where applicable; and/or
12.2.8.the right not to be discriminated against or retaliated against for exercising a privacy right, subject to lawful loyalty, Reward, or financial-incentive programs.
12.3.Privacy rights are not absolute. We may deny, limit, or defer a request where permitted by Applicable Law, including where information is exempt; we cannot reasonably verify the request; or retention is necessary for security, fraud prevention, legal compliance, completion of a Transaction, Platform Partner obligations, dispute resolution, or the establishment, exercise, or defense of legal claims.
12.4.Notice for California residents. For California residents, this Privacy Policy provides the following disclosures:
12.4.1.the categories of personal information and Sensitive Personal Information we collect, the categories of sources, the purposes for collection and use, and the categories of recipients are described in Sections 2 through 5;
12.4.2.the criteria used to determine retention periods are described in Section 9;
12.4.3.we do not sell personal information for money, but we may share identifiers, internet or device activity, usage information, and commercial information for cross-context behavioral advertising as described in Section 5;
12.4.4.financial incentives, Rewards, discounts, and loyalty programs are described in Section 5 and in the applicable point-of-use Notice of Financial Incentive or offer terms.
12.5.How to Exercise Rights. You may submit a privacy request through one or more of the following methods:
12.5.1.email: support@joinabound.com; and
12.5.2.mail: TClub, Inc. d/b/a Abound, TClub, Inc., 108 Lakeland Ave., City of Dover, 19901, County of Kent, Delaware.
12.6.Verifications. We may verify your identity before fulfilling an access, correction, deletion, or portability request by matching information you provide with our records, authenticating you through your Account, or requesting additional information reasonably necessary for verification. We will not require verification for an opt-out request beyond information reasonably necessary to process the request.
12.7.Your agent. You may designate an authorized agent to submit a request where permitted by Applicable Law. We may require proof of the agent’s authority and may verify your identity directly. We will respond within the time and in the manner required by Applicable Law.
12.8.Appeals. If Applicable Law grants a right to appeal and we deny your request, you may appeal by responding to the denial notice or contacting us through the same request channel and stating that you wish to appeal. We will provide the result and any additional complaint mechanism required by Applicable Law.
13.1.Public blockchain records. If you use a Virtual Asset Transfer or another blockchain-enabled Platform Partner Service, information may be submitted to or recorded on a public blockchain. You acknowledge that:
13.1.1.Wallet addresses, Transaction hashes, timestamps, network information, token type, and transfer amounts may be publicly visible and may be copied, indexed, analyzed, or retained by third parties;
13.1.2.public blockchain information may be linked to you by Abound, Platform Partners, Service Providers, analytics providers, regulators, law enforcement, or other third parties;
13.1.3.Abound does not control public blockchain records and generally cannot delete, alter, or reverse information recorded on a blockchain; and/or
13.1.4.Deletion of Account-level personal information therefore does not delete or modify information that remains on a public blockchain.
13.2.AI Input, Output, and Service Providers. If you use an AI Service, Abound and the applicable Service Providers or Platform Partners may process Input, Output, feedback, usage metadata, and derived information to generate Output and to operate, secure, support, evaluate, and improve the AI Service and the Abound Platform, as described in the User Agreement. The applicable provider’s privacy policy applies where it independently provides the AI Service. If the applicable flow identifies an AI provider as providing a service directly to you, that provider is a Platform Partner and its Platform Partner Terms and privacy policy also apply.
13.3.Sensitive information in AI Services. Do not submit one-time passcodes, passwords, full payment-card or bank-account credentials, government-identification numbers, or another person’s personal information through an AI Service unless the feature expressly requests the information and you are authorized to provide it.
13.4.Automated processing. Abound may use automated tools for fraud prevention, security, compliance, risk assessment, support, personalization, and eligibility. AI Output alone will not initiate, authorize, or complete a Transaction. Where Applicable Law grants a right regarding profiling or automated decision-making that produces legal or similarly significant effects, you may exercise that right as described in Section 12.
14.1.Changes. We may update this Privacy Policy from time to time by posting an updated version on the Abound Platform, providing in-app notice, sending email, or using another legally sufficient method. The updated version will state its effective date. When a change is material, we will communicate such changes in a reasonable manner, and Abound will obtain affirmative consent where Applicable Law requires it.
14.2.Applicability of changes. An updated Privacy Policy applies prospectively from its stated effective date. We will not use previously collected personal information for a materially different, incompatible purpose without providing any notice or obtaining any consent required by Applicable Law. Continued use of the Abound Platform after notice constitutes acknowledgment of the updated notice, but does not waive any privacy right or replace a consent that Applicable Law requires separately.
15.1.Privacy requests. If you have questions about this Privacy Policy or would like to submit a privacy request, contact Abound through the following channels:
TClub, Inc. d/b/a Abound, 108 Lakeland Ave., City of Dover, 19901, County of Kent, Delaware; and
Email: support@joinabound.com
A request relating to a Platform Partner Service may also need to be submitted directly to the applicable Platform Partner using the method identified in its terms, privacy policy, receipt, or point-of-use disclosure.
15.2.Notices. For suspected phishing or security concerns, use the official support channels identified on the Abound Platform. Legal notices under the User Agreement should be sent to legal@joinabound.com or the legal-notice address stated in the User Agreement; privacy requests should be submitted through the channels above.